FY 2023 AGENCY FINANCIAL REPORT 196 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

Payment Integrity Information 

Act Reporting

All program outlays can be categorized as one of three payment type categories: proper 

payments, improper payments, and unknown payments. OMB Circular A-123, Appendix 

C, Requirements for Payment Integrity Improvement, defines an improper payment 

as a payment that was made in an incorrect amount under statutory, contractual, 

administrative, or other legally applicable requirements. The term improper payment 

includes any payment to an ineligible recipient; any payment for an ineligible good or 

service; any duplicate payment; any payment for a good or service not received, except 

for those payments where authorized by law; any payment that is not authorized by law; 

and any payment that does not account for credit for applicable discounts. OMB Circular 

A-123, Appendix C, also defines an unknown payment as a payment that could either 

be proper or improper, but it cannot be determined whether the payment was proper or 

improper because of insufficient or lack of documentation. 

The Department places a high value on maintaining the integrity of all payments to 

ensure that the billions of dollars in federal funds it disburses annually are considered 

proper payments. The Department ensures payment integrity by establishing effective 

policies, business processes, systems, and controls over key payment activities, including 

those pertaining to payment data quality, cash management, banking information, thirdparty oversight, assessments of audit reports, and financial reporting. Low amounts of 

improper and unknown payments are key indicators of payment integrity. Accordingly, 

the Department maintains a robust internal control framework that includes internal 

controls designed to help prevent, detect, and recover improper and unknown payments. 

In designing controls, the Department attempts to strike the right balance between 

making timely and accurate payments and ensuring that controls put in place are not 

too costly or overly burdensome and thereby deter intended beneficiaries from obtaining 

funds they are entitled to receive. Additionally, the Department must rely heavily on 

controls established by external entities that receive Department payments, including 

federal, state, and private organizations and institutions, because they further distribute 

funds received from the Department to subordinate organizations and individuals. Due 

to these third-party controls being outside of the Department’s operational management, 

they present a higher risk to the Department, as evidenced by its root cause analysis. 

When control deficiencies are detected, either within the Department or at external 

entities, the Department seeks to identify their root causes, develop corrective action 

plans, and track corrective actions through to completion.

To further promote payment integrity, the Department continues to rely on its Payment 

Integrity Monitoring Application (PIMA), which detects anomalies in grants payment 

data. Case management files for payment anomalies are established within the application 

for follow-up investigation by the Department’s grants program officials to validate 

improper payments and determine root causes. Additionally, the Department continues 

to refine its internal control framework to address gaps, strengthen internal control 

processes, and align assessments with enterprise risk management. Both efforts reflect 

the Department’s recognition of the critical importance that payment integrity plays in 

demonstrating sound financial stewardship to the American taxpayer.
FY 2023 AGENCY FINANCIAL REPORT 197 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

Description of Risk-Susceptible and High-Priority Programs 

In FY 2023, the Federal Pell Grant, William D. Ford Federal Direct Loan, Title I, Part 

A, Education Stabilization Fund (ESF), Special Education Grants to States, and the 

Individuals with Disabilities Education Act (IDEA) programs continued to be designated 

as programs that are “susceptible to significant improper payments” (referred to as Phase 2 

per OMB Circular A-123, Appendix C guidance). The Federal Pell Grant program 

remains an OMB-designated high-priority program. The William D. Ford Federal Direct 

Loan program was considered a high-priority program during the year based on FY 2022 

reporting, but based on FY 2023 improper payment and unknown payment results 

described in this Payment Integrity reporting section, the Direct Loan program no longer 

meets the threshold and is not considered a high-priority program for FY 2023. 

The Department continues to place additional emphasis on ensuring payment integrity 

and minimizing improper and unknown payments in these important programs as 

required by OMB guidance. Readers can obtain a detailed breakdown of information on 

improper and unknown payment estimates, root causes, and corrective actions for the 

programs at https://paymentaccuracy.gov.

Federal Pell Grant 

The Pell Grant Program, authorized under Title IV of the Higher Education Act of 

1965 (HEA), provides need-based grants to low-income undergraduate and certain 

post-baccalaureate students to promote access to postsecondary education. Grant 

funds can be disbursed directly to the school to be applied towards a student’s costs, 

directly to the student, or a combination of both. A student is eligible to receive a Pell 

Grant if the student meets the requirements of an eligible student under 34 Code of 

Federal Regulations (CFR) Part 668. Students may use their grants at any participating 

postsecondary institution as established by 34 CFR Part 690 and further updated by 

the Higher Education Reconciliation Act of 2005 (HERA) and the Higher Education 

Opportunity Act of 2008 (Public Law 110-315) (HEOA).

William D. Ford Federal Direct Loan 

The Direct Loan Program, added to HEA in 1993 by the Student Loan Reform Act of 

1993, authorizes the Department to make loans through participating schools to eligible 

undergraduate and graduate students and their parents. A student is eligible to receive a 

Direct Loan if the student enrolls in a school that provides Direct Loans, and the student 

meets the requirements of an eligible student under 34 CFR Part 668. Eligible students 

may receive a Direct Loan in accordance with the annual and aggregate loan limits as 

established by 34 CFR Part 685.203 and further updated by HERA and HEOA.

Special Education Grants to States

The Special Education Grants to States, Individuals with Disabilities Education Act (IDEA) 

program provides formula grants to assist the 50 states, the District of Columbia, Puerto 

Rico, the Department of the Interior, Outlying Areas, and the Freely Associated States 

in meeting the excess costs of providing special education and related services to children 

with disabilities. To be eligible for funding, states must serve all children with disabilities 

between the ages of 3 through 21, except that they are not required to serve children aged 

3 through 5 or 18 through 21 years if services are inconsistent with state law or practice or 
FY 2023 AGENCY FINANCIAL REPORT 198 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

the order of any court. A state that does not provide a Free Appropriate Public Education 

(FAPE) to children with disabilities aged 3 through 5 cannot receive base payment funds 

attributable to this age group or any funds under the Preschool Grants program. Funds 

are allocated among states in accordance with a variety of factors, as outlined in the 

funding formula under section 611(d) of the IDEA.

Education Stabilization Fund

The Education Stabilization Fund (ESF) was established by the Coronavirus Aid, Relief, 

and Economic Security Act (CARES Act) in March 2020, with subsequent allocations to 

the Fund codified through the Coronavirus Response and Relief Supplemental Appropriations 

Act (CRRSA Act), and the American Rescue Plan Act (ARP Act). The ESF is an investment 

of more than $263 billion and is composed of relief funds that support state and 

institutional efforts to prevent, prepare for, and respond to the coronavirus impacts on 

our nation’s students. Programs created under the ESF investment include: Education 

Stabilization Fund Discretionary Grants, Governor’s Emergency Education Relief Fund, 

Elementary and Secondary School Emergency Relief Fund, Homeless Children and 

Youth, Emergency Assistance to Non-Public School, Outlying Areas, Bureau of Indian 

Education, and Higher Education Emergency Relief Fund.

Title I, Part A

Title I, Part A (Title I) of the Elementary and Secondary Education Act, as amended by the 

Every Student Succeeds Act (ESEA), provides financial assistance to LEAs and schools with 

high numbers or high percentages of children from low-income families to help ensure 

that all children meet challenging state academic standards. Federal funds are currently 

allocated through four statutory formulas that are based primarily on census poverty 

estimates and the cost of education in each state.

In FY 2023, the Department used statistically valid sampling and estimation 

methodologies to estimate the improper payment rates for the Pell Grant, Direct Loan, 

IDEA, ESF, and Title I programs. The methodologies used for each of these programs are 

described in detail on the Department’s improper payments website.

For detailed information on Pell Grant, Direct Loan, IDEA, ESF and Title I improper 

payment estimates in FY 2023 and prior years, please visit https://paymentaccuracy.gov.

Risk Assessments

As required by OMB Circular A-123, Appendix C, the Department assesses the risk of 

improper payments at least once every three years for each program and activity with 

annual outlays of more than $10 million that is not reporting an improper payment 

estimate. In FY 2023, the Department assessed improper payment risk for ten grant 

programs and two administrative activities. These risk assessments did not identify any 

additional Education programs or activities as being susceptible to significant improper 

payments. Additionally, the Department also conducted risk assessments of all FSAmanaged programs. There were no additional programs identified as susceptible to 

significant improper payments.
FY 2023 AGENCY FINANCIAL REPORT 199 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

Identified and Recaptured Improper Payments

Agencies are required to conduct recovery audits for all programs and activities that 

expend more than $1 million in a fiscal year, if conducting such audits would be costeffective. The Department has determined that payment recapture audits would not be 

cost effective for any of its loan and grant programs or for contracts. A comprehensive 

report on the cost effectiveness of the various recapture audit programs can be found 

in the Department’s FY 2012 Report on the Department of Education’s Payment 

Recapture Audits.

The Department identifies and recovers improper payments through sources other 

than payment recapture audits and works with grantees and Title IV (FSA) program 

participants to resolve and recover amounts identified in compliance audits, OIG audits, 

and Department-conducted program reviews. The Department also analyzes the return 

of grant funds from recipients to determine if they are due to improper payments. When 

an improper payment is detected and deemed collectable, the Department establishes 

an account receivable and pursues collection. Recoveries are also made through grant 

program, payroll, and other offsets. Recipients of Department funds can appeal 

management’s decisions regarding funds to be returned to the Department or they may go 

bankrupt before the Department can collect, thereby delaying or decreasing the amounts 

the Department is able to collect. Additionally, the Department has wide discretion to 

decide not to collect improper payments from grantees in cases where it determines that 

pursuing collections would cause more harm to the federal interest. For these and other 

reasons, not all identified improper payments will ultimately be collected and collections 

will not necessarily be made in the same year the improper payments were identified. The 

Department continues to work to improve its methods to identify, collect, and report 

on improper payments. For detailed information on identified and recovered improper 

payments in FY 2023, readers can visit https://paymentaccuracy.gov.

High Priority Programs—Sampling and Estimation Methodology 

Plan (S&EMP)

For FY 2023 AFR reporting, the Department used a statistically valid S&EMP 

to estimate improper and unknown payments for the Pell Grant and Direct Loan 

programs. The Department submitted the statistically valid S&EMP to OMB on 

June 29, 2023. This statistical methodology uses a random sample of annual compliance 

audits, with associated final audit determination (FAD) letters, if applicable, that cover 

approximately 5,400 eligible schools. A small population of schools may apply for and 

receive a waiver or exemption from the compliance audit requirements. FSA accounts 

for these disbursements through a statistically valid sampling process. In addition to 

the compliance audits and related data, the methodology also uses the Free Application 

for Federal Student Aid (FAFSA) Internal Revenue Service (IRS) Data Statistical 

Study (“Study”) and the results of tests of Federal Family Education Loan to Direct 

Loan consolidations and Direct Loan refunds. A plain language description of the 

methodology used and the results obtained for each of these programs is available on the 

Department’s improper payments website.
FY 2023 AGENCY FINANCIAL REPORT 200 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

High-Priority Programs—Improper and Unknown Payment 

Payment Estimates 

Readers can obtain more detailed information on reporting improper payment and 

unknown payment estimates in FY 2023 and prior years at https://paymentaccuracy.gov.

The FY 2023 Pell Grant estimates include results from the Study which estimates Pell 

Grant improper payment rates based on a comparison between information reported 

by recipients of Pell Grant funds on the FAFSA and income details reported to the 

IRS. Rates from the Study are included in the Pell Grant improper payment estimate 

and categorized as a misreported income root cause. The misreported income root 

cause accounts for approximately 75 percent of the estimated FY 2023 Pell Grant 

improper payments. 

Figure 16 summarizes the estimated amount of improper payments and unknown 

payments made directly by the Department and the amount of improper payments made 

by recipients of federal money. For additional details, please refer to the High Priority 

Programs—Root Cause Categories section.

 

 

 

 

Figure 14. FY 2023 Pell Grant Estimates

(Dollars in Millions)

 

 

 

 

 

Figure 15. FY 2023 Direct Loan Estimates

(Dollars in Millions)

Note: The source of the FY 2023 Pell Grant and Direct Loan outlay amounts is FSA’s Financial Management System (FMS).
FY 2023 AGENCY FINANCIAL REPORT 201 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

 

Figure 16. FY 2023 Sources of Improper Payments & Unknown Payments 

(Dollars in Millions)

High Priority Programs—Insufficient or Lack of Documentation 

Of the $812.29 million and $586.66 million in estimated improper payments and 

unknown payments for the Pell Grant and Direct Loan programs, respectively, 

approximately 0.01 percent and 0.00 percent are categorized as unknown due to inability 

to discern whether the payment was proper or improper as a result of insufficient or lack 

of documentation.

High Priority Programs—Monetary Loss and Non-Monetary 

Loss 

This section presents the portion of the improper payment estimates that are attributed to 

monetary loss and non-monetary loss. Monetary loss and non-monetary loss are defined 

by OMB.

• Monetary loss to the Federal Government: An amount that should not have been 

paid and in theory should/could be recovered.

• Non-monetary loss to the Federal Government: Either an underpayment or a 

payment to the correct recipient for the correct amount where the payment process 

fails to follow applicable regulation and/or statute.
FY 2023 AGENCY FINANCIAL REPORT 202 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

The monetary loss and non-monetary loss amounts reported in Table 18 are estimates; not 

all monetary loss is recoverable.

Table 18: FY 2023 Monetary and Non-Monetary Loss for High-Priority Programs*

Program Reporting Category

Amount 

(Dollars in 

Millions)

Percentage of 

Improper Payment 

and Unknown 

Payment 

Estimate 

Pell 

Grant

Estimated Monetary Loss to the Government $403.92 49.72%

Estimated Non-Monetary Loss to the Government $405.23 49.89%

Estimated Unknown Improper Payments $3.15 0.39%

Total $812.29 100.00%

Direct 

Loan

Estimated Monetary Loss to the Government $67.82 11.56%

Estimated Non-Monetary Loss to the Government $518.84 88.44%

Estimated Unknown Improper Payments $0.00 0.00%

Total $586.66 100.00%

*Numbers may not add up due to rounding.

Of the estimated monetary loss for the Pell Grant and Direct Loan programs, the majority 

is outside of the agency’s control. As explained previously, the Department must rely 

heavily on controls established by external entities that receive Department payments, 

including federal, state, and private organizations and institutions, because they further 

distribute the funds they receive from the Department to subordinate organizations and 

individuals. These “third-party” controls are outside of the Department’s operational 

control. Examples of root causes outside of the Department’s operational control are 

defined further in the following section. The amounts of monetary loss within and 

outside of the agency’s control are reported in Table 19.

Table 19: FY 2023 Monetary Loss Within and Outside Agency Control for HighPriority Programs

Program Reporting Category

Amount 

(Dollars in 

Millions)

Percentage of 

Monetary Loss

Pell 

Grant

Estimated Monetary Loss Within Agency Control $381.57 94.47%

Estimated Monetary Loss Outside Agency Control $22.35 5.53%

Total $403.92 100.00%

Direct 

Loan

Estimated Monetary Loss Within Agency Control $0.00 0.00%

Estimated Monetary Loss Outside Agency Control $67.82 100.00%

Total $67.82 100.00%
FY 2023 AGENCY FINANCIAL REPORT 203 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

High Priority Programs—Root Cause Categories

FY 2023 root cause categories of error, as defined in OMB Circular A-123, Appendix 

C (OMB Memorandum M-21-19), were “Statutory Requirements of Program Were 

Not Met,” “Failure to Access Data/Information,” and “Unable to Determine Whether 

Proper or Improper.” Specific root causes associated with the “Statutory Requirements 

of Program Were Not Met” category include, but are not limited to, a school’s failure 

to perform or properly complete verification, a school’s failure to provide disbursement 

notifications to the student in a timely manner, untimely credit balance return to the 

Department, and inadequate documentation for meeting Satisfactory Academic Progress 

(SAP) standards. Specific root causes associated with the “Failure to Access Data/

Information” category include, but are not limited to, misreported income, incorrect 

academic level or enrollment status used, a school’s failure to observe annual eligibility 

limits, a school’s failure to properly complete verification, incorrect financial aid 

determination, and incorrect decision to complete return of Title IV funds calculation. 

Specific root causes associated with the “Unable to Determine Whether Proper or 

Improper” category may include, but are not limited to, inaccurate and/or inadequate 

tracking of attendance, lack of supporting eligibility documentation retained by schools, 

and lack of evidence to support a school completed required verification of information 

reported by an applicant on their FAFSA. 

 

 

 

 

 

 

 

 

 

 

 

Figure 17. FY 2023 Root Causes of Improper Payments* 

(Dollars in Millions)

* Numbers may not add up due to rounding.
FY 2023 AGENCY FINANCIAL REPORT 204 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

High Priority Programs—Corrective Actions

The Department has established an integrated system of complementary oversight 

functions to help prevent, detect, and recover improper payments, and ensure compliance 

by all participating parties. FSA’s Office of Partner Participation and Oversight (PPO) 

annually initiates more than 100 program reviews of the approximately 5,400 eligible 

schools to assess institutions’ compliance with Title IV regulations. PPO evaluates 

a school’s compliance with federal requirements, assesses liabilities for errors in 

performance, and identifies actions the school must take to make the Title IV, HEA 

programs, or the recipients, whole for any funds that were improperly managed and 

to prevent the same problems from recurring. A school with serious violations may 

be placed on heightened cash monitoring (HCM) for disbursements, lose funding 

for specific programs, or be terminated from participation in all Title IV programs 

for noncompliance.

PPO monitors annual compliance audits of schools. A school that participates in any 

Title IV program must at least annually have a compliance audit of its administration 

of that program unless an allowable waiver or exemption has been granted or, for Single 

Audit filers, the Title IV programs (major program) have been determined low-risk. 

Independent auditors perform the compliance audits to monitor schools’ administration 

of FSA programs. If any deficiencies are identified, the school must develop a corrective 

action plan that addresses the audit report findings. Auditors are required to evaluate 

whether the school has taken appropriate corrective action to address findings and 

recommendations from prior audits. PPO also performs audit resolution. This includes 

reviewing and evaluating the effectiveness of a school’s corrective action and mitigation 

efforts for noted exceptions in audit reports.

FSA continues to work with Treasury to implement the authorities provided in the 

FUTURE Act. Implementation of the authorities provided in the FUTURE Act will 

significantly improve data authentication by enabling FSA to automatically receive 

certain federal tax information (FTI) from the IRS through a direct-data exchange with 

applicant approval and enabling customers to automatically report their income for 

the total and permanent disability (TPD) discharge post-monitoring, income-driven 

repayment (IDR), and FAFSA processes. Implementation of the authorities provided in 

the FAFSA Simplification Act will improve reporting through, for example, modifying 

and simplifying the questions that students and their families have to answer on the 

FAFSA form.

The corrective actions listed below are specific to the root causes of improper payments 

identified from the FY 2023 improper payment fieldwork, and are tailored to reflect 

the unique processes, procedures, and risks involved with the Pell Grant and Direct 

Loan programs.
FY 2023 AGENCY FINANCIAL REPORT 205 U.S. DEPARTMENT OF EDUCATION

Other Information (Unaudited)

Table 20. Pell Grant and Direct Loan Improper Payment Corrective Actions

Corrective Action Description of Actions Taken in FY 2023 and Planned for FY 2024 OMB Root Cause 

Category

Implement the authorities provided 

in the FUTURE Act to improve 

verification of applicants’ and 

borrowers’ income data.

In FY 2023, the Department continued to work diligently and collaboratively with the IRS 

to implement and operationalize changes to its programs as a result of the FUTURE Act 

and amendments to section 6103 of the Internal Revenue Code (IRC). FSA and the IRS 

implemented the FUTURE Act IDR Solution on July 30, 2023. 

In FY 2024, through the Student Aid and Borrower Eligibility (SABER) Initiative, FSA will 

continue to implement the authorities and provisions provided in the FUTURE Act and FAFSA 

Simplification Act which ultimately will streamline and strengthen the collection of data used 

to determine eligibility for student financial assistance. Implementation of the authorities 

provided in the FUTURE Act will significantly improve data authentication by enabling FSA to 

automatically receive certain FTI from the IRS through a direct-data exchange with applicant 

approval and enabling customers to automatically report their income for the TPD discharge 

post-monitoring, IDR, and FAFSA processes. Implementation of the authorities provided 

in the FAFSA Simplification Act will improve reporting through, for example, modifying the 

questions that students and their families have to answer on the FAFSA form and requiring ED 

to conduct early awareness and outreach of student aid eligibility. Full implementation of the 

FUTURE Act is planned for FY 2025. FSA expects that full implementation of the authorities 

provided in the FUTURE Act will significantly reduce, or eliminate, improper payments due to 

applicants misreporting income on the FAFSA.

Failure to Access 

Data/Information

Continue to utilize and promote 

the IRS Data Retrieval Tool (DRT). 

Enhance verification procedures.

In FY 2023, FSA monitored the IRS DRT usage on a weekly basis and continued to work 

diligently and collaboratively to implement the Federal Tax Information Module (FTI-M). The 

FTI-M was successfully implemented and recorded an initial usage rate of 91%. FSA is 

encouraged by the high usage rate of the FTI-M.

In FY 2024, FSA will continue to promote the IRS DRT until full implementation of the authorities 

provided in the FUTURE Act is completed. Full implementation of the authorities provided in the 

FUTURE Act is scheduled for FY 2025, which FSA expects will significantly reduce, or eliminate, 

improper payments due to applicants misreporting income on the FAFSA. See the status of 

the corrective action titled “Implement the authorities provided in the FUTURE Act to improve 

verification of applicants’ and borrowers’ income data” for additional information.

Publish and deliver guidance, 

training, and other resources for 

institutions processing financial 

aid that address (1) verification 

errors; (2) administrative 

and process errors; and (3) 

documentation errors frequently 

made by schools.

In FY 2023, FSA published and delivered various free trainings, guidance, and resources 

for school financial aid administrators to target the root causes of improper payments and 

other frequently identified compliance issues. For example, in FY 2023 Q1, FSA published 

the 2022-2023 FSA Handbook and FSA Assessments, which provide guidance on FAFSA 

and verification requirements. FSA also published updates to questions and answers about 

verification requirements to help clarify verification requirements and reduce the risk of 

verification deficiencies. In FY 2023 Q1, FSA held the FSA Training Conference for Financial 

Aid Professionals, which received positive feedback from financial aid administrators. 

In FY 2024, FSA will continue to publish and deliver various free trainings, guidance, and 

resources for school financial aid administrators to target the root causes of improper 

payments and unknown payments and other frequently identified compliance issues. 

For example, FSA will continue to publish the FSA Handbook, FSA Assessments, and 

updates to questions and answers about verification requirements to help clarify verification 

requirements and reduce the risk of verification deficiencies. FSA is coordinating internally to 

ensure relevant offices within FSA participate in the planning for the FY 2024 FSA Training 

Conference to ensure key objectives and milestones are met. FSA will host the FY 2024 FSA 

Training Conference in FY 2024 Q1.

(1) Failure to Access 

Data/Information

(2) Statutory 

Requirements of 

Program Were 

Not Met

(3) Unable to 

Determine 

Whether Proper 

or Improper

Evaluate schools’ compliance with 

federal student aid requirements, 

assess liabilities for errors in 

performance, and identify actions 

schools must take to make the 

Title IV, HEA programs (Pell Grant 

and Direct Loan program), or the 

recipients, whole for any funds 

that were improperly managed 

as part of the program review, 

Single Audit, and/or audit process 

conducted in accordance with the 

Guide For Audits of Proprietary 

Schools and For Compliance 

Attestation Engagements of ThirdParty Servicers Administering Title 

IV Programs.

In FY 2023, FSA evaluated schools’ compliance with federal student aid requirements through 

oversight activities, such as program reviews and compliance audits, and assessed liabilities 

for errors in performance. For improper payments identified through oversight activities, such 

as compliance audits and program reviews, FSA established accounts receivable and pursued 

collection for those deemed collectible, including applicable overpayments. For additional 

information on actions taken to recover overpayments, please see paymentaccuracy.gov. 

In FY 2024, FSA will continue to evaluate schools’ compliance with federal student aid 

requirements through oversight activities, such as program reviews and compliance audits, 

and will assess liabilities for errors in performance. For future improper payments identified 

through oversight activities, such as compliance audits and program reviews, FSA will 

continue to establish accounts receivable and pursue collection for those deemed collectible, 

including applicable overpayments.