School Meals Programs: USDA Has Reported Taking Some Steps to Reduce Improper Payments but Should Comprehensively Assess Fraud Risks
Released: 2019-06-04T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: In 2018, almost 30 million children participated in the National School Lunch Program and over 14 million participated in the School Breakfast Program, with cash payments totaling almost $17 billion. Historically, the school meals programs have reported high estimated improper payment error rates, which suggest that these programs may also be vulnerable to fraud.

GAO was asked to review improper payment error rates and potential fraud in the school meals programs. This report (1) describes steps USDA has reported taking since 2015 to lower improper payment error rates and (2) examines the extent to which USDA has assessed areas of risk for fraud in the school meals programs.

GAO reviewed the results of the most recent study USDA uses to estimate improper payments in the school meals programs, as well as the error rates and actions to reduce them reported in USDA's agency financial reports from fiscal years 2015 through 2018. Further, GAO analyzed guidance for key oversight practices and documentation regarding USDA's risk assessment processes. GAO examined these processes against the leading practices in the Fraud Risk Framework for assessing fraud risks. GAO also interviewed agency officials.

section_title: What GAO Found
paragraphs: The Department of Agriculture (USDA) has reported various actions aimed at lowering estimated improper payment error rates in the National School Lunch Program and School Breakfast Program (school meals programs). Examples include a new application prototype intended to reduce applicant errors and training for food service workers to reduce administrative errors. USDA uses a model based on a periodic study to estimate improper payments, and reported error rates will generally not reflect the effect of most actions until USDA's next study is released, likely in 2020. However, in fiscal year 2018, USDA redefined what it considers an improper payment. Specifically, meal claiming errors—for example, meals that are missing a required nutritional component but that are counted as reimbursable—are no longer considered improper payments, resulting in error rates for fiscal year 2018 that are not comparable to prior years.

USDA has not assessed fraud risks in the school meals programs, which hinders its ability to ensure that its key oversight practices—extensive processes designed for broad monitoring purposes—address areas at risk for fraud. The assess component of A Framework for Managing Fraud Risks in Federal Programs (Fraud Risk Framework) calls for managers to plan regular fraud risk assessments and to assess risks to determine a fraud risk profile. USDA officials stated that the agency considers fraud risks through efforts to assess overall program integrity risk in the programs, which include research projects and consideration of specific risks when allocating monitoring resources. However, GAO found that USDA's efforts to assess risk do not comprehensively consider fraud risks. As a result, these efforts are not aligned with the overarching concepts of planning and conducting fraud risk assessments in the Fraud Risk Framework. Establishing a process to plan and conduct regular fraud risk assessments that align with the leading practices in the Fraud Risk Framework—including those in the figure below—will help USDA design and implement an antifraud strategy, as well as evaluate and adapt its strategy to improve fraud risk management in the school meals programs.

section_title: What GAO Recommends
paragraphs: GAO recommends that USDA establish a process to plan and conduct regular fraud risk assessments for the school meals programs that align with the leading practices in the Fraud Risk Framework. USDA generally agreed with the recommendation.

section_title: Letter
paragraphs: A well-balanced and nutritional diet for school children is essential for  their overall health and well-being and helps promote academic  achievement. In 1946, the Richard B. Russell National School Lunch Act  established the National School Lunch Program, and in 1966, the Child  Nutrition Act established the School Breakfast Program. Through these  programs, the federal government provides reimbursement to schools for  meals that meet federal requirements, and students may be eligible to  receive meals for free or at a reduced price. The school meals programs  are overseen by the Food and Nutrition Service (FNS) at the Department  of Agriculture (USDA). In fiscal year 2018, almost 30 million children  participated in the National School Lunch Program, and over 14 million  participated in the School Breakfast Program, with cash payments of  $12.5 billion and $4.4 billion, respectively.

Historically, the school meals programs have reported high improper  payment error rates, as high as almost 16 percent for the National School  Lunch Program and almost 23 percent for the School Breakfast Program  over the past 4 years. A high improper payment error rate may suggest  that a program may also be vulnerable to fraud, although it is important to  note that fraud is one specific type of improper payment, and improper  payment estimates are not intended to measure fraud in a particular  program. We have previously reported that fraud poses a significant risk  to the integrity of federal programs and erodes public trust in government.  Implementing effective fraud risk management processes can help  ensure that federal programs fulfill their intended purpose, spend their  funding effectively, and safeguard assets.

You asked us to review improper payment error rates and potential fraud  in the school meals programs. This report (1) describes the steps USDA  has reported taking since 2015 to reduce improper payment error rates in  the school meals programs and (2) examines the extent to which USDA  has assessed areas of risk for fraud in the school meals programs.

To address our first objective, we reviewed the results of the most recent  Access, Participation, Eligibility, and Certification (APEC) study—which  USDA uses to estimate improper payments in the school meals  programs—published in May 2015, as well as estimated improper  payment error rates and actions aimed at reducing them reported in  USDA’s agency financial reports from fiscal years 2015 through 2018.

To address our second objective, we analyzed documentation related to  USDA’s risk assessment processes, including the assessment of fraud  risks. We examined these processes against the leading practices in A  Framework for Managing Fraud Risks in Federal Programs (Fraud Risk  Framework) related to assessing fraud risks. The Fraud Risk Framework  describes leading practices in four components: commit, assess, design  and implement, and evaluate and adapt. We selected the leading  practices within the assess component because the identification and  assessment of fraud risks are an important step in determining whether  USDA’s oversight practices identify and address areas at risk for fraud.  We analyzed USDA guidance related to two key oversight processes— management evaluations and administrative reviews. In addition, we  interviewed agency officials about efforts to reduce improper payment  error rates and manage fraud risks.

We conducted this performance audit from June 2018 to May 2019 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.
subsections: section_title: Background
subsections: section_title: Administration and Oversight of the School Meals Programs
paragraphs: The Food and Nutrition Service at USDA is responsible for overseeing the  school meals programs at the federal level, which includes issuing  regulations and guidance. The school meals programs are administered  at the state level by a designated state agency—generally an education  or agriculture agency—that issues guidance to school districts providing  the meals. School districts are responsible for certifying students as  eligible for free or reduced-price meals, providing children with  nutritionally balanced meals each school day, and counting and claiming  eligible meals for federal reimbursement, among other things. USDA and  state agencies also conduct oversight of the school meals programs.  Figure 1 summarizes the responsibilities of the different entities within the  school meals programs.

All students in schools operating the school meals programs may  participate in the programs, and eligible students may be certified to  receive free or reduced-price meals. Individual students can be certified  into the school meals programs either through household application or  direct certification.

Household application. A household can submit an application that  lists all sources of household income and the names of all household  members, among other information. School districts compare this  information to income-eligibility guidelines to determine whether the  student is eligible for free or reduced-price meals. Alternatively, the  household can indicate on the application that it participates in certain  public-assistance programs—such as the Supplemental Nutrition  Assistance Program (SNAP)—or that the student meets an approved  designation, which confers categorical (automatic) eligibility for free  meals. No documentation to support income listings—such as tax  returns or pay stubs—is required at the time of application.

Direct certification. Under the direct certification method, data  matching is used to identify and certify students who are categorically  eligible for free meals. State agencies are required by statute to match  student enrollment records against SNAP records and may also  match against records for other public-assistance programs or  approved designations. Students who are directly certified into the  school meals programs are eligible for free meals without a household  application.

Alternatively, schools can use certain program provisions to serve meals  at no charge to all students (i.e., eligibility is not determined for each  student individually on an annual basis).

Community eligibility provision. Schools and school districts may  apply for community eligibility if their percentage of students identified  as eligible for free meals without an application—known as the  identified student percentage—is at or above 40 percent. Meals  served at schools using the community eligibility provision are  reimbursed using a formula based on the identified student  percentage.

Other special provisions. Under these special provisions, schools  generally use standard procedures to certify free and reduced-price  eligible students and count meals by eligibility category to establish a  base year. Following the base year, schools serve free meals to all  students and are reimbursed based on the information collected in the  base year.
subsections: section_title: Meal Counting and Claiming
paragraphs: USDA reimburses state agencies, which in turn reimburse school  districts, for qualifying meals through the process of meal counting and  claiming. A meal is reimbursable if it meets federal nutrition requirements  and is not reimbursable if it is missing a required food component or fails  to meet the meal pattern requirements. Meals are recorded at the point  of sale in a school. Generally, individual meals are recorded as either  free, reduced price, or paid based on the student’s certification status,  unless the school is operating under community eligibility or a special  provision.

Reimbursable meals are tallied at each school. School districts aggregate  meal tallies from each school and then report to the respective state  agencies on a monthly basis. State agencies then aggregate the reports  from each district and submit tallies of free, reduced-price, and paid  meals to USDA. USDA then reimburses states for the amount reported.  Meals in each category (free, reduced-price, and paid) are reimbursed at  different rates.

section_title: Oversight
paragraphs: Given that the school meals programs are administered on a daily basis  at schools across the country, USDA officials stated that the agency relies  on two key oversight practices—management evaluations and  administrative reviews—to monitor these programs.

Management evaluations. USDA conducts management evaluations  of state agencies’ administration of the school meals programs. USDA  uses risk-based criteria, such as the level of turnover in state agency  staff, to select the state agencies to review each year. According to  USDA officials, starting in fiscal year 2019, USDA will automatically  select a state agency for review if it has not been reviewed in the past  3 years. According to USDA guidance, examples of operations it  reviews during management evaluations include (1) state oversight of  certification and verification of students into the school meals  programs, (2) administrative reviews of school districts conducted by  state agencies, (3) claims for reimbursement, and (4) state oversight  of compliance with federal meal pattern requirements, among other  areas. According to USDA officials, if USDA considers state agencies  reviewed in one year as high risk for program noncompliance, those  agencies may receive an additional management evaluation in the  following year focused on technical assistance.

Administrative reviews. USDA develops guidance for administrative  reviews in which state agencies review school districts’ administration  of the school meals programs. State agencies are required to conduct  administrative reviews of each of their school districts at least once in  a 3-year review cycle. USDA guidance states that the objectives of  administrative reviews include identifying noncompliance, providing  technical assistance, and assessing fiscal actions. Among other  things, state agency staff are to review a school district’s certification  records and its meal counting and claiming data for the most recent  month for which a claim for reimbursement was submitted. State  agency staff are also to review school meals served while the staff are  on-site to determine whether the meals contain the required food  components. State agency staff are to record any identified  noncompliance and also provide technical assistance to school district  staff.

section_title: Estimation of Improper Payments in the School Meals Programs
paragraphs: The Improper Payments Information Act of 2002 (IPIA), as amended,  requires agencies to identify, estimate, and report their improper payment  amounts and to develop and implement improper payment reduction  plans, among other things. USDA estimates improper payments for the  school meals programs through a model based on its APEC study, which  is conducted by contractors. The most recent APEC study (APEC II) was  released in May 2015 and covered activity during the 2012–2013 school  year. USDA conducts an APEC study about every 5 years, with APEC III  expected to be released in 2020.

Conducting the APEC study involves multiple sampling and data analysis  efforts, including the following examples from APEC II.

In-person surveys. Contractors conducted in-person surveys of over  3,000 sampled households to collect information on each household’s  circumstances at the time of application, including income, household  size, and receipt of other public-assistance benefits. Using this  information, contractors determined a sampled student’s eligibility  status and compared it to the school district’s master benefit list and  application or direct certification documentation.

Data matching. Contractors assessed the accuracy of the identified  student percentage—the figure used to determine reimbursement for  schools using the community eligibility provision—for over 100  sampled schools. To do so, contactors used an iterative process to  match sampled students to SNAP and Temporary Assistance for  Needy Families records, as well as additional data sources if  necessary.

Observation of meal service. Contractors observed approximately  25,000 lunch transactions and 23,000 breakfast transactions at over  400 sampled schools to identify the food items in each meal at the  point of sale, whether the meal was served to a student or  nonstudent, and whether the meal was recorded as reimbursable.

USDA determined that conducting the APEC study annually would not be  feasible. Instead, the APEC study includes a model that allows USDA to  use program participation data to report estimated improper payment  error rates on an annual basis. Changes in program participation data  result in small changes to the estimated improper payment error rates  USDA reports during years between APEC studies.

section_title: Fraud Risk Management Standards and Guidance
paragraphs: According to federal standards and guidance, executive-branch agency  managers are responsible for managing fraud risks and implementing  practices for combating those risks. Federal internal control standards call  for agency management officials to assess the internal and external risks  their entities face as they seek to achieve their objectives. The  standards state that as part of this overall assessment, management  should consider the potential for fraud when identifying, analyzing, and  responding to risks.

In July 2015, GAO issued the Fraud Risk Framework, which provides a  comprehensive set of key components and leading practices that serve  as a guide for agency managers to use when developing efforts to  combat fraud in a strategic, risk-based way. The Fraud Risk Framework  describes leading practices in four components, as shown in figure 2.

The Fraud Reduction and Data Analytics Act of 2015, enacted in June  2016, requires the Office of Management and Budget (OMB) to establish  guidelines for federal agencies to create controls to identify and assess  fraud risks and design and implement antifraud control activities. The act  further requires OMB to incorporate the leading practices from the Fraud  Risk Framework in the guidelines. In July 2016, OMB published  guidance about enterprise risk management and internal controls in  federal executive departments and agencies. Among other things, this  guidance affirms that managers should adhere to the leading practices  identified in the Fraud Risk Framework. Further, the act requires federal  agencies to submit to Congress a progress report each year for 3  consecutive years on the implementation of controls established under  OMB guidance, among other things.

It is important to note that fraud and “fraud risk” are distinct concepts.  Fraud is challenging to detect because of its deceptive nature.  Additionally, once suspected fraud is identified, alleged fraud cases may  be prosecuted. If the court determines that fraud took place, then  fraudulent spending may be recovered. Fraud risk exists when individuals  have an opportunity to engage in fraudulent activity, have an incentive or  are under pressure to commit fraud, or are able to rationalize committing  fraud. When fraud risks can be identified and mitigated, fraud may be less  likely to occur.

Although the occurrence of fraud indicates there is a fraud risk, a fraud  risk can exist even if fraud has not yet been identified or occurred. For  example, suspicious billing patterns or complexities in program design  may indicate a risk of fraud. Information to help identify potential fraud  risks may come from various sources, including whistleblowers, agency  officials, contractors, law-enforcement agencies, or beneficiaries.

section_title: USDA Has Reported Taking Various Steps to Reduce Improper Payment Error Rates, but Redefined What It Considers to Be an Improper Payment in Fiscal Year 2018
subsections: section_title: USDA Reported Taking Steps to Reduce School Meals Improper Payment Error Rates
paragraphs: USDA has reported various actions aimed at lowering the school meals  improper payment error rates in its agency financial reports. These  actions—including onetime actions and longer-term efforts—cover  multiple aspects of the programs. The actions USDA reported included  the creation of a new household application prototype intended to reduce  applicant errors and the development of training for food service workers  to address administrative errors. USDA also reported on mechanisms to  collect information on program errors to support agency analysis and  monitoring efforts. Examples of the reported actions are illustrated in  figure 3 below.

Because the study used to develop improper payment error rates in  school meals programs—APEC—is conducted about once every 5 years,  the effect of these actions is currently unknown. Estimated improper  payment error rates reported in years between APEC studies will  generally not reflect the effect of most actions until the next study is  released. Currently, the next APEC study is expected to be released in  2020.

section_title: Reported Error Rates for Fiscal Year 2018 Are Not Comparable to Prior Years Because of a Change in Definition
paragraphs: USDA changed what it considers to be an improper payment in the  school meals programs for fiscal year 2018 reporting, resulting in  improper payment error rates that are not comparable to those of prior  years. Specifically, USDA determined that meal claiming errors do not  meet the definition of an improper payment. According to USDA, meal  claiming errors occur when meals are incorrectly categorized as  reimbursable or nonreimbursable at the point of sale. For example, a  meal claiming error occurs when a meal that is missing a required meal  component (e.g., the required quantity of a vegetable) is counted as  reimbursable.

USDA officials reported that the rationale for the change in what  constitutes an improper payment is that meal claiming error does not  result in the payment of federal funds for services that were not provided  or that were provided to ineligible recipients. Agency officials also stated  that the remedy for meal claiming error is to add the missing food  component to the meal, so correcting the error would not reduce program  payments. Although the errors will not be considered in determining the  reported estimated improper payment error rates, USDA officials stated  that the agency is committed to reducing meal claiming error and will  continue to measure it as part of its periodic APEC studies.

Prior to fiscal year 2018 reporting, meal claiming errors were considered  improper payments. As a result, this change contributed to a significant  decrease in the estimated improper payment error rates for the school  meals programs reported for fiscal year 2018, as shown in figure 4.  Accordingly, the results shown for 2015 through 2018 in figure 4 are not  comparable.

section_title: Limited Risk Assessment Hinders USDA’s Ability to Better Ensure Oversight Practices Address Fraud Risks
paragraphs: Although USDA considers certain program integrity risks through specific  processes, it has not assessed fraud risks in the school meals programs.  As a result, USDA cannot determine whether its key oversight  processes—extensive efforts designed for broad monitoring purposes— address areas at risk for fraud. The assess component of the Fraud Risk  Framework calls for federal managers to plan regular fraud risk  assessments and to assess risks to determine a fraud risk profile.  Furthermore, federal internal control standards state that management  should consider the potential for fraud when identifying, analyzing, and  responding to risks.

According to USDA officials, fraud in the school meals programs would  look the same as nonfraudulent errors. For example, income listed on an  application may be misreported intentionally or unintentionally.  Consequently, agency officials stated that they have not established a  process to plan or conduct a specific fraud risk assessment for these  programs. Instead, fraud risks are considered through the agency’s  efforts to assess overall program integrity risk in the programs. We have  previously reported that integrating fraud risk management into a larger  program integrity approach could limit the amount of resources and  attention focused specifically on fraud prevention, detection, and  response. The deceptive nature of fraud makes it harder to detect than  nonfraudulent errors, potentially requiring control activities that are  specifically designed to prevent and detect criminal intent.

According to agency officials, USDA’s efforts to assess overall program  integrity risks in the school meals programs include researching,  monitoring, and reporting activities designed to identify areas of program  operations susceptible to improper payments and program error.  Specifically, agency officials stated that these efforts include research  projects—the APEC study used to estimate improper payment error rates  and other smaller-scale, informal projects—and a consideration of  specific risks when annually determining which states USDA will review  through management evaluations.

These efforts to assess overall program integrity risk serve specific  purposes and are not designed to identify or address fraud risks in the  school meals programs. For example, the purpose of one research  project mentioned by USDA officials was to identify challenges related to  alternative service models for the School Breakfast Program, which  include serving breakfast in locations other than a cafeteria and at a later  time in the morning. USDA has not developed a process to consider  these disparate efforts to comprehensively assess fraud risks. As a result,  USDA’s efforts do not align with the overarching concepts of planning and  conducting fraud risk assessments in the Fraud Risk Framework.

The Fraud Risk Framework identifies leading practices for planning fraud  risk assessments. Specifically, the leading practices include tailoring the  fraud risk assessment to the program and planning to conduct the  assessment at regular intervals and when there are changes to the  program or operating environment. The leading practices also include  identifying the tools, methods, and sources for gathering information  about fraud risks and involving relevant stakeholders in the assessment  process. Information to help identify potential fraud risks may come from  various sources, including whistleblowers, agency officials, contractors,  law-enforcement agencies, or beneficiaries. Existing oversight efforts— such as USDA’s management evaluations and administrative reviews— may also be a useful source, as information on errors and noncompliance  may highlight areas at risk for fraud.

The Fraud Risk Framework also identifies leading practices for  conducting fraud risk assessments, as illustrated in figure 5.

Without a process to plan and conduct regular assessments, USDA  cannot identify and assess fraud risks facing the school meals programs.  Such information is necessary to appropriately design and implement an  antifraud strategy—including specific controls like USDA’s key oversight  processes—and evaluate and adapt its strategy and controls to improve  fraud risk management in these programs.

section_title: Conclusions
paragraphs: Historically, the school meals programs have reported high estimated  improper payment error rates. USDA has reported various steps to  reduce the error rates, though a change in what USDA considers an  improper payment in the school meals programs resulted in error rates for  fiscal year 2018 that are not comparable to those of prior years. Although  the two concepts are different, high improper payment error rates may  suggest that the school meals programs may also be inherently  vulnerable to fraud. However, USDA has not established a process to  plan and conduct regular fraud risk assessments for the school meals  programs, and existing efforts to assess specific risks in the school meals  programs do not comprehensively consider fraud risks. According to  leading practices, such an assessment is a pivotal step in managing fraud  risks, helping to ensure that USDA’s key oversight efforts are targeted at  areas at greatest risk for fraud in these programs, and helping safeguard  the government’s substantial investment in them.

section_title: Recommendation for Executive Action
paragraphs: The Administrator of the Food and Nutrition Service should establish a  process to plan and conduct regular fraud risk assessments for the school  meals programs that align with the leading practices in the Fraud Risk  Framework. (Recommendation 1)

section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to USDA for review and comment. On  April 29, 2019, the Director of the Office of Program Integrity for Child  Nutrition provided us with the agency’s oral comments on the draft report.  FNS officials generally agreed with the recommendation in the draft  report. FNS officials noted that the agency does not currently conduct a  formal fraud risk assessment, but they explained that the agency  considers fraud risks through multiple existing efforts. These efforts  include APEC and other studies, as well as key oversight processes. For  example, FNS noted that the APEC study aims to identify the factors that  contribute to errors in the school meals programs. Officials explained that  this study includes an interview of sampled households, in part to  determine whether these households underreported income on their  applications and whether such underreporting suggests anything about  the applicants’ intent. As noted in our report, we agree that these efforts  may be a useful source of information on areas at risk for fraud. However,  we continue to believe that additional action is necessary to  comprehensively assess fraud risks in the school meals programs,  consistent with the Fraud Risk Framework. USDA also provided technical  comments, which we incorporated into the report, as appropriate.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretary of Agriculture, the FNS  Administrator, and other interested parties. In addition, the report will be  available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-6722 or bagdoyans@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 I.

section_title: Appendix I: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, the following staff members  made key contributions to this report: Gabrielle M. Fagan, Assistant  Director; James M. Healy, Analyst in Charge; and Matthew L. McKnight.  Also contributing to this report were Rachel Frisk, Maria McMullen, Jean  McSween, and Sabrina Streagle.

Fast facts: The Department of Agriculture's National School Lunch Program and School Breakfast Program give schools billions of dollars every year to provide meals for children. Historically, the rates of estimated payment errors have been high, suggesting that the programs may be vulnerable to fraud.

USDA has reported taking steps to reduce these errors. However, we found that USDA doesn't regularly assess the programs' fraud risks. Without such assessment, it's hard to tell whether USDA's oversight activities are effectively monitoring, preventing, and addressing the greatest sources of potential fraud.

We recommended regularly assessing fraud risks.

Question-summary annotations: questions: question: What programs is the USDA targeting in its effort to lower improper payment error rates?
answer: The Department of Agriculture (USDA) has reported various actions aimed at lowering estimated improper payment error rates in the National School Lunch Program and School Breakfast Program (school meals programs).
child_questions: question: What actions can help the USDA accomplish its goal?
answer: Examples include a new application prototype intended to reduce applicant errors and training for food service workers to reduce administrative errors.

question: How does the USDA estimate improper payments?
answer: USDA uses a model based on a periodic study to estimate improper payments, and reported error rates will generally not reflect the effect of most actions until USDA's next study is released, likely in 2020.

question: How have estimates changed since FY2018?
answer: However, in fiscal year 2018, USDA redefined what it considers an improper payment. Specifically, meal claiming errors—for example, meals that are missing a required nutritional component but that are counted as reimbursable—are no longer considered improper payments, resulting in error rates for fiscal year 2018 that are not comparable to prior years.

questions: question: Why is the lack of fraud risk assessment harmful for oversight?
answer: USDA has not assessed fraud risks in the school meals programs, which hinders its ability to ensure that its key oversight practices—extensive processes designed for broad monitoring purposes—address areas at risk for fraud.
child_questions: question: How does this differ from the Fraud Risk Framwork?
answer: The assess component of A Framework for Managing Fraud Risks in Federal Programs (Fraud Risk Framework) calls for managers to plan regular fraud risk assessments and to assess risks to determine a fraud risk profile.

question: How does the USDA currently consider fraud risks?
answer: USDA officials stated that the agency considers fraud risks through efforts to assess overall program integrity risk in the programs, which include research projects and consideration of specific risks when allocating monitoring resources.
child_questions: question: How well do these efforts consider fraud risks?
answer: However, GAO found that USDA's efforts to assess risk do not comprehensively consider fraud risks. As a result, these efforts are not aligned with the overarching concepts of planning and conducting fraud risk assessments in the Fraud Risk Framework.

question: How can regular fraud risk assessments (following best practices) help the USDA?
answer: Establishing a process to plan and conduct regular fraud risk assessments that align with the leading practices in the Fraud Risk Framework—including those in the figure below—will help USDA design and implement an antifraud strategy, as well as evaluate and adapt its strategy to improve fraud risk management in the school meals programs.

questions: question: What sources did GAO obtain data from?
answer: GAO reviewed the results of the most recent study USDA uses to estimate improper payments in the school meals programs, as well as the error rates and actions to reduce them reported in USDA's agency financial reports from fiscal years 2015 through 2018.
child_questions: question: How did GAO make use of agency documentation to augment its report?
answer: Further, GAO analyzed guidance for key oversight practices and documentation regarding USDA's risk assessment processes.

question: In what context did GAO assess these practices?
answer: GAO examined these processes against the leading practices in the Fraud Risk Framework for assessing fraud risks.

question: How did GAO supplement its raw data?
answer: GAO also interviewed agency officials.