Improper Payments: Progress Made but Challenges Remain in Estimating and Reducing Improper Payments
Published: 2009-04-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: GAO's work over the past several years has demonstrated that improper payments are a long-standing, widespread, and significant problem in the federal government. The Improper Payments Information Act of 2002 (IPIA) has increased visibility over improper payments by requiring executive branch agency heads, using guidance from the Office of Management and Budget, to identify programs and activities susceptible to significant improper payments, estimate amounts improperly paid, and report on the amounts of improper payments and their actions to reduce them. This testimony addresses (1) progress made in agencies' implementation of IPIA for fiscal year 2008, and (2) several major challenges that continue to hinder full reporting of IPIA information. GAO was also asked to provide an overview of Medicare and Medicaid programs' implementation of IPIA. This testimony is based primarily on GAO products, Office of Inspector General (OIG) audit reports, and agencies' fiscal year 2008 reported improper payment information, including information reported by the Department of Health and Human Service's (HHS) Centers for Medicare and Medicaid Services (CMS). GAO also analyzed fiscal year 2008 governmentwide improper payment information to identify trends and reviewed Medicare and Medicaid programs' reported actions to identify, estimate, and reduce improper payments.
section_title: What GAO Found
paragraphs: Agencies reported improper payment estimates of $72 billion for fiscal year 2008, which represented about 4 percent of the $1.8 trillion of reported outlays for the related programs. This represents a significant increase from the fiscal year 2007 estimate attributable to (1) a $12 billion increase in the Medicaid program's estimate and (2) 10 newly reported programs with improper payment estimates totaling about $10 billion. (1) Progress made in estimating and reducing improper payments. The governmentwide improper payment estimates rose about $23 billion from fiscal year 2007 to 2008. This represents a positive step to improve transparency over the full magnitude of the federal government's improper payments. Further, of the 35 agency programs reporting improper payment estimated error rates for each of the 5 fiscal years since implementation of IPIA--2004 through 2008--24 programs (or about 69 percent) reported reduced error rates when comparing fiscal year 2008 error rates to fiscal year 2004 error rates. Also, the number of programs with error rate reductions totaled 35 when comparing fiscal year 2008 error rates to fiscal year 2007 rates. (2) Challenges remain in meeting the goals of IPIA governmentwide. The total improper payment estimate does not yet reflect the full scope of improper payments across executive branch agencies; noncompliance issues with IPIA continue; and agencies continue to face challenges in the design or implementation of internal controls critical to identifying and preventing improper payments. The fiscal year 2008 total improper payment estimate of $72 billion reported for fiscal year 2008 did not include any estimate for ten programs--including the Medicare Prescription Drug Benefit program--with fiscal year 2008 outlays totaling about $61 billion that were identified as susceptible to significant improper payments. Over half of the agencies' OIGs identified management or performance challenges that could increase the risk of improper payments, including challenges related to effective internal controls. (3) Medicare and Medicaid programs' implementation of IPIA and its challenges. Medicare and Medicaid comprise 50 percent of reported governmentwide improper payments in fiscal year 2008. HHS reported improper payment amounts of $10.4 billion in Medicare Fee-for-Service and $6.8 billion in Medicare Advantage. HHS also reported in its agency financial report that it issued its first full-year Medicaid improper payment rate estimate of 10.5 percent, or $18.6 billion for the federal share of expenditures for fiscal year 2008. This Medicaid improper payment estimate represents the largest amount that any federal agency reported for a program in fiscal year 2008. While CMS has taken steps to enhance its program integrity efforts, further work remains to put in place the internal controls necessary to effectively identify and detect improper payments. For example, GAO's work on Medicare's home health care administration and enrollment of durable medical equipment suppliers found weaknesses that exposed the program to significant improper payments. The magnitude of Medicaid improper payments indicates that CMS and the states face significant challenges in addressing the program's vulnerabilities in estimating national improper payment rates for diverse state-administered programs.

section_title: Letter
paragraphs: Thank you for the opportunity to be here today to discuss the  governmentwide problem of improper payments in federal programs and  activities and executive branch agencies’ efforts to address key  requirements of the Improper Payments Information Act of 2002 (IPIA).  Since fiscal year 2000, we have issued a number of reports and testimonies  aimed at raising the level of attention and corrective actions surrounding  improper payments. Our work over the past several years has  demonstrated that improper payments have been a long-standing,  widespread, and significant problem in the federal government. IPIA has  increased visibility over improper payments by requiring executive  branch agency heads to identify programs and activities susceptible to  significant improper payments, estimate amounts improperly paid un those programs and activities, and report on the amounts of improper  payments and their actions to reduce them. As the steward of taxpayer  dollars, the federal government is accountable for how its agencies an d  grantees spend hundreds of billions of taxpayer dollars annually and is  responsible for safeguarding those funds against improper payments as  well as having mechanisms in place to recoup those funds when impro payments occur.
The Office of Management and Budget (OMB) has played a key role in the  oversight of the governmentwide improper payments problem by  providing leadership on financial management improvement initiatives.  OMB continues its commitment to address governmentwide improper  payments by establishing guidance for federal agencies on improper  payment reporting, and by working with agencies to establish corrective  action plans and address their root causes. OMB also reports annually on  agencies’ efforts to address IPIA requirements.
Today, my testimony will focus on three key areas:    progress federal agencies have made in estimating and reducing  improper payments under IPIA for fiscal year 2008, several major challenges that continue to hinder full reporting of  improper payment information, and  an overview of Medicare and Medicaid programs’ implementation of  IPIA.
My testimony today draws primarily from prior GAO reports and  testimonies conducted in accordance with generally accepted government  auditing standards. We also reviewed agencies’ fiscal year 2008  performance and accountability reports (PAR), agency financial reports  (AFR), annual reports, and Office of Inspector General (OIG) audit  reports. In addition, we reviewed the Department of Health and Human  Service’s (HHS) AFR and Centers for Medicare and Medicaid Services’  (CMS) financial report. Further, we analyzed fiscal year 2008  governmentwide improper payment information to identify trends and  reviewed Medicare and Medicaid programs’ reported actions to identify,  estimate, and reduce improper payments. Generally accepted government  auditing 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.
subsections: section_title: Progress Made in Estimating and Reducing Improper Payments
paragraphs: Federal agencies reported improper payment estimates of $72 billion for  fiscal year 2008, which represented about 4 percent of the $1.8 trillion of  reported outlays for the related programs and a $23 billion increase from the  fiscal year 2007 estimate of about $49 billion. These efforts represent a  positive step to improve transparency over the full magnitude of federal  improper payments so that appropriate corrective actions can be put in place.  This increase was primarily attributable to (1) a $12 billion increase in the  Medicaid program’s estimate for its Fee-for-Service and managed care  payments and payments related to incorrect eligibility determinations; and (2)  10 newly reported programs with improper payment estimates totaling about  $10 billion. Of these 10 programs, we identified 4 that had been required by  OMB to report selected improper payment information beginning with fiscal  year 2003 budget submissions prior to the passage of IPIA. In total, these 4  programs represented $3.1 billion, or 31 percent, of the approximately $10  billion in newly reported programs. Further, we noted that agencies  consistently identified new programs or activities as risk-susceptible after the  first year of IPIA implementation:  fiscal year 2005—17 new programs or activities,  fiscal year 2006—15 new programs or activities,  fiscal year 2007—19 new programs or activities, and  fiscal year 2008—10 new programs or activities.
The $72 billion estimate of improper payments federal agencies reported  in fiscal year 2008 encompasses 78 programs spread among 22 agencies  (see app. I for further details) and represents about 2.4 percent of total  fiscal year 2008 federal executive branch outlays of nearly $3 trillion. In  addition, the majority of the $72 billion of reported improper payments in  fiscal year 2008 is accounted for by ten programs, as shown in figure 1.  Specifically, the ten programs account for about $63 billion or  approximately 88 percent of the total estimate.
Seven of the 10 programs with the largest improper payment estimates are  either means-tested programs, state-administered programs, or both. A  common control used by these programs to ensure payment accuracy  includes verifying the financial eligibility of the applicant. However, our  previous work has shown that the financial eligibility of an applicant can  be difficult to verify in means-tested programs, increasing the risk of  payment to an ineligible recipient. Specifically, there are differences  related to detailed aspects of the income rules such as whose income in a  household is counted and the types of income included or excluded in  either whole or part. For example, the Supplemental Nutrition Assistance  Program (previously Food Stamp Program) considers the income of the  entire household, including children aged 18 and over who are not  students, in calculating income; whereas several other programs either do  not include children’s income or exclude portions of their income from  consideration. Similar differences exist in state-administered programs as  a number of states define additional and unique eligibility requirements  beyond what is required at the federal level. Collectively, these multiple  variations in approaches to identifying recipients’ income for determining  program eligibility are likely contributing factors to the high dollar value of  improper payments that exist within these programs.
Federal agencies continued to report progress in reducing improper  payments in their programs and activities. Of the 35 agency programs  reporting improper payment estimated error rates for each of the 5 fiscal  years—2004 through 2008—24 programs, or about 69 percent had reduced  error rates when comparing fiscal year 2008 error rates to the initial error  rates reported for fiscal year 2004. Further, we found the number of  programs with error rate reductions totaled 35 when comparing fiscal  years 2008 and 2007 error rates. For example, the error rate of the U.S.
Department of Labor’s (Labor) Unemployment Insurance (UI) program  decreased from 10.3 percent in fiscal year 2007 to 9.96 percent in fiscal  year 2008. Labor reported that the leading cause of UI overpayments  resulted from claimants who returned to work, yet continued to claim UI  benefits. Early detection of these overpayments allows agencies to stop  payments sooner and to recover these overpayments more expeditiously.  Labor reported that matching Social Security numbers of UI claimants  with the Department of Health and Human Services’ National Directory of  New Hires database is the most effective tool to identify UI program  improper payments and had prevented about $93 million of UI  overpayments during fiscal year 2008.
section_title: Challenges Remain in Meeting IPIA
paragraphs: While federal agencies have shown progress, major challenges remain in  meeting the goals of IPIA and ultimately provide reasonable assurance as  to the integrity of payments. Specifically, while improved, the total  improper payment estimate reported in fiscal year 2008 does not yet  reflect the full scope of improper payments across executive branch  agencies; noncompliance issues with IPIA implementation continue to  exist; and agencies continue to face challenges in the design or  implementation of internal controls to identify and prevent improper  payments. Not all agencies have yet developed improper payment  estimates for all of the programs and activities they identified as  susceptible to significant improper payments. As shown in table 1, the  fiscal year 2008 total improper payment estimate of $72 billion did not  include any amounts for 10 risk-susceptible programs—including the  Medicare Prescription Drug Benefit program—with fiscal year 2008  outlays totaling about $61 billion.
For fiscal year 2008, a limited number of agency auditors reported on IPIA  implementation compliance issues as part of their financial statement  audit, although such reporting is not specifically required by IPIA.  Specifically, auditors for 4 of the 35 agencies included in our scope  reported on agencies’ noncompliance with IPIA. Agency auditors  reported noncompliance issues related to risk assessments, testing of  payment transactions, development of corrective action plans to reduce  improper payments, recovering improper payments, and inadequate  documentation. Fiscal year 2008 reflected the fifth year that auditors for  the Departments of Health and Human Services (HHS) and Homeland  Security (DHS) reported IPIA noncompliance issues, including not  estimating for all risk-susceptible programs, deficiencies related to testing  of payment transactions, and the lack of corrective action plans. Agency  auditors at the Department of Transportation (Transportation) and DOD  reported noncompliance with IPIA for a third year. For example,  Transportation auditors reported that they had not received sufficient  documentation by the time of PAR issuance to determine if the  department’s sampling plan used to estimate improper payments was  statistically valid. The auditors for DOD reported for fiscal year 2008, that  the department was still in the process of developing procedures to  identify improper payments and that its efforts to manage recovery audit  contracts had been largely unsuccessful.
As we previously testified before this Subcommittee, separate  assessments conducted by agency auditors provided a valuable  independent validation of agencies’ efforts to implement IPIA.  Independent assessments can also enhance an agency’s ability to identify  sound performance measures, monitor progress against those measures,  and help establish performance and results expectations. Without this type  of validation or other types of reviews performed by GAO and agency  OIGs, it is difficult to reliably determine the full magnitude of deficiencies  that may exist in agencies’ IPIA implementation efforts.
Agencies continue to face challenges in the design or implementation of  internal controls to identify and prevent improper payments. Over half of  the OIGs for agencies required to report under IPIA identified management  or performance challenges that could increase the risk of improper  payments, including challenges related to internal controls. Examples of  fiscal year 2008 challenges are highlighted below.
Department of Transportation—The OIG reported that its audits and  investigations continue to find oversight and control deficiencies  increasing vulnerability to improper payments, including fraud and  abuse, and other ethics issues involving agency officials and  contractors, including schemes related to bribery and kickbacks, bid  rigging, and over-billing of labor and materials.
Department of Education—The OIG reported that effective oversight of  the agency’s student federal assistance programs has been a long- standing and significant challenge. Specifically, the Education OIG  cited control issues related to insufficient numbers of personnel with  the necessary skills and ineffective oversight and monitoring of its  programs and participants, placing billions of taxpayer dollars at risk of  waste, fraud, abuse, and noncompliance.
Department of the Treasury—The OIG cited erroneous and improper  payments as the sixth top management challenge facing the Internal  Revenue Service (IRS). According to the OIG, erroneous and improper  and payments generally involve improperly paid refunds, tax return  filing fraud, or overpayments to vendors or contractors. The Treasury  OIG also reported some tax credits, such as the Earned Income Tax  Credit (EITC) and the Education Credit, provide opportunities for  abuse in income tax claims. The IRS receives a substantial number of  excessive or incorrect EITC claims. According to the OIG, the  exponential growth in fraud in processing year 2007 presented a  challenge for the IRS, which did not have the resources to handle the  volume. The OIG noted that if this trend continues over the next few  years, the IRS might issue an even greater number of improper refunds,  possibly resulting in a significantly increasing annual revenue loss to  the federal government.
section_title: Implementation of IPIA in Medicare and Medicaid Programs
paragraphs: The Department of Health and Human Services (HHS) annually reports on  improper payments in its Agency Financial Report (AFR). For fiscal year  2008, HHS reported improper payment estimates for several programs,  including Medicare and the Medicaid, which together provide health  insurance for one in four Americans. Collectively, HHS reported improper  payment estimates for Medicare and Medicaid totaling about $36 billion  for fiscal year 2008. (See figure 1.) This represents about 50 percent of  the total $72 billion in reported improper payments. The Centers for  Medicare and Medicaid Services (CMS), a component of HHS, administers  Medicare and oversees Medicaid at the federal level. CMS is responsible  for IPIA implementation for these programs. CMS reported it has taken  steps to address improper payment requirements for its Medicare and  Medicaid programs, but more work remains to measure annual improper  payments for all its risk-susceptible programs and to design and  implement effective internal controls to prevent improper payments.
subsections: section_title: Medicare
paragraphs: Medicare provides health insurance to roughly 44 million elderly and  disabled beneficiaries. As HHS’s largest program, it represented nearly  $400 billion or almost 60 percent of HHS’s outlays for fiscal year 2008. The  Medicare Program is comprised of Medicare Fee-for-Service (FFS) which  includes Hospital Insurance (Medicare Part A) and Supplementary Medical  Insurance (Medicare Part B), Medicare Advantage (Medicare Part C), and  Medicare Prescription Drug Benefit (Medicare Part D).
Medicare FFS represents the largest share of Medicare payments and  covers an array of items and services including hospital, skilled nursing  and home health care; physician services; ambulance services; and  medical equipment and supplies. CMS has a long-history of estimating  improper payments for its Medicare FFS program that predate IPIA.  Beginning in 1996, HHS’s Office of Inspector General (OIG) estimated  improper payments in the Medicare FFS program as part of its annual  financial statement audit. In fiscal year 2003, CMS assumed responsibility  for estimating Medicare FFS improper payments and modified the  methodology to improve error detection and provide more detailed  information on the errors. This coincided with the implementation of the  IPIA. For fiscal year 2008, Medicare FFS improper payment estimate  totaled $10.4 billion, or 3.6 percent of benefit payments for the prior year.  As part of its testing, CMS reported it determined whether the claim  payments complied with Medicare coverage, coding, and billing rules. In  its fiscal year 2008 AFR, HHS reported causes of improper payments  included provision of medically unnecessary services, incorrect coding,  and insufficient documentation.
Medicare Advantage is designed to provide health coverage through  private health plans for Medicare beneficiaries who choose to enroll in this  option. Fiscal year 2008 marks the first year that CMS reported estimated  improper payments for Medicare Advantage, with an error rate of 10.6  percent or $6.8 billion in estimated improper payments. While HHS’s AFR  states that medical record reviews were performed, they did not  specifically identify the types of attributes tested to identify the improper  payments. The causes of improper payments cited were errors in  transferring data, interpretation of data, payment calculations, and  incorrect diagnoses resulting in incorrect beneficiary risk scores.
Medicare Prescription Drug Benefit is an outpatient prescription drug  benefit for Medicare beneficiaries who opt to enroll. As we highlighted  earlier in this testimony, CMS had not yet estimated an error rate for its  Medicare Prescription Drug Benefit, which had total outlays of about $46  billion for fiscal year 2008.
section_title: Medicaid
paragraphs: The Medicaid program is a joint federal/state program, administered by  the states to provide health insurance to certain low income individuals.  Although it was required by OMB to report improper payment information  beginning with its fiscal year 2003 budget submission, CMS began  reporting estimated improper payments for this program in fiscal year  2007. For fiscal year 2008, CMS estimated improper payments for fee-for- service providers, managed care plans, and for ineligible recipients—and  reported an error rate of 10.5 percent or $18.6 billion as the federal share  of these improper payments. Among all federal programs reporting in  fiscal year 2008, Medicaid had the highest estimated dollar value of  reported improper payments. (See figure 1.) To estimate improper  payments for the Medicaid program, CMS developed a multi-faceted  strategy that included obtaining claim payment data from the 50 states and  the District of Columbia, utilizing a three-year state rotation cycle. Using  this methodology, CMS selects 17 states each year to generate and report a  national improper payment estimate for Medicaid. CMS reported that the  most common causes of Medicaid improper payments resulting from its  medical and data processing reviews included insufficient or lack of  documentation (which accounted for 90 percent of the errors), pricing  errors, and non-covered services. As reported in the fiscal year 2008 AFR,  HHS expressed the view that the high percentage of errors related to  insufficient documentation follows a trend similar to the early years of the  Medicare FFS error rate measurement program. From its eligibility  reviews, HHS reported that based on an informal survey of states,  caseworker errors and a lack of internal controls were the causes for the  errors in eligibility determinations.
section_title: Management Challenges in Meeting IPIA Requirements
paragraphs: While CMS has made efforts to estimate improper payments, challenges  remain to design and implement internal controls to effectively prevent  improper payments and to address fraud, waste, and abuse. Since 1990  and 2003, respectively, we have designated Medicare and Medicaid as high  risk and included them on our High-Risk list. These programs were  designated as high risk in part due to the high level of estimated improper  payments and growing concerns about the quality of fiscal oversight,  which is necessary to prevent inappropriate spending. Although the  Medicare FFS payment error rate has decreased in recent years, HHS OIG  raised concerns that the error rates for certain provider types may be  understated based on its review of additional medical records and  interviews with beneficiaries and providers. CMS has taken steps to  enhance its program integrity efforts, but further work remains to put in  place the controls necessary to effectively identify and detect improper  payments. Our recent work in Medicare continues to identify fraudulent  and abusive practices within the program. For example, our review of  Medicare’s spending on home health care found that home health  agencies’ practice of upcoding (overstating the severity of a beneficiary’s  condition), providing kickbacks, and billing for services not rendered  contributed to Medicare’s home health spending and utilization. We  reported that inadequate administration of the Medicare home health  benefit left the program vulnerable to improper payments. Likewise, our  review of enrollment of Medicare’s durable medical equipment suppliers  found weaknesses in Medicare’s screening process that exposed the  program to potentially paying millions of dollars for medical equipment  and supplies that were not necessary or were not provided to  beneficiaries.
Similarly, challenges exist for the Medicaid program. In fiscal year 2008,  the HHS OIG reported that the shared oversight and enforcement activities  between multiple federal and state entities create significant challenges to  program oversight and integrity. The HHS OIG also reported that CMS’s  efforts to identify payment errors, their causes, and vulnerabilities in  Medicaid is particularly challenging because of the diversity of state  programs and the variation in their administrative and control systems.
These findings are consistent with our prior work on federal and state  coordination to estimate improper payments for state-administered  programs, like Medicaid. Specifically, in April 2006, we reported that  communication, coordination, and cooperation among federal agencies  and the states are critical factors in estimating national improper payment  rates and meeting IPIA reporting requirements for state-administered  programs. Further, putting in place a culture of accountability over  improper payments and transparency of the issue helps to reduce fraud  and address the wasteful spending that results from lapses in controls. As  we previously reported, measuring improper payments within the  Medicaid program is critical to recouping and reducing them. The  magnitude of the program’s payment errors indicates that CMS and the  states face significant challenges to address the program’s vulnerabilities.  Identifying and reducing improper payment in Medicaid are important first  steps toward improving the integrity of the program.
section_title: Concluding Observations
paragraphs: In closing, in light of the current fiscal stress and looming deficits, the  need to ensure that every federal dollar is spent as intended has never  been more important. With more federal dollars flowing into risk- susceptible programs, establishing effective accountability measures is  critical. In this regard, implementing strong internal controls can serve as  the front-line of defense against improper payments. Nonetheless,  effectively identifying improper payments and designing and implementing  actions to reduce them are not simple tasks or easily accomplished.  Consequently, agencies’ efforts to fulfill the requirements of IPIA will  require sustained top-level attention and commitment. The ultimate  success of the governmentwide effort to reduce improper payments hinges  on each federal agency’s diligence and commitment to identify, estimate,  determine the causes of, take corrective actions, and measure progress in  reducing improper payments.
Mr. Chairman, this concludes my statement. I would be pleased to respond  to any questions that you or other members of the Subcommittee may  have.
section_title: Contact and Acknowledgments
paragraphs: For more information regarding this testimony, please contact, Kay L.  Daly, Director, Financial Management and Assurance, at (202) 512-9095 or  by e-mail at dalykl@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this testimony. Individuals making key contributions to this testimony  included Carla Lewis, Assistant Director; F. Abe Dymond; Natasha Guerra;  Crystal Lazcano; Christina Quattrociocchi; and Sabrina Springfield.
section_title: Appendix I: Improper Payment Estimates Reported in Agency Fiscal Year 2007 and 2008 Performance and Accountability Reports, Agency Financial Reports, or Annual Reports
paragraphs: Fiscal year  2007 total  estimate  (dollars in  millions)
Fiscal year  2007 error  rate  (percent)
Fiscal year  2008 error  rate  millions) (percent)
3  Grants and Cooperative Agreements  Child and Adult Care Food Program  Conservation Security Program  (previously Farm Security and Rural  Investment)
Fiscal year  2007 total  estimate  (dollars in  millions)
Fiscal year  2007 error  rate  (percent)
Fiscal year  2008 error  rate  millions) (percent)
Fiscal  year 2008  total  estimate  (dollars in  millions)
Fiscal year  2007 error  rate  (percent)
Fiscal year  2008 error  rate  millions) (percent)
Temporary Assistance for Needy Families 48  Customs and Border Protection— Custodial—Refund & Drawback and  Continued Dumping & Subsidy Offset Act  & Payments to Wool Manufacturers   Federal Emergency Management  Agency—Assistance to Firefighters  Grants  Federal Emergency Management  Agency—Homeland Security Grant  Program  Federal Emergency Management  Agency—Individuals and Households  Program  Federal Emergency Management  Agency—Infrastructure Protection  Program  Federal Emergency Management  Agency—National Flood Insurance  Program  Federal Emergency Management  Agency—Public Assistance Programs  Federal Emergency Management  Agency—Vendor payments  Immigration and Customs Enforcement— Detention and Removal Operations  Immigration and Customs Enforcement— Federal Protective Service  Immigration and Customs Enforcement— Investigations  Transportation Security Administration— Aviation Security—Payroll  60  United States Coast Guard—Active Duty  61  United States Coast Guard—Contract  62  Community Development Block Grant  (Entitlement Grants, States/Small Cities)
Fiscal year  2007 total  estimate  (dollars in  millions)
Fiscal year  2007 error  rate  (percent)
Fiscal year  2008 error  rate  millions) (percent)
Fiscal year  2007 total  estimate  (dollars in  millions)
Fiscal year  2007 error  rate  (percent)
Fiscal year  2008 error  rate  millions) (percent)
Fiscal year  2008 error  rate  millions)
Fiscal year  2007 error  rate  (percent) millions) (percent)
108  Non-VA Care Civilian Health and Medical  Program (CHAMPVA)