MEMORANDUM

1050 First Street NE Washington, DC 20463 | www.fec.gov/oig

TO: The Commission 

THROUGH: Christopher Skinner 

Inspector General 

FROM: Shellie Purnell-Brown

Senior Auditor 

SUBJECT: The Federal Election Commission’s Compliance with Improper Payments 

Reporting for Fiscal Year 2022 

DATE: May 4, 2023 

Purpose. This report transmits the results of the Federal Election Commission (FEC) Office of 

Inspector General (OIG) fiscal year (FY) 2022 annual review of the FEC’s compliance with the 

Payment Integrity Information Act of 2019 (PIIA). The Office of Management and Budget 

(OMB) Circular A-123 requires that each agency’s OIG annually review and evaluate whether 

the agency has published the appropriate improper payments information with the annual 

Performance and Accountability Report (PAR) or Annual Financial Report (AFR) and 

accompanying materials for the most recent fiscal year. In addition, each OIG is to determine if 

the agency has complied with the PIIA and other applicable payment integrity guidance. 

Criteria. We conducted a compliance review to satisfy our FY 2022 annual compliance review 

using the requirements in OMB Circular A-123, Appendix C (March 2021), OMB Circular A136 (June 3, 2022), OMB Annual Data Call Instructions, OMB Payment Integrity Question and 

Answer Platform, and the CIGIE Guide for PIIA. 

Results. For FY 2022, the OIG concludes the FEC complied with the following applicable 

requirements outlined in the PIIA and OMB guidance (see table below): 
2

Legal Requirements Compliance

1a. 

Published payment integrity information with the annual 

financial statement and in the accompanying materials 

to the annual financial statement of the agency for the 

most recent FY in accordance with OMB guidance.

Yes

1b. 

Posted the annual financial statement and accompanying 

materials required under guidance of the OMB on the 

agency website.1

Yes

2a. 

Conducted improper payment risk assessments for each 

program with annual outlays greater than $10,000,000 at 

least once in the last three years.

Yes

2b. 

Adequately concluded whether the program is likely to 

make improper payments (IP) and unknown payments 

(UP) above or below the statutory threshold. 

Yes

3. 

Published IP and UP estimates for programs susceptible to 

significant IPs and UPs in the accompanying materials to the 

annual financial statement.

N/A2

4. 

Published corrective action plans for each program for which 

an estimate above the statutory threshold was published in the 

accompanying materials to the annual financial statement.

N/A

5a. 

Published an IP and UP reduction targets for each 

program for which an estimate above the statutory 

threshold was published in the accompanying materials 

to the annual financial statement. 

N/A

5b. 

Demonstrated improvements to payment integrity or 

reached a tolerable improper payment and unknown 

payment rate.

N/A

5c. Developed a plan to meet the IP and UP reduction target. N/A

6. 

Reported an IP and UP estimate of less than 10% for each 

program for which an estimate was published in the 

accompanying materials to the annual financial statement.

N/A

1 Available at Independent Audit Report of FEC's FY 22 Financial Statement. 

2 Requirement is not applicable because FEC determined in its most recent risk assessment that the agency’s programs 

are not susceptible to significant improper payments.
3 

Background. The Improper Payments Elimination and Recovery Act of 2010 (IPERA) amended 

the Improper Payments Information Act of 2002 (IPIA) and required agencies to identify and 

review all programs and activities they administer that may be susceptible to significant 

improper payments3 based on guidance provided by OMB. Additionally, section 3 of IPERA 

required Inspectors General to review each agency’s improper payment reporting and issue an 

annual report. On March 2, 2020, the PIIA repealed IPERA, IPIA, and the Improper Payments 

Elimination and the Recovery Improvement Act of 2012 (IPERIA), but set forth similar 

improper reporting requirements including an annual report by Inspectors General.4

 

The objective of the PIIA is to improve efforts to identify, reduce, and recover government-wide 

improper payments. An improper payment is any payment that should not have been made or 

that was made in an incorrect amount. Incorrect amounts are overpayments or underpayments 

that are made to eligible recipients. An improper payment also includes any payment that was 

made to an ineligible recipient or for an ineligible good or service, or payments for goods or 

services not received (except for such payments authorized by law). In addition, when an 

agency’s review is unable to discern whether a payment was proper because of insufficient or 

lack of documentation, this payment must also be considered an improper payment. 

Beginning in FY 2021, OMB M-20-21 requires agencies to assess the likelihood of total annual 

improper payments (IPs) plus annual unknown payments (UPs) above the statutory threshold. In 

addition, agencies are required to report that they adequately concluded whether the program is 

likely to make IPs and UPs above or below the statutory threshold. 

Work Performed by FEC OIG. The OIG reviewed the agency’s payment integrity section and 

other improper payment disclosure sections of the FEC FY 2022 AFR posted on the agency’s 

website. The OIG also examined the most recent improper payment risk assessment and other 

relevant workpapers included in the FEC’s FY 2022 Financial Statement Audit. 

Conclusion. The OIG determined that the agency had no programs susceptible to significant 

improper payments. Based on our review of the IP risk assessment, the OIG concludes that the 

FEC’s efforts to detect, prevent, and/or reduce IPs and UPs either above or below the statutory 

thresholds are adequate considering that improper payment risk is low, there are no UPs, and the 

agency is not susceptible to significant improper payments. 

3

 Significant improper payments are gross annual improper payments (i.e., the total amount of overpayments and 

underpayments) in the program exceeding (1) both 1.5 percent of program outlays and $10 million of all program or 

activity payments made during the first year reported, or (2) $100 million (regardless of the improper payment 

percentage of total program outlays).

4 OMB A-123 Appendix C (as modified) implements requirements for the following: (1) IPIA; (2) IPERA; 

(3) IPERIA; (4) PIIA; and (5) Executive Order 13520 - Reducing Improper Payments, November 20, 2009.
4 

The OIG is required to report these results to the Senate Committee on Homeland Security and 

Governmental Affairs; the House Committee on Oversight and Reform; the House and Senate 

Committee on Appropriations; other applicable Authorizing Committees of Congress; the 

Comptroller General; and OMB. 

If I can provide you with any further information, please do not hesitate to contact Shellie 

Purnell-Brown at (202) 694-1015. 

cc: John Quinlan, Chief Financial Officer 

Alec Palmer, Staff Director/Chief Information Officer

Lisa Stevenson, Acting General Counsel

FEC OIG 2023-05-001