SERVICEtxXC 

NATIONAL& 

COMMUNITY 

1201 New York Avenue, NW 

Washington, DC 20525 

202-606-5000 

NationaiService.gov 

Subject: High-Dollar Overpayments for the quarter ending September 30, 2015 

Date: November 18,2015 

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 was completed in October 

2015. During the reporting period covering 7/01/2015 through 09/30/2015, 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. 

DISASTER SERVICES I ECONOMIC OPPORTUNITY I EDUCATION I E NVIRONME NTAL STEWARDSHIP I HEALTHY FUTURES I VETERA NS A ND MILITARY FAMILIES 

AMERICOR PS I SE N IOR CORPS I SOC I AL IN NOVATION FUND 

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 amended1 (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 

mbans of information. A report must be made even if there are no high-dollar 

overpayments found. 

I PIA was amended by the Improper Payments Elimination and Recovery Act of 2010 (JPERA; Pub. L. No. 111-204) and the 

Improper Payments Elimination and Recovery Improvement Act of 2012 (I PERlA; Pub. L. No. 111-204). 

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. 

As of September 30, 2015, 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 

1 
approximately 80% of all 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.