Farm Credit Administration

Office of Inspector General

Inspection Report 

Farm Credit Administration’s 

Compliance with the Payment 

Integrity Information Act of 2019 

for Fiscal Year 2022 

I-23-01 

February 22, 2023
1501 Farm Credit Drive, McLean, VA 22102 703-883-4030 www.fca.gov/about/inspector-general

February 22, 2023 

The Honorable Vincent G. Logan, Board Chairman and Chief Executive Officer

The Honorable Jeffery S. Hall, Board Member

The Honorable Glen R. Smith, Board Member

Farm Credit Administration

1501 Farm Credit Drive

McLean, Virginia 22102-5090

Dear Chairman Logan and Board Members Hall and Smith: 

The Office of Inspector General (OIG) completed an inspection on the Farm Credit Administration’s 

(FCA or Agency) compliance with the Payment Integrity Information Act of 2019 (PIIA) for Fiscal Year 

(FY) 2022. The objective of this inspection was to determine if FCA complied with the PIIA for FY 2022. 

We determined that FCA complied with PIIA requirements applicable to the Agency for FY 2022 and, 

based on the limited review performed, the Agency’s efforts to prevent and reduce improper payments 

appear to be reasonable. As required, FCA published a Performance and Accountability Report, which 

contained the financial statements for FY 2022. FCA also published payment integrity information in 

the report and posted the report on the Agency website. FCA also reported agency-level payment 

integrity results on the paymentaccuracy.gov site.

FCA also completed the required improper payment risk assessments and analyzed programs for 

susceptibility to improper payments. FCA completed the risk assessments in May 2021 and determined 

that all programs and activities were low risk and not susceptible to significant improper payments. The 

OIG did not identify any concerns with the conclusion that FCA was low risk for significant improper 

payments and that the programs are below the established thresholds for additional reporting 

requirements. 

In accordance with the PIIA and implementing guidance, the report will be provided to the 

Committee on Homeland Security and Governmental Affairs of the U.S. Senate, the Committee on 

Oversight and Reform of the U.S. House of Representatives, the Office of Management and 

Budget, and the Comptroller General.

We appreciate the courtesies and professionalism extended by FCA to our staff during the inspection. 

If you have any questions, we would be pleased to meet with you at your convenience. 

Respectfully,

Sonya K. Cerne 

Assistant Inspector General for Audits, Inspections, and Evaluations
Objective

The objective of this 

inspection was to determine 

if FCA complied with PIIA for 

FY 2022. 

Recommendations

Due to FCA’s compliance 

with the PIIA requirements, 

we did not make any

recommendations in this 

report.

Agency Response

The Agency elected to not 

provide formal comments 

to be included in the report. 

Why We Did This Inspection

Signed into law on March 2, 2020, the Payment Integrity Information Act of 

2019 (PIIA) was enacted to improve efforts to identify and reduce 

Governmentwide improper payments. PIIA sets forth improper payment 

reporting requirements for federal agencies, including an annual compliance 

review to be conducted by agency offices of inspectors general. 

How We Did This Inspection

To determine compliance with payment integrity requirements, we reviewed 

the Farm Credit Administration’s (FCA or Agency) Fiscal Year (FY) 2022 

Performance and Accountability Report (PAR) for improper payment and 

payment integrity information. We reviewed the improper payment risk 

assessments for outlay data, information considered in risk ratings, and the 

scoring for each area. We also reviewed FCA’s submissions into the Annual 

Improper Payments Dashboard.

What We Found

We determined that FCA complied with PIIA requirements applicable to the 

Agency for FY 2022 and, based on the limited review performed, the Agency’s 

efforts to prevent and reduce improper payments appeared to be reasonable. 

FCA published a PAR for FY 2022, included applicable payment integrity 

reporting information, and posted the FY 2022 PAR on the Agency’s website.

FCA also reported agency-level payment integrity results on the 

paymentaccuracy.gov site. 

FCA also completed the required improper payment risk assessments and 

analyzed programs for susceptibility to improper payments. FCA completed the 

risk assessments in May 2021 and determined that all programs and activities 

were low risk and not susceptible to significant improper payments. As outlined 

in PIIA, FCA is required to complete risk assessments every three years.

As none of the programs or activities assessed by FCA were determined to be 

susceptible to significant improper payments, the Agency was not required to: 

publish improper payment and unknown payment estimates, corrective action 

plans, or reduction targets; demonstrate improvements to payment integrity or 

reach tolerable improper payment and unknown payment rates; develop plans 

to meet reduction targets; or report payment estimates of less than 10 percent.

EXECUTIVE SUMMARY

FCA’s Compliance with the Payment Integrity Information 

Act of 2019 for Fiscal Year 2022 

Report No. I-23-01 February 22, 2023
Table of Contents

Background.................................................................................................................................... 1

Farm Credit Administration .................................................................................................................................... 1

Payment Integrity ....................................................................................................................................................... 1

OIG Compliance Review Requirements ............................................................................................................. 1

Objective, Scope, and Methodology ........................................................................................... 2

Objective........................................................................................................................................................................ 2

Scope............................................................................................................................................................................... 2

Methodology................................................................................................................................................................ 3

Inspection Results ......................................................................................................................... 4

Acronyms ....................................................................................................................................... 6
1 

BACKGROUND

Farm Credit Administration

The Farm Credit Administration (FCA or Agency) is an independent federal agency responsible for 

regulating and supervising the Farm Credit System (System). The Agency is responsible for 

ensuring that all System institutions are safe, sound, and dependable sources of credit and related 

services for all creditworthy and eligible persons in agriculture and rural America. To support the 

mission, FCA’s Office of the Chief Financial Officer is responsible for reporting the agency’s 

financial results, providing financial management policy advice, and managing federal financial 

management requirements. 

Payment Integrity 

An important part of financial management for every federal agency is to ensure that improper 

payments are prevented and reduced. On March 2, 2020, the Payment Integrity Information Act 

of 2019 (PIIA) repealed several improper payment and other related laws. PIIA aims to improve 

efforts to identify and reduce Governmentwide improper payments and sets forth improper 

payment1 reporting requirements for federal agencies, including an annual compliance review to 

be conducted by agency offices of inspectors general (OIGs). 

On March 5, 2021, the U.S. Office of Management and Budget (OMB) issued a revised version of

Appendix C to OMB Circular A-123, Requirements for Payment Integrity Improvement, which 

provides guidance on PIIA implementation. The goal of this revised version is to transform the

payment integrity compliance framework and create a more comprehensive and meaningful set 

of requirements. OMB Circular A-123, Appendix C also sets forth guidance on the annual OIG 

compliance reviews.

OIG Compliance Review Requirements 

In accordance with PIIA, OIGs were directed to consult (in addition to OMB Circular A-123, 

Appendix C), guidance issued by the Council of the Inspectors General on Integrity and Efficiency 

(CIGIE) for specific procedures on how they should determine compliance with PIIA. Guidance 

further requires OIGs to perform the compliance review as informed by OMB Circular A-136, OMB 

Annual Data Call Instructions, and OMB’s Payment Integrity Question and Answer Platform.

Under this guidance, OIGs must determine compliance with specific PIIA requirements. 

Compliance is defined by whether an agency has: 

1 PIIA defines an improper payment as any payment that should not have been made or that was made in 

an incorrect amount, including an overpayment or underpayment, under a statutory, contractual, 

administrative, or other legally applicable requirement. If a program cannot discern whether a payment is 

proper or improper, the payment is considered an unknown payment. 
2 

• Published payment integrity information with the annual financial statement;

• Posted the annual financial statement and accompanying materials on the agency website;

• Conducted improper payment risk assessments for each program with annual outlays 

greater than $10,000,000 at least once in the last three years;

• Adequately concluded whether the program is likely to make improper payments and 

unknown payments above or below the statutory threshold;

• Published improper payment and unknown payment estimates for programs susceptible 

to significant improper payments and unknown payments in the accompanying materials 

to the annual financial statement;

• Published corrective action plans for each program for which an estimate above the 

statutory threshold was published in the accompanying materials to the annual financial 

statement; 

• Published an improper payment and unknown payment reduction target for each program 

for which an estimate above the statutory threshold was published in the accompanying 

materials to the annual financial statement; 

• Demonstrated improvements to payment integrity or reached a tolerable improper 

payment and unknown payment rate; 

• Developed a plan to meet the improper payment and unknown payment reduction target; 

and

• Reported an improper payment and unknown payment estimate of less than 10 percent 

for each program for which an estimate was published in the accompanying materials to 

the annual financial statement. 

In reporting compliance with the above criteria, guidance advises OIGs to use a compliant/noncompliant approach that takes into account whether its current work, prior work, and professional 

judgment lead the OIG to conclude that it has concerns regarding completeness or inaccuracies 

that would significantly alter the payment integrity information reported by the agency.

OBJECTIVE, SCOPE, AND METHODOLOGY

Objective 

The objective of this inspection was to determine if FCA complied with PIIA for Fiscal Year (FY) 

2022. 

Scope

The scope of the inspection was limited to compliance for FY 2022. The inspection was conducted

at FCA’s headquarters in McLean, Virginia from January to February 2023. 
3 

Methodology

We took the following steps to accomplish the objective:

• Identified and reviewed applicable laws, regulations, policy, procedures, guidance, and 

other background information applicable to the objective.

• Identified and reviewed applicable internal FCA policies and procedures.

• Reviewed prior reviews related to the inspection objective.

Tests Performed

 Reviewed FCA’s FY 2022 Performance and Accountability Report (PAR) for improper 

payment and payment integrity information. We compared the information to the 

requirements set forth in PIIA and implementing guidance and verified posting of the FY 

2022 PAR to the agency website.

 Reviewed FCA’s submission in paymentaccuracy.gov for FY 2022. We reviewed the 

Agency’s reporting in the Annual Improper Payments Dashboard for the identification and 

recovery of overpayments and other payment integrity data.

 Reviewed improper payment risk assessments conducted in FY 2021. We reviewed the risk 

assessments for outlay data, information considered in risk ratings, and each area’s risk 

score. This information was not changed from the prior year’s compliance testing, and the 

next set of risk assessments is not due until FY 2024. 

 Summarized compliance ratings for the applicable sections of payment integrity 

requirements. 

Quality Standards for Inspection and Evaluation

This inspection was performed in accordance with CIGIE’s Quality Standards for Inspection and 

Evaluation. These standards require that we plan and perform the inspection to obtain sufficient

and appropriate evidence that provides a reasonable basis for our findings, conclusions, and 

recommendations. We assessed internal controls and compliance with laws and regulations to the 

extent necessary to satisfy the objective. Because our review was limited, it would not necessarily 

have disclosed all internal control deficiencies that may have existed at the time of our inspection. 

We assessed the information and data collected during the inspection and determined it was 

sufficiently reliable and valid for use in meeting the inspection objective. We assessed the risk of 

fraud related to our inspection objective while evaluating evidence and had no matters come to 

our attention indicating fraud or illegal acts were occurring. Overall, we believe the evidence 

obtained is appropriate and sufficient to provide a reasonable basis for our findings and 

conclusions based on the inspection objective.
4 

INSPECTION RESULTS

We determined that FCA complied with PIIA requirements applicable to the Agency for FY 2022 

and, based on the limited review performed, the Agency’s efforts to prevent and reduce improper 

payments appeared to be reasonable. 

• FCA published a PAR for FY 2022 in November 2022 that included the annual financial 

statements and applicable payment integrity reporting information. The Agency also 

posted the FY 2022 PAR on the Agency’s website. 

• FCA reported in the Annual Improper Payments Dashboard on paymentaccuracy.gov on 

the identification and recovery of overpayments and other payment integrity data.

• FCA completed the required improper payment risk assessments and analyzed programs 

for susceptibility to improper payments. As part of the risk assessments conducted for the 

period ended September 30, 2020, FCA assessed five programs and activities: contract 

payments and invoices; purchase cards; travel cards; claims and vouchers; and payroll. FCA 

completed the risk assessments in May 2021 and determined that all programs and 

activities were low risk and not susceptible to significant improper payments. The Agency 

is not required to complete risk assessments again until FY 2024.

• As none of the programs or activities assessed by FCA were determined to be susceptible 

to significant improper payments, the Agency was not required to publish improper 

payment and unknown payment estimates, publish corrective action plans, publish 

reduction targets, demonstrate improvements to payment integrity or reach tolerable 

improper payment and unknown payment rates, develop plans to meet reduction targets, 

or report payment estimates of less than 10 percent.

The following table summarizes FCA’s compliance with payment integrity reporting requirements 

by program. 

Table 1: FCA Compliance with FY 2022 PIIA Requirements

CONTRACT 

PAYMENTS 

AND 

INVOICES

PURCHASE 

CARD

TRAVEL 

CARD

CLAIMS 

AND 

VOUCHERS

PAYROLL

Published payment integrity information 

with the annual financial statement Compliant Compliant Compliant Compliant Compliant

Posted the annual financial statement 

and accompanying materials on the 

agency website

Compliant Compliant Compliant Compliant Compliant
5 

Conducted improper payment risk 

assessments for each program with 

annual outlays greater than $10,000,000 

at least once in the last three years

Compliant Compliant Compliant Compliant Compliant

Adequately concluded whether the 

program is likely to make improper 

payments and unknown payments above 

or below the statutory threshold

Compliant Compliant Compliant Compliant Compliant

Published improper payment and 

unknown payment estimates for 

programs susceptible to significant 

improper payments and unknown 

payments in the accompanying materials 

to the annual financial statement

N/A N/A N/A N/A N/A 

Published corrective action plans for each 

program for which an estimate above the 

statutory threshold was published in the 

accompanying materials to the annual 

financial statement

N/A N/A N/A N/A N/A 

Published an improper payment and 

unknown payment reduction target for 

each program for which an estimate 

above the statutory threshold was 

published in the accompanying materials 

to the annual financial statement

N/A N/A N/A N/A N/A 

Demonstrated improvements to payment 

integrity or reached a tolerable improper 

payment and unknown payment rate

N/A N/A N/A N/A N/A 

Developed a plan to meet the improper 

payment and unknown payment 

reduction target

N/A N/A N/A N/A N/A 

Reported an improper payment and 

unknown payment estimate of less than 

10% for each program for which an 

estimate was published in the 

accompanying materials to the annual 

financial statement

N/A N/A N/A N/A N/A 

Because FCA was in compliance with the PIIA requirements, we did not have recommendations in 

this report. The Agency elected to not provide formal comments to be included in the report and 

waived the exit conference. 
6 

ACRONYMS

CIGIE Council of the Inspectors General on Integrity and Efficiency

FCA or Agency Farm Credit Administration

FY Fiscal Year

OMB U.S. Office of Management and Budget

OIG Office of Inspector General

PAR Performance and Accountability Report

PIIA Payment Integrity Information Act of 2019

System Farm Credit System
REPORT FRAUD, WASTE, ABUSE, &

MISMANAGEMENT

Fraud, waste, abuse, and mismanagement in government concerns 

everyone: Office of Inspector General staff, FCA employees, Congress, 

and the general public. We actively solicit allegations of any inefficient 

and wasteful practices, fraud, and mismanagement related to FCA 

programs and operations. You can report allegations to us in several 

ways:

Phone: (800) 437-7322 (Toll-Free)

(703) 883-4316

Email: fca-ig-hotline@rcn.com

Mail: 1501 Farm Credit Drive

McLean, VA 22102-5090

To learn more about reporting wrongdoing to the OIG, please visit our 

website at https://www.fca.gov/about/inspector-general.