FEDERAL 

EMPLOYEES’ 

COMPENSATION ACT

Case Examples 

Illustrate 

Vulnerabilities That 

Could Result in 

Improper Payments or 

Overlapping Benefits

Report to Congressional Requesters

April 2013

GAO-13-386

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-386, a report to 

congressional requesters

April 2013

FEDERAL EMPLOYEES’ COMPENSATION ACT

Case Examples Illustrate Vulnerabilities That Could 

Result in Improper Payments or Overlapping 

Benefits 

Why GAO Did This Study

In fiscal year 2012, the FECA program 

made more than $2.1 billion in wageloss compensation payments to 

claimants. FECA provides benefits to 

federal employees who sustained 

injuries or illnesses at work. 

GAO was asked to examine whether 

examples of improper payments, 

potential fraud, or overlapping benefits 

could be found in the FECA program. 

This report identifies examples of these 

issues, what factors may contribute to 

these issues, and how, if at all, Labor 

could address them. GAO matched 

QW and unemployment files from five 

selected states with FECA payment 

files for the period of July 2009 to June 

2010. GAO identified 530 individuals 

who received concurrent FECA 

compensation payments and wages of 

at least $5,000 between July 2009 and 

June 2010. GAO also identified 50 

individuals who received concurrent 

FECA compensation and UI benefits of 

at least $5,000 each during the same 

period. GAO randomly selected up to 

seven recipients from each state for an 

in-depth review, for a total of 32 QW 

and 19 UI cases, respectively. These 

examples cannot be generalized 

beyond those presented. GAO also 

reviewed Labor’s policies, guidelines, 

and procedures for managing claims.

What GAO Recommends

GAO recommends that the Secretary 

of Labor develop an effective 

mechanism to share FECA 

compensation information with states 

to help identify whether claimants are 

inappropriately receiving overlapping 

UI and FECA payments. In addition, 

Congress should consider granting 

Labor the additional authority it is 

seeking to access wage data to help 

verify claimants’ reported income and 

help ensure the proper payment of 

benefits. Labor agreed to study the 

feasibility of sharing compensation 

information with the states.

What GAO Found

GAO found examples of improper payments and indicators of potential fraud in 

the Federal Employees’ Compensation Act (FECA) program, which could be 

attributed, in part, to oversight and data-access issues. GAO found examples of 

claimants’ receiving overlapping FECA and unemployment insurance (UI) 

benefits, which may be allowable under certain circumstances, but could also be 

erroneous. GAO also found that FECA program requirements allow claimants to 

receive earnings, and earnings increases, without necessarily resulting in 

adjustment of FECA compensation. For example, of the 32 FECA case files 

reviewed, GAO found five instances where an individual’s wage-earning capacity 

(WEC), which is used to determine FECA benefits, was not adjusted even though 

the individual earned substantially more than the wage that was originally used to 

calculate the WEC. In addition, two FECA claimants continued to receive privateemployment salaries that were not subject to their WEC calculation. This is 

because, as currently written, program procedures allow claimants to receive 

increases in earnings, in certain circumstances, without adjustments to FECA 

compensation, and current law allows for claimants’ earnings from dissimilar 

concurrent private employment at the time of injury to be exempt when 

determining FECA compensation. As discussed below, GAO identified 

challenges related to oversight and data access, which could result in improper 

payments or overlapping benefits. 

GAO found that the Department of Labor (Labor) did not conduct a timely review 

of the medical activity reports of 4 of the 32 FECA claimants and did not 

complete a timely review of the employment activity reports of 2 claimants, which 

could potentially result in an improper payment or be an indicator of potential 

fraud in one case where a claimant did not respond to repeated Labor requests 

for the employment activity reports. Labor has taken some steps to enhance 

oversight of the program, such as developing measures to improve the periodic 

review of claimants’ documentation. 

• GAO found that 8 out of 32 claimants underreported employment wages in 

comparison to the state’s quarterly wage (QW) reports. Labor does not have 

authority to directly access Social Security Administration (SSA) wage data 

to verify claimants’ reported income; consequently, it relies on periodic selfreporting of income. GAO has previously identified this as a potential 

vulnerability that could increase the risk of claimants receiving benefits they 

are not entitled to. To address this, Labor proposed legislation allowing the 

agency to match SSA wage data with FECA files, but the proposal is still 

pending. 

• GAO identified 19 cases where claimants were receiving overlapping UI and 

FECA benefits totaling over $1.3 million. Four of these 19 claimants received

more income from combined UI and FECA benefits than they would have 

received from their federal salary alone. Four of the five selected states in 

our review require the offset of UI benefits against FECA compensation 

payments. Because Labor does not have a process to share necessary data 

with states to identify overlapping FECA and UI payments, a mechanism to 

share FECA information with the states would help provide reasonable 

assurance that payments are being made properly.

View GAO-13-386. For more information, 

contact Stephen M. Lord at (202) 512-4379 or 

lords@gao.gov.
Page i GAO-13-386 Federal Employees’ Compensation Act 

Letter 1 

Background 5

Examples of Improper Payments, Overlapping Benefits, and 

Potential Fraud Highlight the Importance of Data Sharing to 

Verify Benefit Eligibility 9

Conclusions 21

Matter for Congressional Consideration 21

Recommendation for Executive Action 22

Agency Comments and Our Evaluation 22

Appendix I Comments from the Department of Labor 24

Figure

Figure 1: Federal Employees Compensation Act (FECA) Claims 

Process 7

Abbreviations 

CE claims examiner

ECAB Employees’ Compensation Appeals Board

ETA Employment and Training Agency 

FECA Federal Employees’ Compensation Act 

HHS Department of Health and Human Services 

IG Inspector General

Labor Department of Labor

NDNH National Directory of New Hires 

OWCP Office of Workers’ Compensation Programs 

PER Periodic Entitlement Review

QW quarterly wage

SSA Social Security Administration

TSA Transportation Security Administration

UI unemployment insurance

WEC wage-earning capacity

Contents 

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Page 1 GAO-13-386 Federal Employees’ Compensation Act 

United States Government Accountability Office 

Washington, DC 20548

April 3, 2013

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn

Ranking Member

Committee on Homeland Security 

 and Governmental Affairs

United States Senate

The Honorable Susan Collins

Ranking Member

Special Committee on Aging

United States Senate

The Honorable Darrell Issa

Chairman

Committee on Oversight and Government Reform

House of Representatives

The Honorable Claire McCaskill

United States Senate

The Federal Employees’ Compensation Act (FECA) program provides 

workers’ compensation coverage to approximately 2.8 million federal and 

postal employees for work-related injuries and illnesses. Benefits include 

wage-loss benefits, medical benefits, vocational-rehabilitation benefits, 

and survivors’ benefits. In fiscal year 2012, the FECA program made 

more than $2.1 billion in wage-loss compensation payments to claimants.

The program, administered by the Department of Labor (Labor), provides 

benefits to federal employees who sustained injuries or illnesses while 

performing their federal duties. For those claims that are approved, 

employing agencies reimburse Labor for payments made to their 

employees, while Labor bears most of the program’s administrative costs.

Labor’s Office of Workers’ Compensation Programs (OWCP) estimated 

that future actuarial liabilities for government-wide FECA compensation 

payments to those receiving benefits as of fiscal year 2012 would total 

over $34 billion (this amount does not include any costs for workers 

added to the FECA rolls in future years); the U.S. Postal Service 

represents over 40 percent (approximately $14.4 billion) of these 

estimated liabilities. Federal agencies’ Offices of Inspector General (IG) 

 
 

Page 2 GAO-13-386 Federal Employees’ Compensation Act 

have identified programmatic deficiencies at the employing department 

and at Labor that may make the program vulnerable to fraud and abuse.1

For these reasons, you asked us to investigate the oversight mechanism 

Labor has in place to prevent waste, fraud, or abuse in the FECA 

program. This report is a follow-up to our January 2012 report identifying 

potential vulnerabilities in the program’s design and controls that could 

increase the risk for fraud and promising practices that could help to 

reduce the risk of fraud within the FECA program.2

What examples, if any, of improper payments, potential fraud, or 

overlapping benefits can be found in the FECA program, what factors 

may contribute to these issues, and how, if at all, could Labor address 

these factors?

This report addresses 

the following question:

To answer this objective, we determined whether individuals potentially 

received improper payments, potentially committed fraud, or received 

overlapping payments by comparing FECA data to quarterly wage (QW) 

and unemployment insurance (UI) data from selected states. To do this, 

we drew a nonprobability sample from five selected states: California, 

Florida, Maryland, New York, and Virginia.3

 

1

For example, see Office of the Inspector General, Social Security Administration, Federal 

Employees Receiving Both Federal Employees’ Compensation Act and Disability 

Insurance Payments, A-15-09-19008 (October 2010) and U.S. Department of Labor, 

Office of Inspector General–Office of Audit, Mechanisms Used to Identify Changes in 

Eligibility Are Inadequate at the FECA District Office in Jacksonville, Florida, 04-07-004-

04-431 (Washington, D.C.: Sept. 28, 2007).

To identify instances in which 

individuals received both FECA and QW benefits, we matched selected 

states’ QW files with FECA beneficiaries for the period of July 2009 to 

June 2010. We then applied a minimum threshold of $5,000 to the 

amount of both FECA benefits and QW earnings in order to identify a 

sample for further review. The threshold of $5,000 was chosen in order to 

identify a sample that was significant and that would allow for in-depth 

analysis. Individuals may be allowed to receive concurrent FECA and QW 

earnings if a person is on partial disability, however in some cases receipt 

2

GAO, Federal Employees’ Compensation Act: Preliminary Observations on FraudPrevention Controls, GAO-12-402 (Washington, D.C.: Jan. 25, 2012).

3

The specific states were selected because of (1) the size of the census population within 

the state and, in part, (2) the proximity to the Washington, D.C., metropolitan area. This 

nonprobability sample is not representative of all states or FECA recipients. 
 

Page 3 GAO-13-386 Federal Employees’ Compensation Act 

of concurrent payments may be improper. We identified 530 individuals 

who had received concurrent FECA wage-loss compensation payments 

and wage payments of at least $5,000 for the 1-year period (i.e., July 

2009 to June 2010) We then randomly selected up to seven claimants 

from each of the five states for an in-depth review, for a total of 32 cases. 

Of the five states, California, Maryland, and New York had seven 

individuals selected randomly, Florida had six individuals, and Virginia 

had five individuals that met the criteria for selection. For these 

beneficiaries, we reviewed QW files from the selected states and FECA 

files from Labor. The specific findings from the selected cases cannot be 

generalized to other, or all, FECA claimants who also received quarterly 

wages.

To identify FECA claimants who concurrently received UI benefits, we 

obtained and analyzed UI files from the same selection of states. Under 

certain circumstances, individuals can legitimately receive FECA and UI 

concurrently, but claimants could also be receiving these overlapping 

benefits erroneously, which could signal potentially improper or fraudulent 

payments. We matched these claimants with the FECA files for this same 

period. As in our QW analysis, we then applied a minimum threshold of 

$5,000 to the amount of both FECA and UI benefit payments. We 

identified 50 individuals who received concurrent FECA wage-loss 

compensation payments and UI benefits that exceeded the minimum 

threshold. We chose the $5,000 threshold in order to identify a sample 

that was both significant and would allow for in-depth analysis. We then 

randomly selected up to seven claimants from each of the five states for 

an in-depth review, for a total of 19 cases.4

In addition, we conducted investigations of 3 of the 51 (19 UI and 32 QW) 

individual cases. We selected these cases through a two-stage process. 

First, we selected 8 cases for further investigation, 4 from California and 4 

from Virginia. The cases were selected on the basis of the number of 

cases from each state, geographical proximity to Washington, D.C., and 

For these beneficiaries, we 

reviewed UI files from the selected states and FECA files from Labor. The 

findings from these specific cases cannot be generalized to other, or all, 

FECA claimants who also received UI benefits.

 

4

California had seven individuals selected randomly, Florida had five individuals, New 

York had four individuals, and Virginia had three individuals who met the criteria for 

selection. Maryland did not have any UI cases because none of the individuals met the 

$5,000 threshold criteria for selection.
 

Page 4 GAO-13-386 Federal Employees’ Compensation Act 

potential for fraud stemming from an initial file review.5

To identify factors that may have contributed to potentially improper or 

overlapping benefits, and how, if at all, Labor could address these factors, 

we conducted interviews with officials from Labor’s OWCP and 

Employment and Training Agency (ETA), and reviewed prior Inspector 

General (IG) and GAO reports. We also reviewed Labor’s oversight 

mechanisms, which establish policies, guidelines, and procedures for 

adjudicating and managing claims under the FECA program and 

compared them with those outlined in the Standards for Internal Control in 

the Federal Government.

We determined 

that 3 required further investigations on the basis of a lack of supporting 

details in the FECA case files. The other five case files contained 

information that made it clear why the discrepancy occurred.

6

To determine the reliability of the FECA and state QW and UI data we 

received, we reviewed documentation related to these databases and 

interviewed officials responsible for compiling and maintaining relevant 

data. In addition, we performed electronic testing to determine the validity 

of specific data elements in the databases that we used to perform our 

work. We also reviewed detailed FECA and UI case files for the 

nongeneralizable selection of individuals who received concurrent FECA 

and QW or UI benefits. On the basis of our discussions with agency 

officials and our own testing, we concluded that the data elements used 

for this report were sufficiently reliable for our purposes.

We performed our work from June 2012 through March 2013 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. We conducted our related 

investigative work in accordance with standards prescribed by the Council 

of the Inspectors General on Integrity and Efficiency.

 

5

Maryland was not chosen because there were no cases of potential UI fraud in that state. 

6

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).
 

Page 5 GAO-13-386 Federal Employees’ Compensation Act 

Within Labor, the Division of Federal Employees’ Compensation in the 

OWCP administers the FECA program, which provides wage 

replacement and medical benefits to federal employees who suffer partial 

or total disabilities resulting from work-related injuries and occupational 

diseases. OWCP is the central point where FECA claims are processed 

and eligibility and benefit decisions are made. Claims examiners (CE) at 

OWCP’s 12 FECA district offices determine applicants’ eligibility for FECA 

benefits and process claims for wage-loss payments.

FECA laws and regulations specify criteria for computing compensation 

payments. Using information provided by the employing agency and the 

claimant on a claims form, OWCP calculates compensation on the basis 

of a number of factors, including the claimant’s rate of pay, the claimant’s 

marital status, and whether or not the claimant has dependents. Eligible 

disabled employees generally receive 66-2/3 percent (or 75 percent if 

married or with dependents) of their basic salary, tax-free, plus medicalrelated expenses. When an injury results in partial disability, and the 

employee suffers a wage loss because of the disability, the claimant is 

entitled to monthly monetary compensation equal to 66-2/3 percent (or 75 

percent if married or with dependents) of the difference between the 

claimant’s monthly pay and his or her monthly wage-earning capacity 

(WEC).7

According to OWCP officials, initial claims received from employing 

federal agencies are reviewed by claims examiners to assess the 

existence of key elements. (See fig. 1.) The elements include evidence 

that the claim was filed within FECA’s statutory time requirements; that 

the employee was, at the time of injury, disease, or death, an employee of 

the United States; that the employee was injured while on duty; and that 

the condition resulted from the work-related injury. If the key elements are 

in place, OWCP will approve a claim and begin processing bills for 

medical costs. After initial claim approval, additional reviews are done 

while a claim remains active to determine whether the claimant can 

continue to receive wage-loss compensation. Once a claim is approved, 

payments are sent directly to the claimant or provider. An employee can 

continue to receive wage-loss compensation for as long as medical 

 

 

7

WEC is an estimation of a worker’s earnings capacity. It can be based on the 

employee’s calculated earning capacity in current employment or based on constructed 

earning capacity if the individual is not employed (e.g., an estimation done by a 

rehabilitation specialist of an injured worker’s earning capacity). 

Background
 

Page 6 GAO-13-386 Federal Employees’ Compensation Act 

evidence shows that the employee is totally or partially disabled and that 

the disability is related to the accepted injury or condition. Specifically, a 

medical review is required annually for employees receiving temporary 

total-disability payments, every 2 years for claimants earning loss of WEC 

payments, and every 3 years for claimants on the periodic rolls who have 

been determined to not have any WEC.8

 

8

Employees on the periodic rolls have total disabilities or injuries that have lasted or are 

expected to last for prolonged periods. 

Employees receiving 

compensation for partial or total disability must advise OWCP 

immediately if they return to work, either part-time or full-time.
 

Page 7 GAO-13-386 Federal Employees’ Compensation Act 

Figure 1: Federal Employees Compensation Act (FECA) Claims Process
 

Page 8 GAO-13-386 Federal Employees’ Compensation Act 

Claimants are required to self-report all employment wages, whether 

salaried or not, and self-employment. OWCP requires that all individuals 

on the periodic roll (both partial and total disability) complete Form CA1032 on a yearly basis stating their income or whether their dependent 

status has changed. A new employer may also be requested to provide 

information regarding a claimant’s employment and earnings. Labor can 

use this form to adjust the amount of FECA compensation. Employees 

must report even those earnings that do not seem likely to affect their 

level of benefits, such as concurrent income that an employee was 

receiving prior to his or her injury that was not directly related to the 

employee’s federal employment.9 While earning income will not 

necessarily result in a reduced compensation, the FECA statute and 

implementing regulations stipulate that failure to report income may result 

in forfeiture of all benefits paid during the reporting period. To help verify 

income levels, Labor requests that FECA claimants provide it with their 

consent to access their Social Security Administration (SSA) earnings file; 

however, claimants are not required to provide Labor with their consent, 

and authorization to obtain such information is not required to receive 

compensation.10 In instances where Labor is authorized to collect 

earnings information from SSA by claimants, according to OWCP 

officials, SSA’s earnings data may be as much as 2 years old,11 which 

may hinder timely adjustments to compensation benefits.

Established by the Social Security Act of 1935, the federal-state UI 

program generally temporarily and partially replaces the lost earnings of 

those who become unemployed through no fault of their own. To be 

eligible for UI benefits, unemployed workers must meet eligibility 

 

9

Employment income that an employee was receiving prior to his or her injury that was not 

related to the employee’s federal employment is exempt from the calculation Labor uses 

to determine FECA compensation, as discussed in more detail later in this report.

10If the SSA authorization is not signed and returned and there is some indication in the 

file that the claimant may have earnings or work activity, the case may be referred to the 

IG for investigation to determine if the claimant has in fact earned wages for the period 

under consideration. Benefits may not be suspended for failure to complete this form, 

however, as authorization to obtain reports from SSA is not a requirement for receipt of 

compensation.

11The data are older because, without a systemic data match, OWCP must obtain a 

release from the claimant and send this release to SSA along with a request for earnings 

statements for the period covered in the release—a cumbersome and time-intensive 

process.

FECA Claimants Earning 

Wages

FECA and UI Benefits
 

Page 9 GAO-13-386 Federal Employees’ Compensation Act 

requirements established by state laws that conform to federal law, 

including that they have worked recently, are involuntarily unemployed, 

and are able and available for work. Whereas federal statutes and 

regulations provide broad guidelines on UI eligibility, the specifics of UI 

eligibility are determined by each state. According to Labor’s Employment 

and Training Agency, all states require that a claimant must have earned 

a specified amount of wages, worked a certain number of weeks in 

covered employment, or must have met some combination of the wage 

and employment requirements within his or her base period. To be 

eligible for benefits, claimants must also be free from disqualification for 

acts such as voluntarily leaving without good cause, discharge for 

misconduct connected with the work, and refusal of suitable work.

However, the specific eligibility requirements regarding an applicant being 

“able and available for work” vary among the states. For example, a few 

states specify that a worker must be physically able, or mentally and 

physically able, to work. Likewise, while some states require that a worker 

must be available for work, other states require that a worker must be 

available for suitable work; still other states may find an individual able 

and available for work so long as any limitation due to illness, injury, or 

presence in the usual labor market does not constitute a withdrawal from 

the labor market. In addition to being able and available for work, all 

states require by law or by practice that a worker be actively seeking work 

or making a reasonable effort to obtain work. According to ETA, some 

states permit payment of benefits to sick or disabled individuals under 

certain circumstances, but there is nothing in their laws that prohibit a 

denial of benefits in those circumstances. 

We found examples of improper payments, overlapping benefits, and 

potential fraud in the FECA program, which could be attributed, in part, to 

factors such as oversight and data-access issues. OWCP has taken 

some steps to enhance oversight of the FECA program; however, Labor 

lacks authority to directly access wage data, which limits its ability to 

verify self-reported wage information. In addition, OWCP does not have a 

process to access data needed to identify the extent that claimants are 

receiving overlapping FECA and UI benefits and does not report FECA 

claimant information to states, which increases the risk that FECA 

claimants are receiving overlapping benefits improperly.

Examples of 

Improper Payments, 

Overlapping Benefits, 

and Potential Fraud 

Highlight the 

Importance of Data 

Sharing to Verify 

Benefit Eligibility
 

Page 10 GAO-13-386 Federal Employees’ Compensation Act 

OWCP has designed additional oversight mechanisms to better monitor 

claimants’ eligibility, which could help identify improper payments and 

potential fraud. To determine a claimant’s eligibility for FECA, claimants 

who suffer partial or total disabilities resulting from work-related injuries 

are required to submit medical evidence to OWCP so it can determine the 

nature and extent of disability resulting from this condition and any 

changes to their condition that could affect continuing entitlement. 

Specifically, a CE is required to conduct a medical review annually for 

claimants on total disability receiving long-term compensation who are on 

the program’s periodic rolls, every 2 years for claimants earning loss of 

WEC payments, and every 3 years for claimants who have been 

determined to not have any WEC. OWCP bears the burden of justifying 

the termination or modification of compensation benefits. Accordingly, 

OWCP must have medical evidence in order to support any change in 

compensation to a claimant.12

In addition, claimants are also required to submit an annual form (Form 

CA-1032) stating whether their income or dependent status has changed. 

The form must be signed to acknowledge evidence of benefit eligibility 

and to acknowledge that criminal prosecution may result from deliberate 

falsehood. OWCP’s review of this annual form is especially important for 

claimants who are deemed to not have any WEC and, therefore, have 

less frequent medical reviews.

Without up-to-date medical reports for 

claimants, OWCP lacks the necessary evidence to change compensation 

levels.

 

12According to OWCP, it can also modify a claimant’s compensation due to FECA fraud, 

felony incarceration or documentation of a return to the claimant’s previous employment.

Labor Is Taking Steps That 

Could Enhance Oversight 

of Eligibility Information
 

Page 11 GAO-13-386 Federal Employees’ Compensation Act 

Our review of a nongeneralizable sample of 32 individual cases identified 

four claimants who were on partial disability,13 receiving payments for loss 

of WEC, but did not have evidence that OWCP obtained or reviewed the 

required medical reports every 2 years,14 as required.15

For the 28 cases that had medical reports, we found that 14 cases did not 

include the Work Capacity Evaluation (OWCP-5c) form, which is not a 

mandatory form but is to be completed by a medical professional. 

According to OWCP, a narrative medical report may be more informative 

than the OWCP-5c and more helpful in determining a claimant’s ability to 

earn wages. The purpose of the OWCP-5c form is to help clarify whether 

a claimant is capable of fulfilling his employment duties by identifying a 

claimant’s specific work-tolerance limitation, where the accepted condition 

is musculoskeletal in nature. Without this form, it can be difficult to 

determine whether the claimant is capable of performing the job and 

whether employers can readily accommodate the medical condition. For 

all 14 cases, the claimant did suffer a musculoskeletal injury.

These individuals 

continued to receive FECA compensation benefits without evidence that 

their medical condition has not improved, which potentially could result in 

an improper payment.

 

13The nongeneralizable sample of 32 individuals included 23 individuals who were on 

partial disability.

14Specifically, for these four individuals, Labor did not have evidence in their files of a 

medical activity report between the dates of July 2009 and May 2012.

15Individuals who are on partial disability are those who cannot return to their position at 

the time of injury (or earn equivalent wages) because of the work-related injury, but who 

are also not totally disabled for all gainful employment.

Medical Evaluations
 

Page 12 GAO-13-386 Federal Employees’ Compensation Act 

Our review identified 2 out of our sample of 32 FECA claimants who did 

not have evidence in their FECA file that OWCP reviewed their 

employment activity annually, as required.16

Labor and IGs from employing departments and agencies have 

consistently reported similar FECA program-management challenges and 

have linked increased program costs to improper payments. For example, 

Labor’s oversight of the FECA program has been identified as a 

management challenge in prior work.

These two claimants 

continued to improperly receive higher FECA compensation benefits than 

warranted during our period of review because a timely adjustment was 

not made to their disability compensation. In addition, one claimant failed 

to submit the income certification, and OWCP did not promptly terminate 

benefits.

17 As we previously reported, 

beginning with its 2004 Performance and Accountability Report, and 

every year since, Labor has indicated that adequately overseeing the 

FECA program was one of its chief management challenges, citing 

verifying beneficiaries’ eligibility as one of the oversight difficulties that it 

faces.18

According to Labor officials, OWCP has recently taken steps to address 

oversight issues. For example, in response to recommendations we made 

in 2007, OWCP has implemented a Periodic Entitlement Review (PER) 

application that alerts CEs when medical evidence and annual income 

certifications need to be reviewed. The PER application has helped CEs 

identify individuals who have return-to-work potential so that they can be 

referred to vocational rehabilitation for additional assistance. In addition, 

in 2012 OWCP instituted two new PER timeliness reviews as part of its 

Moreover, IGs from employing agencies that participate in FECA 

have reported that certain policies and procedures did not exist, or when 

they did exist, they were not always followed by employing agencies.

Most often these deficiencies were related to a lack of controls that would 

have enabled staff to verify beneficiaries’ continued eligibility.

 

16All cases on the periodic roll require completion of Forms CA-1032 and SSA-581 on a 

yearly basis.

17For example, see U.S. Department of Labor, Office of Inspector General–Office of Audit, 

Mechanisms Used to Identify Changes in Eligibility Are Inadequate at the FECA District 

Office in Jacksonville, Florida. 

18GAO, Federal Employees’ Compensation Act: Status of Previously Identified 

Management Challenges, GAO-12-508R (Washington, D.C.: Mar. 21, 2012).

Income Certifications
 

Page 13 GAO-13-386 Federal Employees’ Compensation Act 

performance measures.19 Finally, OWCP officials stated that they are in 

the process of establishing quality-assurance reviews of PER processing.

As such, Labor will convene Accountability Review teams of program 

specialists to evaluate the quality of workload processing in its district 

operations. These evaluations are to scrutinize processed work, such as 

elements relating to fiscal and operational integrity. Accountability Review 

findings are to be reviewed by the relevant OWCP program director and 

corrective action plans will be developed, as necessary. In addition, 

according to OWCP officials, two new Quality Measures have been 

implemented in fiscal year 2013 to rate the accuracy of compensation 

benefit payments, and whether the factual and medical evidence of 

record supports the current level of benefits provided. According to Labor 

officials, OWCP plans to start conducting these reviews by the end of 

fiscal year 2013. In 2012, we reported that periodic reviews of FECA case 

files are a promising practice and can be used to help increase program 

officials’ awareness of potential fraudulent activities.20 Further, these 

controls are consistent with the detection and monitoring component of 

GAO’s fraud-prevention framework,21 and could help to validate 

claimants’ eligibility including medical conditions and income information. 

If implemented properly, these steps will assist OWCP in identifying 

cases for return-to-work potential and referral to vocational rehabilitation. 

In addition, verification of proper and accurate benefit levels will also 

support FECA program fiscal integrity.

 

19The first of the two PER measures indicates whether an initial review is completed within 

60 days and results in either: (1) closure without need for further development, or (2) 

designation for further development. The second measure ensures that actions on cases 

that could not be closed within 60 days (i.e., those requiring further development) are 

completed and the PER is closed within 180 days of PER creation.

20GAO-12-402. 

21GAO, Hurricanes Katrina and Rita Disaster Relief: Prevention Is the Key to Minimizing 

Fraud, Waste, and Abuse in Recovery Efforts, GAO-07-418T (Washington, D.C.: Jan. 29, 

2007).
 

Page 14 GAO-13-386 Federal Employees’ Compensation Act 

As we have previously reported, because Labor does not have statutory 

authority to directly access private or public wage data that is reported to 

SSA and the Department of Health and Human Services’ (HHS) National 

Directory of New Hires (NDNH) database,22 OWCP relies heavily on 

claimants’ self-reporting of earnings on the annual Form CA-1032 to 

identify potential fraud.23

Our review of a nongeneralizable sample of 32 individual cases identified 

eight FECA claimants who had significantly underreported employment 

wages in comparison to the wages reported in the state’s QW reports for 

the same period.

For example, while OWCP requests that FECA 

claimants provide it with consent to access their SSA earnings file, 

claimants are not required to provide OWCP with consent, and 

authorization to obtain such information is not required to receive 

compensation.

24 We also found that three claimants did not provide 

authorization to OWCP to access their SSA earnings file.25

Our January 2012 report identified self-reported data as a potential 

vulnerability within the FECA program.26

 

22NDNH is a national directory of employment information that contains, among other 

data, QW data on individual employees from records of state workforce agencies and 

federal agencies and is maintained by HHS.

For example, individuals who are 

working can self-certify that they have no other income, and continue to 

remain in the program, as their statements are not verified. Moreover, 

Labor has no access to state data or HHS’s NDNH data to determine if a 

claimant is receiving wages, which we have also previously identified as a 

potential vulnerability that could increase the risk of claimants receiving 

benefits they are not entitled to. In 2008, we recommended that Labor 

develop a proposal seeking legislative authority to enter into a datamatching agreement with HHS to identify FECA claimants who have 

earnings reported in NDNH, which provides more timely information than 

23GAO-12-402. 

24We considered claimants to significantly underreport their incomes if they received more 

than $10,000 in annual earnings than what was reported to Labor and the percentage 

difference between actual income and what was reported to Labor was at least 25 

percent.

25Of the 29 recipients that did provide consent, six files had documentation in their FECA 

file indicating that Labor received earnings information from SSA.

26GAO-12-402. 

Labor Lacks Authority to 

Directly Access Wage 

Data, Which Limits Its 

Ability to Identify 

Improper Payments and 

Potential Fraud
 

Page 15 GAO-13-386 Federal Employees’ Compensation Act 

the SSA.27

Labor has also proposed legislative reforms to FECA that would enhance 

its ability to assist FECA beneficiaries and also enhance program 

oversight. As part of this reform, OWCP sought authority to match SSA 

wage data directly with FECA files. According to Labor OIG officials, to 

enhance its FECA program oversight, Labor OIG has also requested 

changes to legislation that would allow Labor to easily and expeditiously 

access NDNH wage records, so that its investigations can be more 

efficient and effective. However, at this time, Labor does not have direct 

access to the NDNH or SSA wage data. Having access to these data 

sources would allow Labor to verify claimants’ self-reported employment 

income and better position the agency to identify potential fraud.

In response to our recommendation, OWCP officials stated 

that they studied whether to use NDNH and communicated with HHS, but 

determined that this would not be an effective solution because of cost 

issues, limited participation by employers in NDNH, and the likelihood that 

unreported earnings would not be listed. For example, OWCP officials 

stated that it would cost about $1 million to implement an automated 

process for verifying wage information with NDNH. To help address the 

issue, OWCP officials reported ongoing negotiations over several years 

with SSA to develop a formal agreement that includes regular data 

matching to verify wage data so that Labor does not have to rely on 

obtaining consent to access SSA wage data from the claimant. A current 

agreement is being developed, though officials stated that these 

negotiations were still in the early stages.

 

27GAO, Federal Workers’ Compensation: Better Data and Management Strategies Would

Strengthen Efforts to Prevent and Address Improper Payments, GAO-08-284

(Washington, D.C.: Feb. 26, 2008).
 

Page 16 GAO-13-386 Federal Employees’ Compensation Act 

Because of case law and regulatory requirements, once OWCP

calculates an individual’s WEC, it remains in place unless the evidence 

establishes that there is a material change in the nature and extent of the 

injury-related condition; the claimant has been retrained, or otherwise 

vocationally rehabilitated; or it is established that OWCP’s original 

determination was erroneous.28 As a result, claimants could be earning

more money than they were originally determined capable of earning but 

never have the WEC adjusted to account for the increase in wage earning 

capacity. According to program procedures, OWCP can modify the WEC 

if the claimant is earning 25 percent more than the current pay of the job 

for which the beneficiary was originally rated. However, to adjust the 

WEC, OWCP must demonstrate that customary criteria for modification is 

met such as the claimant is rehabilitated or self-rehabilitated, or evidence 

shows that the claimant was retrained for a different job. Of the 32 cases 

we reviewed, we found five instances where an individual’s WEC was not 

adjusted even though the individual earned substantially more (at least 25 

percent) than what was originally calculated as their WEC.29 While this 

situation is allowable under FECA program requirements, it could be an 

indicator of potential waste in the FECA program.

 

28An individual’s WEC forms the basis for payment of compensation for partial disability. 

29According to Labor, three of the five cases did not meet the requirements for 

rehabilitation and therefore no adjustments were required to the WEC; in two of the cases, 

Labor stated that adjustment to the WEC may have been warranted. 

Some FECA Program 

Regulations and Policies 

Introduce Challenges to 

Identifying and Mitigating 

Potential Fraud and Waste

FECA Program Requirements 

Allow Claimants to Receive 

Earnings and Earnings 

Increases without Necessarily 

Resulting in Adjustment of 

FECA Compensation
 

Page 17 GAO-13-386 Federal Employees’ Compensation Act 

In addition, two FECA total-disability claimants continued to receive 

private-employment salaries that were not subject to the WEC. Earnings 

received from dissimilar private employment at the time of injury may not 

be used by Labor when determining an injured employee’s pay rate for 

compensation purposes, and earnings from that same employment 

cannot be considered in determining the employee’s WEC.30 Thus, 

claimants are allowed to receive income, in some cases substantial 

income, while also receiving FECA compensation benefits.

The FECA program statute31 allows claimants to select their own 

physician, which we reported in 2012 to be a potential vulnerability.32

 

30See, for example, In the Matter of Burnett Terry and U.S. Postal Service, 46 E.C.A.B. 

457 (1995). The Employees’ Compensation Appeals Board (ECAB) is an adjudicative 

body that hears appeals from FECA determinations by the Labor Department.

The 

regulation also requires examination by a physician employed or selected 

by the government only when a second opinion is deemed necessary by 

the government. As a result, as we previously reported, essential 

processes within the FECA program could be operating without a review 

conducted by a physician selected by the government. This potential 

vulnerability affects key control processes outlined in GAO’s fraudprevention framework in two areas: first, the lack of reviews when 

assessing validity of initial claims, and second, the lack of the same when 

monitoring the duration of the injury. Out of the 32 individual cases that 

we reviewed, 12 did not have a second opinion from a medical 

professional assessing the injury and possible work restrictions, and a 

physician selected by the government was not involved in making the 

disability determination. Without a second opinion, the federal 

government must rely on the physician of the claimant’s choosing, which 

is a potential vulnerability in assessing the validity of the claim. 

315 U.S.C. § 8103(a).

32GAO-12-402. 

FECA Program Statute Allows 

Claimants to Choose Their 

Own Physicians
 

Page 18 GAO-13-386 Federal Employees’ Compensation Act 

While FECA claimants can be eligible to receive state UI benefits in 

addition to FECA benefits, Labor lacks a process to share the necessary 

data with states to determine whether FECA claimants may be improperly 

receiving overlapping benefits. Individuals may be eligible for both FECA 

and UI depending on the applicable state laws regarding UI eligibility, and 

federal law does not authorize an automatic reduction or potential 

elimination of benefits if a claimant receives both. For example, under 

FECA, an individual is encouraged to return to work. Upon returning to 

work, the individual’s FECA compensation payment is supposed to be 

reduced or terminated. In certain circumstances these individuals may 

have returned to the workforce, for example, with partial disability, and 

subsequently been involuntarily terminated. These individuals may also 

meet the states’ “able and available for work” criteria and thus also be 

eligible for UI benefits. As a result, some individuals may have a disability 

under federal law but still be able and available for work under state law, 

and thus are eligible to receive concurrent UI and FECA benefits.

However, claimants may be not eligible to receive both types of payments 

because their disability, especially for those receiving compensation for 

total disability, may render them unable and unavailable to work.

33 In 

February 2012, the Middle Class Tax Relief and Job Creation Act was 

enacted, which amended federal law and included a requirement that 

individuals claiming UI benefits be actively seeking work as a condition of 

some eligibility.34

 

33Temporary total disability is defined as the inability to return to the position held at the 

time of injury or earn equivalent wages, or perform other gainful employment, because of

the work-related injury. An individual who is partially disabled is not able to return to the 

position held at time of injury or earn equivalent wages, but is not totally disabled for all 

gainful employment. 

 In addition, certain states, for example four of the five 

selected states in our review, require the offset of UI benefits against 

certain workers’ compensation payments, including FECA.

34 Section 2101 of Pub. L. No. 112-96 (Feb. 22, 2012)

Labor Lacks a Process to 

Identify Overlapping FECA 

and UI Benefits and Does 

Not Report FECA Claimant 

Information to States

Overlapping Benefits 
 

Page 19 GAO-13-386 Federal Employees’ Compensation Act 

Labor officials acknowledged that they do not have a process to share the 

necessary data to identify overlapping payments, which would help the 

ETA and the states identify the extent to which overlapping payments are 

not being offset. As previously reported, we have found that processes 

that rely heavily on self-reported data by claimants create potential 

vulnerabilities within the program. Without the ability to verify self-reported 

information on the receipt of other benefits, Labor may make overlapping 

payments contrary to the regulations governing the program.

Our review of a nongeneralizable sample of 19 individual cases identified 

claimants who received overlapping UI and FECA benefits totaling over 

$1.3 million from January 2008 to June 2012. Four claimants who resided 

in states that require UI payments to be offset received more income from 

the combined UI and FECA benefits than they would have received from 

their federal salary alone. Some of these claimants were former FECA 

claimants who attempted to return to the federal agency to perform work 

within their medical restrictions. However, the claimants were 

subsequently discharged because they did not meet the federal agency 

requirements for continuing employment. As such, these claimants were 

entitled to their FECA benefits and they also applied for and received UI 

benefits that were not offset by their respective states.

According to OWCP officials, Labor does not systematically report 

information on claimants receiving FECA benefits to states, which would 

help states identify overlapping FECA and UI payments as well as UI 

payments that might need to be offset. Currently, states must rely on 

obtaining this information either directly from the UI applicant or UI 

applicant’s recent employers.35

Labor is not required to and thus does not report FECA payments to 

NDNH, which is a primary mechanism that some states use to verify 

employee wage levels, because NDNH was established as a depository 

As previously discussed, certain states 

use the workers’ compensation amount, such as FECA, to reduce or 

eliminate the UI benefit amount. States utilize this information to 

determine whether the individual is actually “able and available for work.” 

As such, all states must require claimants to certify that they are still 

meeting all UI eligibility criteria such as changes in employment status. 

 

35Four of the five selected states require that applicants report workers’ compensation 

payments, such as FECA, on their UI applications. 
 

Page 20 GAO-13-386 Federal Employees’ Compensation Act 

for wage reporting that, among other things, enables state child-support 

agencies to be more effective in enforcing child-support orders. Were 

Labor to report FECA payments to this database, states would more 

easily be able to identify such payments in their review. Our review of a 

nongeneralizable sample of 19 individual cases identified nine claimants 

who potentially committed fraud or improperly obtained UI benefits 

because they did not properly disclose their FECA benefits to the state on 

their UI application, which could have potentially reduced or eliminated 

the UI benefit amount.36

As previously discussed, limited access to necessary information is a 

potential vulnerability. Without information on individuals who are 

receiving federal workers’ compensation payments, it is difficult for the 

states to identify those individuals and reduce or terminate the UI 

payments to them. As a promising practice we previously reported, Labor 

provides quarterly data extracts to employing agencies on wagecompensation payments, medical billing payments, and casemanagement data. Similarly, if OWCP reported FECA compensation data

to the states (either directly or through NDNH), this could help federal and 

state agencies coordinate benefits and reduce the risk of overlapping 

payments.

We have previously reported on the importance of interagency 

collaborative mechanisms, such as sharing information across 

organizational boundaries, to achieve crosscutting program goals.37

Further, although not a requirement, the value of greater information 

sharing between federal and state entities is demonstrated by the actions 

of some states that check the NDNH to determine if an applicant is 

working.38

 

36California could not provide the UI application for five applicants because the records 

had been purged under the state’s legal-record retention policy. Five of the 19 applicants 

did disclose the workers’ compensation on the UI application (although one claimant who 

did receive workers’ compensation subsequently stated that he did not). 

For example, by cross-matching UI claims against NDNH data, 

states can better detect overpayments to UI claimants who have gone 

back to work. While our sample of individuals who have received 

37GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012). 

38NDNH contains UI and wage data from state directories of new hires, state workforce 

agencies, and federal agencies.
 

Page 21 GAO-13-386 Federal Employees’ Compensation Act 

overlapping FECA and UI benefits cannot be generalized to the entire 

population of FECA claimants, we did identify some claimants who 

potentially committed fraud or improperly obtained UI benefits because 

they did not properly disclose their FECA benefits to the state on their UI 

application. Thus, establishing a mechanism to share FECA 

compensation information with states to help identify whether claimants 

are inappropriately receiving overlapping UI and FECA payments, to the 

extent that it is cost-effective, could help provide ETA with greater 

assurance that individuals are receiving benefits in accordance with 

statute. We discussed this proposal with OWCP program officials in 

January 2013 and they agreed that sharing compensation data with the 

states may be beneficial, although they stated that they have never been 

asked to provide FECA compensation information previously.

With estimated future actuarial liabilities for government-wide FECA 

compensation payments at over $34 billion as of fiscal year 2012, and in 

an era of scarce government resources, it is vital that Labor ensures 

effective stewardship of those resources. FECA and UI provide an 

important safety net for workers who have lost their income because of 

workplace injuries or unemployment. However, Labor and the states must 

continually monitor these claimants to ensure that they continue to be 

entitled to these benefits and that the benefits are adjusted to account for 

changes in claimants’ wage earnings and for overlapping state UI 

payments. While in certain circumstances receiving concurrent UI and 

FECA benefits may be allowable, the cases we identified where claimants 

received concurrent UI and FECA benefits without Labor’s knowledge 

could be an indicator of improper payments. A cost-effective mechanism 

to share FECA compensation information with states to help identify 

whether claimants are inappropriately receiving overlapping UI and FECA 

payments could help determine the extent that improper payments or 

potential fraud are occurring, which could help save taxpayer dollars. In 

addition, without the authority to access wage data, which both OWCP 

and Labor’s OIG have sought, Labor’s reliance on claimants’ self-reported 

employment information limits the agency’s ability to identify potential 

fraud.

Congress should consider granting Labor the additional authority it is 

seeking to access wage data to help verify claimants’ reported income 

and help ensure the proper payment of benefits.

Conclusions

Matter for 

Congressional 

Consideration
 

Page 22 GAO-13-386 Federal Employees’ Compensation Act 

We recommend that the Secretary of Labor assess the feasibility of 

developing a cost-effective mechanism to share FECA compensation 

information with states, such as reporting information to NDNH, to help 

identify whether claimants are inappropriately receiving overlapping UI 

and FECA payments.

We provided a draft of this report to Labor for comment on February 28, 

2013. Labor provided written comments on the draft, which can be found 

in appendix I. Labor agreed with the recommendation to assess the 

feasibility of developing a cost-effective mechanism to share FECA 

compensation information with the states, such as reporting information to 

NDNH, to help identify whether claimants are inappropriately receiving 

overlapping UI and FECA payments. Labor stated that it will undertake a 

review to determine whether such data sharing and reporting is feasible. 

However, Labor expressed concerns regarding the cost-effectiveness of 

such an approach. We agree that it will be important for Labor to assess 

the cost-effectiveness of such an approach when conducting its review. 

As stated in the report, some states check the NDNH database to verify 

employee wage levels. Thus, establishing a mechanism, such as 

reporting FECA compensation to NDNH, could provide a cost-effective 

way for states to identify whether claimants are inappropriately receiving 

overlapping UI and FECA payments, and could help provide ETA with 

greater assurance that individuals are receiving benefits in accordance 

with statute. 

In its response, Labor also stated that since FECA contains no offset for 

UI benefits, a claimant may be entitled to receive both FECA and UI 

benefits under a particular state law, which would not be classified as 

receiving improper payments. We recognize, as stated in this report, that 

there may be certain situations where individuals are entitled to the 

concurrent receipt of FECA and UI benefits. However, it is also important 

to note that, as discussed in the report, claimants may not be eligible to 

receive both types of payments in some cases. For example, some 

claimants are not able to meet the “able and available” requirement for UI 

benefits because their disability, especially for those receiving 

compensation for total disability, may render them unable and unavailable 

to work. In addition, certain states, such as four of the five selected states 

in our review, require the offset of UI benefits against certain workers’ 

compensation payments, including FECA. In addition, Labor stated that 

one of our examples cited in our report—example 5—should not be 

classified as an improper payment because FECA program procedures 

allow a claimant to receive wages from two different employers and not 

have those wages affect the claimant’s WEC or ability to receive FECA 

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 23 GAO-13-386 Federal Employees’ Compensation Act 

benefits. We agree that this is not an improper payment and did not 

classify it as such. As stated in the report, claimants are allowed to 

receive such income, in some cases substantial income, while also 

receiving FECA compensation benefits. 

Labor also provided technical comments, which we incorporated as 

appropriate.

As agreed with your offices, 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 of this report to the 

Secretary of Labor, 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 has questions about this report, please contact me at 

202-512-4379 or LordS@gao.gov. Contact points for our Offices of 

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

of this report.

Stephen M. Lord

Director, Forensic Audits and Investigative Service
Appendix I: Comments from the Department of 

Labor

Page 24 GAO-13-386 Federal Employees’ Compensation Act 

Appendix I: Comments from the Department

of Labor
Appendix I: Comments from the Department of 

Labor

Page 25 GAO-13-386 Federal Employees’ Compensation Act (192382)
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