IMPROPER 

PAYMENTS

Additional Guidance 

Needed to Improve 

Oversight of Agencies 

with Noncompliant 

Programs

Report to Congressional Committees

December 2018

GAO-19-14

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-19-14, a report to 

congressional committees 

December 2018

IMPROPER PAYMENTS

Additional Guidance Needed to Improve Oversight of 

Agencies with Noncompliant Programs

What GAO Found

Over half of the 24 Chief Financial Officers Act of 1990 (CFO Act) agencies

were reported by their inspectors general (IG) as noncompliant with one or more 

criteria under the Improper Payments Elimination and Recovery Act of 2010 

(IPERA) for fiscal years 2016 and 2017. Nine CFO Act agencies have been 

reported as noncompliant in one or more programs every year since the 

implementation of IPERA in fiscal year 2011, totaling 7 consecutive years of 

noncompliance. 

Number of Chief Financial Officers Act Agencies Compliant under IPERA, as Reported or 

Acknowledged by Their Inspectors General

a

For fiscal year 2013, one inspector general did not issue a compliance report because the agency 

did not publish improper payment information.

The IGs of the 14 noncompliant agencies reported that a total of 58 programs 

were responsible for the identified instances of noncompliance in fiscal year 

2017. Further, 18 of the 58 programs at 9 agencies were reported as 

noncompliant for 3 or more consecutive years. Fourteen of these 18 programs

accounted for an estimated $74.4 billion of the $141 billion total estimated

improper payments for fiscal year 2017; the other 4 programs did not report 

improper payment estimates. This sum may include estimates that are of 

unknown reliability. The $74.4 billion is primarily composed of estimates 

reported for two noncompliant programs, the Department of Health and Human 

Services’ Medicaid program and the Department of the Treasury’s (Treasury)

Earned Income Tax Credit program; estimated improper payments for these two 

programs are also a central part of certain high-risk areas in GAO’s 2017 HighRisk List.

Agencies with any program reported as noncompliant for 3 or more consecutive 

years are required to notify Congress of their program’s consecutive 

noncompliance and submit a proposal for reauthorization or statutory change to 

bring that program into compliance. GAO found that three agencies with one or 

more programs reported as noncompliant for 3 or more consecutive years, as of 

fiscal year 2016, did not notify Congress or submit the required proposals. The 

Departments of Labor and the Treasury submitted proposed legislative changes 

in response to their programs being previously reported as noncompliant, but 

did not notify Congress of the programs’ continued noncompliance as of fiscal 

year 2016. The U.S. Department of Agriculture (USDA) has not notified 

Congress despite prior GAO and USDA IG recommendations to do so. To 

address these issues, in June 2018 the Office of Management and Budget

Why GAO Did This Study

Government-wide estimated improper 

payments totaled almost $1.4 trillion 

from fiscal year 2003 through fiscal 

year 2017. IPERA requires IGs to 

annually assess and report on whether 

executive branch agencies complied 

with the six criteria to (1) publish an 

agency financial report or performance 

accountability report, (2) conduct 

program-specific improper payment risk 

assessments, (3) publish improper 

payment estimates, (4) publish 

corrective action plans, (5) publish and 

meet annual improper payment 

reduction targets, and (6) report a gross 

improper payment rate of less than 10 

percent.

This report examines the extent to 

which

1. CFO Act agencies complied with 

IPERA criteria for fiscal years 2016 

and 2017, and the trends evident 

since 2011, as reported by their 

IGs; 

2. CFO Act agencies addressed

requirements for programs reported 

as noncompliant with IPERA 

criteria for 3 or more consecutive 

years, as of fiscal year 2016, and 

communicated their strategies to 

Congress for reducing improper 

payments and achieving 

compliance; and 

3. OMB made determinations 

regarding whether additional 

funding would help CFO Act 

agency programs reported as 

noncompliant with IPERA criteria 

for 2 consecutive years, as of fiscal 

years 2016 and 2017, come into 

compliance. 
United States Government Accountability Office

(OMB) updated its guidance to clarify the notification requirements for each 

consecutive year a program is reported as noncompliant.

GAO found that five agencies did notify Congress as required, and included 

additional quality information that is not specifically required, but could be useful in 

updating Congress on their compliance efforts. For example, all five agencies 

provided information on the root causes, risks, changes, or issues affecting their 

efforts and corrective actions or strategies to address them; three agencies provided 

other quality information on accountability mechanisms, designated senior officials, 

and measurable milestones.

Additional Information Included in Notifications to Congress by Five Agencies with Programs 

Reported by Their Inspectors General as Noncompliant under the Improper Payments 

Elimination and Recovery Act of 2010 for 3 or More Consecutive Years, as of Fiscal Year 2016

Agency

Additional information included 

Root 

causes

Risks/ 

issues/ 

changes

Corrective 

actions/

strategies

Measurable 

milestones

Designated 

senior 

officials

Accountability 

mechanisms

Dept. of 

Defense Yes Yes Yes Yes Yes Yes

Dept. of 

Education Yes Yes Yes Yes Yes Yes

Dept. of 

Health Human 

Services Yes Yes Yes No No No

Dept. of 

Homeland

Security Yes Yes Yes Yes Yes Yes

Social Security 

Administration Yes Yes Yes No No No

Total 5 5 5 3 3 3

Source: GAO analysis of Chief Financial Officers Act of 1990 agencies’ notifications to Congress for programs with 3 or more 

consecutive years of noncompliance with the Improper Payments Elimination and Recovery Act of 2010 as of fiscal year 2016. | GAO19-14

In June 2018, OMB updated its guidance to clarify agency reporting requirements for 

programs reported as noncompliant for 3 or more consecutive years. However, the 

updated guidance does not direct agencies to include the types of quality information 

included in these five agencies’ notifications for fiscal year 2016. GAO’s Standards 

for Internal Control in the Federal Government emphasizes the importance of 

communicating quality information, such as significant matters affecting agencies’ 

efforts to achieve compliance objectives. Such information could be useful in 

understanding the current challenges of these programs and is essential for 

assessing agency efforts to address high-risk and other issues. As a result, Congress 

could have more complete information to effectively oversee agency efforts to 

address program noncompliance for 3 or more consecutive years.

When programs are reported as noncompliant for 2 consecutive years, IPERA gives

OMB authority to determine whether additional funding is needed to help resolve the 

noncompliance. In April 2018, OMB staff stated that they determined that no 

additional funding was needed for the 15 programs that were reported as 

noncompliant for 2 consecutive years, as of fiscal year 2016, and that they primarily 

rely on the IGs’ recommendations in their annual IPERA compliance reports when 

making funding determinations. OMB staff subsequently stated that they no longer 

need to conduct a detailed review of the IGs’ IPERA compliance reports to identify 

recommendations related to additional funding needs. Instead, OMB updated its 

guidance in June 2018 to direct agencies to submit proposals to OMB regarding 

additional funding needs to help address IPERA noncompliance and clarified that the

funding determination process will unfold as part of the annual development of the 

President’s Budget. As of September 2018, OMB was in the process of making 

funding determinations for 12 programs that were reported as noncompliant as of 

fiscal year 2017 and stated that any determinations made would be developed in the 

President’s Budget for fiscal year 2020. 

GAO analyzed the IGs’ fiscal years 

2016 and 2017 IPERA compliance 

reports; reviewed prior GAO reports on 

agencies’ IPERA compliance; 

reviewed agency information submitted 

to Congress; and made inquiries to 

OMB, applicable agencies, and IGs; 

and assessed such information based 

on relevant IPERA provisions and 

OMB and other guidance.

What GAO Recommends

GAO recommends that OMB update 

its guidance to specify other types of 

quality information that agencies with 

programs noncompliant for 3 or more 

consecutive years should include in 

their notifications to Congress, such as 

significant matters related to risks, 

issues, root causes, measurable 

milestones, designated senior officials, 

accountability mechanisms, and 

corrective actions or strategies 

planned or taken by agencies to 

achieve compliance.

GAO provided a draft of this report to 

OMB and requested comments, and 

OMB said that it had no comments. 

GAO also provided a draft of this 

report to the 24 CFO Act agencies and 

their IGs and requested comments. In 

its written comments, the Social 

Security Administration (SSA) stated 

that it provided information on 

measurable milestones, designated 

senior officials, and accountability 

mechanisms in its agency financial 

report. However, SSA did not provide 

this information in its notifications to 

Congress for programs reported as 

noncompliant under IPERA as of fiscal 

year 2016. GAO believes that OMB 

should take steps to update OMB’s 

guidance to help ensure that agencies 

report such significant information and 

include it in their notifications to 

Congress. In addition, several 

agencies and IGs provided technical 

comments, which were incorporated in 

the report as appropriate.

View GAO-19-14. For more information, 

contact Beryl H. Davis at (202) 512-2623 or 

davisbh@gao.gov. 
Page i GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Letter 1

Background 4

Over Half of the CFO Act Agencies Were Reported as 

Noncompliant under IPERA for Fiscal Years 2016 and 2017, 

and Consecutive Years of Noncompliance Continue for Certain 

Programs 10

CFO Act Agencies Did Not Always Notify Congress, and They 

Provided Varying Information on Programs Reported as 

Noncompliant for 3 or More Consecutive Years 17

OMB Updated Guidance for Determining Additional Funding 

Needs for Programs Reported as Noncompliant for 2 

Consecutive Years 23

Conclusions 27

Recommendation for Executive Action 27

Agency Comments and Our Evaluation 27

Appendix I Objectives, Scope, and Methodology 29

Appendix II CFO Act Agencies’ Overall IPERA Compliance 

for Fiscal Years 2011 through 2017, as Reported 

or Acknowledged by Their IGs 33

Appendix III CFO Act Agencies and Programs Reported 

as Noncompliant with IPERA for Fiscal Years 

2016 and 2017 35

Appendix IV CFO Act Agencies with Programs Reported 

by Their IGs as Noncompliant for 2 or More 

Consecutive Years, as of Fiscal Years 

2016 and 2017 44

Contents
Page ii GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Appendix V Comments from the Department of Homeland 

Security Office of Inspector General 46

Appendix VI Comments from the Social Security Administration 47

Appendix VII Comments from the United States Agency 

for International Development 48

Appendix VIII GAO Contact and Staff Acknowledgments 49

Tables

Table 1: Overview of OMB and Agency Requirements for Agency 

Programs Not in Compliance under IPERA as Reported 

by Their IGs 8

Table 2: Fiscal Year 2017 Reported Improper Payment Estimates 

for 18 Programs Reported as Noncompliant under IPERA 

for 3 or More Consecutive Years 15

Table 3: Additional Information Included in Notifications to 

Congress by Five Agencies with Programs Reported as 

Noncompliant under the Improper Payments Elimination 

and Recovery Act of 2010 for 3 or More Consecutive 

Years, as of Fiscal Year 2016 22

Table 4: CFO Act Agency Programs Reported as Noncompliant 

for 2 Consecutive Years by Their IGs and Noncompliance 

Determinations for Each IPERA Criterion, as of Fiscal 

Year 2017 24

Table 5: CFO Act Agency Programs That IGs Reported as 

Noncompliant with IPERA Criteria for Fiscal Year 2016 35

Table 6: CFO Act Agency Programs That IGs Reported as 

Noncompliant with IPERA Criteria for Fiscal Year 2017 39

Table 7: CFO Act Agencies and Programs Reported or 

Acknowledged by Their IGs as Noncompliant for 2 or 

More Consecutive Years, as of Fiscal Years 2016 and 

2017 44
Page iii GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Figures

Figure 1: Number of CFO Act Agencies Compliant under IPERA 

for Fiscal Years 2011 through 2017, as Reported or 

Acknowledged by Their Inspectors General 11

Figure 2: Total Instances of CFO Act Agencies’ Noncompliance 

with IPERA Criteria, for Fiscal Years 2011 through 2017, 

as Reported or Acknowledged by Their Inspectors 

General 12

Figure 3: Number of CFO Act Agency Programs Noncompliant 

under IPERA for 3 or More Consecutive Years, for Fiscal 

Years 2015 through 2017, as Reported or Acknowledged 

by Their IGs 14

Figure 4: CFO Act Agencies’ Overall IPERA Compliance for Fiscal 

Years 2011 through 2017, as Reported or Acknowledged 

by Their IGs 34
Page iv GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Abbreviations

AFR agency financial report 

CFO Chief Financial Officer

CFO Act Chief Financial Officers Act of 1990

DHS Department of Homeland Security 

DOD Department of Defense 

DOL Department of Labor 

Education Department of Education 

EITC Earned Income Tax Credit 

FNS Food and Nutrition Service 

Ginnie Mae Government National Mortgage Association

HHS Department of Health and Human Services 

IG inspector general 

IPERA Improper Payments Elimination and Recovery Act of 2010 

IPERIA Improper Payments Elimination and Recovery 

Improvement Act of 2012 

IPIA Improper Payments Information Act of 2002 

IRS Internal Revenue Service 

OIG Office of Inspector General 

OMB Office of Management and Budget 

PAR performance and accountability report 

SSA Social Security Administration 

Treasury Department of the Treasury 

USDA U.S. Department of Agriculture

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Page 1 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

441 G St. N.W.

Washington, DC 20548

December 7, 2018

The Honorable Ron Johnson

Chairman

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Trey Gowdy

Chairman

The Honorable Elijah Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

Improper payments—payments that should not have been made or were 

made in incorrect amounts—have been estimated to total almost 

$1.4 trillion government-wide from fiscal years 2003 through 2017.1

Estimates of total improper payments have increased over the years—

from $35 billion for 27 programs in fiscal year 2003 to approximately 

$141 billion for 90 programs in fiscal year 2017. It is important to note that 

these estimates themselves may not be accurate, reliable, or complete, 

because, as we have reported, the federal government is unable to 

determine the full extent to which improper payments occur and 

reasonably assure that appropriate actions are taken to reduce them.2 In 

addition, certain inspectors general (IG) have reported issues with their 

 1

As required by the Improper Payments Information Act of 2002, Pub. L. No. 107-300, 116 

Stat. 2350 (Nov. 26, 2002), codified as amended at 31 U.S.C. § 3321 note, certain 

agencies were required to start reporting improper payment estimates beginning for fiscal 

year 2003. An improper payment is defined as any payment that should not have been 

made or that was made in an incorrect amount (including overpayments and 

underpayments) under statutory, contractual, administrative, or other legally applicable 

requirements. It includes any payment to an ineligible recipient, any payment for an 

ineligible good or service, any duplicate payment, any payment for a good or service not 

received (except for such payments where authorized by law), and any payment that does 

not account for credit for applicable discounts. Office of Management and Budget 

guidance also instructs agencies to report as improper payments any payments for which 

insufficient or no documentation was found. It is important to note that improper payment 

totals are estimated and may or may not represent a loss to the government. 

2

GAO, Financial Audit: Fiscal Years 2017 and 2016 Consolidated Financial Statements of 

the U.S. Government, GAO-18-316R (Washington, D.C.: Feb. 15, 2018). 

Letter
Page 2 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

agencies’ reported improper payment estimates that were caused by 

insufficient sampling methods and flawed estimation methodologies for 

calculating and reporting improper payment estimates.

Fiscal year 2017 marked the seventh year of the implementation of the 

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

which, among other things, requires federal agencies’ IGs to annually 

assess and report on whether the agencies under their jurisdiction have 

complied with six IPERA criteria.3 The IGs’ annual IPERA compliance 

reports serve a key function to reasonably assure that improper payment 

estimates are accurate, reliable, and complete and that Congress has 

information on agencies’ efforts to address improper payments. We 

previously reported on agencies’ IPERA compliance for fiscal years 2011 

through 2015, as reported by the IGs.

4

We performed our work under the authority of the Comptroller General to 

conduct evaluations on his own initiative and to assist Congress with its 

oversight responsibilities.5 We conducted this audit to summarize and 

evaluate agency compliance under IPERA for fiscal years 2016 and 2017, 

as reported by their IGs.6 Specifically, this report discusses the extent to 

which (1) agencies listed in the Chief Financial Officers Act of 1990, as 

amended,7 (CFO Act) complied with the six criteria listed in IPERA for 

fiscal years 2016 and 2017, and the trends evident since fiscal year 2011, 

as reported by their IGs; (2) CFO Act agencies addressed the 

requirements for programs and activities reported as noncompliant with 

IPERA criteria for 3 or more consecutive years, as of fiscal year 2016, 

 3

IGs are required to issue compliance reports as indicated in IPERA, Pub. L. No. 111-204, 

§ 3, 124 Stat. 2224, 2232 (July 22, 2010), codified at 31 U.S.C. § 3321 note. 

4

GAO, Improper Payments: CFO Act Agencies Need to Improve Efforts to Address 

Compliance Issues, GAO-16-554 (Washington, D.C.: June 30, 2016), and Improper 

Payments: Additional Guidance Could Provide More Consistent Compliance 

Determinations and Reporting by Inspectors General, GAO-17-484 (Washington, D.C.: 

May 31, 2017). 

5

31 U.S.C. § 717(b).

6

The IGs’ IPERA compliance reports for fiscal years 2016 and 2017 were due in May 2017 

and 2018, respectively.

7

The CFO Act, Pub. L. No. 101-576, 104 Stat. 2838 (Nov. 15, 1990), among other things, 

established chief financial officers to oversee financial management activities at 23 major 

executive departments and agencies. The list now includes 24 entities, which are often 

referred to collectively as CFO Act agencies, and is codified, as amended, in section 901 

of Title 31, United States Code. 
Page 3 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

and communicated their strategies to Congress for reducing improper 

payments and achieving compliance; and (3) the Office of Management 

and Budget (OMB) made determinations regarding whether additional 

funding would help CFO Act agency programs and activities reported as 

noncompliant with IPERA criteria for 2 consecutive years to come into 

compliance, as of fiscal years 2016 and 2017. We focused on the 24 

agencies listed in the CFO Act because estimates of their improper 

payments represent over 99 percent of the total reported estimated 

improper payments for fiscal years 2016 and 2017.

To determine the extent to which CFO Act agencies were reported as 

compliant with the six criteria listed in IPERA for fiscal years 2016 and 

2017, and trends evident since fiscal year 2011, we reviewed the IGs’ 

IPERA compliance reports issued for fiscal years 2016 and 2017 and 

identified trends in agencies’ compliance, and their respective programs’ 

and activities’ compliance, since fiscal year 2011 based on results 

summarized in our prior reports.8

To determine the extent to which CFO Act agencies addressed the 

requirements for programs and activities reported as noncompliant for 3 

or more consecutive years as of fiscal year 2016, we requested and 

reviewed the applicable agencies’ notifications to Congress provided by 

the respective agencies.9 In addition, we reviewed the content of 

agencies’ notifications to evaluate their efforts to communicate quality 

information to Congress, consistent with Principle 15 of Standards for 

Internal Control in the Federal Government, which emphasizes the need 

for an entity’s management to externally communicate the necessary, 

quality information—such as significant matters related to risks, changes, 

or issues concerning their strategies for achieving compliance.10 We did 

 8

GAO-16-554 and GAO-17-484. 

9

Under IPERA, when programs are reported as noncompliant for 3 or more consecutive 

years, the respective agencies are required to submit to Congress within 30 days of the 

IG’s report either (1) a reauthorization proposal for the program or (2) the proposed 

statutory changes necessary to bring the program or activity into compliance. GAO has 

previously recommended that agencies also notify Congress if they determine that such 

proposals are not necessary. We reviewed agency notifications submitted to Congress 

after the IGs’ fiscal year 2016 IPERA compliance results in May 2017 because the IGs’ 

reporting triggers the agency reporting requirements. 

10GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Page 4 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

not evaluate the sufficiency and completeness of the agency-provided 

information.

To determine the extent to which OMB made determinations regarding 

whether additional funding would help CFO Act agency programs and 

activities reported as noncompliant for 2 consecutive years come into 

compliance, as of fiscal years 2016 and 2017, we interviewed key OMB 

staff on their process for determining additional funding needs for 

noncompliant programs and activities and reviewed the applicable 

agencies’ IG compliance reports that OMB staff stated they relied on 

when making such determinations. Lastly, we corroborated our findings 

with OMB, the 24 CFO Act agencies, and their IGs. Appendix I provides 

additional information on our scope and methodology.

We conducted this performance audit from November 2017 to December 

2018 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.

In November 2002, Congress passed and the President signed the 

Improper Payments Information Act of 2002 (IPIA), which was later 

amended by IPERA and the Improper Payments Elimination and 

Recovery Improvement Act of 2012 (IPERIA).11 The amended legislation 

requires executive branch agencies to (1) review all programs and 

activities and identify those that may be susceptible to significant 

improper payments (commonly referred to as a risk assessment), 

(2) publish improper payment estimates for those programs and activities 

that the agency identified as being susceptible to significant improper 

payments, (3) implement corrective actions to reduce improper payments 

 11Pub. L. No. 112-248, 126 Stat. 2390 (Jan. 10, 2013). 

Background
Page 5 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

and set reduction targets, and (4) report on the results of addressing the 

foregoing requirements.12

In addition to the agencies’ identifying programs and activities that are 

susceptible to significant improper payments, OMB designates as high 

priority the programs with the most egregious cases of improper 

payments. Specifically, under a provision added to IPIA by IPERIA, OMB 

is required to annually identify a list of high-priority federal programs in 

need of greater oversight and review. In general, for fiscal years 2014 

through 2017, OMB implemented this requirement by designating highpriority programs based on a threshold of $750 million in estimated 

improper payments for a given fiscal year.13 OMB also plays a key role in 

implementing laws related to improper payment reporting. Specifically, 

OMB is directed by statute to provide guidance to federal agencies on 

estimating, reporting, reducing, and recovering improper payments.

IPERA also requires executive agencies’ IGs to annually determine and 

report on whether their respective agencies complied with certain IPERArelated criteria. If an agency does not meet one or more of the six IPERA 

criteria for any of its programs or activities, the agency is considered 

noncompliant overall. The six criteria are as follows:

1. publish a report in the form and content required by OMB—typically 

an agency financial report (AFR) or a performance and accountability 

report (PAR)—for the most recent fiscal year, and post that report on 

the agency website;

 12For fiscal year 2014 and beyond, “significant improper payments” are defined as gross 

annual improper payments in a program that may have exceeded either (1) 1.5 percent of 

program outlays and $10 million or (2) $100 million (regardless of the improper payment 

rate). Additionally, the Disaster Relief Appropriations Act, 2013, Pub. L. No. 113-2, div. A, 

§ 904(b), 127 Stat. 4, 17 (Jan. 29, 2013), required that all programs receiving funds 

appropriated by that act be deemed susceptible to significant improper payments, which 

consequently requires the agencies responsible for these programs to estimate improper 

payments, implement corrective actions, and report on their results for these programs. 

13Office of Management and Budget, Appendix C to Circular No. A-123, Requirements for 

Effective Estimation and Remediation of Improper Payments, OMB Memorandum M-15-

02 (Washington, D.C.: October 2014). OMB updated its guidance in June 2018, and 

effective for fiscal year 2018 reporting, the threshold for high-priority program 

determinations is increased to $2 billion in estimated improper payments. Office of 

Management and Budget, Appendix C to Circular No. A-123, Requirements for Payment 

Integrity Improvement, OMB Memorandum M-18-20 (Washington, D.C.: June 2018). 
Page 6 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

2. conduct a program-specific risk assessment, if required, for each 

program or activity that conforms with IPIA as amended;14

3. publish improper payment estimates for all programs and activities 

deemed susceptible to significant improper payments under the 

agency’s risk assessments;

4. publish corrective action plans for those programs and activities 

assessed to be at risk for significant improper payments;

5. publish and meet annual reduction targets for all programs and 

activities assessed to be at risk for significant improper payments; and

6. report a gross improper payment rate of less than 10 percent for 

each program and activity for which an improper payment estimate 

was published.

Under IPERA, agencies reported by their IG as not in compliance with 

any of these criteria in a fiscal year are required to submit a plan to 

Congress describing the actions they will take to come into compliance, 

and such plans shall include measureable milestones, the designation of 

senior accountable officials, and the establishment of accountability 

mechanisms to achieve compliance. OMB guidance states that agencies 

are required to submit these plans to Congress and OMB in the first year 

of reported noncompliance.15

When agency programs are reported as noncompliant for consecutive 

years, IPERA and OMB guidance requires agencies and OMB to take 

additional actions.16 Specifically, an agency with a program reported as 

noncompliant for 3 or more consecutive years is required to submit to 

Congress within 30 days of the IG’s report either (1) a reauthorization 

proposal for the program or (2) the proposed statutory changes 

 14IPIA requires that program and activity risk assessments be conducted at least once 

every 3 fiscal years.

15Office of Management and Budget, Appendix C to Circular No. A-123, Requirements for 

Effective Estimation and Remediation of Improper Payments, OMB Memorandum M-15-

02, and Office of Management and Budget, Appendix C to Circular No. A-123, 

Requirements for Payment Integrity Improvement, OMB Memorandum M-18-20. OMB M15-02 was effective for fiscal years 2016 and 2017 reporting, the years included in our 

audit. OMB M-15-02 was superseded by OMB M-18-20, which was issued June 26, 2018, 

and will be effective beginning with fiscal year 2018 reporting. Unless noted otherwise, the 

requirements in OMB M-15-02 and OMB M-18-20 referenced in this report are the same. 

16Hereafter in this report, programs represents both programs and activities, as applicable.
Page 7 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

necessary to bring the program or activity into compliance.17 We 

previously recommended that when agencies determine that 

reauthorization or statutory changes are not necessary to bring the 

programs into compliance, the agencies should state so in their 

notifications to Congress. Effective starting with fiscal year 2018 

reporting, OMB updated its guidance to instruct agencies with programs 

reported as noncompliant for 3 consecutive years to explain what the 

agency is doing to achieve compliance if a reauthorization proposal or 

proposed statutory change will not bring a program into compliance with 

IPERA. The updated guidance also instructs agencies with programs 

reported as noncompliant for 4 or more consecutive years to submit a 

report to Congress and OMB (within 30 days of the IG’s determination of 

noncompliance) detailing the activities taken and still being pursued to 

prevent and reduce improper payments.18

If agency programs are reported as noncompliant under IPERA for 2 

consecutive years, and the Director of OMB determines that additional 

funding would help the agency come into compliance, the head of the 

agency must obligate additional funding in the amount determined by the 

Director to intensify compliance efforts.19 IPERA directs the agency to 

exercise any reprogramming or transfer authority that the agency may 

have to provide additional funding to meet the level determined by OMB 

and, if necessary, submit a request to Congress for additional 

reprogramming or transfer authority to meet the full level of funding 

determined by OMB. Table 1 summarizes agency and OMB requirements 

related to agency programs that are noncompliant under IPERA, as 

reported by their IGs.

 17While IPERA states that these procedures are required of agencies with programs 

reported as noncompliant more than 3 consecutive years, OMB M-15-02 adds to this by 

instructing agencies with exactly 3 consecutive years of reported noncompliance to also 

take these steps. 

18Office of Management and Budget, Appendix C to Circular No. A-123, Requirements for 

Payment Integrity Improvement, OMB Memorandum M-18-20.

19OMB interprets this requirement as applying only to agencies and programs with exactly 

2 consecutive years of noncompliance findings. According to OMB staff, the annual 

budget process allows agencies to continue submitting budget requests that support 

achieving IPERA compliance in subsequent years. 
Page 8 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Table 1: Overview of OMB and Agency Requirements for Agency Programs Not in Compliance under IPERA as Reported by 

Their IGs

Years program 

reported as 

noncompliant

Requirements for applicable 

agencies and OMB

Fiscal years effectivea

2016 and 2017 2018

One yearb Agency: Within 90 days of the IG’s determination of noncompliance, 

the agency should submit a plan to Congress and OMB describing

the actions that the agency will take to come into compliance that 

includes measurable milestones, senior agency officials, and 

accountability mechanisms. 

X X

Two consecutive 

yearsc OMB: The Director of OMB has authority to determine if additional funding for intensified compliance efforts would help the agency 

program(s) come into compliance. 

X X

Agency: If OMB determines that additional funding for intensified 

compliance efforts is warranted, the agency shall (1) exercise 

reprogramming or transfer authority to provide additional funding to 

meet the level determined by OMB; and (2) submit a request to 

Congress for additional re-programming or transfer authority if 

additional funding is needed to meet the full level of funding 

determined by OMB.

X X

Agency: The agency should create a proposal and submit it to OMB 

during its next budget submission that will bring the agency into 

compliance.

— X

Three or more 

consecutive yearsd Agency: Within 30 days of the IG’s determination of noncompliance, the agency is required to submit to Congress either (1) a 

reauthorization proposal or (2) proposed statutory changes 

necessary to bring the program or activity into compliance. 

X X

Agency: If the proposals are not deemed necessary, then the 

agency must state so and explain what the agency is doing to 

achieve compliance. 

— X
Page 9 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Years program 

reported as 

noncompliant

Requirements for applicable 

agencies and OMB

Fiscal years effectivea

2016 and 2017 2018

Four or more 

consecutive years

Agency: Within 30 days of the IG’s determination of noncompliance, 

agencies are required to submit a report to Congress and OMB 

detailing the activities taken to complete the requirements for 1 year, 

2 years, 3 years, 4 years, and so forth of noncompliance and include 

a description of any of the requirements that were fulfilled in years 

one, two, or three that are still relevant and being pursued as a 

means to prevent and reduce improper payments.

— X

Legend:

X = requirement was applicable to agencies or OMB in the fiscal year(s) indicated

— = requirement was not applicable to agencies or OMB in the fiscal year(s) indicated

IG = inspector general

IPERA = Improper Payments Elimination and Recovery Act of 2010

OMB = Office of Management and Budget

Sources: IPERA and OMB memorandums. | GAO-19-14

a

OMB Circular No. A-123, Appendix C (M-15-02) was issued in October 2014 and was effective for 

agencies reporting for fiscal years 2016 and 2017, the years included in our audit. In June 2018, OMB 

issued revised guidance (OMB Circular No. A-123, Appendix C (M-18-20)), which included additional 

agency reporting requirements that are effective for fiscal year 2018.

b

OMB guidance states that agencies are required to submit these plans to Congress and OMB in the 

first year of reported noncompliance.

c

OMB interprets this requirement as applying only to agencies and programs with exactly 2 

consecutive years of noncompliance findings. According to OMB staff, the annual budget process 

allows agencies to continue submitting budget requests that support achieving IPERA compliance in 

subsequent years.

d

While IPERA states that these procedures are required of agencies with more than 3 consecutive 

years of noncompliance findings by their IGs, OMB Circular No. A-123, Appendix C (M-15-02), adds 

to this by instructing agencies with exactly 3 consecutive years of reported noncompliance to also 

take these steps.
Page 10 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Seven years after the initial implementation of IPERA, over half of the 24 

CFO Act agencies were reported as noncompliant by their IGs for fiscal 

years 2016 and 2017. Specifically, 13 agencies were reported as 

noncompliant with one or more IPERA criteria for fiscal year 2016, and 14 

agencies were reported as noncompliant for fiscal year 2017 (see fig. 1). 

Nine of these agencies have been reported as noncompliant in one or 

more programs every year since IPERA was implemented in 2011 (see 

app. II for additional details on CFO Act agencies’ compliance under 

IPERA for fiscal years 2011 through 2017, as reported by their IGs).

Over Half of the CFO 

Act Agencies Were 

Reported as 

Noncompliant under 

IPERA for Fiscal 

Years 2016 and 2017, 

and Consecutive 

Years of 

Noncompliance 

Continue for Certain 

Programs

Over Half of the Agencies 

Were Reported as 

Noncompliant for Fiscal 

Years 2016 and 2017
Page 11 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Figure 1: Number of CFO Act Agencies Compliant under IPERA for Fiscal Years 

2011 through 2017, as Reported or Acknowledged by Their Inspectors General

a

For fiscal year 2013, one inspector general did not issue a compliance report because the agency 

did not publish improper payment information.

Although the number of agencies reported as noncompliant under IPERA 

has varied slightly since fiscal year 2011, the total instances of 

noncompliance for all six criteria substantially improved after fiscal year 

2011, when IPERA was first implemented. As shown in figure 2, the total 

instances decreased from 38 instances (for 14 noncompliant agencies) 

for fiscal year 2011 to 26 instances (for 14 noncompliant agencies) for 

fiscal year 2017.20

 20See app. III for additional details on agencies’ and programs’ compliance for each 

criterion, as reported by their IGs, for fiscal years 2016 and 2017. Total reported instances 

of noncompliance exceed the number of noncompliant agencies because certain agencies 

were reported as noncompliant with more than one IPERA criterion.
Page 12 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Figure 2: Total Instances of CFO Act Agencies’ Noncompliance with IPERA Criteria, 

for Fiscal Years 2011 through 2017, as Reported or Acknowledged by Their 

Inspectors General

Also, for fiscal year 2017, 7 of 14 agencies were reported as 

noncompliant for only one criterion per noncompliant program. Of these, 6 

agencies—the Departments of Homeland Security (DHS), Education 

(Education), Commerce, and Transportation; the General Services 

Administration; and the Social Security Administration (SSA)—were only 

reported as noncompliant with the IPERA criterion that requires agencies 

to publish and meet reduction targets. In addition, the Department of the 

Treasury (Treasury) was only reported as noncompliant with the IPERA 
Page 13 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

criterion that requires agencies to report improper payment rates below 

10 percent.

Furthermore, the programs reported as noncompliant for fiscal year 2017 

accounted for a significantly smaller portion of the total reported 

estimated improper payments as compared to the noncompliant 

programs for fiscal year 2015. Specifically, we previously reported that 52 

noncompliant programs accounted for $132 billion (or about 96 percent) 

of the $137 billion total reported estimated improper payments for fiscal 

year 2015, whereas 58 noncompliant programs accounted for $80 billion 

(or about 57 percent) of the $141 billion total reported estimated improper 

payments for fiscal year 2017.21 Although improper payment estimates 

associated with noncompliant programs vary from year to year, this 

decrease (approximately $52 billion) was primarily due to two programs. 

Specifically, the Department of Health and Human Services’ (HHS) 

Medicare Fee-for-Service (Parts A and B) and Medicare Part C programs 

were reported as noncompliant and accounted for approximately 

$43 billion and $14 billion, respectively, of estimated improper payments 

for fiscal year 2015. These programs were reported as compliant for fiscal 

year 2017 and accounted for approximately $36 billion and $14 billion, 

respectively, or about 36 percent of the $141 billion total reported 

improper payments for fiscal year 2017.

Almost a third (18 programs) of the 58 programs that contributed to 14 

CFO Act agencies’ noncompliance under IPERA, as of fiscal year 2017, 

were reported as noncompliant for 3 or more consecutive years. The 

number of programs noncompliant for 3 or more consecutive years has 

continually increased since fiscal year 2015, as shown in figure 3. 

Specifically, 12 programs (associated with 7 agencies) were reported as 

noncompliant for 3 or more consecutive years, as of fiscal year 2015, and 

the number increased to 14 programs (associated with 8 agencies) and 

18 programs (associated with 9 agencies), as of fiscal years 2016 and 

2017, respectively.

 21GAO-17-484.

Certain Programs 

Continue to Be Reported 

as Noncompliant for 

Consecutive Years
Page 14 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Figure 3: Number of CFO Act Agency Programs Noncompliant under IPERA for 3 or 

More Consecutive Years, for Fiscal Years 2015 through 2017, as Reported or 

Acknowledged by Their IGs

These programs accounted for a substantial portion of the $141 billion 

total estimated improper payments for fiscal year 2017. As shown in table 

2, 14 of the 18 programs that were reported as noncompliant for 3 or 

more consecutive years reported improper payment estimates that 

accounted for an estimated $74.4 billion (about 53 percent) of the 

$141 billion, while the other 4 programs did not report improper payment 

estimates for fiscal year 2017 and were reported by their respective IGs 

as noncompliant with the IPERA criterion to publish improper payment 

estimates. The $74.4 billion is primarily composed of estimates reported 

for 2 noncompliant programs—HHS’s Medicaid program ($36.7 billion) 

and Treasury’s Earned Income Tax Credit program ($16.2 billion)—

totaling $52.9 billion (or approximately 71 percent of the $74.4 billion). 

Improper payments associated with these two noncompliant programs 

are also a central part of two areas included in our 2017 High-Risk List, 

which includes federal programs and operations that are especially 
Page 15 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

vulnerable to waste, fraud, abuse, and mismanagement, or that need 

transformative change.22

Table 2: Fiscal Year 2017 Reported Improper Payment Estimates for 18 Programs Reported as Noncompliant under IPERA for 

3 or More Consecutive Years

Agency Program

Estimatea

(dollars in millions)

U.S. Department 

of Agriculture 

1. Food and Nutrition Service (FNS) Child and Adult 

Care Food Programb Not reported

2. FNS National School Lunch Programb 1,875

3. FNS School Breakfast Programb 958

4. FNS Special Supplemental Nutrition Program for 

Women, Infants, and Childrenb 197

5. FNS Supplemental Nutrition Assistance Program Not reported

Department of Defense 6. Travel Pay 263

Department of Health 

and Human Services 

7. Temporary Assistance for Needy Familiesb Not reported

8. Children’s Health Insurance Program 1,236

9. Medicaid 36,731

Department of Housing 

and Urban Development 

10. Rental Housing Assistance Programsc Not reported

Department of Labor 11. Unemployment Insurance Benefitb 4,066

Department of the Treasury 12. Earned Income Tax Creditb 16,232

Department of Veterans Affairs 13. Community Care 5,258

14. Purchased Long Term Service and Support 1,890

15. Beneficiary Travel 224

16. Supplies and Materials 480

 22GAO, High-Risk Series: Progress on Many High-Risk Areas, While Substantial Efforts 

Needed on Others, GAO-17-317 (Washington, D.C.: Feb. 15, 2017). Improper payments 

associated with these two programs are a central part of the Medicaid Program and 

Enforcement of Tax Laws high-risk areas.
Page 16 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agency Program

Estimatea

(dollars in millions)

Social Security Administration 17. Supplemental Security Incomeb 5,020

Department of Homeland Security 18. U.S. Customs and Border Protection – Refund & 

Drawback

15

Total for 18 programs reported as 

noncompliant for 3 or more consecutive 

years, as of fiscal year 2017

74,445

Source: GAO analysis of Office of Management and Budget data and Chief Financial Officers Act of 1990 agencies’ inspector general Improper Payments Elimination and Recovery Act of 2010 (IPERA) 

reports for fiscal year 2017. | GAO-19-14

a

Reported estimates of improper payments totaled approximately $141 billion for fiscal year 2017, 

attributable to 90 programs across 21 agencies. It is important to note that these estimates 

themselves may not be accurate, reliable, or complete, because, as we have reported, the federal 

government is unable to determine the full extent to which improper payments occur and reasonably 

assure that appropriate actions are taken to reduce them. See GAO, Financial Audit: Fiscal Years 

2017 and 2016 Consolidated Financial Statements of the U.S. Government, GAO-18-316R 

(Washington, D.C.: Feb. 15, 2018). In addition, certain inspectors general have reported issues with 

their agencies’ reported improper payment estimates that were caused by insufficient sampling 

methods and flawed estimation methodologies for calculating and reporting improper payment 

estimates.

b

These programs have been reported as noncompliant since the implementation of the Improper 

Payments Elimination and Recovery Act of 2010 in fiscal year 2011.

c

The Department of Housing and Urban Development ceased reporting an estimate of improper 

payments for certain of its Rental Housing Assistance Programs in fiscal year 2017.

Eight of the 18 noncompliant programs have been reported as 

noncompliant since the implementation of IPERA in fiscal year 2011, for a 

total of 7 consecutive years, as shown in table 2. Reported compliance for 

Treasury’s Earned Income Tax Credit improved from being reported as 

noncompliant with multiple IPERA criteria in fiscal year 2013 to 

noncompliance with only one criterion for the last 4 years (fiscal years 

2014 through 2017).
Page 17 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Eight CFO Act agencies’ programs were reported as noncompliant under 

IPERA for 3 or more consecutive years, as of fiscal year 2016.23 Three of 

these agencies did not notify Congress of their program’s continued 

noncompliance as required.24 In addition to submitting the required 

notifications for their noncompliant programs, the other five agencies also 

included additional information in their notifications—such as measurable 

milestones, designation of senior officials, and accountability 

mechanisms—useful for assessing their efforts to achieve compliance. In 

June 2018, OMB updated its guidance to clarify agency reporting 

requirements for each consecutive year a program is reported as 

noncompliant. However, OMB’s updated guidance did not direct agencies 

to include other types of quality information in their notifications for 

programs reported as noncompliant for 3 or more consecutive years that 

could help Congress to more effectively assess their efforts to address 

long-standing challenges and other issues affecting these programs and 

to achieve compliance.

Of the eight agencies with programs reported as noncompliant under 

IPERA for 3 or more consecutive years as of fiscal year 2016, we found 

that five agencies notified Congress of their noncompliance as required. 

Specifically, the Department of Defense (DOD), Education, HHS, DHS, 

and SSA notified Congress of their programs’ reported noncompliance for 

3 or more consecutive years as of fiscal year 2016 as required by IPERA 

and OMB guidance. The remaining three agencies—the U.S. Department 

of Agriculture (USDA), the Department of Labor (DOL), and Treasury—

did not notify Congress as required.

 23See app. IV for a list of CFO Act agencies and programs reported as noncompliant for 3 

or more consecutive years, as of fiscal year 2016. We limited our review to agency 

notifications submitted to Congress after the IGs reported the fiscal year 2016 IPERA 

compliance results in May 2017 because the IGs’ reporting triggers the agency reporting 

requirements. In addition, we did not review the notifications for programs reported as 

noncompliant as of fiscal year 2017 (with IPERA compliance results reported in May 

2018), because of timing limitations. 

24IPERA and OMB require agencies to submit a request for program reauthorization or a 

proposal for statutory changes necessary to bring programs into compliance with IPERA. 

While IPERA states that this requirement is for agencies with more than 3 consecutive 

years of noncompliance findings by their IGs, OMB M-15-02 adds to this by instructing 

agencies with exactly 3 consecutive years of reported noncompliance to also take these 

steps. We previously reported that when an agency determines that a reauthorization or 

statutory change proposal is not needed to bring a program into compliance, the agency 

should indicate such in its notifications to Congress. 

CFO Act Agencies 

Did Not Always Notify 

Congress, and They 

Provided Varying 

Information on 

Programs Reported 

as Noncompliant for 3 

or More Consecutive 

Years

CFO Act Agencies with 

Programs Reported as 

Noncompliant for 3 or 

More Consecutive Years 

Did Not Always Notify 

Congress
Page 18 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Additional information regarding the three agencies that did not submit 

their required notifications to Congress is summarized below:

• USDA: In May 2017, the USDA IG reported that four USDA Food and 

Nutrition Service programs—Child and Adult Care Food Program; 

National School Lunch Program; School Breakfast Program; and 

Special Supplemental Nutrition Program for Women, Infants, and 

Children—had been noncompliant for 6 consecutive years, as of fiscal 

year 2016. However, USDA has not notified Congress of these 

programs’ continued noncompliance with IPERA as of fiscal year 

2016, despite prior recommendations that we, and the USDA IG, 

made to USDA to do so.25 USDA staff stated in May 2018 that USDA 

drafted, but had not submitted, a letter to Congress regarding these 

programs’ noncompliance.

• DOL: In June 2017, the DOL IG reported that the Unemployment 

Insurance Benefit program had been noncompliant for 6 consecutive 

years, as of fiscal year 2016. In October 2016, DOL included 

proposed legislation in its last notification to Congress regarding this 

program, approximately 8 months prior to the DOL IG’s IPERA 

compliance report. However, because the requirement for agencies to 

notify Congress is triggered by IG reporting of programs that are 

noncompliant for 3 or more consecutive years, DOL should have also

notified Congress regarding the program’s continued noncompliance 

in fiscal year 2016 after the IG’s report was issued in June 2017. DOL 

staff stated in August 2018 that the proposed legislation included in its 

October 2016 notification had not been enacted and that DOL is 

currently working to develop a new report to Congress and OMB 

detailing corrective actions taken to bring the program into 

compliance.

• Treasury: In May 2017, the Treasury IG reported that the Earned 

Income Tax Credit (EITC) program had been noncompliant for 6 

consecutive years, as of fiscal year 2016. We previously reported that 

Treasury submitted proposed statutory changes to Congress for this 

program in August 2014 and in June 2015.26 As stated in the Treasury 

IG’s fiscal year 2016 IPERA compliance report, the proposed statutory 

 25See GAO recommendations in GAO-16-554 and GAO-17-484. See the USDA IG 

recommendation in, U.S. Department of Agriculture, Office of Inspector General, USDA’S 

Fiscal Year 2016 Compliance with Improper Payment Requirements, Audit Number 

50024-0011-11 (Washington, D.C.: May 2017).

26GAO-16-554 and GAO-17-484.
Page 19 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

changes would help prevent the improper issuance of billions of 

dollars in refunds as it would provide the Internal Revenue Service 

(IRS) with expanded authority to systematically correct erroneous 

claims that are identified when tax returns are processed and allow 

IRS to deny erroneous EITC refund claims before they are paid. 

Further, Treasury stated that IRS has repeatedly requested authority 

to correct such errors in subsequent fiscal year budgets, including its

fiscal year 2019 budget submission. In June 2018, Treasury staff 

stated that the Consolidated Appropriations Act, 2016 provided IRS 

with additional tools for reducing EITC improper payments; however, 

the act did not expand IRS’s authority to systematically correct the 

erroneous claims that are identified when tax returns are processed.27

Treasury staff also stated that the department has continued to 

coordinate with OMB on required reporting for the EITC program 

because of the program’s complexity, and that OMB has not 

requested additional actions or documentation regarding the 

program’s noncompliance. Although continued coordination with OMB 

is important, Treasury did not notify Congress regarding the EITC 

program’s continued noncompliance as required.

In summary, despite reporting requirements in IPERA and OMB 

guidance, one agency (USDA) has not notified Congress about four 

programs being reported as noncompliant for 6 consecutive years, as of 

fiscal year 2016. The remaining two agencies (DOL and Treasury) that 

did not notify Congress of their programs’ consecutive noncompliance, as 

of fiscal year 2016, submitted notifications to Congress prior to their 

respective IGs’ fiscal year 2016 compliance results. However, IPERA 

requires agencies to notify Congress when programs are reported as 

noncompliant for more than 3 consecutive years and thus DOL and 

Treasury should have also notified Congress about their programs’ being 

reported as noncompliant for 6 consecutive years, as of fiscal year 2016.

It is important that agencies continue to notify Congress of their programs’ 

consecutive noncompliance each year after the third consecutive year as 

the information related to their proposals or regarding their IPERA 

compliance efforts included in prior years’ notifications to Congress may 

significantly change over time. Unless agencies continue to notify 

 27The Protecting Americans from Tax Hikes Act of 2015, which was enacted as part of the 

Consolidated Appropriations Act, 2016, included reforms, that among other things, allow 

IRS earlier access to Form W-2s, which enables IRS to systemically verify more wage 

data and return information. Pub. L. No. 114-113, div. Q, § 201, 129 Stat. 2242, 3076 

(Dec. 18, 2015). 
Page 20 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Congress in subsequent years, Congress may lack the current and 

relevant information needed to effectively assess agencies’ proposals or 

monitor their efforts to address problematic programs in a timely manner. 

OMB updated its guidance in June 2018 to provide more clarity regarding 

the notification requirements for each consecutive year a program is 

reported as noncompliant. Effective implementation of this guidance may 

help ensure that agencies consistently provide required information to 

Congress on these programs in future years.

We found that the five agencies—DOD, DHS, Education, HHS, and 

SSA—that notified Congress regarding their programs’ reported 

noncompliance for 3 or more consecutive years, as of fiscal year 2016, 

also included additional information about their efforts to achieve IPERA 

compliance. Although IPERA does not specifically require that agency 

proposals for reauthorization or other statutory change provide such 

information, including it could help Congress to better assess the 

agencies’ proposals included in these notifications and to oversee agency 

efforts to address long-standing challenges and compliance issues 

associated with these programs.

In many instances, the types of additional information provided by these 

agencies are similar to information that agencies are required to provide 

to Congress or OMB in other required notifications or other reports, such 

as annual AFRs or PARs. For example, all improper payment estimates 

reported under IPIA, as amended, must be accompanied by information 

on what the agency is doing to reduce improper payments, including a 

description of root causes and the steps the agency has taken to ensure 

accountability. Further, IPERA and OMB guidance require agencies to 

provide corrective action plans to Congress for programs reported as 

noncompliant for 1 year. Such plans should include actions planned or 

taken to address the program’s noncompliance, measurable milestones, 

a senior official designated to oversee progress, and the accountability 

mechanisms in place to hold the senior official accountable.28

In addition, GAO’s Standards for Internal Control in the Federal 

Government emphasizes the importance of communicating quality 

 28IPERA requires agencies to submit corrective action plans to Congress when programs 

are reported as noncompliant for a fiscal year. As noted above, OMB guidance interprets 

this requirement as applying only to agencies with exactly 1 year of reported 

noncompliance. 

Certain Agencies Provided 

Additional Quality 

Information on IPERA 

Compliance Efforts in 

Their Notifications to 

Congress
Page 21 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

information, such as significant matters related to risks, changes, or 

issues affecting agencies’ efforts to achieve compliance objectives, to 

external parties—such as legislators, oversight bodies, and the general 

public.29 Furthermore, in our fiscal year 2017 High-Risk Update, we also 

highlight the importance of these types of information when assessing 

agency efforts to address issues associated with programs included on 

our High-Risk List.30 Examples of such information include (1) action 

plans that are accessible and transparent with clear milestones and 

metrics, including established goals and performance measures to 

address identified root causes; (2) leadership commitment of top (or 

senior) officials to establish long-term priorities and goals and continued 

oversight and accountability; (3) monitoring progress against goals, 

assessing program performance, or reporting potential risks; and 

(4) demonstrated progress, through recommendations implemented, 

actions taken for improvement, and effectively addressing identified root 

causes and managing high-risk issues.

Table 3 summarizes the types of additional information described above 

that the five agencies provided in their fiscal year 2016 notifications to 

Congress to address programs with 3 or more consecutive years of 

noncompliance. All five agencies informed Congress of (1) root causes 

that directly lead to improper payments or hindered the program’s ability 

to achieve compliance; (2) certain risks, significant changes, or issues 

affecting their efforts; and (3) their corrective actions or strategies to 

achieve compliance. Three of the five agencies—DOD, Education, and 

DHS—also included the other types of additional information described 

above in their notifications, including measurable milestones, designated 

senior officials to oversee progress, and accountability mechanisms 

 29GAO-14-704G. Such significant matters could include internal or external risk factors in 

an agency’s environment—including significant related changes that have (or may) occur, 

such as complex organizational or program structures, new or existing legal requirements, 

or natural disasters, and internal control issues in the design, implementation, or operating 

effectiveness of a system or related processes, which may adversely affect the entity’s 

ability to achieve compliance and its reporting objectives.

30GAO-17-317. Every 2 years at the start of a new Congress, GAO calls attention to 

agencies and program areas that are at high risk because of their vulnerabilities to fraud, 

waste, abuse, and mismanagement or that are most in need of transformation. Two 

programs, HHS’s Medicaid and Treasury’s EITC, were reported as noncompliant under 

IPERA for 3 or more consecutive years, as of fiscal years 2016 and 2017. As noted in 

table 2, these two programs accounted for approximately $52.9 billion (or 37.5 percent) of 

the $141 billion of the total reported improper payments estimates for fiscal year 2017. 

Improper payments associated with these two noncompliant programs are also a central 

part of two areas included in our 2017 High-Risk List.
Page 22 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

established to help achieve compliance. For example, all three agencies 

designated their chief financial officers (CFO) to oversee progress toward 

achieving measurable milestones and expanded their official roles and 

responsibilities to hold them accountable. Education and DHS stated that 

these responsibilities were added to their respective CFOs’ individual 

performance plans.

Table 3: Additional Information Included in Notifications to Congress by Five Agencies with Programs Reported as 

Noncompliant under the Improper Payments Elimination and Recovery Act of 2010 for 3 or More Consecutive Years, as of 

Fiscal Year 2016

Agency 

Additional information includeda

Root 

causes

Risks, 

issues, or 

changes

Corrective 

actions 

or strategies

Measurable 

milestones

Designated 

senior 

officials

Accountability 

mechanisms

Department of Defense Yes Yes Yes Yes Yes Yes

Department of Education Yes Yes Yes Yes Yes Yes

Department of Health and 

Human Services

Yes Yes Yes No No No

Department of Homeland Security Yes Yes Yes Yes Yes Yes

Social Security Administration Yes Yes Yes No No No

Total 5 5 5 3 3 3

Source: GAO analysis of Chief Financial Officers Act of 1990 agencies’ notifications to Congress for programs with 3 or more consecutive years of noncompliance as of fiscal year 2016. | GAO-19-14

a

Descriptions of the additional types of information shown above are as follows:

Root causes: Underlying issues or causes that directly lead to an improper payment or hinder the 

program’s ability to achieve compliance and, if corrected, would prevent the improper payments.

Risks, issues, or changes: Internal or external risk factors in an agency’s environment, significant 

changes that have (or may) occur, and internal control issues in their systems or processes that may 

adversely affect their ability to achieve compliance.

Corrective actions or strategies: Specific action items or strategies planned, developed, 

implemented, or taken to address a program’s noncompliance.

Measurable milestones: Key action items in the agency’s efforts to achieve compliance that are 

measurable and include specific target dates.

Designated senior officials: Senior agency official designated to oversee and be held accountable for 

the agency’s efforts and related progress for each of its programs or activities to achieve 

compliance.

Accountability mechanisms: Appropriate incentives and consequences for the senior official 

designated to oversee the agency’s efforts to achieve compliance.

Although OMB updated its guidance in June 2018 to clarify agency 

reporting requirements related to programs reported as noncompliant for 

3 or more consecutive years, the updated guidance did not direct 

agencies to include other types of quality information in their notifications, 

such as those described above. In addition, information related to 

measurable milestones, corrective actions, risks, issues, or other items 
Page 23 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

affecting agencies’ efforts may change significantly over time. With this 

additional information, Congress could have more complete information to 

effectively oversee agency efforts to address long-standing challenges 

and other issues that have contributed to programs being reported as 

noncompliant for 3 or more consecutive years.

Fifteen programs in seven agencies and 12 programs in six agencies 

were reported as noncompliant for 2 consecutive years as of fiscal years 

2016 and 2017, respectively.31 For agencies reported as noncompliant 

under IPERA for 2 consecutive years for the same program, IPERA gives 

the Director of OMB the authority to determine whether additional funding 

would help the agencies come into compliance.32 If the OMB Director 

determines that such funding would help, the agency is required to use 

any available reprogramming or transfer authority to meet the funding 

level that the OMB Director specified and, if such authorities are not 

sufficient, submit a request to Congress for additional reprogramming or 

transfer authority. According to OMB staff, OMB determined that no 

additional funding was needed for programs reported as noncompliant for 

2 consecutive years as of fiscal year 2016. As of September 2018, OMB 

was in the process of making funding determinations for 12 programs that 

were reported as noncompliant as of fiscal year 2017 and stated that any 

determinations made would be developed in the President’s Budget for 

fiscal year 2020.

The 12 programs reported as noncompliant for 2 consecutive years, as of 

fiscal year 2017, accounted for approximately $3 billion (2 percent) of the

$141 billion total improper payment estimate for that year. Of these 12 

programs, more than half (or 7 of the 12) were attributable to DOD; 

however, Education’s Pell Grant program accounted for $2.2 billion (or 74 

percent) of the $3 billion in improper payment estimates for programs 

reported as noncompliant programs for 2 consecutive years, for fiscal 

year 2017. In addition, as shown in table 4, the 12 programs reported as 

noncompliant for 2 consecutive years, as of fiscal year 2017, were 

primarily noncompliant with the IPERA criteria that required agencies to 

 31See app. IV for all agencies and programs with 2 consecutive years of noncompliance 

as reported by their IGs, as of fiscal years 2016 and 2017.

32As noted above, OMB interprets this requirement as applying only to agencies and 

programs with exactly 2 consecutive years of noncompliance findings. According to OMB 

staff, the annual budget process allows agencies to continue submitting budget requests 

that support achieving IPERA compliance in subsequent years.

OMB Updated 

Guidance for 

Determining 

Additional Funding 

Needs for Programs 

Reported as 

Noncompliant for 2 

Consecutive Years
Page 24 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

publish information in their PAR or AFR or publish and meet reduction 

targets.

Table 4: CFO Act Agency Programs Reported as Noncompliant for 2 Consecutive Years by Their IGs and Noncompliance 

Determinations for Each IPERA Criterion, as of Fiscal Year 2017

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) 

below 10 

percent

Department of Defense

1. Navy Commercial Bill Pay Office -

Naples X * * * * *

2. Defense Finance and Accounting 

Services - Commercial Pay X * X * * *

3. U.S. Army Corps of Engineers -

Travel Pay X * * * X *

4. Military Health Benefits X * X X * *

5. Military Pay X * * X * *

6. Civilian Pay X * * * * *

7. Military Retiree and Annuitant 

Benefit Payments X * * X X *

Department of Education

8. Pell Grant * * * * X *

Department of Health and Human Services

9. Foster Care * * * * X *

Department of Veterans Affairs

10. Civilian Health and Medical 

Program of the Department of 

Veterans Affairs * * * * X *

General Services Administration

11. Rental of Space Program * * * * X *
Page 25 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) 

below 10 

percent

Small Business Administration

12. Section 7(a) Loan Guaranty 

Purchases * * * * X *

Legend:

X = Program was noncompliant with IPERA criterion, as reported by the agencies’ IG

* = Program was not reported by the IG as noncompliant with IPERA criterion

AFR = agency financial report

CFO Act = Chief Financial Officers Act of 1990

IG = inspector general

IPERA = Improper Payments Elimination and Recovery Act of 2010

OMB = Office of Management and Budget

PAR = performance and accountability report

Source: GAO analysis of CFO Act agencies’ IG IPERA compliance reports for fiscal years 2017. | GAO-19-14

Note: These12 programs were determined to be noncompliant with IPERA for 2 consecutive years as 

of fiscal year 2017. The specific IPERA criterion (or criteria) with which each program was 

noncompliant in fiscal year 2017, as shown in this table, may differ from the criterion the program was 

noncompliant with in a prior year. For agencies reported as noncompliant under IPERA for 2 

consecutive years for the same program, IPERA gives the Director of OMB the authority to determine 

whether additional funding would help the agency come into compliance. OMB interprets this 

requirement as applying only to agencies and programs with exactly 2 consecutive years of 

noncompliance findings. According to OMB staff, the annual budget process allows agencies to 

continue submitting budget requests that support achieving IPERA compliance in subsequent years.

As noted previously, IPERA gives OMB authority to determine whether 

additional funding for intensified compliance efforts would help the agency 

come into compliance under IPERA. Therefore, an established process 

for making timely, well-informed funding determinations is an essential 

part of ensuring that agencies have sufficient resources and take steps to 

intensify their compliance efforts in a timely manner. In April 2018, OMB 

staff stated that when making funding determinations, they primarily rely 

on the IGs’ recommendations in their annual IPERA compliance reports. 

OMB staff also stated that for its fiscal year 2016 determinations, OMB 

determined that additional funding was not needed because the IGs’ 

recommendations did not specify that additional funding was needed to 

help resolve the programs’ noncompliance.

The IGs’ annual reports provide information on agencies’ IPERA 

compliance and may be useful to OMB as a tool to help them make 

determinations for additional funding. However, IPERA does not require 

IGs to address funding levels in their annual compliance reports, and 

OMB’s guidance does not inform the IGs that their work might be relied 

upon in this manner. We reviewed the IGs’ fiscal years 2016 and 2017 

IPERA compliance reports for the agencies with programs reported as 
Page 26 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

noncompliant for 2 consecutive years and found that the IGs did not make 

any recommendations regarding additional funding needed to bring these 

programs into compliance. In addition, as specifically stated by the IGs for 

Education and USDA in their IPERA reports, OMB has the statutory 

responsibility to make these funding determinations. Education IG’s fiscal 

year 2017 IPERA compliance report stated that “If OMB recommends that 

the Department needs additional funding or should take any other actions 

to become compliant with IPERA, we recommend that the Department 

implement OMB’s recommendations.” Also, the USDA IG’s fiscal year 

2016 IPERA compliance report stated, “For agencies that are not 

compliant for 2 consecutive years for the same program, the Director of 

OMB will determine if additional funding would help these programs come 

into compliance.” As a result, OMB’s reliance on IG recommendations as 

the source of information to support additional funding determinations 

may not provide sufficient information to effectively assess agencies’ 

funding needs to address noncompliance.

OMB staff subsequently stated that they no longer need to conduct a 

detailed review of the IGs’ IPERA compliance reports to identify 

recommendations related to additional funding needs. Instead, OMB 

Memorandum M-18-20, issued in June 2018, updated OMB Circular No. 

A-123, Appendix C, and clarified that the funding determination process 

will unfold as part of the annual development of the President’s Budget, 

as described in OMB Circular No. A-11.33 This updated guidance also 

directs agencies to submit proposals to OMB regarding additional funding 

needs that may help them address IPERA noncompliance.

To illustrate, under this new guidance, the IGs’ fiscal year 2018 IPERA 

compliance reports will be due in May 2019, and any funding needs to 

address noncompliance would be incorporated in the next annual budget 

preparation process, the results of which are due to be submitted to 

Congress in February 2020 for the President’s Budget for fiscal year 

2021. Once OMB’s determinations have been made and communicated 

to agencies, agencies would respond by performing the required 

reprogramming and making transfers under existing authority, where 

 33Office of Management and Budget, Appendix C to Circular No. A-123, Requirements for 

Payment Integrity Improvement, OMB Memorandum M-18-20, and Preparation, 

Submission, and Execution of the Budget, OMB Circular No. A-11 (Washington, D.C.: 

June 2018).
Page 27 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

available. Any requests for additional transfer authority may be 

incorporated into subsequent appropriations legislation.34

Estimated improper payments reported government-wide total almost 

$1.4 trillion from fiscal year 2003 through fiscal year 2017. The number of 

programs reported as noncompliant under IPERA for 3 or more 

consecutive years has continued to increase, from 12 programs 

(associated with 7 agencies) to 18 programs (associated with 9 agencies) 

as of fiscal years 2015 and 2017, respectively. Including additional useful, 

up-to-date information—such as measurable milestones, risks, or other 

issues affecting agency efforts to achieve compliance—in notifications to 

Congress, which are required when programs are reported as 

noncompliant for 3 or more consecutive years, could help Congress 

better assess agency efforts to address long-standing challenges and 

other issues associated with them. Although certain agencies included 

certain types of additional information in their notifications as of fiscal year 

2016, OMB guidance does not require agencies to include such 

information in their notifications. As a result, Congress may lack sufficient 

information to effectively oversee agency efforts and take prompt action 

to help address long-standing challenges or other issues associated with 

these programs.

The Director of OMB should take steps to update OMB guidance to 

specify other types of quality information that agencies with programs 

noncompliant for 3 or more consecutive years should include in their 

notifications to Congress, such as significant matters related to risks, 

issues, root causes, measurable milestones, designated senior officials, 

accountability mechanisms, and corrective actions or strategies planned 

or taken by agencies to achieve compliance. (Recommendation 1)

We provided a draft of this report to OMB and requested comments, and 

OMB said that it had no comments. We also provided a draft of this report 

to the 24 CFO Act agencies and their IGs and requested comments. We 

received letters from the DHS Office of Inspector General (OIG), SSA, 

and the United States Agency for International Development. These 

 34A full timeline for preparation of the annual President’s Budget can be found in OMB 

Circular No. A-11 § 10.5. 

Conclusions

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
Page 28 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

letters are reproduced in appendixes V through VII. We also received 

technical comments from DOL, the Department of Veterans Affairs, the 

General Services Administration, HHS, the Department of Housing and 

Urban Development, and the Treasury OIG, which we incorporated in the 

report as appropriate. The remaining agencies and OIGs either did not 

provide comments or notified us via email that they had no comments.

In its comments, SSA stated that it provided information to Congress on 

measurable milestones, designated senior officials, and accountability 

mechanisms in its AFR. In the report, we acknowledge that these types of 

additional information are similar to information that agencies are required 

to provide to Congress or OMB in other reports, such as annual AFRs. 

However, our analysis was based on SSA’s fiscal year 2016 notifications 

to Congress for programs reported as noncompliant under IPERA, in 

which this specific information was not reported. As such, we continue to 

believe that OMB should take steps to update OMB guidance to help

ensure that agencies report such significant information and include it in 

their notifications to Congress.

We are sending copies of this report to the appropriate congressional 

committees, the Director of the Office of Management and Budget, and 

other interested parties. In addition, the report is available at no charge on 

the GAO website at http://www.gao.gov.

If you or your staff have any questions on matters discussed in this report, 

please contact me at (202) 512-2623 or davisbh@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. GAO staff who made key 

contributions to this report are listed in appendix VIII.

Beryl H. Davis

Director

Financial Management and Assurance 
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Our objectives were to determine the following:

1. The extent to which the 24 agencies listed in the Chief Financial 

Officers Act of 1990, as amended (CFO Act),1 complied with the six 

criteria listed in the Improper Payments Elimination and Recovery Act 

of 2010 (IPERA),2 for fiscal years 2016 and 2017, and the trends 

evident since 2011, as reported by their inspectors general (IG).

2. The extent to which CFO Act agencies addressed requirements for 

programs and activities reported as noncompliant with IPERA criteria 

for 3 or more consecutive years, as of fiscal year 2016, and 

communicated their strategies to Congress for reducing improper 

payments and achieving compliance.

3. The extent to which the Office of Management and Budget (OMB) 

made determinations regarding whether additional funding would help 

CFO Act programs and activities reported as noncompliant with 

IPERA criteria for 2 consecutive years, as of fiscal years 2016 and 

2017, come into compliance.

Although the responsibility for complying with provisions of improper 

payment-related statutes rests with the head of each executive agency, 

we focused on the 24 agencies listed in the CFO Act because estimates 

of their improper payments represent over 99 percent of the total reported

estimated improper payments for fiscal years 2016 and 2017. Our work 

did not include validating or retesting the data or methodologies that the 

IGs used to determine and report compliance. We corroborated all of our 

findings with OMB and all 24 CFO Act agencies and IGs.

To address our first objective, we identified the requirements that 

agencies must meet by reviewing the Improper Payments Information Act 

of 2002 (IPIA),3 IPERA, and OMB guidance. We reviewed the CFO Act 

agency IGs’ IPERA compliance reports for fiscal years 2016 and 2017, 

which were the most current reports available at the time of our review. 

 1

The CFO Act, Pub. L. No. 101-576 104 Stat. 2838 (Nov. 15, 1990), established, among 

other things, chief financial officers to oversee financial management activities at 23 major 

executive departments and agencies. The list now includes 24 entities, which are often 

referred to collectively as CFO Act agencies, and is codified, as amended, in section 901 

of Title 31, United States Code. 

2

Pub. L. No. 111-204, 124 Stat. 2224 (July 22, 2010), codified as amended at 31 U.S.C. § 

3321 note. 

3

Pub. L. No. 107-300, 116 Stat. 2350 (Nov. 26, 2002), codified as amended at 31 U.S.C. § 

3321 note. 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

We summarized the overall agency and program-specific compliance 

determinations with the six IPERA criteria, as reported by the IGs. For 

fiscal years 2011 through 2015, we relied on and reviewed prior year 

supporting documentation and analyses of CFO Act agencies’ IPERA 

compliance, as reported in our prior reports, in order to identify 

compliance trends since 2011, as reported by the IGs.4 Based on these 

reports, we summarized the programs and the number of consecutive 

years that they were reported as noncompliant. For each IG report that 

did not specifically state that the agency had programs noncompliant for 

consecutive years, we compared the list of programs reported as 

noncompliant for fiscal years 2016 and 2017 to the list of programs 

reported as noncompliant for fiscal years 2014 and 2015 in our prior 

reports. Lastly, we corroborated our findings with OMB and all 24 CFO 

Act agencies and IGs.

To address our second objective, we determined if the agencies 

responsible for programs and activities reported as noncompliant for 3 or 

more consecutive years as of fiscal year 2016 had submitted the required 

proposals (reauthorizations or statutory changes) to Congress by 

requesting and reviewing documentation of the required submissions and 

relevant notifications to Congress obtained from each applicable agency. 

Further, we reviewed the content of each agency notification to evaluate 

agencies’ efforts to communicate quality information to Congress 

concerning their strategies for achieving compliance consistent with 

Standards for Internal Control in the Federal Government.

5 Principle 15 of 

these standards emphasizes the need for an entity’s management to 

communicate necessary quality information, such as significant matters 

related to risks, changes, or issues affecting agencies’ efforts, to achieve 

compliance objectives, to external parties—such as legislators, oversight 

bodies, and the general public. To identify other types of information 

useful for this purpose, we reviewed IPIA, as amended; IPERA; and OMB 

guidance for information agencies are required to provide to Congress or 

OMB in other notifications and reports, such as their corrective action 

plans or strategies, measurable milestones, designated senior officials, 

 4

GAO, Improper Payments: CFO Act Agencies Need to Improve Efforts to Address 

Compliance Issues, GAO-16-554 (Washington, D.C.: June 30, 2016), and Improper 

Payments: Additional Guidance Could Provide More Consistent Compliance 

Determinations and Reporting by Inspectors General, GAO-17-484 (Washington, D.C.: 

May 31, 2017). 

5

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

and accountability mechanisms for achieving compliance. We also 

reviewed information used to assess agency efforts to address issues 

associated with programs on our High-Risk List.6

To determine the extent to which agencies’ notifications to Congress 

included these additional types of useful information for their applicable 

program(s), we used a data collection instrument to document our 

determinations regarding the additional types of quality information 

included in each notification. In addition, two GAO analysts independently 

reviewed each agency’s notification and documented their determinations 

regarding the types of information included in the notifications. 

Differences between the analysts’ determinations were identified and 

resolved to ensure that the types of additional information were 

consistently identified and categorized. We did not evaluate the 

sufficiency and completeness of the agency-provided information. Lastly, 

we corroborated our findings with the respective agencies and IGs.

To address our third objective, we identified provisions in IPIA, IPERA, 

and OMB guidance that are applicable to OMB for programs reported as 

noncompliant for 2 consecutive years.7 To determine if OMB made 

additional funding determinations for agency programs and activities 

reported as noncompliant for 2 consecutive years as of fiscal years 2016 

and 2017, we requested relevant information and communications from 

OMB and the applicable agencies and IGs. We also interviewed key OMB 

staff on their process for determining additional funding needs for 

noncompliant programs and activities as of fiscal years 2016 and 2017 

and related results. In addition, we reviewed the applicable fiscal years 

2016 and 2017 CFO Act agency IG IPERA compliance reports, which 

OMB staff stated they relied on for determining whether noncompliant 

programs and activities required additional funding. We also asked the 

agencies whether they coordinated with OMB regarding their need for 

additional funding for programs and activities reported as noncompliant 

for 2 consecutive years as of fiscal years 2016 and 2017. Lastly, we 

corroborated our findings with OMB and the respective agencies and IGs.

 6

GAO, High-Risk Series: Progress on Many High-Risk Areas, While Substantial Efforts 

Needed on Others, GAO-17-317 (Washington, D.C.: February 2017).

7

Office of Management and Budget, Appendix C to Circular No. A-123, Requirements for 

Effective Estimation and Remediation of Improper Payments, OMB Memorandum M-15-

02, and Appendix C to Circular No. A-123, Requirements for Payment Integrity 

Improvement, OMB Memorandum M-18-20.
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

We conducted this performance audit from November 2017 to December 

2018 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.
Appendix II: CFO Act Agencies’ Overall IPERA 

Compliance for Fiscal Years 2011 through 

2017, as Reported or Acknowledged by Their 

IGs

Page 33 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Figure 4 details the 24 Chief Financial Officers Act of 1990 (CFO Act) 

agencies’ overall compliance under the Improper Payments Elimination 

and Recovery Act of 2010 (IPERA), as reported by their inspectors 

general, for fiscal years 2011 through 2017. We previously reported on 

CFO Act agencies’ overall reported compliance for fiscal years 2011 

through 2015.1

 1

GAO, Improper Payments: Additional Guidance Could Provide More Consistent 

Compliance Determinations and Reporting by Inspectors General, GAO-17-484 

(Washington, D.C.: May 31, 2017). 

Appendix II: CFO Act Agencies’ Overall 

IPERA Compliance for Fiscal Years 2011 

through 2017, as Reported or Acknowledged

by Their IGs
Appendix II: CFO Act Agencies’ Overall IPERA 

Compliance for Fiscal Years 2011 through 

2017, as Reported or Acknowledged by Their 

IGs

Page 34 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Figure 4: CFO Act Agencies’ Overall IPERA Compliance for Fiscal Years 2011 through 2017, as Reported or Acknowledged by 

Their IGs
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant with IPERA for 

Fiscal Years 2016 and 2017

Page 35 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Tables 5 and 6 detail the Chief Financial Officers Act of 1990 (CFO Act) 

agencies and programs reported by their inspectors general as 

noncompliant with the six criteria specified by the Improper Payments 

Elimination and Recovery Act of 2010 (IPERA), for fiscal years 2016 and 

2017. We previously reported on CFO Act agencies’ reported compliance 

with the six IPERA criteria for fiscal year 2015.1

Table 5: CFO Act Agency Programs That IGs Reported as Noncompliant with IPERA Criteria for Fiscal Year 2016 

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) below 

10 percent

U.S. Department of Agriculture

1. Food and Nutrition Service (FNS) 

Supplemental Nutrition Assistance 

Program * * X * * *

2. FNS Child and Adult Care Food 

Program * * X * * *

3. FNS National School Lunch Program * * * * X X

4. FNS School Breakfast Program * * * * X X

5. FNS Special Supplemental Nutrition 

Program for Women, Infants, and 

Children * * * * X *

6. Farm Service Agency (FSA) Loan 

Deficiency Payment * * * * X *

7. FSA Livestock Forage Disaster Program * * * * X *

8. FSA Livestock Indemnity Program * * * * X X

9. FSA Supplemental Revenue Assistance 

Payments * * * * X X

Department of Defensea

10. Navy Commercial Bill Pay Office -

Naples X * * X * *

11. Defense Finance and Accounting 

Service Commercial Pay X * * X * *

12. U.S. Army Corps of Engineers 

Travel Pay X * X X X *

 1

GAO, Improper Payments: Additional Guidance Could Provide More Consistent 

Compliance Determinations and Reporting by Inspectors General, GAO-17-484 

(Washington, D.C.: May 31, 2017). 

Appendix III: CFO Act Agencies and

Programs Reported as Noncompliant with 

IPERA for Fiscal Years 2016 and 2017
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant with IPERA for 

Fiscal Years 2016 and 2017

Page 36 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) below 

10 percent

Department of Defensea

13. Military Health Benefits X * * X * *

14. Military Pay X * * X * *

15. Civilian Pay X * * X * *

16. Military Retiree and Annuitant 

Benefit Payments X * * X * *

17. Travel Pay X * X X X *

18. Navy Enterprise Resource 

Planning Commercial Pay X * * X * *

19. Navy Commercial Bill Pay 

Office - Singapore X X * * * *

Department of Education

20. Pell Grant * * * * X *

21. Department-managed grant programs * X * * * *

22. Federal Student Aid - managed 

contracting activities * X * * * *

23. Direct Loan * * * * X *

Department of Health and Human Services

24. Temporary Assistance for Needy 

Families (TANF)b * * X X X X

25. Medicaid * * * * * X

26. Children’s Health Insurance Program * * * * X *

27. Foster Care * * * * X *

28. Medicare Advantage (Part C) * * * * X *

29. Medicare Fee-for-Service 

(Parts A and B) * * * * * X

Department of Homeland Security

30. U.S. Customs and Border Protection -

Refund & Drawback * * * * X *

31. Federal Emergency Management 

Agency (FEMA) - Assistance to 

Firefighters Grant * * * * X *

32. FEMA - Flood Risk Map-Flood 

Hazard Mapping & Risk Analysis * * * * X *
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant with IPERA for 

Fiscal Years 2016 and 2017

Page 37 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) below 

10 percent

Department of Homeland Security

33. FEMA - Public Assistance * * * * X *

34. FEMA - Port Security Grant Program * * * * X *

35. FEMA - Vendor Pay * * * * X *

36. Office of Inspector General -Hurricane 

Sandy Payroll & Travel * * * * X *

37. FEMA - Federal Insurance and 

Mitigation Administration -

Non Claims Loss Payments

X * * * * *

38. FEMA - Flood Risk Map 

Program – Grants X * * * * *

39. Non Disaster Relief Fund Travel X * * * * *

Department of Housing and Urban Development

40. Rental Housing Assistance Programs * * * * X *

41. Government National Mortgage 

Association programsc * X * * * *

42. Payments to Federal employees 

for all program offices * X * * * *

43. Federal Housing Administration 

(FHA) Single Family Notes * X * * * *

44. FHA - Other Disbursements * X * * * *

Department of Labor

45. Unemployment Insurance Benefit * * * * X X

46. Federal Employees’ Compensation Act * * * * X *

Department of Transportation

47. Federal Aviation Administration 

Facilities and Equipment - Disaster 

Relief Appropriations Act * * * * X *

48. Federal Railroad Administration’s 

High-Speed Intercity Passenger Rail * * * * X *

49. Federal Transit Administration’s 

Formula Grants and Passenger Rail 

Investment and Improvement Act * * * * X *

Department of the Treasury

50. Earned Income Tax Credit * * * * * X
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant with IPERA for 

Fiscal Years 2016 and 2017

Page 38 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) below 

10 percent

Department of Veterans Affairs

51. Civilian Health and Medical Program of 

the Department of Veterans Affairs * * * * X *

52. Community Care * * * * X X

53. Purchased Long Term Service 

and Support * * * * X X

54. Beneficiary Travel * * * * X *

55. Supplies and Materials * * * * X *

56. State Home Per Diem Grants * * * * X *

General Services Administration

57. Rental of Space Program * * * * X *

Small Business Administration

58. Section 7(a) Loan Guaranty Purchases * * * * X *

59. Disbursements for Goods and Services * * * * * X
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant with IPERA for 

Fiscal Years 2016 and 2017

Page 39 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) below 

10 percent

Social Security Administration

60. Supplemental Security Income * * * * X *

61. Old-Age, Survivors, 

and Disability Insurance * * * * X *

Total agencies noncompliant

with criterion (marked X)

2 3 3 2 12 6

Total noncompliant programs as of 

fiscal year 2016 

13 7 5 10 38 12

Legend:

X = Program was noncompliant with IPERA criterion, as reported by the agency’s IG

* = IG did not report the program as noncompliant with IPERA criterion

AFR = agency financial report

CFO Act = Chief Financial Officers Act of 1990

IG = inspector general

IPERA = Improper Payments Elimination and Recovery Act of 2010

PAR = performance and accountability report

Source: GAO analysis of CFO Act agencies’ IG IPERA compliance reports for fiscal year 2016. | GAO-19-14

a

The Department of Defense (DOD) published the Improper Payment and Payment Recapture 

Programs section of its fiscal year 2016 AFR on November 15, 2016. However, it did not publish the 

AFR by March 1, 2017; therefore, the DOD IG determined the agency to be noncompliant with this 

IPERA criterion, as reported in the fiscal year 2016 IPERA compliance report.

b

The Department of Health and Human Services (HHS) does not agree with its IG’s assessment of 2 

criteria for the TANF program—published and met reduction target(s) and reported rate(s) below 10 

percent—which were reported by HHS IG as noncompliant for fiscal year 2016.

c

The Department of Housing and Urban Development does not agree with its IG’s assessment of the 

criterion to conduct program-specific risk assessments for the Government National Mortgage 

Association (Ginnie Mae) programs. The agency stated that although some of Ginnie Mae’s programs 

were noncompliant with this criterion in fiscal year 2016, not all of its programs were noncompliant.

Table 6: CFO Act Agency Programs That IGs Reported as Noncompliant with IPERA Criteria for Fiscal Year 2017

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) 

below 10 

percent

U.S. Department of Agriculture

1. Farm Service Agency Noninsured Crop 

Disaster Assistance Program * * * * X *

2. Food and Nutrition Service (FNS) 

Supplemental Nutrition Assistance 

Program * * X * * *

3. FNS Child and Adult Care Food Program * * X * * *
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant with IPERA for 

Fiscal Years 2016 and 2017

Page 40 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) 

below 10 

percent

U.S. Department of Agriculture

4. FNS National School Lunch Program * * * * X X

5. FNS School Breakfast Program * * * * X X

6. FNS Special Supplemental 

Nutrition Program for Women, 

Infants, and Children * * * * X *

Department of Commerce

7. Disaster Relief Appropriations Act * * * * X *

Department of Defensea

8. U.S. Army Corps of Engineers 

(USACE) Commercial Pay X * X X X *

9. Navy Commercial Bill Pay 

Office - Naples X * * * * *

10. Defense Finance and Accounting 

Service Commercial Pay X * X * * *

11. USACE Travel Pay X * * * X *

12. Military Health Benefits X * X X * *

13. Military Pay X * * X * *

14. Civilian Pay X * * * * *

15. Military Retiree and Annuitant Benefit 

Payments X * * X X *

16. Travel Pay X * X X X *

Department of Education

17. Pell Grant * * * * X *

Department of Health and Human Services

18. Temporary Assistance 

for Needy Families * * X X * *

19. Medicaid * * * * X X

20. Children’s Health Insurance Program * * * * X *

21. Foster Care * * * * X *

Department of Homeland Security

22. U.S. Customs and Border Protection 

Refund & Drawback * * * * X *
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant with IPERA for 

Fiscal Years 2016 and 2017

Page 41 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) 

below 10 

percent

Department of Homeland Security

23. U.S. Coast Guard Acquisition, 

Construction, and Improvement and 

Operating Expense: Hurricane Sandy 

Disbursements 

* * * * X *

Department of Housing and Urban Development

24. Rental Housing Assistance Programs * * X * * *

25. Community Development Block Grant 

entitlement grant * * X * * *

26. Federal Housing Administration 

Single Family Insurance 

Claims Program * * X * * *

27. Disaster - Federal Emergency 

Management Agency, Disaster 

Housing Assistance Program * X * * * *

28. U.S. Department of Transportation Surface 

Transportation Project * X * * * *

29. HOME Investment Partnerships Program 

(HOME) * X X * * *

30. Housing Trust Fund * X * * * *

31. Hurricane Ike, Other Disasters * X * * * *

32. Self-Help and Assistance 

Homeownership * X * * * *

33. Master Subservicer 

Default Activity * X * * * *

34. American Recovery and 

Reinvestment Act - Energy and 

Green Retrofit Loan Financing * X * * * *

35. Emergency Home Loan 

Program (EHLP) * X * * * *

36. EHLP - Direct Loan 

Financing Account * X * * * *

37. Homeownership and Rental Housing 

Solutions Grant Assistance, Section 236 * X * * * *

38. Housing Counseling * X * * * *

39. Housing for Special Populations - Capital 

Advance Portion of Expenditures, Section 

202 * X * * * *

40. Housing for the Elderly and 

Handicapped * X * * * *
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant with IPERA for 

Fiscal Years 2016 and 2017

Page 42 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) 

below 10 

percent

Department of Labor

41. Unemployment Insurance Benefit * * * * X X

Department of Transportation

42. Federal Transit Administration 

Emergency Relief Program -

Disaster Relief Appropriations Act, 

2013 (DRAA) Program 

* * * * X *

43. Office of Inspector General 

DRAA Activity * * * * X *

Department of the Treasury

44. Earned Income Tax Credit * * * * * X

Department of Veterans Affairs

45. Civilian Health and Medical 

Program of the Department 

of Veterans Affairs * * * * X *

46. Community Care * * * * X X

47. Purchased Long Term Service 

and Support * * * * X X

48. Beneficiary Travel * * * * X X

49. Supplies and Materials * * * * X X

50. Communications, Utilities, 

and Other Rents * * * * * X

51. Prosthetics * * * * * X

52. Post-9/11 GI Bill * * * * X *

53. Pension * * * * X *

54. Medical Care Contracts 

and Agreements * * * * * X

General Services Administration

55. Rental of Space Program * * * * X *
Appendix III: CFO Act Agencies and Programs 

Reported as Noncompliant with IPERA for 

Fiscal Years 2016 and 2017

Page 43 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Agencies and 

programs

Published 

information 

in PAR/AFR

Conducted 

programspecific risk 

assessment(s)

Published 

estimate(s)

Published 

corrective 

action 

plan(s)

Published 

and met 

reduction 

target(s)

Reported 

rate(s) 

below 10 

percent

Small Business Administration

56. Section 7(a) Loan Guaranty 

Purchases * * * * X *

57. Disaster Direct Loan Program * * * * X X

Social Security Administration

58. Supplemental Security Income * * * * X *

Total agencies noncompliant

with criterion (marked X)

1 1 4 2 12 6

Total noncompliant programs 

as of fiscal year 2017

9 14 11 6 29 13

Legend:

X = Program was noncompliant with IPERA criterion, as reported by the agency’s IG

* = IG did not report the program as noncompliant with IPERA criterion

AFR = agency financial report

CFO Act = Chief Financial Officers Act of 1990

IG = inspector general

IPERA = Improper Payments Elimination and Recovery Act of 2010

PAR = performance and accountability report

Source: GAO analysis of CFO Act agencies’ IG IPERA compliance reports for fiscal year 2017. | GAO-19-14

a

The Department of Defense (DOD) published a Payment Integrity section in its fiscal year 2017 AFR. 

However, it did not publish all required information; therefore, the DOD IG determined the agency to 

be noncompliant with this IPERA criterion, as reported in the fiscal year 2017 IPERA compliance 

report.
Appendix IV: CFO Act Agencies with Programs 

Reported by Their IGs as Noncompliant for 2 

or More Consecutive Years, as of Fiscal Years 

2016 and 2017

Page 44 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Table 7 details the Chief Financial Officers Act of 1990 (CFO Act) 

agencies and programs reported by their inspectors general as 

noncompliant under the Improper Payments Elimination and Recovery 

Act of 2010 (IPERA) for 2 or more consecutive years, as of fiscal years 

2016 and 2017. We previously reported on CFO Act agencies’ reported 

compliance for fiscal year 2015.1

Table 7: CFO Act Agencies and Programs Reported or Acknowledged by Their IGs as Noncompliant for 2 or More 

Consecutive Years, as of Fiscal Years 2016 and 2017

Consecutive 

years of reported 

noncompliance as 

of fiscal year

Agencies Noncompliant programs 2016 2017

U.S. Department 

of Agriculture 

Food and Nutrition Service (FNS) Supplemental Nutrition Assistance Program 2 3

Farm Service Agency (FSA) Livestock Forage Disaster Program 2 NA

FSA Supplemental Revenue Assistance Payments 2 NA

FNS Child and Adult Care Food Program 6 7

FNS National School Lunch Program 6 7

FNS School Breakfast Program 6 7

FNS Special Supplemental Nutrition Program for Women, Infants, and Children 6 7

Department 

of Defense 

Defense Finance and Accounting Service Commercial Pay 1 2

Civilian Pay 1 2

Military Health Benefits 1 2

Military Pay 1 2

Military Retiree and Annuitant Benefit Payments 1 2

U.S. Army Corps of Engineers Travel Pay 1 2

Navy Commercial Bill Pay Office - Naples 1 2

Travel Pay 5 6

Department 

of Education

Pell Grant 1 2

Direct Loan 3 NA

Department of Health 

and Human Services 

Foster Care 1 2

Medicare Advantage (Part C) 2 NA

Children’s Health Insurance Program 2 3

Medicaid 3 4

 1

GAO, Improper Payments: Additional Guidance Could Provide More Consistent 

Compliance Determinations and Reporting by Inspectors General, GAO-17-484 

(Washington, D.C.: May 31, 2017). 

Appendix IV: CFO Act Agencies with 

Programs Reported by Their IGs as 

Noncompliant for 2 or More Consecutive 

Years, as of Fiscal Years 2016 and 2017
Appendix IV: CFO Act Agencies with Programs 

Reported by Their IGs as Noncompliant for 2 

or More Consecutive Years, as of Fiscal Years 

2016 and 2017

Page 45 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Consecutive 

years of reported 

noncompliance as 

of fiscal year

Agencies Noncompliant programs 2016 2017

Medicare Fee-for-Service (Parts A and B) 5 NA

Temporary Assistance for Needy Families 6 7

Department of 

Homeland Security 

U.S. Customs and Border Protection Refund & Drawback 2 3

Federal Emergency Management Agency (FEMA) - Assistance to Firefighters Grant 2 NA

FEMA - Public Assistance 3 NA

FEMA - Vendor Pay 3 NA

Department of Housing 

and Urban Development 

Government National Mortgage Association programsa 2 NA

Rental Housing Assistance Programs 2 3

Department of Labor Unemployment Insurance Benefit 6 7

Department of the 

Treasury 

Earned Income Tax Credit 6 7

Department of 

Veterans Affairs 

Civilian Health and Medical Program of the Department of Veterans Affairs 1 2

Community Care 2 3

Purchased Long Term Service and Support 2 3

Beneficiary Travel 2 3

Supplies and Materials 2 3

Small Business 

Administration 

Section 7(a) Loan Guaranty Purchases 1 2

Disbursements for Goods and Services 2 NA

General Services 

Administration

Rental of Space Program 1 2

Social Security 

Administration 

Old-Age, Survivors, and Disability Insurance 2 NA

Supplemental Security Income 6 7

Total programs reported noncompliant for 2 consecutive years, as of fiscal years 2016 and 2017 15 12

Total programs reported noncompliant for 3 or more consecutive years, as of fiscal years 2016 and 2017 14 18

Legend:

CFO Act = Chief Financial Officers Act of 1990

IG = inspector general

IPERA = Improper Payments Elimination and Recovery Act of 2010

NA = Not applicable because IGs did not report program as noncompliant as of fiscal year 2016 or noncompliant as of fiscal year 2017

Source: GAO analysis of CFO Act agencies’ IG IPERA compliance reports for fiscal years 2016 and 2017. | GAO-19-14

a

The Department of Housing and Urban Development does not agree with its IG’s reporting of the 

Government National Mortgage Association programs as noncompliant for 2 consecutive years, as of 

fiscal year 2016.
Appendix V: Comments from the Department 

of Homeland Security Office of Inspector 

General

Page 46 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Appendix V: Comments from the Department 

of Homeland Security Office of Inspector 

General
Appendix VI: Comments from the Social 

Security Administration

Page 47 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Appendix VI: Comments from the Social 

Security Administration
Appendix VII: Comments from the United 

States Agency for International Development

Page 48 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Appendix VII: Comments from the United 

States Agency for International Development
Appendix VIII: GAO Contact and Staff 

Acknowledgments

Page 49 GAO-19-14 Fiscal Years 2016 and 2017 IPERA Compliance

Beryl H. Davis, (202) 512-2623 or davisbh@gao.gov

In addition to the contact named above, Michelle Philpott (Assistant 

Director), Matthew Valenta (Assistant Director), Vivian Ly (Auditor in 

Charge), Juvy Chaney, John Craig, Caitlin Cusati, Francine DelVecchio, 

Patrick Frey, Maria Hasan, Maxine Hattery, Jason Kelly, Jim Kernen, 

Jason Kirwan, Sharon Kittrell, Lisa Motley, Heena Patel, Anne RhodesKline, and Kailey Schoenholtz made key contributions to this report.

Appendix VIII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102476)
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