IMPROPER 

PAYMENTS

Additional Guidance 

Could Provide More 

Consistent 

Compliance 

Determinations and 

Reporting by 

Inspectors General 

Report to the Ranking Member, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate

May 2017

GAO-17-484

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-484, a report to the

Ranking Member, Committee on Homeland 

Security and Governmental Affairs, U.S. 

Senate

May 2017

IMPROPER PAYMENTS

Additional Guidance Could Provide More 

Consistent Compliance Determinations and 

Reporting by Inspectors General 

Why GAO Did This Study

Fiscal year 2015 marked the fifth year 

of the implementation of IPERA, which 

requires IGs to annually assess and 

report on whether executive branch 

agencies complied with six IPERA 

criteria related to the estimation of 

improper payments. Improper 

payments have been estimated to total 

over $1.2 trillion government-wide from 

2003 through 2016. 

This report examines (1) the extent to 

which the 24 CFO Act agency IGs 

reported that agencies complied with 

the six IPERA criteria for fiscal years 

2011 through 2015 and the programs 

reported as noncompliant for 3 or more 

consecutive years; (2) the extent to 

which the IGs reported that they 

performed optional procedures during 

their fiscal year 2015 reviews; and 

(3) the number and status of the IGs’ 

fiscal years 2011 through 2015 IPERA 

compliance review recommendations. 

To conduct this work, GAO analyzed 

the IGs’ fiscal years 2011 through 2015 

IPERA compliance reports and 

corroborated the findings with OMB 

and all 24 CFO Act agencies and their

IGs. 

What GAO Recommends 

GAO recommends that the (1) Director 

of OMB coordinate with CIGIE to 

develop and issue guidance, either 

jointly or independently, to specify what

procedures should be conducted as 

part of the IGs’ IPERA compliance 

determinations and (2) Department of 

Agriculture submit a proposal to 

Congress, as required in response to 

3 years of IPERA noncompliance. In 

response to the draft report, OMB had 

no comments and CIGIE stated that it

would coordinate with OMB. Also, the 

Department of Agriculture concurred 

with the recommendation to it. 

What GAO Found

Five years after the implementation of the Improper Payments Elimination and 

Recovery Act of 2010 (IPERA), 15 of the 24 Chief Financial Officers Act of 1990 

(CFO Act) agencies were reported by their inspectors general (IG) as 

noncompliant under IPERA for fiscal year 2015. The programs associated with 

these 15 agencies accounted for $132 billion (or about 96 percent) of the 

reported $136.7 billion government-wide improper payment estimate for fiscal 

year 2015. In addition, the inconsistent IG compliance determinations in the IGs’

fiscal year 2015 IPERA compliance reports may present potentially misleading 

information. Specifically, certain IGs reported compliance based on the presence 

or absence of the required analysis or reporting, regardless of whether the IGs 

identified flaws, whereas certain other IGs reported agencies as noncompliant 

based on their performance of some degree of evaluative procedures to 

determine whether the analysis or reporting that the agency produced was 

substantively adequate. While the severity of the IGs’ findings may have resulted 

in the IGs reporting noncompliance for some agencies, similar findings were

identified for both the compliant and noncompliant agencies. IPERA and Office of 

Management and Budget (OMB) guidance does not specify what, if any, 

evaluative procedures should be conducted as part of the IGs’ compliance 

determinations. The Council of the Inspectors General on Integrity and Efficiency 

(CIGIE), which represents the IGs, has also not issued such guidance.

Number of Chief Financial Officers Act Agencies Compliant and Noncompliant under IPERA 

for Fiscal Years 2011 through 2015, as Reported/Acknowledged by Their Inspectors General

IGs reported programs at 7 agencies as noncompliant for 3 or more consecutive 

years as of the end of fiscal year 2015 and, as a result, were required to submit 

certain information to Congress. However, the Department of Agriculture had not 

submitted the required information, despite prior recommendations from its IG 

and GAO. When agencies do not submit the required information, Congress may 

lack the information necessary to effectively monitor the implementation of 

IPERA and take action to address problematic programs in a timely manner. 

The IGs’ IPERA compliance reviews serve a key function: to reasonably assure

that federal dollars are not misspent and that improper payment estimates are 

accurate, reliable, and complete. To that end, 20 of the 24 IGs reported in their 

fiscal year 2015 IPERA compliance reports that they also performed one or more 

optional procedures, which included evaluating the accuracy and completeness 

of their agencies’ reporting. The IGs made 425 recommendations in their fiscal 

years 2011 through 2015 IPERA compliance reports, and 320 of these 

recommendations were closed as of December 31, 2016. 

View GAO-17-484. For more information,

contact Beryl H. Davis at (202) 512-2623 or

davisbh@gao.gov
Page i GAO-17-484 Fiscal Year 2015 IPERA Compliance

Letter 1

Background 4

Over Half of the CFO Act Agencies Continue to Be Reported as 

Noncompliant under IPERA, but the IGs’ Compliance 

Determinations for Fiscal Year 2015 Were Inconsistent 7

Majority of CFO Act Agency IGs Reported Performing One or 

More Optional Procedures during Their Fiscal Year 2015 

IPERA Compliance Reviews 24

CFO Act Agency IGs Made About 400 Recommendations in Their 

Fiscal Years 2011 through 2015 IPERA Compliance Reports, 

and More Than 100 Recommendations Remain Open as of 

December 31, 2016 27

Conclusions 33

Recommendations for Executive Action 33

Agency Comments 34

Appendix I Objectives, Scope, and Methodology 36

Appendix II CFO Act Agencies Reported as Noncompliant under IPERA by IGs for 

Fiscal Year 2015 40

Appendix III CFO Act Agencies and Programs Reported as Noncompliant under 

IPERA by Their IGs for Fiscal Year 2015 42

Appendix IV Reported Improper Payment Estimates by Agency and Program/Activity 

for Fiscal Year 2015 45

Appendix V Optional Procedures Performed by the IGs during Their Fiscal Year 

2015 IPERA Compliance Reviews 52

Contents
Page ii GAO-17-484 Fiscal Year 2015 IPERA Compliance

Appendix VI Fiscal Years 2011 through 2015 Compliance Results and the Status of 

the IGs’ Recommendations 55

Appendix VII Reported Improper Payment Estimates by Agency and Program/Activity 

for Fiscal Year 2016 61

Appendix VIII Comments from the Council of the Inspectors General on Integrity and 

Efficiency 67

Appendix IX Comments from the Department of Homeland Security Office of 

Inspector General 68

Appendix X Comments from the Department of Housing and Urban Development 69

Appendix XI Comments from the Department of Housing and Urban Development 

Office of Inspector General 70

Appendix XII Comments from the Department of the Treasury 72

Appendix XIII Comments from the Social Security Administration 74

Appendix XIV GAO Contact and Staff Acknowledgments 75
Page iii GAO-17-484 Fiscal Year 2015 IPERA Compliance

Tables

Table 1: IGs’ Originally Reported Fiscal Year 2015 

Noncompliance Results for the CFO Act Agencies and 

Potential Noncompliance Results if Consistently Based on 

Pass/Fail Determinations or Evaluative Procedures 22

Table 2: CFO Act Agencies’ Programs That IGs Reported as 

Noncompliant under IPERA for Fiscal Year 2015 42

Table 3: Reported Improper Payment Estimates by Agency and 

Program/Activity for Fiscal Year 2015 45

Table 4: Summary of Optional Procedures the IGs Reported That 

They Performed during Their Fiscal Year 2015 IPERA 

Compliance Reviews 52

Table 5: Status of Recommendations Made in the IGs’ Fiscal 

Years 2011 through 2015 IPERA Compliance Reports, as 

of December 31, 2016 55

Table 6: Reported Improper Payment Estimates by Agency and 

Program/Activity for Fiscal Year 2016 61

Figures

Figure 1: Overview of Inspector General Procedures That Are 

Required and Optional Related to Improper Payment 

Reporting 7

Figure 2: The Number of CFO Act Agencies Compliant and 

Noncompliant under IPERA for Fiscal Years 2011 

through 2015, as Reported/Acknowledged by Their IGs 8

Figure 3: CFO Act Agencies’ Overall IPERA Compliance for Fiscal 

Years 2011 through 2015, as Reported/Acknowledged by 

Their IGs 9

Figure 4: Programs at CFO Act Agencies That Accounted for the 

Total Reported Fiscal Year 2015 Improper Payment 

Estimates 10

Figure 5: CFO Act Agency Programs Noncompliant under IPERA 

for 3 Consecutive Years or More, as Reported by Their 

IGs, as of Fiscal Year 2015 12

Figure 6: CFO Act Agencies’ IPERA Compliance by IPERA 

Criteria for Fiscal Years 2011 through 2015, as 

Reported/Acknowledged by Their IGs 14

Figure 7: Total Instances of Noncompliance under IPERA Criteria 

at CFO Act Agencies for Fiscal Years 2011 through 2015, 

as Reported/Acknowledged by Their IGs 15
Page iv GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 8: Number of CFO Act Agency IGs That Reported 

Performing Optional Procedures during Their Fiscal Year 

2015 IPERA Compliance Reviews 24

Figure 9: Number of Improper Payments Recommendations 

Included in the CFO Act Agency IGs’ Fiscal Years 2011 

through 2015 IPERA Compliance Reports 28

Figure 10: Number and Status of Improper Payment-Related 

Recommendations Made by the CFO Act Agency 

Inspectors General in Their Fiscal Years 2011 through 

2015 IPERA Compliance Reports, as of December 31, 

2016 30

Figure 11: Summary of Noncompliant CFO Act Agencies per 

IPERA Criteria, as Reported/Acknowledged by the IGs, 

and Status of IGs’ Recommendations Designed to 

Address Noncompliance, as of December 31, 2016 31

Figure 12: Fiscal Year 2015 CFO Act Agencies’ Overall IPERA 

Compliance by IPERA Criteria, as Reported by Their IGs 40

Figure 13: Fiscal Year 2015 CFO Act Agencies’ IPERA 

Compliance as Reported by Their IGs 41
Page v GAO-17-484 Fiscal Year 2015 IPERA Compliance

Abbreviations

AFR Agency Financial Report

CFO Act Chief Financial Officers Act of 1990

CIGIE Council of the Inspectors General on Integrity and

Efficiency

DHS Department of Homeland Security

DOD Department of Defense

DOI Department of the Interior

DOL Department of Labor

DOT Department of Transportation

DRAA Disaster Relief Appropriations Act

Education Department of Education

EPA Environmental Protection Agency

FEMA Federal Emergency Management Agency

FNS Food and Nutrition Service

GSA General Services Administration

HHS Department of Health and Human Services

HUD Department of Housing and Urban Development

IG Inspector General

IPERA Improper Payments Elimination and Recovery Act of 2010

IPERIA Improper Payments Elimination and Recovery

Improvement Act of 2012

IPIA Improper Payments Information Act of 2002

NASA National Aeronautics and Space Administration

NRC Nuclear Regulatory Commission

NSF National Science Foundation

OCFO Office of Chief Financial Officer

OMB Office of Management and Budget

OPM Office of Personnel Management

PAR Performance and Accountability Report

SBA Small Business Administration

SSA Social Security Administration

State Department of State

TANF Temporary Assistance for Needy Families program

Treasury Department of the Treasury

USDA U.S. Department of Agriculture

VA Department of Veterans Affairs
Page vi GAO-17-484 Fiscal Year 2015 IPERA Compliance

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Page 1 GAO-17-484 Fiscal Year 2015 IPERA Compliance

441 G St. N.W.

Washington, DC 20548

May 31, 2017

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs 

United States Senate

Dear Senator McCaskill:

Improper payments—payments that should not have been made or were 

made in incorrect amounts—have been estimated to total over $1.2 trillion 

government-wide from fiscal year 2003 through fiscal year 2016.1

Specifically, for fiscal year 2003, 27 agency programs reported estimated 

improper payments totaling $35 billion, and by fiscal year 2016, 

112 agency programs reported estimated improper payments totaling 

$144.3 billion.2 The focus of this review is fiscal year 2015, and for that 

year 122 agency programs reported estimated improper payments 

totaling $136.7 billion. It is important to note that these estimates 

themselves may not be accurate, reliable, or complete, as we have 

reported that the federal government is unable to determine the full extent 

of improper payments and to reasonably assure that actions are taken to 

reduce them. In addition, certain inspectors general (IG) have reported 

issues with agencies’ reported improper payment estimates because of 

 1

Under the Improper Payments Information Act of 2002, Pub. L. No. 107-300, 116 Stat. 

2350 (Nov. 26, 2002), codified as amended at 31 U.S.C. § 3321 note, certain agencies 

were required to start reporting improper payment estimates beginning for fiscal year 

2003. An improper payment is defined as any payment that should not have been made or 

that was made in an incorrect amount (including overpayments and underpayments) 

under statutory, contractual, administrative, or other legally applicable requirements. 

Office of Management and Budget (OMB) guidance also instructs agencies to report as 

improper payments any payments for which insufficient or no documentation was found. It 

is important to note that improper payment totals are estimated and may or may not 

represent a loss to the government. 

2

The improper payment estimates for fiscal years 2015 and 2016 exclude the Department 

of Defense’s Defense Finance and Accounting Service (DFAS) Commercial Pay program. 

Although OMB included this program in its government-wide improper payment estimate 

for both years, because of continuing GAO concerns based on audit findings in a 2013 

report regarding the reliability of its improper payment estimate, the DFAS Commercial 

Pay estimate was excluded from GAO’s calculations. See GAO, DOD Financial 

Management: Significant Improvements Needed in Efforts to Address Improper Payment 

Requirements, GAO-13-227 (Washington, D.C.: May 13, 2013). The government-wide 

improper payment estimates for fiscal years 2015 and 2016 are detailed in apps. IV and 

VII. 

Letter
Page 2 GAO-17-484 Fiscal Year 2015 IPERA Compliance

insufficient sampling methods and flawed estimation methodologies were 

used to calculate and report improper payment estimates. Fiscal year 

2015 marked the fifth year of the implementation of the Improper 

Payments Elimination and Recovery Act of 2010 (IPERA), which, among 

other things, requires federal agencies’ IGs to annually assess and report 

on whether the agencies under their jurisdiction complied with the six 

criteria listed in IPERA.3 The IGs’ annual IPERA compliance reports serve 

a key function: to reasonably assure that federal dollars are not misspent 

and that improper payment estimates are accurate, reliable, and 

complete. The reports also provide Congress with information on 

agencies’ efforts to address improper payments. These reports are the 

focus of this review. We previously reported on agency compliance under

IPERA for fiscal years 2013 and 2014, as reported by the IGs.4

This audit was conducted to summarize agencies’ compliance under 

IPERA for fiscal year 2015, as reported by their IGs in fiscal year 2016, as 

well as provide compliance trends for the past 5 years. Specifically, this 

report discusses the following:

1. A summary of IPERA compliance determinations by the IGs for the 

24 agencies listed in the Chief Financial Officers Act of 1990, as 

amended (CFO Act),5 including the extent to which the agencies 

complied with the criteria listed in IPERA for fiscal years 2011 through 

2015 as reported by their IGs; the criteria and programs the IGs 

concluded were responsible for agency noncompliance and the 

number of programs that were reported as noncompliant for 3 or more 

consecutive years as of fiscal year 2015; and the extent to which the 

responsible agencies submitted the required information to Congress.

 3

At the start of our audit, fiscal year 2015 was the most current reporting year for which 

inspectors general issued compliance reports as required by section 3 of the IPERA,

Pub. L. No. 111-204, 124 Stat. 2224 (July 22, 2010), codified at 31 U.S.C. § 3321 note.

Fiscal year 2016 IPERA compliance reports were due in May 2017.

4

GAO, Improper Payments: Inspector General Reporting of Agency Compliance under the 

Improper Payments Elimination and Recovery Act, GAO-15-87R (Washington, D.C.: 

Dec. 9, 2014), and Improper Payments: CFO Act Agencies Need to Improve Efforts to 

Address Compliance Issues, GAO-16-554 (Washington, D.C.: June 30, 2016). 

5

The CFO Act, Pub. L. No. 101-576, 104 Stat. 2838 (Nov. 15, 1990), established, among 

other things, chief financial officers to oversee financial management activities at 23 major 

executive departments and agencies. The list now includes 24 entities, which are often 

referred to collectively as CFO Act agencies, and is codified, as amended, in section 901 

of Title 31, United States Code. The CFO Act agencies accounted for over 99 percent of 

the government-wide improper payment estimate in fiscal year 2015.
Page 3 GAO-17-484 Fiscal Year 2015 IPERA Compliance

2. The extent to which the IGs reported that they performed optional 

procedures during their fiscal year 2015 reviews, as outlined in Office 

of Management and Budget (OMB) guidance.

3. The extent to which the IGs’ fiscal years 2011 through 2015 IPERA 

compliance reports included recommendations and the status of these 

recommendations as of December 31, 2016, and for the open 

recommendations associated with noncompliant agencies, the extent 

to which the recommendations were designed to address agencies’

noncompliance with one or more of the six IPERA criteria.

To determine the number of CFO Act agencies (hereafter referred to as 

agencies) and programs that were reported as compliant or noncompliant 

under IPERA, including those reported as noncompliant for 3 or more 

consecutive years as of fiscal year 2015, we reviewed the fiscal years 

2011 through 2015 reports prepared by the IGs at the 24 agencies and 

summarized their findings and conclusions. We selected these 

24 agencies because they represented over 99 percent of the 

government-wide improper payment estimate in fiscal year 2015. To 

determine if agencies submitted the required information to Congress to 

address consecutive reported noncompliance, we interviewed officials 

from the Offices of Chief Financial Officer at relevant agencies and 

reviewed supporting documentation. Additionally, we reviewed the 

improper payments information reported in the agencies’ fiscal years 

2015 and 2016 agency financial reports (AFR) or performance and 

accountability reports (PAR) to determine the total improper payment 

estimate reported for the 24 agencies.6 To determine the extent to which 

the IGs performed any optional procedures as outlined in OMB guidance, 

we reviewed the IGs’ fiscal year 2015 reports. In addition, to determine 

the number and status of the IGs’ recommendations, we reviewed the 

IGs’ fiscal years 2011 through 2015 IPERA compliance reports and 

obtained recommendation status information from the IGs. Additionally, 

we reviewed and categorized the IGs’ open recommendations, as of 

December 31, 2016, to determine whether the IGs associated with the 

15 noncompliant agencies had recommended actions designed to 

address the agencies’ noncompliance with one or more of the six IPERA 

criteria. Finally, we corroborated our findings with OMB and all 24 CFO 

Act agencies and their IGs.

 6

An AFR is a report on an agency’s end of fiscal year financial position that includes, but 

is not limited to, financial statements, notes on the financial statements, and a report of the 

independent auditor. A PAR is an AFR combined with an annual performance report, 

which includes information on an agency’s efforts to achieve goals during the past fiscal 

year.
Page 4 GAO-17-484 Fiscal Year 2015 IPERA Compliance

We conducted this performance audit from June 2016 to May 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Appendix I provides additional 

information on our scope and methodology.

In November 2002, Congress passed and the President signed the 

Improper Payments Information Act of 2002 (IPIA), which was later 

amended by IPERA and the Improper Payments Elimination and 

Recovery Improvement Act of 2012 (IPERIA).7 The amended legislation 

requires executive branch agencies to (1) review all programs and 

activities and identify those that may be susceptible to significant 

improper payments (commonly referred to as a risk assessment), 

(2) publish improper payment estimates for those programs and activities 

that the agency identified as being susceptible to significant improper 

payments, (3) implement corrective actions to reduce improper payments 

and set reduction targets, and (4) report on the results of addressing the 

foregoing requirements.8

In addition to the agencies’ identifying programs and activities that are 

susceptible to significant improper payments, OMB also designates as 

high-priority the programs with the most egregious cases of improper 

payments. Specifically, OMB is required by IPERIA to annually identify a 

list of high-priority federal programs in need of greater oversight and 

review. In general, OMB has implemented this requirement by 

designating high-priority programs based on a threshold of $750 million in 

estimated improper payments for a given fiscal year.

 7

Pub. L. No. 112-248, 126 Stat. 2390 (Jan. 10, 2013). 

8

For fiscal year 2014 and beyond, “significant improper payments” are defined as gross 

annual improper payments in a program that may have exceeded either (1) 1.5 percent of 

program outlays and $10 million or (2) $100 million (regardless of the improper payment 

rate). The Disaster Relief Appropriations Act, 2013, Pub. L. No. 113-2, div. A, § 904(b), 

127 Stat. 4, 17 (Jan. 29, 2013), required that all programs receiving funds appropriated by 

that act be deemed susceptible to significant improper payments, which consequently 

requires the agencies responsible for these programs to estimate improper payments, 

implement corrective actions, and report on their results for these programs. 

Background
Page 5 GAO-17-484 Fiscal Year 2015 IPERA Compliance

IPERA calls for executive agencies’ IGs to annually determine and report 

on whether their respective agencies complied with the following six 

criteria:9

• publish a report in the form and content required by OMB—typically 

an AFR or a PAR—for the most recent fiscal year, and post that report 

on the agency website;

• conduct a program-specific risk assessment for each program or 

activity;10

• publish improper payment estimates for all programs and activities 

deemed susceptible to significant improper payments under the 

agency’s risk assessment;

• publish corrective action plans for those programs and activities 

assessed to be at risk for significant improper payments;

• publish and meet annual reduction targets for all programs and 

activities assessed to be at risk for significant improper payments; and

• report a gross improper payment rate of less than 10 percent for each 

program and activity for which an improper payment estimate was 

published.

IPERA states that if an IG reports that an agency is not in compliance 

with any of the IPERA criteria for 1 fiscal year, the agency head must 

submit a plan to appropriate congressional committees and OMB 

describing the actions that the agency will take to come into compliance. 

If an agency is found noncompliant with respect to the same program for 

2 consecutive years, IPERA directs OMB to review the program and 

determine if additional funding would help bring the program into 

compliance and, if so, directs the agency to use any available 

reprogramming or transfer authority, or request further reprogramming or 

transfer authority from Congress, to aid in the program’s remediation 

efforts. For programs determined to be noncompliant for more than 

3 consecutive years, IPERA requires the agency to submit to Congress 

within 30 days of the IG’s report either (1) a reauthorization proposal for 

the program or (2) proposed statutory changes necessary to bring the 

 9

These requirements are outlined in section 3 of IPERA.

10Risk assessments were required for all programs in fiscal year 2011 and must be 

performed at least once every 3 fiscal years thereafter.
Page 6 GAO-17-484 Fiscal Year 2015 IPERA Compliance

program or activity into compliance.11 Because the legal requirement to 

report to Congress is triggered by the IG reporting noncompliance, rather 

than the noncompliance itself, agencies are not subject to the 

congressional reporting requirement until their IGs report their 

determinations. In addition, as we previously reported, when agencies 

determine that reauthorization or statutory changes are not considered 

necessary to bring the programs into compliance, the agencies should 

state so in their letters to Congress.

Furthermore, IPERIA requires the IGs at agencies with OMB-designated 

high-priority programs to perform additional procedures. OMB also 

provides guidance, in OMB Circular No. A-123, Appendix C (OMB M-15-

02),12 to the IGs regarding their annual IPERA compliance reports. This 

guidance restates the statutory requirements and adds procedures that 

the IGs are encouraged to adopt at their discretion during their annual 

IPERA reviews (hereafter referred to as optional procedures).13 It is 

important to note that some of the optional procedures outlined in OMB 

guidance are similar to those required for programs designated by OMB 

as high-priority; however, whether to perform such procedures for 

non-high-priority programs is up to the IGs.14 Figure 1 details the IGs’

required and optional procedures.

 11While IPERA states that these procedures are required of agencies with more than 

3 consecutive years of noncompliance findings by their IGs, OMB’s guidance instructs 

agencies with 3 or more years of consecutive noncompliance to take these steps, thereby 

including those agencies with exactly 3 years of consecutive reported noncompliance.

12Office of Management and Budget, Appendix C to Circular No. A-123, Requirements for 

Effective Estimation and Remediation of Improper Payments, OMB Memorandum No. 

M-15-02 (Washington, D.C.: October 2014).

13OMB plays a key role in overseeing the implementation of laws related to improper 

payment reporting. Specifically, OMB is directed by statute to provide guidance to federal 

agencies on estimating, reporting, reducing, and recovering improper payments.

14IGs have general authority to conduct audits, investigations, and other oversight 

procedures related to their agencies’ operations, including improper payments estimation 

and reporting. IGs are expected to prioritize their discretionary work based on a strategic 

planning process that takes into consideration requests from external stakeholders such 

as OMB where applicable. Council of the Inspectors General on Integrity and Efficiency, 

Quality Standards for Federal Offices of Inspector General (2012).
Page 7 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 1: Overview of Inspector General Procedures That Are Required and Optional Related to Improper Payment Reporting

Five years after the implementation of IPERA, 15 of the 24 agencies were 

reported as noncompliant under IPERA for fiscal year 2015. Although the 

number of agencies reported as noncompliant improved in fiscal years 

2012 and 2013, decreasing to 12 and 11 agencies, respectively, IGs 

collectively reported an increase in agency noncompliance to 15 agencies 

in fiscal years 2014 and 2015. However, as discussed later in this report, 

we found that the IGs’ compliance determinations for fiscal year 2015 

were not based on a consistent government-wide approach. Figure 2 

summarizes the number of agencies noncompliant under IPERA each 

year since fiscal year 2011, as reported by their IGs.

Over Half of the CFO 

Act Agencies 

Continue to Be 

Reported as 

Noncompliant under 

IPERA, but the IGs’

Compliance 

Determinations for

Fiscal Year 2015 

Were Inconsistent
Page 8 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 2: The Number of CFO Act Agencies Compliant and Noncompliant under 

IPERA for Fiscal Years 2011 through 2015, as Reported/Acknowledged by Their IGs

We found that noncompliance frequently stretched across multiple years. 

For instance, 14 of the 15 agencies were noncompliant in fiscal years

2014 and 2015. In addition, 9 of the 15 noncompliant agencies in fiscal 

year 2015 have been reported as noncompliant since IPERA was 

implemented—for 5 consecutive years. Figure 3 details the 24 agencies’

overall compliance under IPERA, as reported by their IGs, for fiscal years 

2011 through 2015.
Page 9 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 3: CFO Act Agencies’ Overall IPERA Compliance for Fiscal Years 2011 through 2015, as Reported/Acknowledged by 

Their IGs

a

The NSF IG did not issue an IPERA compliance report for fiscal year 2013 because NSF did not 

publish improper payment data in its fiscal year 2013 agency financial report.

b

The SSA IG reported for fiscal year 2012 that the agency was compliant under IPERA criteria, but 

we noted that its Supplemental Security Income program failed to meet its reported reduction target 

for that year and in fiscal year 2011. The SSA IG concurred with this finding but does not plan to 
Page 10 GAO-17-484 Fiscal Year 2015 IPERA Compliance

reissue its fiscal year 2012 IPERA compliance report to state a conclusion of noncompliance or its 

fiscal year 2011 report to state that the agency missed its reduction target. SSA was already reported 

noncompliant in fiscal year 2011 based on other criteria.

The IGs associated with the 15 noncompliant agencies reported that a 

total of 52 programs were responsible for identified instances of 

noncompliance in fiscal year 2015.15 As shown in figure 4, the 

noncompliant programs accounted for a reported $132 billion in fiscal 

year 2015 estimated improper payments, which is approximately 96 

percent of the $136.7 billion government-wide reported estimate.16

Figure 4: Programs at CFO Act Agencies That Accounted for the Total Reported Fiscal Year 2015 Improper Payment 

Estimates

 15App. III contains a list of the 52 noncompliant programs at CFO Act agencies and the 

specific IPERA criteria that IGs reported contributed to the programs’ noncompliance for 

fiscal year 2015.

16App. IV details the fiscal year 2015 improper payment estimates for all programs at CFO 

Act agencies, including the 52 programs that the IGs reported as noncompliant.
Page 11 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Seven agencies were reported as noncompliant for 3 or more consecutive 

years as of the end of fiscal year 2015, representing 12 programs. IPERA 

requires agencies that have been deemed noncompliant for consecutive 

years to take certain actions. Specifically, according to IPERA and OMB 

guidance, if a program is found to be noncompliant by an agency’s IG for 

3 or more consecutive years, the agency must submit to Congress within 

30 days of such determination a reauthorization proposal for each 

noncompliant program or any proposed statutory changes it deems 

necessary to bring the program into compliance. OMB guidance also 

states that agencies should share these proposals or plans with their 

respective IGs.

For the 7 agencies that had noncompliant programs for 3 or more 

consecutive years as of the end of fiscal year 2015, as reported by their 

IGs, we found that 6 agencies submitted the required information to 

Congress. The remaining agency, the U.S. Department of Agriculture 

(USDA), had not submitted the required information to Congress, despite 

our prior recommendation, as well as USDA IG recommendations, to do 

so. Specifically, 5 USDA programs were reported as noncompliant for at 

least 3 consecutive years as of fiscal year 2015. Four of these programs 

were noncompliant for 5 consecutive years, and 1 was noncompliant for 

3 consecutive years. Figure 5 lists the 7 agencies and the 12 programs 

that were noncompliant for 3 or more consecutive years, as reported by 

their IGs.17

 17The Department of Homeland Security (DHS) also had programs that were 

noncompliant for 3 or more consecutive years; however, DHS’s IG did not originally report 

the programs as noncompliant. Although the DHS IG subsequently reissued its IPERA 

compliance reports to reflect determinations of noncompliance, OMB advised DHS to take 

the actions required under IPERA in response to 1 year of noncompliance for fiscal year 

2014. Therefore, as of the end of fiscal year 2015, these programs would have been 

reported as noncompliant for 2 consecutive years. See GAO-16-554.

Seven Agencies Were 

Reported as Noncompliant 

for 3 Consecutive Years or 

More, as of Fiscal Year 

2015, and One Agency 

Did Not Provide Congress 

with the Required 

Information
Page 12 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 5: CFO Act Agency Programs Noncompliant under IPERA for 3 Consecutive Years or More, as Reported by Their IGs, 

as of Fiscal Year 2015

USDA’s Office of Chief Financial Officer (OCFO) informed us that some 

of the delays for issuing the letter were caused by the office’s need to 

meet with OMB to determine how best to satisfy the requirements. For 

example, according to the USDA OCFO, OCFO met with OMB in June 

2014, and OMB advised USDA OCFO that proposed statutory changes 

were not needed and that a letter to Congress was acceptable to satisfy 

the requirements. However, almost 3 years later, USDA has still not 
Page 13 GAO-17-484 Fiscal Year 2015 IPERA Compliance

issued the letter. The USDA OCFO stated that it plans to submit the 

required information for all 5 programs by the end of fiscal year 2017. 

However, IPERA and OMB guidance calls for the information to be 

submitted within 30 days of the IG’s reported noncompliance. Therefore, 

for the 4 programs that were noncompliant for 5 consecutive years, the 

required information should have been submitted within 30 days of the 

3 consecutive years noncompliance reporting, which occurred in April 

2014. We also recommended in June 2016 that USDA take the required 

actions for these 4 programs, and as of March 2017, our prior 

recommendation remains open. For the 1 remaining program, which was 

noncompliant for 3 consecutive years, the information was required to be 

submitted in June 2016. When agencies do not report the required 

information, Congress may lack the information necessary to monitor the 

implementation of IPERA and take action to address problematic 

programs in a timely manner.

The IGs’ IPERA compliance reports showed areas where agency 

compliance has remained a challenge throughout the past 5 years. 

Specifically, as shown in figure 6, noncompliance with the IPERA criterion 

to publish and meet annual improper payment reduction targets has been 

the primary reason agencies were reported as noncompliant by their 

respective IGs for 5 consecutive years. For instance, for fiscal years 2011 

through 2015, IGs reported that 11 agencies did not comply with this 

criterion. Of these 11 noncompliant agencies, 8 agencies have been 

noncompliant with this criterion every year since fiscal year 2011.18 While 

the IGs generally reported that agencies published reduction targets for 

applicable programs, the targets were regularly not met as the actual 

rates exceed the targets.

 18These eight agencies were the Small Business Administration, the Social Security 

Administration, and the Departments of Health and Human Services, Homeland Security, 

Labor, Transportation, Veterans Affairs, and Agriculture.

IGs Reported Agencies’

Continued Noncompliance 

with Several IPERA 

Criteria
Page 14 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 6: CFO Act Agencies’ IPERA Compliance by IPERA Criteria for Fiscal Years 2011 through 2015, as 

Reported/Acknowledged by Their IGs

Although reported noncompliance for several IPERA criteria increased or 

stayed the same in fiscal year 2015, as compared to fiscal year 2014, the 

total instances of noncompliance (i.e., sum of all instances of IG-reported 

agency noncompliance for all six IPERA criteria) has declined since 

IPERA was first implemented in fiscal year 2011, as noted in figure 7. 

Specifically, in fiscal year 2011, the IGs reported 38 total instances of 

noncompliance for all six IPERA criteria, compared to 28 reported 

instances of noncompliance in fiscal year 2015.
Page 15 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 7: Total Instances of Noncompliance under IPERA Criteria at CFO Act 

Agencies for Fiscal Years 2011 through 2015, as Reported/Acknowledged by Their 

IGs

Although agencies’ continued noncompliance is concerning, we have 

previously reported that an agency’s failure to meet reduction targets and 

report improper payment rates below 10 percent may not necessarily 

suggest that the agency failed to adequately monitor its programs’

improper payments.19 For example, certain IGs reported increases in 

 19GAO-16-554.
Page 16 GAO-17-484 Fiscal Year 2015 IPERA Compliance

improper payment rates because of factors such as improved sampling 

and emphasis on training, which enhanced their agencies’ ability to detect 

improper payments. Specifically, the Department of Veterans Affairs (VA) 

IG reported in its fiscal year 2015 report that 2 VA programs—Community 

Care and Purchased Long-Term Services and Support—reported 

improper payment rates of 54.77 percent and 59.14 percent, respectively. 

According to the VA IG, these rates were significantly higher than those in 

the prior year when both programs reported improper payment rates 

slightly below 10 percent. According to the VA IG, the dramatic increase 

in improper payment rates for the 2 programs occurred primarily because 

of improved sample evaluation procedures in fiscal year 2015, which 

resulted in more improper payments being identified. Significant 

improvements in sampling, training, and the ability to detect improper 

payments could considerably reduce the likelihood that an agency will 

meet a predetermined reduction target or report an improper payment 

rate below 10 percent.

As previously discussed, for the past 5 years, IGs reported that there 

were 11 agencies that did not meet the IPERA criterion that required 

agencies to publish and meet reduction targets. For fiscal year 2015, 4 of 

the 11 agencies—the Department of Defense (DOD), Department of 

Education (Education), Department of Homeland Security (DHS), and 

Social Security Administration (SSA)—that did not meet reduction targets 

were compliant with the remaining five IPERA criteria. Therefore, once 

these 4 agencies implement the necessary controls to prevent and detect 

improper payments, they may be able to meet their reduction targets, 

which in turn, could result in these 4 agencies becoming compliant under 

IPERA overall in future years. Furthermore, 3 other agencies—the 

Department of Labor (DOL), VA, and Small Business Administration 

(SBA)—out of the 11 that did not meet reduction targets were reported by 

their IGs as being noncompliant with only one other IPERA criterion (to 

report improper payment rates below 10 percent). Therefore, these 

3 agencies may also become compliant under IPERA once they 

implement the necessary controls to prevent and detect improper 

payments, as they may be able to meet their reduction targets and report 

improper payment rates below 10 percent. Appendix III details the agency 

programs that did not meet their reduction targets and that reported 

improper payment rates above the 10 percent threshold for fiscal year 

2015.
Page 17 GAO-17-484 Fiscal Year 2015 IPERA Compliance

We reviewed the IGs’ fiscal year 2015 IPERA compliance reports and 

found that the IGs were not consistent with one another regarding how 

they determined and reported on compliance when issues were identified. 

Some IGs reported compliance based on the presence or absence of the 

required analysis or reporting (hereafter referred to as a pass/fail 

determination by the IG), regardless of whether the IGs identified flaws, 

whereas other IGs reported agencies as noncompliant based on the IGs 

performing some degree of evaluative procedures to determine whether 

the agencies’ analyses or reports were substantively adequate (hereafter 

referred to as a determination based on evaluative procedures). IPERA 

does not clearly indicate whether, for example, an IG should report an 

agency as compliant under the criteria regarding publication of improper 

payment estimates if the agency reports an improper payment estimate 

that is based on a flawed methodology. While we recognize that the 

severity of the issues may have resulted in the IGs’ reporting 

noncompliance for some agencies, we found, as noted in some of the 

examples below, the types of issues identified for both the compliant and 

noncompliant agencies were similar.

• IPERA criterion: Publish an AFR or PAR. One IG reported its 

respective agency as noncompliant with this criterion. While this IG 

reported the Department of Transportation (DOT) noncompliant as a 

result of finding issues with improper payment information included in 

the AFR (i.e., noncompliance based on evaluative procedures), six 

other IGs reported their respective agencies—the Department of 

Housing and Urban Development (HUD), Department of State (State), 

Environmental Protection Agency (EPA), National Aeronautics and 

Space Administration (NASA), General Services Administration 

(GSA), and Office of Personnel Management (OPM)—as compliant 

despite finding similar issues with the improper payment information 

included in the agencies’ published AFRs or PARs (i.e., compliance 

based on pass/fail determinations). For example, the DOT IG reported 

noncompliance with this criterion as a result of identified issues with 

the outlays reported in DOT’s AFR, which is the same issue that was 

identified by another IG that reported its agency (GSA) as compliant. 

As shown in table 1, if the IGs consistently determined compliance 

with this IPERA criterion based on pass/fail determinations or based 

on evaluative procedures, the number of agencies reported as 

noncompliant with this IPERA criterion could have decreased by 1 

(from 1 agency to none) or increased by 6 (from 1 to 7 agencies), 

respectively.

IGs Reported Fiscal Year 

2015 Compliance 

Determinations 

Inconsistently
Page 18 GAO-17-484 Fiscal Year 2015 IPERA Compliance

• IPERA criterion: Conduct program-specific risk assessments. Four 

IGs reported their respective agencies as noncompliant with this 

criterion. One of the 4 IGs reported its agency, the Department of the 

Interior (DOI), as noncompliant because the agency did not prepare a 

required risk assessment (i.e., compliance based on pass/fail 

determinations). The remaining 3 IGs reported their respective 

agencies—the Department of Health and Human Services (HHS), 

HUD, and OPM—as noncompliant based on identified issues with the 

risk assessments (i.e., noncompliance based on evaluative 

procedures). However, 6 other IGs reported their respective 

agencies—EPA, GSA, NASA, the National Science Foundation 

(NSF), State, and the Department of the Treasury (Treasury)—as 

compliant despite finding similar issues with the risk assessments 

(i.e., compliance based on pass/fail determinations). For example, 2 

IGs reported that their respective agencies (HUD and OPM) were 

noncompliant with the IPERA risk assessment criterion as a result of 

their agencies not considering all nine required risk factors, as 

outlined in OMB guidance, during program-specific risk assessments, 

whereas another IG reported its agency (NSF) as compliant with this 

IPERA criterion, despite also finding issues with the agency’s 

consideration of the nine required risk factors. In addition, although 

the State IG reported that the qualitative risk assessments conducted 

by State included an evaluation of the nine risk factors required by 

OMB, the State IG also reported that the agency could have improved 

its risk assessment process regarding one of the nine risk factors—

significant increases in funding. Specifically, the State IG reported that 

there was a deficiency with State’s process for identifying programs 

with significant funding changes. The State IG recommended that 

State expand its process to identify programs with significant funding 

changes to consider additional factors that may increase the risk of 

significant improper payments, including, at a minimum, the 

percentage increase of the change. According to the State IG, if the

State’s risk assessment process does not consider the percentage 

increase, then the agency may not identify all programs that had 

increased risks of improper payments because of increased funding.

20

For example, the State IG stated that a program that had 

expenditures of $101 million in year one and experienced an increase 

in expenditures of $99 million (98 percent) in year two would not meet 

the $100 million threshold and, as a result, would not be identified as 

 20In response to a draft of this report, State officials stated that no additional programs 

would have been identified as needing a risk assessment if its process had included the 

percentage change in funding as one of its criteria. 
Page 19 GAO-17-484 Fiscal Year 2015 IPERA Compliance

a program with significant funding changes, which would require a risk 

assessment. As shown in table 1, if the IGs consistently determined 

noncompliance with this IPERA criterion based on pass/fail 

determinations or based on evaluative procedures, the number of 

agencies reported as noncompliant with this IPERA criterion could 

have decreased by 3 (from 4 to 1 agencies) or increased by 6 (from 4 

to 10 agencies), respectively.21

• IPERA criterion: Publish improper payment estimates. This criterion 

did not apply to 5 agencies.22 For the remaining 19 agencies, 5 

agencies were reported as noncompliant with this criterion. Two of 

these agencies (GSA and HHS) were reported as noncompliant 

because the agencies did not publish required estimates (i.e., 

compliance based on pass/fail determinations), and the remaining 

3 agencies (USDA, DOI, and OPM) were reported as noncompliant 

because of identified issues with their estimates (i.e., noncompliance 

based on evaluative procedures). While the IGs for these 3 agencies 

reported noncompliance as a result of identified issues with the 

estimates, there were 6 other IGs that reported their respective 

agencies (DOD, DOL, Education, HUD, SBA, and VA) were compliant 

despite finding similar issues with the estimates (i.e., compliance 

based on pass/fail determinations). For example, 1 IG (USDA) 

reported that its respective agency was noncompliant with the IPERA 

improper payment estimate criterion because the agency was not 

using sufficient sampling methods to report improper payment 

estimates, whereas another IG (Education) reported its agency as 

compliant with the same IPERA criterion, despite reporting that its 

agency used flawed estimation methodologies to calculate its 

estimates. As shown in table 1, if the IGs consistently determined 

noncompliance with this IPERA criterion based on pass/fail 

determinations or based on evaluative procedures, the number of 

agencies reported as noncompliant with this IPERA criterion could 

have decreased by 3 (from 5 to 2 agencies) or increased by 6 (from 5

to 11 agencies), respectively.

 21As noted above, there were three IGs that reported noncompliance based on evaluative 

procedures (IG-reported noncompliance based on issues). Therefore, if IGs consistently 

reported compliance based on a pass/fail determination, the number of agencies reported 

as noncompliant with this IPERA criterion could have decreased by three agencies.

22This criterion did not apply to agencies that did not have any programs that were 

identified as susceptible to significant improper payments.
Page 20 GAO-17-484 Fiscal Year 2015 IPERA Compliance

• IPERA criterion: Publish corrective action plans. This criterion did not 

apply to 9 agencies.23 Of the remaining 15 agencies, 1 (HHS) was 

reported as noncompliant with this criterion because it did not publish 

a corrective action plan for one of its eight risk-susceptible programs. 

Although we did not find any instances of IGs reporting 

noncompliance as a result of identified issues with the corrective 

action plans, we identified 5 IGs that reported their respective 

agencies (DOD, GSA, OPM, USDA, and HUD) as compliant despite 

finding issues with the corrective action plans (i.e., compliance based 

on pass/fail determinations). For example, 1 IG reported that its 

respective agency was compliant with this IPERA criterion, but the IG 

also reported that the agency’s corrective action plans did not explain 

how it addressed the root causes identified and did not include 

planned or actual completion dates of the actions. As shown in 

table 1, if the IGs consistently determined noncompliance with this 

IPERA criterion based on evaluative procedures, the number of 

agencies reported as noncompliant with this IPERA criterion could 

have increased by 5 (from 1 to 6 agencies). There would be no 

changes to the number of agencies reported as noncompliant if such 

determinations were made based on pass/fail basis, as the 1 IG would 

have still reported its agency as noncompliant for failing to publish a 

corrective action plan.

For the two remaining IPERA criteria, which required agencies to publish 

and meet reduction targets and report improper payment rates below 

10 percent, we found that the IGs consistently made pass/fail 

determinations. Specifically, 11 agencies were reported as noncompliant 

because they each had at least 1 program that did not meet its reduction 

target, and 6 agencies were reported as noncompliant because they had 

at least 1 program that did not report an improper payment rate below 

10 percent. As a result, for these two IPERA criteria, table 1 shows no 

differences between the original IG noncompliance determinations and 

the potential noncompliance results if determinations were consistently 

based on pass/fail or evaluative procedures.

We believe that the variations in the IGs’ determinations reduce their 

usefulness for comparing compliance and progress across agencies. As 

shown in table 1, compliance results could change significantly if the IGs 

consistently determined compliance by performing either pass/fail 

 23This criterion did not apply to agencies that did not have any programs that were 

identified as susceptible to significant improper payments or if the reported improper 

payment estimates for the agencies’ programs were zero.
Page 21 GAO-17-484 Fiscal Year 2015 IPERA Compliance

determinations or the evaluative procedures that some IGs use, which we 

describe in this report. Specifically, if the IGs had all performed IPERA 

compliance determinations based on pass/fail determinations, the number 

of noncompliant agencies could decrease by 1 agency (OPM), from 15 to 

14 agencies.24 In addition, the total instances of noncompliance for all six 

IPERA criteria could have been 21 as compared to 28 instances as 

originally reported by the IGs. Alternatively, if the IGs had consistently 

determined compliance based on the evaluative procedures some IGs 

used, the number of noncompliant agencies could have been over 

one-third higher—an increase of 4 noncompliant agencies (State, EPA, 

NASA, and NSF), for a total 19 noncompliant agencies for fiscal year 

2015. Also, the number of instances of noncompliance for all six IPERA

criteria could increase from the originally reported 28 instances to 

51 instances.25

 24The small decrease is a result of most of the agencies being noncompliant with multiple 

IPERA criteria.

25The number of instances is the sum of the number of agencies reported as noncompliant 

per IPERA criteria, which is greater than the total number of noncompliant agencies 

reported as noncompliant for fiscal year 2015 because some agencies were noncompliant 

with more than one IPERA criteria.
Page 22 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Table 1: IGs’ Originally Reported Fiscal Year 2015 Noncompliance Results for the CFO Act Agencies and Potential 

Noncompliance Results if Consistently Based on Pass/Fail Determinations or Evaluative Procedures

Potential noncompliance 

results if determinations were 

consistently based on 

IPERA criteria Fiscal year 2015 

noncompliance results, as 

originally reported by the IGs

Pass/fail 

determinationsa Evaluative proceduresb

Published required information in an AFR or PAR 1 0 7

Conducted program-specific risk assessment 4 1 10

Published improper payment estimates 5 2 11

Published corrective action plans 1 1 6

Published and met reduction targets 11 11c 11c

Reported rates below 10 percent 6 6c 6c

Reported or potential number of noncompliant instances 

for all six IPERA criteria

28 21 51

Reported or potential number of noncompliant agencies 

for fiscal year 2015

15 14 19

Legend:

AFR: agency financial report

CFO Act: Chief Financial Officers Act of 1990

IG: inspector general

IPERA: Improper Payments Elimination and Recovery Act of 2010

PAR: performance and accountability report

Source: GAO analysis of CFO Act agencies’ IG IPERA compliance reports for fiscal year 2015. | GAO-17-484

a

Actual reported fiscal year 2015 noncompliance determinations based on the presence or absence 

of the required analysis or report (pass/fail determinations) and excluding noncompliance 

determinations based on evaluative procedures.

b

Actual reported fiscal year 2015 noncompliance determinations based on evaluative procedures (IG 

reported noncompliance based on issues), plus hypothetical results if all IGs had reported 

noncompliance as a result of identifying issues based on evaluative procedures that some IGs used, 

as well as pass/fail noncompliance determinations (i.e., agency did not do something, so there was 

no chance for the IG to identify issues).

c

These numbers are as originally reported by the IGs.

Standards for Internal Control in the Federal Government states that 

management should establish measurable objectives that are stated in a 

form that permits reasonably consistent measurement. However, IPERA 

and related guidance from OMB does not specify what, if any, evaluative

procedures should be conducted as part of the compliance determination, 

beyond simply checking for the presence or absence of the required 

analysis or report. In addition, there are no specific requirements for IGs 

to be consistent with one another when determining agency compliance.

Lastly, the Council of the Inspectors General on Integrity and Efficiency 
Page 23 GAO-17-484 Fiscal Year 2015 IPERA Compliance

(CIGIE) stated that although it provided general guidance to the IGs in 

fiscal year 2011, it has not provided the IGs with any guidance regarding 

how compliance determinations should be made.26

OMB issued OMB M-15-02, the latest iteration of its Circular No. A-123, 

Appendix C, in October 2014, which was effective starting with the IGs’

fiscal year 2014 IPERA compliance reviews. The new OMB guidance 

attempted to make IG determinations of compliance clearer and more 

concise by instructing IGs to include in their reports a high-level summary 

of compliance, both overall and by IPERA criteria. While our audit scope 

did not include testing to determine if the IGs complied with all of the 

IPERA requirements or whether the IGs followed OMB guidance, as 

noted above we identified inconsistent reporting among the IGs during the

course of our audit work. We presented the inconsistencies we identified 

to OMB staff, and they informed us that they had noticed similar 

inconsistencies.

Although OMB held IPERA compliance town halls prior to the IGs’ fiscal 

years 2015 and 2016 IPERA compliance reviews, the town hall briefing 

slides did not state OMB’s position on whether the IGs should make 

compliance determinations based on pass/fail determinations or 

evaluative procedures. OMB staff confirmed that their guidance, as well 

as IPERA, does not specify what, if any, evaluative procedures should be 

conducted as part of the compliance determination, beyond simply 

checking for the presence or absence of the required analysis or report. 

Continuing inconsistent compliance determinations may result in 

potentially misleading information regarding government-wide compliance 

under IPERA.

 26CIGIE was statutorily established as an independent entity within the executive branch 

by the Inspector General Reform Act of 2008 to (1) address integrity, economy, and 

effectiveness issues that transcend individual government agencies and (2) increase the 

professionalism and effectiveness of personnel by developing policies, standards, and 

approaches to aid in establishing well-trained and highly skilled workforces in the IG 

offices.

OMB Has Taken Steps to 

Coordinate with IGs on the 

IPERA Compliance 

Reporting Requirements
Page 24 GAO-17-484 Fiscal Year 2015 IPERA Compliance

We reviewed the IGs’ fiscal year 2015 IPERA compliance reports and 

found that 20 of the 24 agencies’ IGs reported that they performed at 

least one procedure beyond what is required by IPERA and IPIA, as 

amended by IPERIA.27 Specifically, as shown in figure 8, we found that 

the IGs reported that they performed optional procedures, which included 

evaluations of the (1) agency’s assessment of the level of risk for 

non-high-priority programs, (2) quality of the agency’s estimation 

methodology for non-high-priority programs, (3) accuracy and 

completeness of agency reporting, (4) agency’s performance in 

recapturing improper payments, and (5) agency’s corrective action plans. 

Appendix V lists the 20 IGs and the specific optional procedures 

performed by each IG.

Figure 8: Number of CFO Act Agency IGs That Reported Performing Optional 

Procedures during Their Fiscal Year 2015 IPERA Compliance Reviews

 27If the IGs reported audit findings, investigations, and so forth on their agencies’ activities 

related to improper payment requirements in separate reports, that work would not be 

reflected in this analysis.

Majority of CFO Act 

Agency IGs Reported 

Performing One or 

More Optional 

Procedures during 

Their Fiscal Year 

2015 IPERA 

Compliance Reviews
Page 25 GAO-17-484 Fiscal Year 2015 IPERA Compliance

While current improper payment estimation laws and corresponding OMB 

guidance require the IGs to conduct evaluative procedures of the 

agencies’ risk assessments and estimation methodologies when 

reviewing programs that OMB designated as high-priority, these types of 

evaluative procedures are optional for non-high-priority programs. To put 

this in perspective, in fiscal year 2015, there were 122 programs that 

published improper payment estimates, and OMB designated 16 of those 

programs as high-priority programs.28 Therefore, only those 16 programs 

were required to undergo the IGs’ evaluations of their risk assessments 

and improper payment estimates (two IPERA criteria). While $127 billion 

of the $136.7 billion fiscal year 2015 government-wide improper payment 

estimate was attributable to the 16 OMB-designated high-priority 

programs, there was $9.7 billion in reported estimated improper payments 

for the remaining programs that are not considered high-priority. Although 

the IGs were not required to perform annual evaluative procedures to 

identify issues with the agencies’ risk assessments and estimation 

methodologies for the non-high-priority programs, as noted in figure 8, 

some IGs elected to perform these evaluative procedures for such 

programs. OMB staff stated that they believe that performing evaluative 

procedures is beneficial to addressing government-wide improper 

payments, and, for that reason, they encourage IGs to do more 

substantive, in-depth work during their annual IPERA compliance 

reviews.

The following examples provide additional details regarding the IGs’

performance of these optional procedures:

• Evaluation of agency’s risk assessment(s) for non-high-priority 

programs: As noted in figure 8, we found that 11 IGs reported that 

they evaluated the agency’s program-specific risk assessment(s). Of 

these 11 agencies, we identified 3 IGs (USDA, Treasury, and NASA) 

that performed their own independent risk assessments and/or 

analysis and, as a result, identified additional agency programs that 

they believed should have been identified as susceptible to significant 

improper payments during the agencies’ own risk assessments. As a 

result of performing this optional procedure, certain IGs recommended 

 28For the 122 programs that published improper payment estimates in fiscal year 2015, 

115 were CFO Act agency programs and the remaining 7 were non-CFO Act agency 

programs. The 16 high-priority programs were all CFO Act agency programs. App. IV lists 

the programs that OMB designated as high-priority for fiscal year 2015 and the reported 

improper payment estimates for those programs, as well as the non-high-priority 

programs. 
Page 26 GAO-17-484 Fiscal Year 2015 IPERA Compliance

that the agencies revise their program-specific risk assessment 

processes to reduce the risk of the agencies not identifying all 

programs susceptible to significant improper payments. The 

recommended improvements included revising the processes to 

include factors such as quantitative assessments in addition to (or 

instead of) qualitative assessments.

• Evaluation of agency’s estimation methodologies for non-high-priority 

programs: As noted in figure 8, we found that 10 IGs reported that 

they evaluated the quality of the agencies’ improper payment 

estimates and methodologies for certain non-high-priority programs. 

Specifically, we found that these IGs reported that the published 

improper payment estimate for at least 1 agency program was 

unreliable because the agencies used inaccurate data, incomplete 

data, or insufficient sampling methodologies. As a result of performing 

this optional procedure, certain IGs provided recommendations to 

help the agencies improve the precision of their improper payment 

estimates, such as using improved sampling methodology prepared 

by a trained statistician.

• Evaluation of the accuracy and completeness of agency reporting: As 

noted in figure 8, this was the most frequently performed optional 

procedure. Specifically, we found that 15 of the 24 IGs reported that 

they evaluated the accuracy and completeness of their agencies’

reporting on improper payments. Specifically, we found most of these 

IGs reported that they identified errors in improper payment-related 

information in the agencies’ published AFRs. As a result of performing 

this optional procedure, these IGs provided recommendations to help 

the agencies improve the accuracy of the improper payment-related 

information published in their reports, such as recommending that the 

agencies implement additional internal controls.

• Evaluation of agencies’ performance in recapturing improper 

payments: As noted in figure 8, we found that 9 IGs reported that they 

evaluated their agencies’ efforts to recapture improper payments and 

in some cases found that more improper payments were actually 

recaptured by the agencies than the agencies reported. Specifically, 

certain agencies’ summaries of recaptured improper payments failed 

to include all identified and recaptured improper payments identified 

through sources outside of the agencies’ recapture audits, such as 

those payments identified through IG audits. As a result of performing 

this optional procedure, these IGs made recommendations to help the 

agencies improve the accuracy and completeness in reporting of their 

recaptured payments, such as recommending that the agencies 

develop written policies and procedures detailing the process for 
Page 27 GAO-17-484 Fiscal Year 2015 IPERA Compliance

reporting overpayments identified and recaptured from sources 

outside of payment recapture audits.

• Evaluation of agency corrective action plans: As noted in figure 8, we 

found that 6 IGs reported that they determined whether their agencies’

corrective action plans were (1) robust and focused on the appropriate 

root causes of improper payments, (2) effectively implemented, and 

(3) prioritized within the agency. Specifically, we found that certain IGs 

reported that their agencies’ corrective action plans did not explain 

how the corrective actions addressed the root causes identified, 

lacked planned or actual completion dates of the actions, or had not 

been updated to include more current root causes. Identifying the root 

causes of improper payments enables the agencies to revise their 

corrective action plans to better reflect the unique processes, 

procedures, and risks involved with each agency program susceptible 

to significant improper payments. As a result of performing this

optional procedure, 1 IG recommended that the agency revise its 

corrective action plans to address the issues identified by the IG.

Although hundreds of IG recommendations were made, and over 

two-thirds were closed (320 closed recommendations out of 425 total 

recommendations) during the past 5 years of the IGs’ IPERA compliance 

reviews, agencies’ overall noncompliance under IPERA continues to be at 

its highest point—15 noncompliant agencies for both fiscal years 2014 

and 2015.29 As detailed in figure 9, the total annual number of IG-reported 

recommendations made by the 24 agencies’ IGs has stayed relatively 

steady for the IGs’ fiscal years 2011 through 2015 IPERA compliance 

reviews. There was a decrease in the number of IG-reported 

recommendations related to the agencies’ compliance under IPERA 

during fiscal years 2012 and 2013, which coincides with the 2 years that 

the IGs’ reporting showed slight improvements in agencies’ compliance 

under IPERA.

 29Whether the IGs made recommendations in other products that are pertinent to their 

agencies’ improper payments reporting would not be captured by our analysis. The 

number of recommendations excludes the same (or similar) recommendations that were 

repeated from a prior year, as the IGs identified these recommendations as duplicate 

recommendations. 

CFO Act Agency IGs 

Made About 400 

Recommendations in 

Their Fiscal Years 

2011 through 2015 

IPERA Compliance 

Reports, and More 

Than 100 

Recommendations 

Remain Open as of 

December 31, 2016
Page 28 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 9: Number of Improper Payments Recommendations Included in the CFO 

Act Agency IGs’ Fiscal Years 2011 through 2015 IPERA Compliance Reports

As detailed in appendix VI, the number of recommendations per agency 

varied significantly from fiscal years 2011 through 2015. For instance, the 

number of recommendations per agency fluctuated from as little as no 

recommendations for one agency—the Nuclear Regulatory Commission 

(NRC)—during this time period, to 49 recommendations for another 

agency—HUD. One potential reason for the significant difference in the 

number of recommendations per agency could be the extent to which the 

agencies were compliant under IPERA over the past 5 years. For 

example, NRC has been reported as compliant for the past 5 years, 

whereas HUD has been reported as noncompliant for the past 3 years.

As noted in figure 10, there were 105 recommendations open as of 

December 31, 2016. While the majority of the open recommendations 

were made in the past 2 years, and the agencies may not have had 

sufficient time to implement the necessary corrective actions, there was 

1 recommendation from fiscal year 2011 that was still open at the time of 

our review. Specifically, in the HHS IG’s fiscal year 2011 IPERA 

compliance report issued in March 2012, the HHS IG recommended that 
Page 29 GAO-17-484 Fiscal Year 2015 IPERA Compliance

HHS develop an improper payment estimate (one of the six IPERA 

criteria) for the Temporary Assistance for Needy Families (TANF) 

program and, if necessary, seek statutory authority to require state 

participation in such a measurement. In the HHS IG’s fiscal year 2015 

IPERA compliance report issued in May 2016, the HHS IG made another 

recommendation for HHS to publish an estimate for TANF. Specifically, 

the IG recommended that HHS continue to work with OMB to implement 

one of the OMB-suggested potential alternative approaches to reporting 

on TANF improper payments in fiscal year 2016.

According to HHS’s fiscal year 2016 AFR, issued in November 2016, 

HHS plans to encourage Congress to consider statutory modifications 

that would affect the development of an improper payment estimate when 

legislation is considered to reauthorize TANF. In addition, in a June 2016 

letter to Congress, HHS stated that it wanted to work with Congress to 

address a set of issues concerning the TANF program related to 

accountability and how funds are used. Until HHS develops an improper 

payment estimate for TANF, HHS will continue to be reported as 

noncompliant with the IPERA criteria that agencies publish improper 

payment estimates and corrective action plans for all susceptible 

programs. Based on the HHS IG’s fiscal year 2015 compliance report, 

HHS was noncompliant with five of the six IPERA criteria; however, its 

noncompliance with the IPERA criteria to publish an improper payment 

estimate and publish a corrective action plan was based on the TANF 

program only.
Page 30 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 10: Number and Status of Improper Payment-Related Recommendations Made by the CFO Act Agency Inspectors 

General in Their Fiscal Years 2011 through 2015 IPERA Compliance Reports, as of December 31, 2016

The open recommendations address a number of improper payment 

issues, including compliance under IPERA. We reviewed the open 

recommendations for the 15 agencies reported as noncompliant for fiscal 

year 2015, and as shown in figure 11, we found that agencies generally 

had open recommendations for each of the IPERA criteria for which they 

were reported as noncompliant. If the agencies take the necessary 

corrective actions to address the IGs’ open recommendations, the 

number of noncompliant agencies could decrease in future fiscal years, if 

no new compliance issues arise. In addition, as shown in figure 11, 

recommendations designed to address noncompliance with certain 

IPERA criteria were closed by some of the IGs after their fiscal year 2015 

IPERA compliance reports were issued. Although these agencies may 

have taken corrective actions that resulted in the IGs closing the 

recommendations, the compliance results for these agencies for fiscal 

year 2016 were not published at the time of our review.
Page 31 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 11: Summary of Noncompliant CFO Act Agencies per IPERA Criteria, as 

Reported/Acknowledged by the IGs, and Status of IGs’ Recommendations Designed 

to Address Noncompliance, as of December 31, 2016

As noted in figure 11, the 3 agencies (DOL, SBA, and Treasury) that did 

not report improper payment rates below 10 percent either submitted 
Page 32 GAO-17-484 Fiscal Year 2015 IPERA Compliance

plans to address noncompliance to Congress or submitted proposed 

statutory changes. For example, in June 2015, Treasury submitted 

proposed statutory changes to reduce the improper payment rate of the 

Earned Income Tax Credit program, which reported an estimated 

improper payment rate of 23.8 percent in fiscal year 2015. Specifically, 

according to the Treasury IG’s fiscal year 2015 IPERA compliance report, 

the proposed statutory change would help prevent the improper issuance 

of billions of dollars in refunds as it would provide the Internal Revenue 

Service (IRS) with expanded authority to systematically correct erroneous 

claims that are identified when tax returns are processed, which, 

according to Treasury, would allow the IRS to deny erroneous Earned 

Income Tax Credit refund claims before they are paid. However, as of 

March 2017, legislation had not been enacted to provide Treasury with 

this authority.30

Related to its noncompliance with the IPERA criterion to report an 

improper payment rate below 10 percent, DOL submitted a legislative 

proposal in October 2016 to make changes to the federal-state 

unemployment compensation system to help reduce improper payments. 

DOL’s Unemployment Insurance program was its only program that 

reported an improper payment rate over 10 percent, and that program 

was compliant with the remaining IPERA criteria.31 However, as of March 

2017, legislation had not been enacted to make changes to the 

federal-state unemployment compensation system. Related to SBA’s 

fiscal year 2015 noncompliance with the IPERA criterion to report an 

improper payment rate below 10 percent, its IG noted that the improper 

payment rate for one program (Disbursements for Goods and Services) 

increased from 8.46 percent in fiscal year 2014 to 13.52 percent in fiscal 

year 2015. Although the IG did not issue a recommendation in its fiscal 

year 2015 IPERA compliance report to address such noncompliance, the 

IG reported that SBA submitted a letter to Congress and OMB detailing 

 30In response to a draft of this report, Treasury staff stated that it has been working with 

OMB on supplemental measures in lieu of reduction targets (see app. XII). The Treasury 

IG reported Treasury as compliant with the IPERA criterion regarding reduction targets. 

The information discussed in this report is regarding Treasury’s noncompliance with the 

IPERA criterion for reporting improper payments below 10 percent. 

31DOL was reported as noncompliant in fiscal year 2015 as a result of noncompliance with 

the two IPERA criteria that agencies publish and meet reduction targets and report 

improper payment rates below 10 percent. Specifically, DOL’s Unemployment Insurance 

program reported an improper payment rate of 10.7 percent during fiscal year 2015. In 

addition, the Workforce Investment Act grants program did not meet its reduction target; 

however, this program was terminated in fiscal year 2015. 
Page 33 GAO-17-484 Fiscal Year 2015 IPERA Compliance

how it would become compliant under IPERA. SBA’s March 2016 letter to 

Congress included SBA’s corrective action plan for reducing improper 

payments in its Disbursements for Goods and Services program.

The total amount of estimated improper payments reported governmentwide has been estimated to total over $1.2 trillion from fiscal year 2003 

through fiscal year 2016. Five years after the implementation of IPERA, 

15 of the 24 CFO Act agencies were reported as noncompliant under 

IPERA for fiscal year 2015. Although noncompliance under IPERA 

continues to be at its highest point, the inconsistencies in IGs’

determinations of noncompliance that we found in the IGs’ fiscal year

2015 IPERA compliance reports may present potentially misleading 

information to individuals and entities interested in comparative 

government-wide compliance under IPERA. OMB guidance and IPERA 

do not specify what, if any, evaluative procedures should be conducted as 

part of the IGs’ compliance determinations. CIGIE, which represents the 

IGs, has also not issued such guidance.

In addition, IGs reported programs at 7 agencies as noncompliant for 3 or 

more consecutive years as of the end of fiscal year 2015, and as a result, 

the agencies were required to submit certain information to Congress. 

However, USDA had not submitted the required information despite prior 

recommendations from its IG and GAO. When agencies do not submit the 

required information, Congress may lack the information necessary to 

effectively monitor the implementation of IPERA and take prompt action 

to address problematic programs.

We are making the following two recommendations:

To help ensure that government-wide compliance under IPERA is 

consistently determined and reported, we recommend that the Director of 

OMB coordinate with CIGIE to develop and issue guidance, either jointly 

or independently, to specify what procedures should be conducted as part 

of the IGs’ IPERA compliance determinations.

To help fulfill USDA’s requirements under IPERA and OMB guidance—

that agencies submit proposals to Congress when a program reaches 

3 or more consecutive years of noncompliance with IPERA criteria—we 

recommend that the Secretary of Agriculture submit a letter to Congress 

detailing proposals for reauthorization or statutory changes in response to 

3 consecutive years of noncompliance as of fiscal year 2015 for its Farm 

Conclusions

Recommendations for 

Executive Action
Page 34 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Security and Rural Investment Act Program. To the extent that 

reauthorization or statutory changes are not considered necessary to 

bring a program into compliance, the Secretary or designee should state 

so in the letter.

We requested comments on a draft of this report from the 24 CFO Act 

agencies and their IGs, OMB, and CIGIE. We received letters from 

CIGIE, HUD, Treasury, and SSA, as well as from the IGs for DHS and 

HUD. These letters are reprinted in appendixes VIII through XIII. In 

addition, all of the other agencies and the IGs either notified us that they 

had no comments or provided their comments via e-mail. Specifically, 

OMB’s liaison to GAO stated in an e-mail that they had no comments on 

the report or the recommendation to coordinate with CIGIE to develop 

guidance.32 Similarly, USDA’s Acting Deputy Secretary concurred with 

our recommendation to USDA by e-mail.

We also received technical comments from the Department of 

Commerce, HHS, HUD, State, Treasury, EPA, NSF, SBA, and SSA, 

which we incorporated in the report as appropriate. In addition, the IGs for 

DHS, HUD, State, Treasury, VA, EPA, NASA, NSF, and SSA also 

provided technical comments, which we also incorporated in the report as 

appropriate. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Secretary of Agriculture, the Director of 

the Office of Management and Budget, and other interested parties. In 

addition, the report will be available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-2623 or davisbh@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

 32Although this recommendation was not directed to CIGIE, the CIGIE Chairperson stated 

that CIGIE would coordinate with OMB as needed and provide feedback on any draft 

OMB guidance (see app. VIII).

Agency Comments
Page 35 GAO-17-484 Fiscal Year 2015 IPERA Compliance

page of this report. GAO staff who made key contributions to this report 

are listed in appendix XIV.

Sincerely yours,

Beryl H. Davis

Director

Financial Management and Assurance
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Our objectives were to review the following:

1. The extent to which the 24 agencies listed in the Chief Financial 

Officers Act of 1990, as amended (CFO Act),1 complied with the 

criteria listed in the Improper Payments Elimination and Recovery Act 

of 2010 (IPERA),2 for fiscal years 2011 through 2015 as reported by 

their inspectors general (IG); the criteria and programs that the IGs 

concluded were responsible for instances of agency noncompliance 

and the number of programs at the 24 CFO Act agencies that were 

reported as noncompliant under IPERA criteria by their IGs for 3 or 

more consecutive years as of fiscal year 2015: and the extent to 

which the responsible agencies submitted the required information to 

Congress.

2. The extent to which CFO Act agency IGs reported that they performed 

additional optional procedures during their fiscal year 2015 reviews, 

as outlined in Office of Management and Budget (OMB) guidance 

contained in OMB Circular No. A-123, Appendix C, OMB 

Memorandum No. M-15-02 (OMB M-15-02).3

3. The extent to which the IGs’ fiscal years 2011 through 2015 IPERA 

compliance reports included recommendations and the status of these 

recommendations as of December 31, 2016, and for the open 

recommendations associated with noncompliant agencies, the extent 

to which the recommendations were designed to address agencies’

noncompliance with one or more of the six IPERA criteria.

Although the responsibility for complying with provisions of improper 

payment-related statutes rests with the head of each executive agency, 

we focused on those agencies designated as CFO Act agencies because 

these agencies represented over 99 percent of the total government-wide 

improper payments reported in fiscal year 2015. Our work did not include 

validating or retesting the data or methodologies used by the IGs to 

 1

The CFO Act, Pub. L. No. 101-576 104 Stat. 2838 (Nov. 15, 1990), among other things 

established chief financial officers to oversee financial management activities at 23 major 

executive departments and agencies. The list now includes 24 entities, which are often 

referred to collectively as CFO Act agencies, and is codified, as amended, in section 901 

of Title 31, United States Code. The CFO Act agencies accounted for over 99 percent of 

the government-wide improper payment estimate in fiscal year 2015.

2

Pub. L. No. 111-204, 124 Stat. 2224 (July 22, 2010).

3

Office of Management and Budget, Appendix C to Circular No. A-123, Requirements for 

Effective Estimation and Remediation of Improper Payments, OMB Memorandum No. M15-02 (Washington, D.C.: October 2014).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-17-484 Fiscal Year 2015 IPERA Compliance

determine and report compliance. We corroborated our findings with OMB 

and all 24 CFO Act agencies and IGs.

To address our first objective, we identified the requirements that 

agencies must meet by reviewing the Improper Payments Information Act 

of 2002 (IPIA),4 IPERA, the Improper Payments Elimination and Recovery 

Improvement Act of 2012 (IPERIA),5 and OMB guidance. We analyzed 

CFO Act agency IGs’ fiscal year 2015 IPERA reports, which were the 

most current reports available at the time of our review; summarized 

information related to agency compliance under IPERA criteria; and 

identified common findings and related causes for improper payments, as 

reported by the IGs. We also relied on and reviewed prior year supporting 

documentation and analyses of CFO Act agencies’ IG IPERA reports for 

fiscal years 2011 through 2014, as reported in our June 2016 report on 

IPERA compliance reporting,6 and compared agencies’ compliance with 

each IPERA criterion over fiscal years 2011 through 2015, as reported by 

the IGs.

In addition, we identified the programs responsible for noncompliance 

over this period by analyzing and summarizing the determinations made 

in the IG reports. Further, we reviewed the fiscal years 2015 and 2016

improper payments information, which OMB provided to GAO during the 

audit of the fiscal years 2016 and 2015 consolidated financial statements 

of the U.S. Government, and compared such information to the agency 

financial reports or performance and accountability reports to determine 

the total improper payment estimate reported for the 24 agencies (see 

apps. IV and VII, respectively).7 To determine the extent of 

inconsistencies between the IGs’ fiscal year 2015 noncompliance 

determinations, we summarized the noncompliance determinations by 

“noncompliance based on pass/fail determinations” and “noncompliance 

based on evaluative procedures.” To determine if agencies responsible 

for the programs that were reported as noncompliant for 3 or more 

consecutive years had submitted either proposals for reauthorization or 

 4

Pub. L. No. 107-300, 116 Stat. 2350 (Nov. 26, 2002), codified as amended at 31 U.S.C. § 

3321 Note.

5

Pub. L. No. 112-248, 126 Stat. 2390 (Jan. 10, 2013).

6

GAO, Improper Payments: CFO Act Agencies Need to Improve Efforts to Address 

Compliance Issues, GAO-16-554 (Washington, D.C.: June 30, 2016).

7

GAO, Financial Audit: Fiscal Years 2016 and 2015 Consolidated Financial Statements of 

the U.S. Government, GAO-17-283R (Washington, D.C.: Jan. 12, 2017).
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-17-484 Fiscal Year 2015 IPERA Compliance

statutory changes to Congress, we interviewed and requested information 

from relevant agency offices of chief financial officer in coordination with 

the agency IGs. We did not draw conclusions as to the sufficiency or 

completeness of the information contained in proposals for 

reauthorization or statutory changes submitted to Congress. Lastly, we 

corroborated our findings with OMB and all 24 CFO Act agencies and 

IGs.

To address our second objective, we identified procedures that agencies’

IGs were required to perform during their annual IPERA compliance 

reviews, as required by IPIA, IPERA, IPERIA, and OMB M-15-02. We 

also reviewed IPIA, IPERA, IPERIA, and OMB guidance to identify a list 

of optional procedures. To verify that we had properly identified and 

categorized the optional IG procedures, we interviewed and obtained 

confirmation from OMB staff. We reviewed and summarized the CFO Act 

agencies’ IGs’ fiscal year 2015 IPERA compliance reports to determine if 

the IGs reported that they performed one or more of the optional 

procedures. Given that some of the optional procedures were only 

optional when the IGs were reviewing non-high-priority programs, we 

determined the population of OMB designated high-priority programs for 

fiscal year 2015 based on information from www.paymentaccuracy.gov.8

To verify that this list was reported correctly on the website, we 

interviewed OMB staff and corroborated the information. For each agency 

responsible for a non-high-priority program, we reviewed the related IG’s 

IPERA compliance report for fiscal year 2015 to determine whether the IG 

reported that it performed one or more of the optional procedures for nonhigh-priority programs. We did not evaluate the sufficiency of the optional 

procedures performed by the IGs nor did we determine whether the IGs 

completed the required procedures, as outlined in IPIA, IPERA, IPERIA, 

and OMB guidance. Lastly, we corroborated our findings with the 24 CFO 

Act agencies’ IGs.

To address our third objective, we reviewed the 24 CFO Act agency IGs’

fiscal years 2011 through 2015 IPERA compliance reports to determine 

the number of recommendations made by the IGs. To determine the 

status of the recommendations as of December 31, 2016, we reviewed 

the recommendation status information obtained from the IGs. To 

determine whether the IGs associated with the 15 noncompliant agencies 

 8

An official website of the United States Government that contains information about 

current and historical rates and amounts of improper payments, why improper payments 

occur, and what agencies are doing to reduce and recover improper payments.
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-17-484 Fiscal Year 2015 IPERA Compliance

had open recommendations that were designed to address the agencies’

noncompliance with one or more of the six IPERA criteria, we reviewed 

and categorized the IGs’ open recommendations, as of December 31, 

2016. For those agencies that did not have open recommendations, as of 

December 31, 2016, that addressed the agencies’ noncompliance with 

the IPERA criteria, we determined whether any of the closed 

recommendations addressed noncompliance with the IPERA criteria and 

were closed after the IGs’ fiscal year 2015 IPERA compliance reports 

were issued in May 2016. For the noncompliant agencies that did not 

have any open recommendations or recommendations that were closed 

after May 2016 that were designed to address the agencies’

noncompliance with one or more of the six IPERA criteria, we determined 

whether those agencies submitted information to Congress to address 

IPERA noncompliance, such as reauthorization proposals, proposed 

statutory changes, or agency action plans. Lastly, we corroborated our 

findings with the respective agencies and their IGs.

We conducted this performance audit from June 2016 to May 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: CFO Act Agencies Reported as 

Noncompliant under IPERA by IGs for Fiscal 

Year 2015

Page 40 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figures 12 and 13 detail agencies’ compliance under Improper Payments 

Elimination and Recovery Act of 2010 criteria, as reported by their 

inspectors general, for fiscal year 2015.

Figure 12: Fiscal Year 2015 CFO Act Agencies’ Overall IPERA Compliance by IPERA 

Criteria, as Reported by Their IGs

Appendix II: CFO Act Agencies Reported as 

Noncompliant under IPERA by IGs for Fiscal 

Year 2015
Appendix II: CFO Act Agencies Reported as 

Noncompliant under IPERA by IGs for Fiscal 

Year 2015

Page 41 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Figure 13: Fiscal Year 2015 CFO Act Agencies’ IPERA Compliance as Reported by Their IGs
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant under IPERA by 

Their IGs for Fiscal Year 2015

Page 42 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Table 2 lists the Chief Financial Officers Act of 1990 agencies and their 

programs that their inspectors general reported in fiscal year 2015 were 

noncompliant under the Improper Payments Elimination and Recovery 

Act of 2010.

Table 2: CFO Act Agencies’ Programs That IGs Reported as Noncompliant under IPERA for Fiscal Year 2015

Noncompliant CFO Act agencies and 

programs

Conduct programspecific risk 

assessment(s)

Publish 

estimate(s)

Publish 

corrective 

action 

plan(s)

Publish and 

meet 

reduction 

target(s)

Report rate(s) 

below 10 

percent

Department of Agriculture 

1. Food and Nutrition Service (FNS) 

Supplemental Nutrition Assistance 

Program 

* * * X *

2. FNS National School Lunch Program * * * X X

3. FNS School Breakfast Programs * * * * X

4. FNS Special Supplemental Nutrition 

Program for Women, Infants, and Children 

* * * X *

5. Forest Service Administration (FSA) 

Livestock Forage Disaster Program 

* * * X *

6. FSA Supplemental Revenue Assistance 

Payments Program 

* * * X *

7. FSA Noninsured Crop Disaster Assistance 

Program 

* * * X *

8. FNS Child and Adult Care Food Program * X * * *

9. Natural Resources Conservation Service 

Farm Security and Rural Investment Act 

Programs 

* * * X X

Department of Defense (DOD)

10. DOD Travel Pay * * * X *

Department of Education 

11. Direct Loan * * * X *

Department of Health and Human Services (HHS)a

12. Medicare Fee-for-Service (Parts A and B) * * * * X

13. Medicare Advantage (Part C) * * * X *

14. Medicaid * * * X *

15. Children’s Health Insurance Program * * * X *

16. Child Care Development Fund * * * X *

17. Temporary Assistance for Needy Families * X X * *

Appendix III: CFO Act Agencies and 

Programs Reported as Noncompliant under 

IPERA by Their IGs for Fiscal Year 2015
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant under IPERA by 

Their IGs for Fiscal Year 2015

Page 43 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Noncompliant CFO Act agencies and 

programs

Conduct programspecific risk 

assessment(s)

Publish 

estimate(s)

Publish 

corrective 

action 

plan(s)

Publish and 

meet 

reduction 

target(s)

Report rate(s) 

below 10 

percent

Department of Homeland Security (DHS)

18. Customs and Border Protection (CBP) -

Refund & Drawback

* * * X *

19. CBP - Sandy * * * X *

20. Federal Emergency Management Agency 

(FEMA) - Assistance to Firefighters Grant 

Program 

* * * X *

21. FEMA - Homeland Security Grant 

Program

* * * X *

22. FEMA - Individuals and Households 

Program

* * * X *

23. FEMA - National Flood Insurance Program * * * X *

24. FEMA - Public Assistance * * * X *

25. FEMA – Vendor Pay * * * X *

Department of Housing and Urban Development (HUD)a

26. Rental Housing Assistance Programs * * * X *

Department of the Interior (Interior)

27. Disaster Relief X X * * *

Department of Labor 

28. Unemployment Insurance * * * * X

29. Workforce Investment Act * * * X *

Department of Transportation (DOT)b

30. Federal Highway Administration Highway 

Planning and Construction

* * * X *

Department of the Treasury 

31. Earned Income Tax Credit * * * * X

Department of Veteran’s Affairs (VA)

32. Beneficiary Travel * * * X *

33. VA Community Care * * * X X

34. Purchased Long Term Services and 

Support 

* * * X X

35. Supplies and Materials * * * X *

36. Compensation * * * X *

37. Education - Chapter 1606 * * * X *

38. Education - Chapter 1607 * * * X *

39. Disaster Relief Act - Hurricane Sandy * * * X *
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant under IPERA by 

Their IGs for Fiscal Year 2015

Page 44 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Noncompliant CFO Act agencies and 

programs

Conduct programspecific risk 

assessment(s)

Publish 

estimate(s)

Publish 

corrective 

action 

plan(s)

Publish and 

meet 

reduction 

target(s)

Report rate(s) 

below 10 

percent

General Services Administration 

40. Hurricane Sandy Disaster Relief Fund * X * * *

Office of Personnel Management 

41. Total Program - Retirement * X * * *

42. Federal Employees’ Group Life Insurance X * * * *

43. Background Investigations X * * * *

44. Payroll X * * * *

45. Travel Card X * * * *

46. Vendor Payment Process X * * * *

Small Business Administration 

47. 7(a) Guaranty Approvals * * * X *

48. 504 Certified Development Company

Guaranty Approvals

* * * X *

49. Disbursements for Goods and Services * * * X X

50. Hurricane Sandy Disaster Relief Grants * * * X *

Social Security Administration 

51. Old Age, Survivors & Disability Insurance * * * X *

52. Supplemental Security Income * * * X *

Total 6 5 1 38 9

Legend:

X: Program was noncompliant with IPERA criterion, as reported by the IG

*: Program was not reported by the IG as noncompliant with IPERA criterion

AFR: agency financial report

CFO Act: Chief Financial Officers Act of 1990

IPERA: Improper Payments Elimination and Recovery Act of 2010

PAR: performance and accountability report

Source: GAO analysis of CFO Act agencies’ IG IPERA compliance reports for fiscal year 2015. | GAO-17-484

a

The IGs for HHS and HUD reported noncompliance with the risk assessment criteria but did not 

specify any specific program(s) as being responsible for the noncompliance.

b

One agency (DOT) was reported as noncompliant with the IPERA criterion to publish required 

information in the PAR/AFR, which is an agency-wide criterion and not specific to agency programs. 
Appendix IV: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2015

Page 45 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Table 3 lists the Office of Management and Budget (OMB)-reported 

improper payment estimates by agency and program or activity for fiscal 

year 2015, which relate to fiscal year 2015 compliance determinations of 

the CFO Act agency inspectors general (IG) as discussed in this report. 

As noted in table 3, excluding the Defense Finance Accounting Service 

Commercial Pay program, there were 115 Chief Financial Officers Act of 

1990 agency programs that reported an improper payment estimate 

(either a zero estimate or higher) for fiscal year 2015. Appendix VII details 

the fiscal year 2016 improper payment estimates, which OMB provided 

to GAO in December 2016 during the audit of the fiscal years 2016 and 

2015 consolidated financial statements of the U.S. government;

1 the IGs’

reports regarding such estimates are due in May 2017.

Table 3: Reported Improper Payment Estimates by Agency and Program/Activity for Fiscal Year 2015 

Reported by OMB for fiscal year 2015

Agency/reporting program Outlays (dollars) Improper 

payment estimate 

(dollars) 

Improper 

payment rate 

(percentage) 

OMBdesignated 

highpriority 

programs

CFO Act agencies

Department of Agriculture 111,262,780,000 6,339,132,000 

1 Food and Nutrition Service (FNS) Supplemental 

Nutrition Assistance Program

70,022,000,000 2,562,810,000 3.66 √

2 FNS National School Lunch Program 11,319,000,000 1,773,000,000 15.66 √

3 FNS School Breakfast Programs 3,812,000,000 875,000,000 22.95 √

4 FNS Special Supplemental Nutrition Program for 

Women, Infants, and Children

4,542,000,000 210,000,000 4.62

5 Forest Service Administration (FSA) Livestock 

Forage Disaster Program 

3,357,000,000 104,200,000 3.10

6 FSA Livestock Indemnity Program 63,000,000 4,000,000 6.35

7 FSA Supplemental Revenue Assistance 

Payments Program

34,000,000 3,370,000 9.90

8 FSA Noninsured Crop Disaster Assistance 

Program

174,000,000 12,800,000 7.36

9 FNS Child and Adult Care Food Program 930,000,000 7,800,000 0.84

 1

GAO, Financial Audit: Fiscal Years 2016 and 2015 Consolidated Financial Statements of 

the U.S. Government, GAO-17-283R (Washington, D.C.: Jan. 12, 2017).

Appendix IV: Reported Improper Payment 

Estimates by Agency and Program/Activity 

for Fiscal Year 2015
Appendix IV: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2015

Page 46 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2015

Agency/reporting program Outlays (dollars) Improper 

payment estimate 

(dollars) 

Improper 

payment rate 

(percentage) 

OMBdesignated 

highpriority 

programs

10 Rental Assistance Program 1,147,000,000 16,200,000 1.41

11 Federal Crop Insurance Corporation Program Fund 13,734,000,000 302,150,000 2.20 √

12 Natural Resources Conservation Service Farm 

Security and Rural Investment Act Programs

2,122,000,000 467,790,000 22.04

13 Hurricane Sandy - Emergency Conservation 

Program

400,000 2,000 0.50

14 Farm Service Agency Hurricane Sandy - Emergency 

Forest Restoration Program 

300,000 10,000 1.67

15 Forest Service Hurricane Sandy - Emergency Forest 

Restoration Program

70,000 - 0.00

16 Hurricane Sandy - Capital Improvement and 

Maintenance

1,180,000 - 0.00

17 Hurricane Sandy - Emergency Watershed Protection 

Program 

4,830,000 - 0.00

Department of Commerce 80,770,000 -

18 Funds Received by National Oceanic and 

Atmospheric Administration under Disaster Relief 

Appropriations Act 

80,770,000 - 0.00

Department of Defense 560,770,000,000 1,256,080,000 

19 Military Health Benefits 19,700,000,000 157,670,000 0.80

20 Military Pay 107,400,000,000 242,900,000 0.23

21 Civilian Pay 56,600,000,000 57,200,000 0.10

22 Military Retirement 59,300,000,000 20,800,000 0.04

23 Department of Defense Travel Pay 6,600,000,000 521,470,000 7.90

Defense Finance Accounting Service (DFAS) 

Commercial Paya 287,800,000,000 256,000,000 0.09

24 U.S. Army Corps of Engineers Commercial Pay 18,200,000,000 - 0.00

25 U.S. Army Corps of Engineers Travel Pay 170,000,000 40,000 0.02

26 Navy Enterprise Resource Planning Commercial Pay 5,000,000,000 - 0.00

Department of Education 144,395,930,000 1,866,270,000 

27 Pell Grants 29,909,280,000 562,290,000 1.88 √

28 Direct Loan 98,771,650,000 1,284,030,000 1.30 √

29 Title I 15,715,000,000 19,950,000 0.13

Department of Health and Human Services 882,445,960,000 89,776,830,000 

30 Medicare Fee-for-Service (Parts A and B) 358,348,600,000 43,325,610,000 12.09 √

31 Medicare Advantage (Part C) 148,593,710,000 14,117,000,000 9.50 √
Appendix IV: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2015

Page 47 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2015

Agency/reporting program Outlays (dollars) Improper 

payment estimate 

(dollars) 

Improper 

payment rate 

(percentage) 

OMBdesignated 

highpriority 

programs

32 Medicare Prescription Drug Benefit (Part D) 62,003,910,000 2,234,250,000 3.60 √

33 Medicaid 297,672,020,000 29,124,610,000 9.78 √

34 Children’s Health Insurance Program 9,293,910,000 632,110,000 6.80 √

35 Foster Care 841,010,000 30,680,000 3.65

36 Child Care Development Fund 5,420,320,000 311,130,000 5.74

37 Disaster Relief - Administration for Children and 

Families (ACF) Head Start 

16,380,000 60,000 0.38

38 Disaster Relief - ACF Social Services Block Grant 209,140,000 460,000 0.22

39 Disaster Relief - ACF Family Violence Prevention 

and Services Act

890,000 10,000 0.89

40 Disaster Relief - Assistant Secretary for 

Preparedness and Response Research 

1,550,000 - 0.00

41 Disaster Relief - Centers for Disease Control

Research

4,600,000 - 0.00

42 Disaster Relief - Substance Abuse and Mental Health 

Services Administration

1,320,000 20,000 1.38

43 Disaster Relief - National Institutes of Health 

Research

38,600,000 890,000 2.29

Department of Homeland Security 11,592,360,000 217,410,000 

44 Customs and Border Protection (CBP) - Refund & 

Drawback

1,590,560,000 3,880,000 0.24

45 CBP - Administratively Uncontrollable Overtime 337,960,000 840,000 0.25 

46 CBP - Hurricane Sandy 470,000 - 0.15

47 Domestic Nuclear Detection Office - Hurricane Sandy 50,000 - 0.00

48 Federal Emergency Management Agency (FEMA) 

- Assistance to Firefighters Grant Program

224,900,000 1,440,000 0.64

49 FEMA - Flood Risk Map & Risk Analysis Program 131,000,000 10,920,000 8.34

50 FEMA - Hazard Mitigation - Hurricane Sandy 34,030,000 - 0.00

51 FEMA - Homeland Security Grant Program 1,496,520,000 17,960,000 1.20

52 FEMA - Individuals and Households Program 23,970,000 1,680,000 7.01

53 FEMA - National Flood Insurance Program 894,360,000 1,470,000 0.16

54 FEMA - Public Assistance 3,902,650,000 56,580,000 1.45

55 FEMA - Port Security Grant Program 300,890,000 2,020,000 0.67

56 FEMA - Transit Security Grant Program 353,260,000 3,120,000 0.88

57 FEMA - Vendor Pay 733,620,000 54,990,000 7.50
Appendix IV: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2015

Page 48 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2015

Agency/reporting program Outlays (dollars) Improper 

payment estimate 

(dollars) 

Improper 

payment rate 

(percentage) 

OMBdesignated 

highpriority 

programs

58 Immigration and Customs Enforcement -

Enforcement and Removal Operations

1,525,280,000 61,940,000 4.06

59 National Protection and Programs Directorate -

Hurricane Sandy

1,020,000 - 0.00

60 Office of the Inspector General - Hurricane Sandy 2,000,000 - 0.00

61 Science & Technology Directorate - Hurricane Sandy 280,000 - 0.00

62 U.S. Coast Guard - Hurricane Sandy 39,540,000 570,000 1.44

Department of Housing and Urban Development 33,643,120,000 1,300,600,000 

63 Rental Housing Assistance Programs 32,001,120,000 1,281,790,000 4.01 √

64 Community Development Block Grant - Disaster 

Relief

1,642,000,000 18,810,000 1.15

Department of the Interior 90,990,000 2,970,000 

65 Disaster Relief 90,990,000 2,970,000 3.27

Department of Justice 1,930,000 -

66 Law Enforcement - Disaster Relief 530,000 - 0.00

67 Prisons & Detention - Disaster Relief 1,400,000 - 0.00

Department of Labor 38,412,500,000 3,638,150,000 

68 Unemployment Insurance 32,895,310,000 3,530,160,000 10.73 √

69 Workforce Investment Act 2,530,000,000 22,260,000 0.88

70 Federal Employees Compensation Act 2,987,190,000 85,730,000 2.87

Department of Transportation 60,295,690,000 491,020,000 

71 Federal Aviation Administration Airport Improvement 

Program

3,117,090,000 1,270,000 0.04

72 Federal Aviation Administration Facilities & 

Equipment - Disaster Relief Appropriations Act

9,580,000 - 0.00

73 Federal Highway Administration Highway 

Planning and Construction

44,424,550,000 479,200,000 1.08

74 Federal Railroad Administration Grants to Amtrak 1,363,120,000 4,240,000 0.31

75 Federal Railroad Administration High-Speed Intercity 

Passenger Rail

1,113,590,000 360,000 0.03

76 Federal Transit Administration Formula Grants 9,419,660,000 5,090,000 0.05

77 Federal Transit Administration Emergency Relief 

Program - Disaster Relief Appropriations Act

570,440,000 170,000 0.03

78 Maritime Administration Ready Reserve Force 277,660,000 690,000 0.25

Department of the Treasury 65,600,000,000 15,600,000,000 

79 Earned Income Tax Credit 65,600,000,000 15,600,000,000 23.78 √
Appendix IV: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2015

Page 49 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2015

Agency/reporting program Outlays (dollars) Improper 

payment estimate 

(dollars) 

Improper 

payment rate 

(percentage) 

OMBdesignated 

highpriority 

programs

Department of Veterans Affairs (VA) 113,464,530,000 4,976,180,000 

80 Beneficiary Travel 811,550,000 50,480,000 6.22

81 Civilian Health and Medical Program of the VA 1,135,340,000 38,750,000 3.41

82 VA Community Care 3,912,170,000 2,142,690,000 54.77

83 Purchased Long-Term Services and Support 1,479,710,000 875,130,000 59.14

84 State Home Per Diem Grants 1,077,840,000 21,770,000 2.02

85 Supplies and Materials 2,457,240,000 32,440,000 1.32

86 Compensation 58,449,560,000 1,361,350,000 2.33

87 Pension 5,832,790,000 264,190,000 4.53

88 Vocational Rehabilitation and Employment 

Beneficiary Payments

1,081,220,000 11,260,000 1.04

89 Education - Chapter 33 11,172,650,000 135,050,000 1.21

90 Education - Chapter 1606 147,150,000 1,550,000 1.05

91 Education - Chapter 1607 67,330,000 1,500,000 2.23

92 Disaster Relief Act - Hurricane Sandy 27,270,000 1,560,000 5.71

93 Payments to Federal Employees - Payroll 25,812,710,000 38,460,000 0.15

Environmental Protection Agency 2,714,120,000 3,740,400 

94 Clean Water State Revolving Fund 1,549,930,000 1,510,000 0.10

95 Drinking Water State Revolving Fund 1,162,900,000 2,230,000 0.19

96 Hurricane Sandy Disaster Relief Fund 1,290,000 400 0.03

General Services Administration 6,146,610,000 8,920,000 

97 Rental of Space 5,745,950,000 6,900,000 0.12

98 Building Operations - Utilities 369,870,000 40,000 0.01

99 Purchase Cards 30,220,000 1,980,000 6.55

100 Hurricane Sandy Disaster Relief Fund 570,000 - 0.00

National Aeronautics and Space Administration 5,000,000 -

101 Hurricane Sandy Disaster Relief Program 5,000,000 - 0.00

Office of Personnel Management 129,166,810,000 372,630,000 

102 Total Program - Retirement 81,067,700,000 304,200,000 0.38

103 Federal Employee Health Benefit - All Carriers 48,099,110,000 68,430,000 0.14

Small Business Administration 20,789,560,000 1,053,580,000 

104 7(a) Guaranty Purchases 880,160,000 7,910,000 0.90

105 7(a) Guaranty Approvals 15,160,480,000 848,080,000 5.59

106 504 CDC Guaranty Approvals 4,189,530,000 158,200,000 3.78
Appendix IV: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2015

Page 50 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2015

Agency/reporting program Outlays (dollars) Improper 

payment estimate 

(dollars) 

Improper 

payment rate 

(percentage) 

OMBdesignated 

highpriority 

programs

107 Disaster Loan Disbursements 302,280,000 24,570,000 8.13

108 Disbursements for Goods and Services 105,440,000 14,260,000 13.52

109 Hurricane Sandy Disaster Relief Grants 4,300,000 130,000 3.02

110 Hurricane Sandy Disaster Relief Administrative 

Funds - Payroll

136,740,000 410,000 0.30

111 Hurricane Sandy Disaster Relief Administrative 

Funds - Travel

10,120,000 10,000 0.12

112 Hurricane Sandy Disaster Relief Administrative 

Funds - Purchase Cards

510,000 10,000 0.98

Social Security Administration 919,177,430,000 9,802,930,000 

113 Old Age, Survivors & Disability Insurance 862,719,790,000 5,038,190,000 0.58 √

114 Supplemental Security Income 56,457,560,000 4,764,740,000 8.44 √

115 Disaster Relief Act Funds Total Payment 80,000 - 0.00

Department of Energy NR NR NR

Department of State NR NR NR

National Science Foundation NR NR NR

Nuclear Regulatory Commission NR NR NR

U.S. Agency for International Development NR NR NR

Subtotal: CFO Act Agencies 3,100,056,090,000 136,706,442,400 4.40

Subtotal: Non-CFO Act agencies 20,806,240,000 244,150,000 

Corporation for National & Community Service

116 AmeriCorps - State and National 222,400,000 14,500,000 6.5

Federal Communications Commission 8,568,020,000 154,760,000 

117 Universal Service Fund (USF) - High Cost 3,744,680,000 2,800,000 0.07

118 USF - Schools and Libraries 2,286,310,000 144,650,000 6.33

119 USF - Lifeline 1,635,860,000 7,310,000 0.45

120 Telecommunications Relay Service - Interstate 

Telecommunications Relay Services Fund

901,170,000 - 0.00

Railroad Retirement Board 12,015,820,000 74,890,000 

121 Retirement and Survivors Benefits 11,909,620,000 70,600,000 0.59

122 Railroad Unemployment Insurance Act 106,200,000 4,290,000 4.04

Subtotal: Non-CFO Act Agencies 20,806,240,000 244,150,000 1.17

Government-wide total as reported by OMB 3,120,862,330,000 136,950,592,400 4.40 

Exclusion of DFAS Commercial Pay Programa (287,800,000,000) (256,000,000)
Appendix IV: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2015

Page 51 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2015

Agency/reporting program Outlays (dollars) Improper 

payment estimate 

(dollars) 

Improper 

payment rate 

(percentage) 

OMBdesignated 

highpriority 

programs

Fiscal year 2015 government-wide total,b excluding 

DFAS Commercial Pay Program

2,833,062,330,000 136,694,592,400 4.82

Total reported for OMB-designated high-priority 

programs

2,153,153,860,000 127,007,740,000 5.90 √

Total Reported for programs noncompliant under 

IPERA

$2,294,478,580,000 $131,981,610,000 5.75

Legend:

AFR: agency financial report

CFO Act: Chief Financial Officers Act of 1990

IPERA: Improper Payments Elimination and Recovery Act of 2010

OMB: Office of Management and Budget

PAR: performance and accountability report

Source: GAO analysis of OMB data. | GAO-17-484

Note: Bolded/italicized programs represent 47 of the 52 programs that were reported as noncompliant 

under IPERA by their respective IGs, as shown in app. III. The remaining 5 programs that were 

reported as noncompliant did not report improper payment estimates and therefore are not shown in 

this table.

a

This table includes DOD’s DFAS Commercial Pay improper payment estimate of $256 million and 

corresponding outlays of $287.8 billion as reported by DOD and OMB in fiscal year 2015. However, 

the reported government-wide estimate of $136.7 billion in improper payments excludes the 

estimates for the Department of Defense’s DFAS Commercial Pay program. Although OMB included 

this program’s estimates in its government-wide improper payment estimate, because of continuing 

GAO concerns based on audit findings in a 2013 report regarding the reliability of DFAS’s improper 

payment estimate, the DFAS Commercial Pay estimate was excluded from GAO’s calculations. See 

GAO, DOD Financial Management: Significant Improvements Needed in Efforts to Address Improper 

Payment Requirements, GAO-13-227 (Washington, D.C.: May 13, 2013).

b

This report presents the IPERA compliance results for fiscal years 2011 through 2015, and as a 

result, we are including the fiscal year 2015 improper payment estimates. The dollar estimates in the 

table were rounded to the nearest ten thousand, and some estimates were updated and accepted by 

OMB during OMB’s review of the agencies’ fiscal year 2016 AFRs and PARs. As a result, the 

information for certain programs in this table may differ from the information in the agencies’ AFRs 

and PARs, as well as the original estimates as published in GAO, Improper Payments: CFO Act 

Agencies Need to Improve Efforts to Address Compliance Issues, GAO-16-554 (Washington, D.C.: 

June 30, 2016). Additional information for each program (e.g., outlays and improper payment 

amounts that have not been rounded) is available on www.paymentaccuracy.gov.
Appendix V: Optional Procedures Performed 

by the IGs during Their Fiscal Year 2015 IPERA 

Compliance Reviews

Page 52 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Table 4 summarizes the optional procedures the CFO Act agency 

inspectors general reported that they performed during their fiscal year 

2015 IPERA compliance reviews.

Table 4: Summary of Optional Procedures the IGs Reported That They Performed during Their Fiscal Year 2015 IPERA 

Compliance Reviews

Optional procedure category

CFO agency IGs IGs reported 

performing 

one or more 

optional 

procedures

Evaluation of 

agency’s risk 

assessment(s)

(for non-highpriority 

programs)

Evaluation of 

agency’s 

estimation 

methodologies 

(for non-highpriority programs)

Evaluation of the 

accuracy and 

completeness of 

agency’s 

reporting

Evaluation of 

agency’s 

recapturing of 

improper 

payments

Evaluation of 

agency’s 

corrective 

action plans

Department of 

Agriculture

Y Y Y Y Y N

Department of 

Commerce

Y N N Y Y N/A

Department of 

Defense

Y N Y Y N Y

Department of 

Education

N N/A N N N/A N

Department of Energy N N N/A N N N/A

Department of Health 

and Human Services

Y Y Y Y Y N

Department of 

Homeland Security 

Y Y N N N N

Department of 

Housing and Urban 

Development

Y Y Y Y Y Y

Department of the 

Interior

Y N/A Y N N N

Department of Justice Y N N N Y N/A

Department of Labor Y N Y N N N

Department of State Y Y N/A Y N N/A

Department of 

Transportation

Y N N Y N N

Department of the 

Treasury

Y Y N/A Y Y N

Department of 

Veterans Affairs

Y N Y Y N N

Environmental 

Protection Agency

Y Y N Y N N/A

General Services 

Administration

Y Y Y Y Y Y

Appendix V: Optional Procedures Performed 

by the IGs during Their Fiscal Year 2015 

IPERA Compliance Reviews
Appendix V: Optional Procedures Performed 

by the IGs during Their Fiscal Year 2015 IPERA 

Compliance Reviews

Page 53 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Optional procedure category

CFO agency IGs IGs reported 

performing 

one or more 

optional 

procedures

Evaluation of 

agency’s risk 

assessment(s)

(for non-highpriority 

programs)

Evaluation of 

agency’s 

estimation 

methodologies 

(for non-highpriority programs)

Evaluation of the 

accuracy and 

completeness of 

agency’s 

reporting

Evaluation of 

agency’s 

recapturing of 

improper 

payments

Evaluation of 

agency’s 

corrective 

action plans

National Aeronautics 

and Space 

Administration

Y Y N Y N N/A

National Science 

Foundation

Y Y N/A N N/A N/A

Nuclear Regulatory 

Commission

N N N/A N N N/A

Office of Personnel 

Management

Y Y Y Y Y Y

Small Business 

Administration

Y N/A Y Y Y Y

Social Security 

Administration

Y N/A N Y N Y

U.S. Agency for 

International 

Development 

N N N/A N N N/A

Total IGs that 

performed optional 

procedures

20 11 10 15 9 6

Total IGs for which 

optional procedure 

was applicable

20 18 24 22 15

Total IGs for which 

optional procedure 

was not applicable

4 6 0 2 9

Percentage of IGs that 

performed optional 

procedures when 

applicable

55 56 63 41 40

Legend:

CFO Act: Chief Financial Officers Act of 1990

IG: inspector general

IPERA: Improper Payments Elimination and Recovery Act of 2010

IPIA: Improper Payments Information Act of 2002

OMB: Office of Management and Budget

N: The IG did not perform optional procedures in the designated category

N/A: not applicable

Y: The IG performed optional procedures in the designated category

Source: GAO analysis of CFO Act agencies’ IG IPERA compliance reports for fiscal year 2015. | GAO 17 484

Notes: A non-high-priority program is any program not designated as high-priority by OMB.
Appendix V: Optional Procedures Performed 

by the IGs during Their Fiscal Year 2015 IPERA 

Compliance Reviews

Page 54 GAO-17-484 Fiscal Year 2015 IPERA Compliance

N/A designations for each column are as follows: For risk assessment: Not applicable because the IG 

had nothing to evaluate because the agency did not complete any program-specific risk assessments 

for non-high-priority programs during fiscal year 2015. For estimation methodologies: Not applicable 

because (1) the IG reported that the agency was not required to comply with this criterion because 

the agency’s risk assessment concluded its programs were not susceptible to significant improper 

payments, as defined by IPIA and therefore the IG had nothing to evaluate or (2) the only estimate 

prepared by the agency was for a high-priority program and, as a result, the IG was required to 

evaluate the estimate. For corrective action plans: Not applicable because the IG reported that the 

agency was not required to comply with this criterion because the improper payment estimates for the 

agency’s program(s) were zero. As a result, the IG had nothing to evaluate. For recapturing of 

improper payments: Not applicable because the IG reported that the agency determined, and OMB 

concurred, it was not cost-effective for the agency to conduct a payment recapture audit (i.e., the 

benefits (recaptured amounts) would likely not exceed the costs (e.g., staff time and resources, or 

payments for the payment recapture audit contractor) associated with implementing and overseeing 

the program). As a result, the IG had nothing to evaluate.
Appendix VI: Fiscal Years 2011 through 2015 

Compliance Results and the Status of the IGs’ 

Recommendations

Page 55 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Table 5 details the status of the recommendations made in the Improper 

Payments Elimination and Recovery Act of 2010 (IPERA) compliance 

reports of the CFO Act agency inspectors general (IG) for fiscal years 

2011 through 2015, as of December 31, 2016. The IGs’

recommendations address a number of improper payment issues, 

including compliance under IPERA. The number of open and closed 

recommendations, as well as the total number of recommendations, 

excludes the same (or similar) recommendations that were repeated from 

a prior year. Additional information regarding the status of the 

recommendations can be found in the IGs’ annual IPERA compliance 

reports.

Table 5: Status of Recommendations Made in the IGs’ Fiscal Years 2011 through 2015 IPERA Compliance Reports, as of 

December 31, 2016

Compliance results and number of 

open and closed recommendations per fiscal year

CFO Act agency 2011 2012 2013 2014 2015 Totals for 2011

through 2015

Department of Agriculture X X X X X

Open recommendations 0 0 1 1 5 7

Closed recommendations 8 10 3 7 0 28

Total recommendations 8 10 4 8 5 35

Prior year repeated 

recommendations

N/A 0 0 2 0 2

Department of Commerce √ √ √ √ √

Open recommendations 0 0 0 0 2 2

Closed recommendations 2 1 1 3 0 7

Total recommendations 2 1 1 3 2 9

Prior year repeated 

recommendations

N/A 0 0 0 0 0

Department of Defense √ X X X X

Open recommendations 0 0 3 3 4 10

Closed recommendations 0 2 6 1 0 9

Total recommendations 0 2 9 4 4 19

Prior year repeated 

recommendations

N/A 0 0 0 0 0

Appendix VI: Fiscal Years 2011 through 2015 

Compliance Results and the Status of the 

IGs’ Recommendations
Appendix VI: Fiscal Years 2011 through 2015 

Compliance Results and the Status of the IGs’ 

Recommendations

Page 56 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Compliance results and number of 

open and closed recommendations per fiscal year

CFO Act agency 2011 2012 2013 2014 2015 Totals for 2011

through 2015

Department of Education √ √ √ X X

Open recommendations 0 0 0 0 9 9

Closed recommendations 11 5 3 10 0 29

Total recommendations 11 5 3 10 9 38

Prior year repeated 

recommendations

N/A 1 1 0 0 2

Department of Energy X √ √ √ √

Open recommendations 0 0 0 0 0 0

Closed recommendations 4 0 0 0 0 4

Total recommendations 4 0 0 0 0 4

Prior year repeated 

recommendations

N/A 0 0 0 0 0

Department of Health and Human 

Services 

X X X X X

Open recommendations 1 1 0 1 7 10

Closed recommendations 4 3 0 0 0 7

Total recommendations 5 4 0 1 7 17

Prior year repeated 

recommendations

N/A 0 0 0 3 3

Department of Homeland Security X X X X X

Open recommendations 0 0 0 0 4 4

Closed recommendations 6 8 1 3 0 18

Total recommendations 6 8 1 3 4 22

Prior year repeated 

recommendations

N/A 0 0 1 1 2

Department of Housing and Urban 

Development 

√ √ X X X

Open recommendationsa 0 0 9 1 13 23

Closed recommendations 2 7 12 5 0 26

Total recommendations 2 7 21 6 13 49

Prior year repeated 

recommendations

N/A 0 0 0 0 0
Appendix VI: Fiscal Years 2011 through 2015 

Compliance Results and the Status of the IGs’ 

Recommendations

Page 57 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Compliance results and number of 

open and closed recommendations per fiscal year

CFO Act agency 2011 2012 2013 2014 2015 Totals for 2011

through 2015

Department of the Interior X √ √ X X

Open recommendations 0 0 0 0 0 0

Closed recommendations 0 0 0 1 3 4

Total recommendations 0 0 0 1 3 4

Prior year repeated 

recommendations

N/A 0 0 0 0 0

Department of Justice √ √ √ √ √

Open recommendations 0 0 0 0 0 0

Closed recommendations 4 2 0 0 0 6

Total recommendations 4 2 0 0 0 6

Prior year repeated 

recommendations

N/A 0 0 0 0 0

Department of Labor X X X X X

Open recommendations 0 0 0 3 0 3

Closed recommendations 2 0 0 0 0 2

Total recommendations 2 0 0 3 0 5

Prior year repeated 

recommendations

N/A 0 0 0 0 0

Department of State X √ √ √ √

Open recommendations 0 0 0 0 0 0

Closed recommendations 3 1 1 1 0 6

Total recommendations 3 1 1 1 0 6

Prior year repeated 

recommendations

N/A 2 1 2 0 5

Department of Transportation X X X X X

Open recommendations 0 1 0 0 1 2

Closed recommendations 2 1 2 3 1 9

Total recommendations 2 2 2 3 2 11

Prior year repeated 

recommendations

N/A 0 1 1 0 2

Department of the Treasury X X X X X

Open recommendations 0 0 0 0 3 3

Closed recommendations 2 3 1 4 0 10

Total recommendations 2 3 1 4 3 13

Prior year repeated 

recommendations

N/A 0 1 1 0 2
Appendix VI: Fiscal Years 2011 through 2015 

Compliance Results and the Status of the IGs’ 

Recommendations

Page 58 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Compliance results and number of 

open and closed recommendations per fiscal year

CFO Act agency 2011 2012 2013 2014 2015 Totals for 2011

through 2015

Department of Veterans Affairs X X X X X

Open recommendations 0 0 0 1 7 8

Closed recommendations 7 6 3 8 0 24

Total recommendations 7 6 3 9 7 32

Prior year repeated 

recommendations

N/A 0 0 0 0 0

Environmental Protection Agency √ X √ √ √

Open recommendations 0 0 0 0 0 0

Closed recommendations 4 6 5 3 7 25

Total recommendations 4 6 5 3 7 25

Prior year repeated 

recommendations

N/A 0 0 0 0 0

General Services Administration √ √ √ X X

Open recommendations 0 0 0 0 0 0

Closed recommendations 6 3 7 7 11 34

Total recommendations 6 3 7 7 11 34

Prior year repeated 

recommendations

N/A 0 0 1 0 1

National Aeronautics and Space 

Administration 

X √ √ √ √

Open recommendations 0 0 0 6 3 9

Closed recommendations 9 3 7 3 1 23

Total recommendations 9 3 7 9 4 32

Prior year repeated 

recommendations

N/A 0 3 1 1 5

National Science Foundation (NSF) √ X NRb X √

Open recommendations 0 0 0 0 8 8

Closed recommendations 0 10 0 1 0 11

Total recommendations 0 10 0 1 8 19

Prior year repeated 

recommendations

N/A 0 0 1 0 1

Nuclear Regulatory Commission √ √ √ √ √

Open recommendations 0 0 0 0 0 0

Closed recommendations 0 0 0 0 0 0

Total recommendations 0 0 0 0 0 0

Prior year repeated 

recommendations

N/A 0 0 0 0 0
Appendix VI: Fiscal Years 2011 through 2015 

Compliance Results and the Status of the IGs’ 

Recommendations

Page 59 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Compliance results and number of 

open and closed recommendations per fiscal year

CFO Act agency 2011 2012 2013 2014 2015 Totals for 2011

through 2015

Office of Personnel Management X √ √ √ X

Open recommendations 0 0 1 1 4 6

Closed recommendations 4 1 0 2 0 7

Total recommendations 4 1 1 3 4 13

Prior year repeated 

recommendations

N/A 0 0 1 2 3

Small Business Administration X X X X X

Open recommendations 0 0 0 0 0 0

Closed recommendations 12 0 0 6 4 22

Total recommendations 12 0 0 6 4 22

Prior year repeated 

recommendations

N/A 0 0 0 0 0

Social Security Administration (SSA) X Xc X X X

Open recommendations 0 0 0 0 1 1

Closed recommendations 3 1 0 1 0 5

Total recommendations 3 1 0 1 1 6

Prior year repeated 

recommendations

N/A 0 1 1 1 3

U.S. Agency for International 

Development 

√ √ √ √ √

Open recommendations 0 0 0 0 0 0

Closed recommendations 1 3 0 0 0 4

Total recommendations 1 3 0 0 0 4

Prior year repeated 

recommendations

N/A 0 0 0 0 0

Total open recommendations for CFO 

Act agencies

1 2 14 17 71 105

Total closed recommendations for CFO 

Act agencies

96 76 52 69 27 320

Total recommendations per fiscal year 

for CFO Act agencies

97 78 66 86 98

Total recommendations for fiscal years 

2011 through 2015

425

Total prior year repeated 

recommendationsd for CFO Act agencies

0 3 8 12 8 31

Legend:

√: Agency reported by its IG as compliant

X: Agency reported by its IG as noncompliant
Appendix VI: Fiscal Years 2011 through 2015 

Compliance Results and the Status of the IGs’ 

Recommendations

Page 60 GAO-17-484 Fiscal Year 2015 IPERA Compliance

CFO Act: Chief Financial Officers Act of 1990

IG: inspector general

IPERA: Improper Payments Elimination and Recovery Act of 2010

N/A: not applicable

NR: not reported

Source: GAO analysis of CFO Act agencies’ IG compliance reports and recommendation information from IGs for fiscal years 2011 through 2015. | GAO-17-484

Notes: Use of N/A indicates that IGs were first required to report on the agencies’ compliance for 

fiscal year 2011; therefore, there are no repeat recommendations for fiscal year 2011. Use of NR 

indicates that the IG did not report on IPERA compliance.

a

According to the Department of Housing and Urban Development’s IG, 3 of the open 

recommendations for fiscal year 2015, as shown in this table, were initially closed by the department 

prior to December 31, 2016. However, according to the IG, in early 2017, the IG determined that the 

issues associated with these 3 recommendations have not been resolved and therefore, the IG plans 

to reopen the recommendations. As a result, this table shows these 3 recommendations as open.

b

The NSF IG did not issue an IPERA compliance report for fiscal year 2013 because NSF did not 

publish improper payment data in its fiscal year 2013 agency financial report.

c

The SSA IG reported in fiscal year 2012 that the agency was compliant under IPERA criteria, but we 

noted that SSA’s Supplemental Security Income program failed to meet its reported reduction targets 

for that year and in fiscal year 2011. The SSA IG concurred with this finding but does not plan to 

reissue its fiscal year 2012 IPERA compliance report to state a conclusion of noncompliance or its 

fiscal year 2011 report to state that the agency missed its reduction target. SSA was already reported 

noncompliant in fiscal year 2011 based on other criteria.

d

The prior year repeated recommendations include both open and closed recommendations.
Appendix VII: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2016

Page 61 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Table 6 lists Office of Management and Budget (OMB)-reported improper 

payment estimates by agency and program or activity for fiscal year 2016, 

which OMB provided to GAO in December 2016 during the audit of the 

fiscal years 2016 and 2015 consolidated financial statements of the U.S. 

government.

1 The IGs’ reports regarding these estimates are due in May 

2017. As noted in table 6, excluding the Defense Finance Accounting 

Service Commercial Pay program, there were 105 Chief Financial 

Officers Act of 1990 agency programs that reported an improper payment 

estimate (either a zero estimate or higher) for fiscal year 2016. The total 

government-wide improper payment estimate for fiscal year 2016 totaled 

$144.3 billion for 112 federal entity programs that reported estimates.

Table 6: Reported Improper Payment Estimates by Agency and Program/Activity for Fiscal Year 2016

Reported by OMB for fiscal year 2016

Agency/reporting program Outlays (dollars) Improper payment 

estimate (dollars)

Improper 

payment rate 

(percentage)

CFO Act agencies

Department of Agriculture 38,738,480,000 3,355,710,100 

1 National School Lunch Program 11,994,800,000 1,819,740,000 15.17

2 School Breakfast Programs 3,959,600,000 890,170,000 22.48

3 Special Supplemental Nutrition Program for Women, Infants, 

and Children

4,335,000,000 207,650,000 4.79

4 Livestock Forage Disaster Program 2,581,120,000 122,350,000 4.74

5 Livestock Indemnity Program 54,270,000 6,980,000 12.86

6 Supplemental Revenue Assistance Payments Program 4,550,000 520,000 11.43

7 Noninsured Crop Disaster Assistance Program 128,850,000 7,050,000 5.47

8 Child and Adult Care Food Program 910,910,000 4,920,000 0.54

9 Rental Assistance Program 1,141,390,000 12,560,000 1.10

10 Federal Crop Insurance Corporation Program Fund 11,503,290,000 232,370,000 2.02

11 Farm Security and Rural Investment Act Programs 1,994,140,000 47,410,000 2.38

12 Hurricane Sandy - Emergency Conservation Program 40,000 100 0.25

13 Farm Service Agency Hurricane Sandy - Emergency Forest 

Restoration Program 

790,000 10,000 1.27

14 Forest Service Hurricane Sandy - Emergency Forest 

Restoration Program

60,000 - 0.00

 1

GAO, Financial Audit: Fiscal Years 2016 and 2015 Consolidated Financial Statements of 

the U.S. Government, GAO-17-283R (Washington, D.C.: Jan. 12, 2017).

Appendix VII: Reported Improper Payment 

Estimates by Agency and Program/Activity 

for Fiscal Year 2016
Appendix VII: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2016

Page 62 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2016

Agency/reporting program Outlays (dollars) Improper payment 

estimate (dollars)

Improper 

payment rate 

(percentage)

15 Hurricane Sandy - Capital Improvement and Maintenance 580,000 - 0.00

16 Hurricane Sandy - Emergency Watershed Protection Program 5,080,000 - 0.00

17 Farm Service Agency Loan Deficiency Payments 124,010,000 3,980,000 3.21

Department of Commerce 101,170,000 50,000 

18 Funds Received by National Oceanic and Atmospheric 

Administration under Disaster Relief Appropriations Act (DRAA)

101,170,000 50,000 0.05

Department of Defense (DOD) 533,894,500,000 973,770,000 

19 Military Health Benefits 20,461,500,000 146,100,000 0.71

20 Military Pay 114,902,750,000 96,230,000 0.17

21 Civilian Pay 58,088,100,000 58,730,000 0.10

22 Military Retirement 59,931,730,000 9,460,000 0.02

23 Department of Defense Travel Pay 6,254,670,000 451,990,000 7.23

Defense Finance Accounting Service (DFAS) Commercial Paya 248,536,450,000 110,820,000 0.04

24 U.S. Army Corps of Engineers Commercial Pay 8,158,000,000 - 0.00

25 U.S. Army Corps of Engineers Travel Pay 188,000,000 380,000 0.20

26 Navy Enterprise Resource Planning Commercial Pay 6,901,270,000 - 0.00

Navy Commercial Bill Pay Office - Naples 472,030,000 60,000 0.01

Department of Education 125,371,320,000 6,080,670,000 

27 Pell Grants 8,188,550,000 2,212,800,000 7.85

28 Direct Loan 97,182,770,000 3,867,870,000 3.98

Department of Health and Human Services 67,563,100,000 96,941,861,000 

29 Medicare Fee-for-Service (Parts A and B) 373,650,450,000 41,084,650,000 11.00

30 Medicare Advantage (Part C) 161,944,040,000 16,182,660,000 9.99

31 Medicare Prescription Drug Benefit (Part D) 70,235,940,000 2,393,940,000 3.41

32 Medicaid 345,973,720,000 36,253,250,000 10.48

33 Children’s Health Insurance Program 9,233,060,000 737,590,000 7.99

34 Foster Care 692,000,000 47,680,000 6.89

35 Child Care 5,547,090,000 240,740,000 4.34

36 Disaster Relief - Administration for Children and Families Head 

Start

71,780,000 - 0.00

37 Disaster Relief - Administration for Children and Families Social 

Services Block Grant

198,330,000 1,350,000 0.68

38 Disaster Relief - Assistant Secretary for Preparedness and 

Response Research

3,060,000 - 0.00

39 Disaster Relief - Substance Abuse and Mental Health Services 

Administration

1,280,000 1,000 0.05
Appendix VII: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2016

Page 63 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2016

Agency/reporting program Outlays (dollars) Improper payment 

estimate (dollars)

Improper 

payment rate 

(percentage)

40 Disaster Relief - National Institutes of Health Research 12,350,000 - 0.00

Department of Homeland Security 11,855,250,000 120,453,000 

41 Customs and Border Protection - Refund & Drawback 3,008,520,000 10,520,000 0.35

42 Customs and Border Protection - Administratively Uncontrollable 

Overtime

172,980,000 10,000 0.01

43 Domestic Nuclear Detection Office - Hurricane Sandy 60,000 - 0.00

44 Federal Emergency Management Agency - Assistance to 

Firefighters Grant Program

270,910,000 2,290,000 0.85

45 Federal Emergency Management Agency - Flood Risk Map & 

Risk Analysis Program

111,250,000 6,110,000 5.49

46 Federal Emergency Management Agency (FEMA) - Homeland 

Security Grant Program

658,630,000 2,770,000 0.42

47 FEMA - National Flood Insurance Program 828,970,000 1,380,000 0.17

48 FEMA - Public Assistance 4,198,300,000 57,100,000 1.36

49 FEMA - Port Security Grant Program 117,380,000 1,140,000 0.97

50 FEMA - Transit Security Grant Program 218,480,000 1,490,000 0.68

51 FEMA - Vendor Pay 581,510,000 31,430,000 5.40

52 Immigration and Customs Enforcement - Enforcement and 

Removal Operations

1,616,010,000 5,750,000 0.36

53 Office of the Inspector General - Hurricane Sandy 170,000 3,000 1.76

54 Science & Technology Directorate - Hurricane Sandy 2,080,000 - 0.00

55 U.S. Coast Guard - Hurricane Sandy 70,000,000 460,000 0.66

Department of Housing and Urban Development 34,723,330,000 1,709,420,000 

56 Public Housing/Rental Assistance 32,741,330,000 1,701,890,000 5.20

57 Community Planning and Development - DRAA 1,982,000,000 7,530,000 0.38

Department of the Interior 137,290,000 570,000 

58 Disaster Relief 137,290,000 570,000 0.41

Department of Justice 3,080,000 -

59 Law Enforcement - Disaster Relief 2,910,000 - 0.00

60 Prisons & Detention - Disaster Relief 170,000 - 0.00

Department of Labor 36,091,240,000 3,960,310,000 

61 Unemployment Insurance 33,090,000,000 3,853,990,000 11.65

62 Federal Employees Compensation Act 3,001,240,000 106,320,000 3.54

Department of Transportation 55,497,570,000 207,373,000 

63 Federal Aviation Administration Facilities & Equipment - DRAA 8,650,000 140,000 1.59

64 Federal Highway Administration Highway Planning and 

Construction

43,307,010,000 110,850,000 0.26
Appendix VII: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2016

Page 64 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2016

Agency/reporting program Outlays (dollars) Improper payment 

estimate (dollars)

Improper 

payment rate 

(percentage)

65 Federal Railroad Administration Grants to Amtrak 1,119,780,000 1,750,000 0.16

66 Federal Railroad Administration High-Speed Intercity Passenger 

Rail

1,156,460,000 5,950,000 0.51

67 Federal Transit Administration (FTA) Formula Grants 9,287,960,000 88,120,000 0.95

68 FTA Emergency Relief Program - DRAA 361,810,000 330,000 0.09

69 Maritime Administration Ready Reserve Force 255,300,000 230,000 0.09

70 Office of the Inspector General - DRAA 600,000 3,000 0.42

Department of the Treasury 69,786,230,000 16,762,650,000 

71 Earned Income Tax Credit 69,786,230,000 16,762,650,000 24.02

Department of Veterans Affairs (VA) 121,719,610,000 5,485,660,000 

72 Beneficiary Travel 890,060,000 65,640,000 7.37

73 Civilian Health and Medical Program of the VA 1,145,730,000 53,870,000 4.70

74 VA Community Care 4,728,950,000 3,587,250,000 75.86

75 Purchased Long-Term Services and Support 1,705,600,000 1,179,490,000 69.15

76 State Home Per Diem Grants 1,126,260,000 28,930,000 2.57

77 Supplies and Materials 2,476,710,000 22,270,000 0.90

78 Compensation 63,864,040,000 376,580,000 0.59

79 Pension 5,594,760,000 127,100,000 2.27

80 Vocational Rehabilitation and Employment Beneficiary 

Payments

1,260,380,000 6,950,000 0.55

81 Education - Chapter 33 11,344,070,000 3,920,000 0.03

82 Education - Chapter 1606 143,470,000 90,000 0.06

83 Education - Chapter 1607 47,730,000 620,000 1.31

84 Disaster Relief Act - Hurricane Sandy 23,610,000 870,000 3.66

85 Payments to Federal Employees - Payroll 27,368,240,000 32,080,000 0.12

Environmental Protection Agency 2,893,210,000 250,000 

86 Clean Water State Revolving Fund 1,668,300,000 80,000 0.01

87 Drinking Water State Revolving Fund 1,223,480,000 170,000 0.01

88 Hurricane Sandy Disaster Relief Fund 1,430,000 - 0.00

General Services Administration 5,623,770,000 4,810,000 

89 Rental of Space 5,596,300,000 3,240,000 0.06

90 Purchase Cards 27,050,000 1,570,000 5.80

91 Hurricane Sandy Disaster Relief Fund 420,000 - 0.00

National Aeronautics and Space Administration 8,970,000 -

92 Hurricane Sandy Disaster Relief Program 8,970,000 - 0.00
Appendix VII: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2016

Page 65 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2016

Agency/reporting program Outlays (dollars) Improper payment 

estimate (dollars)

Improper 

payment rate 

(percentage)

Office of Personnel Management 131,833,410,000 401,260,000 

93 Total Program - Retirement 82,013,200,000 304,210,000 0.37

94 Federal Employee Health Benefit - All Carriers 49,820,210,000 97,050,000 0.19

Small Business Administration 23,119,210,000 329,801,100 

95 7(a) Guaranty Purchases 576,920,000 13,370,000 2.32

96 7(a) Guaranty Approvals 17,457,040,000 166,770,000 0.96

97 504 Certified Development Company Guaranty Approvals 4,594,810,000 119,590,000 2.60

98 Disaster Loan Disbursements 344,910,000 18,360,000 5.32

99 Disbursements for Goods and Services 112,430,000 11,640,000 10.35

100 Hurricane Sandy Disaster Relief Grants 5,570,000 4,000 0.07

101 Hurricane Sandy Disaster Relief Administrative Funds - Payroll 27,110,000 66,000 0.24

102 Hurricane Sandy Disaster Relief Administrative Funds - Travel 270,000 200 0.07

103 Hurricane Sandy Disaster Relief Administrative Funds -

Purchase Cards

150,000 900 0.60

Social Security Administration 910,315,020,000 7,873,650,000 

104 Old Age, Survivors & Disability Insurance 853,689,440,000 3,672,160,000 0.43

105 Supplemental Security Income 56,625,580,000 4,201,490,000 7.42

Department of Energy NR NR NR

Department of State NR NR NR

National Science Foundation NR NR NR

Nuclear Regulatory Commission NR NR NR

U.S. Agency for International Development NR NR NR

Subtotal – CFO Act agencies 3,069,275,760,000 144,208,268,200 4.70

Non-CFO Act agencies

Broadcasting Board of Governors 219,680,000 610,000 

106 Domestic Payroll 219,680,000 610,000 0.28

Corporation for National and Community Service 151,990,000 46,900,000 

Foster Grandparents Program 78,650,000 26,820,000 34.10

Retired and Senior Volunteer Program 41,460,000 9,480,000 22.87

Senior Companion Program 31,880,000 10,600,000 33.25

Federal Communications Commission 8,767,400,000 161,110,000 

107 Universal Service Fund - High Cost 4,305,420,000 1,100,000 0.03

108 Universal Service Fund - Schools and Libraries 2,093,190,000 119,360,000 5.70
Appendix VII: Reported Improper Payment 

Estimates by Agency and Program/Activity for 

Fiscal Year 2016

Page 66 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Reported by OMB for fiscal year 2016

Agency/reporting program Outlays (dollars) Improper payment 

estimate (dollars)

Improper 

payment rate 

(percentage)

109 Universal Service Fund - Lifeline 1,387,130,000 40,650,000 2.93

110 Telecommunications Relay Service - Interstate 

Telecommunications Relay Services Fund

981,660,000 - 0.00

Railroad Retirement Board 12,292,390,00 74,690,000

111 Retirement and Survivors Benefits 12,188,270,000 71,210,000 0.58

112 Railroad Unemployment Insurance Act 104,120,000 3,480,000 3.34

Subtotal - Non-CFO Act agencies 21,431,460,000 283,310,000 1.32

Government-wide total as reported by OMB 3,090,707,220,000 144,491,578,200 4.68

Excluded from OMB’s government-wide calculationb (624,020,000) (46,960,000)

Foster Grandparents Program 78,650,000 26,820,000 34.10

Retired and Senior Volunteer Program 41,460,000 9,480,000 22.87

Senior Companion Program 31,880,000 10,600,000 33.25

Navy Commercial Bill Pay Office - Naples 472,030,000 60,000 0.01

Exclusion of DFAS Commercial Pay Program (248,536,450,000) (110,820,000)

Fiscal year 2016 government-wide total, excluding DFAS 

Commercial Pay Program

2,841,546,750,000 144,333,798,200 5.08

Legend:

CFO Act: Chief Financial Officers Act of 1990

OMB: Office of Management and Budget

Source: GAO analysis of OMB data. | GAO-17-484

a

This table includes DOD’s DFAS Commercial Pay improper payment estimate of $110.8 million and 

corresponding outlays of $248.5 billion as reported by DOD and OMB in fiscal year 2016. However, 

the reported government-wide estimate of $144.3 billion in improper payments excludes the estimate 

for the DFAS Commercial Pay program. Although OMB included this program’s estimates in its 

government-wide improper payment estimate, because of continuing GAO concerns based on audit 

findings in a 2013 report regarding the reliability of its improper payment estimate, the DFAS 

Commercial Pay estimate was excluded from GAO’s calculations. See GAO, DOD Financial 

Management: Significant Improvements Needed in Efforts to Address Improper Payment 

Requirements, GAO-13-227 (Washington, D.C.: May 13, 2013).

b

OMB excluded these programs from the fiscal year 2016 government-wide calculation because they 

did not have OMB-approved sampling methodologies.
Appendix VIII: Comments from the Council of 

the Inspectors General on Integrity and 

Efficiency

Page 67 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Appendix VIII: Comments from the Council 

of the Inspectors General on Integrity and 

Efficiency
Appendix IX: Comments from the Department 

of Homeland Security Office of Inspector 

General

Page 68 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Appendix IX: Comments from the 

Department of Homeland Security Office of 

Inspector General
Appendix X: Comments from the Department 

of Housing and Urban Development

Page 69 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Appendix X: Comments from the Department 

of Housing and Urban Development
Appendix XI: Comments from the Department 

of Housing and Urban Development Office of 

Inspector General

Page 70 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Appendix XI: Comments from the 

Department of Housing and Urban 

Development Office of Inspector General
Appendix XI: Comments from the Department 

of Housing and Urban Development Office of 

Inspector General

Page 71 GAO-17-484 Fiscal Year 2015 IPERA Compliance
Appendix XII: Comments from the Department 

of the Treasury

Page 72 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Appendix XII: Comments from the 

Department of the Treasury
Appendix XII: Comments from the Department 

of the Treasury

Page 73 GAO-17-484 Fiscal Year 2015 IPERA Compliance
Appendix XIII: Comments from the Social Security 

Administration

Page 74 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Appendix XIII: Comments from the Social 

Security Administration
Appendix XIV: GAO Contact and Staff Acknowledgments

Page 75 GAO-17-484 Fiscal Year 2015 IPERA Compliance

Beryl H. Davis, (202) 512-2623 or davisbh@gao.gov

In addition to the contact named above, Phillip McIntyre (Assistant 

Director), Michelle Philpott (Auditor in Charge), John Craig, Melanie 

Darnell, Sophie Geyer, Wilfred Holloway, Jason Kelly, Jason Kirwan, 

Emily Matic, Brian Paige, Dacia Stewart, and Fabiola Torres made key

 contributions to this report.

Appendix XIV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100948)
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