payments made throughout the different grant programs. Most staff are not typically
compensated at a rate where improper overpayments reach the HDOP threshold level

within a three month period.

The Office of Accountability and Oversight (OAO) has spoken with CNCS’s Office of
General Counsel (OGC) to determine the methodology used to track HDOPs. When
performing IPERA testing, OAO tracks the amount, date, and person and/or entity of
each tested transaction. When a payment is identified as improper, OAO will identify
whether the specific payment qualifies as an HDOP. If it is not an HDOP on its face,
OAO will then assess the potentiality that other payments made to that individual
and/or entity over the current quarter are also improper and in aggregate could reach
the level of an HDOP. We will do this by extrapolating the data collected during IPERA
testing to the entire quarter (i.e. for payroll we will determine the number of payments
in that quarter and determine the amount of overpayment which likely occurred in each
payment). If the extrapolation shows that payments to the individual or entity could
reach the HDOP threshold, OAO will work with Program Officers and Grants Officers
to collect all the necessary information to make a final determination as to whether any

actual HDOPs were made.

Part of HDOP reporting includes reporting on any efforts made to recover the cost of
the payment. Although no HDOPs have been identified yet, OAO will work with the
Program and Grants Offices to recover costs associated with the HDOP in the same way

that OAO recovers identified improper payments.


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Subject: High-Dollar Overpayments for the quarter ended June 30, 2015
Date: July 7, 2015

The purpose of this Document is to comply with the High-Dollar overpayments'
reporting requirements addressed in the Office of Management and Budget (OMB)
implementation guidance M-15-02 Circular A-123, Appendix C, dated October 20, 2014,
relative to Executive Order 13520. The OMB implementation guidance makes necessary
for agency heads to submit reports quarterly on High-Dollar overpayments to the Office
of Inspector General.

The Corporation for National and Community Service (CNCS) identifies high-dollar
overpayments through improper payments testing, which is currently ongoing. During
the reporting period covering 10/01/2014 through 06/30/2015, CNCS has not identified
any high-dollar overpayments. :

This report upholds CNCS’s commitment to carrying out the Executive Order's goals of

eliminating payment errors. Reducing improper payments remains vital for CNCS. We
continue to monitor programs in order to reduce the amount of overpayments.

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Supplemental Information

High-Dollar Overpayment Reporting Procedures

Office of Management and Budget (OMB) Circular A-123, Appendix C requires that
agencies with programs susceptible to significant improper payments under the
Improper Payments Information Act of 2002, (Pub. L. No. 107-300, 31 U.S.C. 3301 note,
as amended! (IPIA)) are required to report quarterly on high-dollar overpayments that
occurred within those specific programs. This information must be reported to the
agency’s Inspector General and to the public through the agency’s website or other
means of information. A report must be made even if there are no high-dollar

overpayments found.

OMB A-123, Appendix C was last updated in October of 2014, which changed the
reporting threshold for high-dollar overpayments (HDOP). Now, a HDOP is one made
to an individual that exceeds $25,000 in a quarter or a payment to an entity that exceeds
$100,000 in a quarter. An agency must identify HDOPs through one or more relevant
sources of information available to the agency, as cost-effective, such as annual
improper payment testing samples, payment recapture audits or other sources

identified by the agency.

CNCS has identified three programs that are susceptible to significant improper
payments, triggering quarterly HDOP reporting. These programs are AmeriCorps State
and National, the Foster Grandparents Program, and Retired and Senior Volunteer
Program. Currently, CNCS is identifying HDOPs through IPERA testing. Given the
nature of CNCS’s grant programs, it is unlikely that many, if any, high-dollar
overpayments will be identified. Staff and member payroll are approximately 80% of all

1 PIA was amended by the Improper Payments Elimination and Recovery Act of 2010 {IPERA; Pub. L. No. 111-204) and the
Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERIA; Pub. L. No. 111-204).