FEDERAL MARITIME COMMISSION

800 North Capitol Street, N.W.

Washington, DC 20573 

Inspector General

TO: Chairman Maffei

Commissioner Dye 

Commissioner Sola 

Commissioner Bentzel

Commissioner Vekich

FROM: Jon Hatfield

Inspector General 

DATE: May 13, 2024 

SUBJECT: Improper Payments Compliance Report for Fiscal Year 2023 

Results in Brief

This report communicates the results of the Federal Maritime Commission (FMC) Office 

of Inspector General’s (OIG) annual review of the FMC’s compliance with reporting and 

performance requirements regarding improper payments. For fiscal year (FY) 2023, the OIG 

concluded the FMC complied with all the requirements that are applicable to the agency for 

improper payment reporting. According to Office of Management and Budget (OMB) guidance, 

compliance with the Payment Integrity Information Act of 2019 (PIIA) means that the agency met 

the following six requirements, as appropriate: 

Requirements for PIIA Compliance Did the Agency 

Comply?

1a Published payment integrity information with the annual financial 

statement

Yes

1b Posted the annual financial statement and accompanying materials on 

the agency website

Yes

2a Conducted improper payment (IP) risk assessments for each program 

with annual outlays greater than $10,000,000 at least once in the last 

three years

Yes

2b Adequately concluded whether the program is likely to make IPs and 

unknown payments (UPs) above or below the statutory threshold

Yes

3 Published IP and UP estimates for programs susceptible to significant 

IPs in the accompanying materials to the annual financial statement

N/A1

4 Published corrective action plans for which an estimate above the 

statutory threshold was published in the accompanying materials to the 

annual financial statement 

N/A1

1 Requirement is not applicable because the FMC determined in its 2023 risk assessment that the agency’s programs 

are not susceptible to significant improper payments. FMC’s next required risk assessment is 2026.
2

5a Published IP and UP reduction targets for which an estimate above the 

statutory threshold was published in the accompanying materials to the 

annual financial statement

N/A1

5b Has demonstrated improvements to payment integrity or a tolerable IP 

and UP rate

N/A1

5c Has developed a plan to meet the IP and UP reduction target N/A1

6 Reported an IP and UP estimate of less than 1% for each program for 

which an estimate was published in the accompanying materials to the 

annual financial statement

N/A1

During our review, we noted two issues where the FMC could improve its improper 

payment reporting process. The OIG concluded that none of the issues affected compliance nor 

altered the payment integrity information reported by the FMC. The OIG has prepared a separate 

management letter with a suggestion to the Chief Financial Officer to address the issues for future 

reporting.

Background

The Improper Payments Elimination and Recovery Act of 2010 (IPERA) (Public Law 111-

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

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

significant improper payments based on guidance provided by the Office of Management and 

Budget (OMB). In addition, section 3 of IPERA required inspectors general to review each 

agency’s improper payment reporting and issue an annual report. On March 2, 2020, the Payment 

Integrity Information Act of 2019 (PIIA) (Public Law 116-117) repealed IPERA (and other laws) 

but set forth similar improper payment reporting requirements, including an annual compliance 

report by inspectors general. The OIG completed this annual review based on guidance contained 

in OMB Circular A-123, Appendix C, Requirements for Payment Integrity Improvement (M-21-

19, March 2021); OMB Circular A-136, Financial Reporting Requirements (May 19, 2023); OMB 

Payment Integrity Question and Answer Platform; and the Council of the Inspectors General on 

Integrity and Efficiency, Guidance for Payment Integrity Information Act Compliance Reviews, 

October 19, 2023. 

The purpose of IPIA, as amended, and the related requirements, are to improve the federal 

government’s efforts to reduce and recover improper payments. An improper payment is any 

payment that should not have been made or that was made in an incorrect amount. Incorrect 

amounts are overpayments or underpayments that are made to eligible recipients. An improper 

payment also includes any payment that was made to an ineligible recipient or for an ineligible 

good or service, or payments for goods or services not received (except for such payments 

authorized by law). In addition, when an agency's review is unable to discern whether a payment 

was proper because of insufficient or lack of documentation, this payment must also be considered 

an improper payment.

Each agency inspector general is required to review improper payment reporting in their 

agency’s annual Performance and Accountability Report (PAR) or Agency Financial Report 

(AFR) and any accompanying materials to determine if the agency is in compliance with PIIA. 

1 Requirement is not applicable because the FMC determined in its 2023 risk assessment that the agency’s programs 

are not susceptible to significant improper payments. FMC’s next required risk assessment is 2026.
3

The OIG reviewed the agency’s Improper Payments Information Act section of FMC’s FY 2023

PAR posted on the agency’s website for compliance with PIIA, as well as the FMC’s 

PaymentAccuracy.gov data call submission. 

Conclusion

The OIG concluded the FMC is compliant for FY 2023. Specifically, the FMC is compliant 

with requirements 1a, 1b, 2a, and 2b. Requirements 3 through 6 are not applicable to the agency. 

The OIG is required to report these results to the Commission; the Senate Committee on Homeland 

Security and Governmental Affairs; the Senate Committee on Appropriations; the House of 

Representatives Committee on Oversight and Accountability; the House Committee on 

Appropriations; the Comptroller General; and OMB. 

If you have any questions or comments, please contact Parker Skaats (pskaats@fmc.gov) 

or myself (jhatfield@fmc.gov), or call (202) 523-5863 . Thank you.

Cc: Office of the Managing Director

Office of Budget and Finance

Office of the General Counsel