FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

Office of Inspector General 

TO: Caroline C. Hunter, Commissioner (Chair) 

Steven T. Walther, Commissioner (Vice Chair) 

Ellen L. Weintraub, Commissioner 

FROM: Christopher Skinner 

Inspector General 

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

Requirements for Fiscal Year 2019 

DATE: May 12, 2020 

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

Inspector General (OIG) fiscal year (FY) 2019 review of the FEC’s compliance with the 

Improper Payments Information Act of 2002 (IPIA), as amended.1 Our review concluded 

that FEC is compliant with the improper payment requirements2 for FY 2019. 

The IPIA requires each agency to annually review all programs and activities that it 

administers, identify those susceptible to significant improper payments, and submit to 

Congress an estimate of the annual amount of improper payments. The Improper 

Payments Elimination and Recovery Act of 2010 (IPERA) amends the IPIA, and requires 

each agency to periodically review all programs and activities that may be susceptible to 

significant improper payments in accordance with Office of Management and Budget 

(OMB) requirements. IPERA defines “significant improper payments” as 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). 

Our review was conducted in accordance with guidance set forth by OMB Memorandum 

M-18-20, Transmittal of Appendix C to OMB Circular A-123, Requirements for Payment 

Integrity Improvement, June 26, 2018 (OMB Memorandum M-18-20). As a result, FEC 

complied and met the following six (6) requirements as defined by OMB Memorandum 

M-18-20. 

1 The Improper Payments Information Act of 2002 (IPIA) is amended by the Improper Payments 

Elimination and Recovery Act of 2010 (IPERA) and the Improper Payments Elimination and Recovery 

Improvement Act of 2012 (IPERIA). 

2 An improper payment is defined as any payment that should not have been made or that was made in an 

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

Incorrect amounts are defined as 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). 

FEC OIG 2020-05-001 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Summary of OMB Memorandum M-18-20 Requirements for IPERA Compliance 

1 

Published an Agency Financial Report (AFR) or a 

Performance Accountability Report (PAR) for the most recent 

fiscal year and posted report on the agency website.3

√ 

2 Conducted a program specific risk assessment for each program 

that conforms to Section 31 U.S. Code § 3321.4 √ 

3 

Published improper payment estimates for all programs 

identified as susceptible to significant improper payments 

under its risk assessment. 

N/A 

4 Published programmatic corrective action plans in the AFR or 

PAR. N/A 

5 

Published, and is meeting, annual reduction targets for 

each program assessed to be at risk and estimated for 

improper payments. 

N/A 

6 

Reported a gross improper payment rate of less than 10 

percent for each program for which an improper payment N/A

estimate was obtained and published in the AFR or PAR. 

The FEC conducted a risk assessment of improper payments in FY 2019. That risk 

assessment did not identify any programs or activities susceptible to significant improper 

payments at or above threshold levels set by the OMB. Additionally, the OIG reviewed 

the agency’s applicable improper payment disclosures contained in the FEC FY 2019 

Agency Financial Report and other relevant work papers included in the FY 2019 

Financial Statement Audit. Based on our review, we determined that the FEC is in 

compliance with IPERA for FY 2019. 

The OIG is required to report these results to the FEC, the Committee on Homeland 

Security and Governmental Affairs of the Senate, the Committee on Oversight and 

Reform of the House of Representatives, the Comptroller General, and the OMB. 

The OIG appreciates the cooperation and courtesies extended to us by the FEC Office of 

the Chief Financial Officer during the course of this review. If you have any questions or 

concerns, please contact me at (202) 694-1017, or by email at cskinner@fec.gov. 

cc: John Quinlan, Chief Financial Officer 

Alec Palmer, Staff Director 

Lisa Stevenson, Acting General Counsel 

3 Available at https://www.fec.gov/resources/cmscontent/documents/FEC_audit_report_FY_19_financial_statement_audit-final.pdf. 

4 IPERA requires agencies to perform risk assessments at least once every 3 years for programs that are 

deemed to be not susceptible to significant improper payments.