DOD Financial Management:

Significant Improvements Needed in Efforts to Address Improper Payment Requirements

GAO-13-227: Published: May 13, 2013. Publicly Released: Jun 6, 2013.

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Asif A. Khan
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What GAO Found

The Department of Defense (DOD) did not adequately implement key provisions of the Improper Payments Information Act of 2002 (IPIA) and the Improper Payments Elimination and Recovery Act of 2010 (IPERA) and Office of Management and Budget (OMB) requirements for fiscal year 2011. Most important, GAO found that DOD's improper payment estimates reported in its fiscal year 2011 Agency Financial Report were neither reliable nor statistically valid because of long-standing and pervasive financial management weaknesses and significant deficiencies in the department's procedures to estimate improper payments. For example, DOD did not

  • have key quality assurance procedures in place, such as reconciliations, to validate the completeness and accuracy of the populations used to estimate improper payments;

  • develop appropriate sampling methodologies for estimating improper payments;

  • produce a statistical estimate for its largest program, Defense Finance and Accounting Service (DFAS) commercial pay; and

  • maintain key documentation supporting its reported improper payment estimates.

Also, GAO found significant deficiencies in DOD's policies and procedures to address other key improper payment requirements for fiscal year 2011. Specifically, DOD did not

  • perform a required risk assessment to identify those programs susceptible to significant improper payments,

  • have procedures to identify root causes of improper payments and develop related corrective actions,

  • conduct recovery audits for any of its programs or determine that these audits would not be cost effective, and

  • have procedures to ensure that its annual improper payment and recovery audit reporting is complete, accurate, and in compliance with IPERA and OMB reporting requirements.

DOD has taken some actions since fiscal year 2011, such as reporting a statistical estimate for Defense Finance and Accounting Service commercial pay and issuing revised Financial Management Regulation chapters on improper payments and recovery audits. However, until the department takes action to correct the deficiencies GAO found related to identifying, estimating, reducing, recovering, and reporting improper payments and thereby fulfills legislative requirements and implements related guidance, it remains at risk of continuing to make improper payments and wasting taxpayer funds.

Why GAO Did This Study

DOD reported $1.1 billion in improper payments for fiscal year 2011, which marked the eighth year of implementation of IPIA, as well as the first year of implementation of IPERA. IPIA required executive branch agencies to annually identify programs and activities susceptible to significant improper payments, estimate the amount of improper payments for such programs and activities, and report these estimates along with actions taken to reduce them. IPERA amended IPIA and expanded requirements for recovering overpayments across a broad range of federal programs.

GAO was asked to review the progress DOD has made to identify, estimate, and reduce improper payments. GAO's objective was to review the extent to which DOD has implemented key provisions of IPIA, IPERA, and OMB guidance. GAO reviewed improper payment requirements; analyzed agency financial reports, internal guidance and plans, and sampling methodologies; and interviewed cognizant officials. The scope for this engagement was DOD's reported improper payment information for fiscal year 2011 and DOD's plans and actions to estimate commercial pay improper payments for fiscal year 2012.

What GAO Recommends

GAO is making 10 recommendations to improve DOD's processes to identify, estimate, reduce, recover, and report on improper payments. DOD concurred with 9 and partially concurred with 1 of the recommendations and described its plans to address them.

For more information, contact Asif A. Khan at (202) 512-9869 or Khana@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: The Department of Defense (DOD), in concurring with this recommendation, stated that the department will work with the Defense Finance and Accounting Service (DFAS) to implement key quality assurance procedures, such as reconciliations, to ensure the completeness and accuracy of sampled populations. As of July 2015, DOD reported that reconciliations and ensuring the full universe of payments for review (if appropriate) are still under development as it moves toward full financial statement auditability. DFAS officials told us that DFAS performed reconciliations of gross outlays reported on the Statement of Budgetary Resources (SBR) to outlays reviewed for improper payments for fiscal years 2012 through 2014. However, these reconciliations were performed at a summary level based on information used to prepare the SBR that does not include details needed to identify different payment types. As a result, a complete reconciliation of reported outlays to each improper payment population has not yet been performed to ensure the completeness and accuracy of the sampled populations.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller)with regard to estimating improper payments, to establish and implement key quality assurance procedures, such as reconciliations, to ensure the completeness and accuracy of the sampled populations.

    Agency Affected: Department of Defense

  2. Status: Open

    Comments: The Department of Defense (DOD) partially concurred with this recommendation, stating that sampling methodologies would be reviewed for all payment types and would be modified as appropriate to produce valid improper payment estimates and appropriate confidence intervals for them. As of July 2015, based on our review, we determined that DOD's revised sampling methodologies for the Defense Finance and Accounting Service (DFAS) commercial pay, U.S. Army Corps of Engineers (USACE) commercial pay, and USACE travel pay programs, if effectively implemented, would produce valid improper payment estimates and appropriate confidence intervals. However, according to DFAS officials, although simplistic in nature, current sampling methodologies for its civilian pay, military pay, travel pay, and retiree and annuitant pay programs support statistically valid improper payment estimates with appropriate confidence intervals. Therefore, DFAS does not see added value in changing the methodology for these programs. Also, the Defense Health Agency (DHA) revised its sampling methodology for its military health benefits program and, according to DHA officials, will make further revisions to include testing for small dollar claims. Although the revised methodology stratifies the payment population based on payment amounts, it does not address how improper payment rate and dollar estimate confidence intervals are calculated.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller)with regard to estimating improper payments, to revise the procedures documented in DOD's sampling methodologies so that they (1) are in accordance with OMB guidance and generally accepted statistical standards and (2) produce statistically valid improper payment error rates, statistically valid improper payment dollar estimates, and appropriate confidence intervals for both. At a minimum, such procedures should take into account the size and complexity of the transactions being sampled.

    Agency Affected: Department of Defense

  3. Status: Closed - Implemented

    Comments: The Department of Defense (DOD) concurred with this recommendation, stating that department will collaborate with the Defense Finance and Accounting Service (DFAS) and Defense Manpower Data Center (DMDC) to develop and implement procedures to collect and maintain the supporting documentation necessary to support improper payment estimates. As of December 2014, DOD reported that this recommendation was closed due to the documentation that DFAS was maintaining to support its improper payment estimates, which included additional documentation, such as SAS logs, from DMDC. In addition, DOD stated that ongoing auditability efforts by the Department will continue to improve data reliability and ensure that payment information is complete and accurate. To assess the status of the recommendation, GAO requested selected documentation supporting improper payment estimates of four programs reported in the DOD Annual Financial Report (AFR): DFAS commercial pay, civilian pay, USACE commercial pay, and military health benefits. For example, we requested software logs and output files used to select sample items for testing, component standard operating procedures for testing improper payment sample items, and spreadsheets used to calculate improper payment error rates and dollar estimates. Based on our review of documentation provided by DOD, we determined that DOD generally maintains supporting documentation necessary to support its improper payment estimates reported in the AFR and concur with its determination that this recommendation is closed.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller)with regard to estimating improper payments, to develop and implement procedures to collect and maintain the supporting documentation necessary to support improper payment estimates.

    Agency Affected: Department of Defense

  4. Status: Open

    Comments: The Department of Defense (DOD), in concurring with this recommendation, stated that it would work collaboratively with the applicable Defense components to develop a framework to conduct a risk assessment that is in compliance with the Improper Payments Elimination and Recovery Act (IPERA). As of July 2015, risk assessments for six programs (military health benefits, military pay, civilian pay, Defense Finance and Accounting Service (DFAS) travel pay, retiree & annuitant pay, and DFAS commercial pay) complied with IPERA requirements based on documentation provided to support them. However, based on our review of documentation provided by the U.S. Army Corps of Engineers (USACE), risk assessments for the two programs it administers (USACE travel pay and USACE commercial pay) have not been performed. According to USACE officials, the sampling methodologies for these programs address the requirement to perform risk assessments based on OMB's 2006 determination that all DOD payments are at risk of improper payments. Subsequent to this determination and as discussed in our report, IPERA laid out a clear statutory requirement to perform risk assessments. Further, we reported that performing such assessments are critical to ensuring that the department is identifying the root causes of improper payments and developing appropriate corrective actions. By not performing a risk assessment, USACE continues to miss the opportunity to gain critical information for determining corrective actions to reduce the likelihood of improper payments. In addition, although Navy officials indicated the Navy is preparing to perform a risk assessment for the Navy ERP commercial pay program, a risk assessment for this program has not yet been performed. Therefore, we conclude that our recommendation to conduct risk assessments in compliance with IPERA requirements remains open at this time.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller)with regard to identifying programs susceptible to significant improper payments, to conduct a risk assessment that is in compliance with IPERA.

    Agency Affected: Department of Defense

  5. Status: Open

    Comments: The Department of Defense, in concurring with this recommendation, stated that it would work collaboratively with applicable components to establish procedures that produce corrective action plans that fully comply with the Improper Payment Elimination and Recovery Act and Office of Management and Budget (OMB) guidance. According to DOD officials, these established procedures will include individual accountability for implementing corrective actions and monitoring the status of corrective actions. As of July 2015, DOD plans to enter corrective actions plans associated with audit findings into a "Notice of Findings and Recommendations" database developed to track their status and progress.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller)With regard to reducing improper payments, to establish procedures that produce corrective action plans that comply fully with IPERA and OMB implementation guidance, including at a minimum, holding individuals responsible for implementing corrective actions and monitoring the status of the corrective actions.

    Agency Affected: Department of Defense

  6. Status: Open

    Comments: The Department of Defense (DOD), in concurring with this recommendation, stated that it would work collaboratively with the applicable components to establish procedures that produce corrective action plans that incorporate best practices, including those recommended by the Chief Financial Officers Council. DOD's corrective action plans would include information on (1) measuring the progress made toward remediating root causes and (2) communicating to agency leaders and key stakeholders the progress made toward remediating the root causes of improper payments. As of July 2015, DOD plans to enter corrective actions plans associated with audit findings into a "Notice of Findings and Recommendations" database developed to track their status and progress.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller)With regard to reducing improper payments, to establish procedures that produce corrective action plans that are in accordance with best practices, such as those recommended by the Chief Financial Officers Council (CFOC), and include (1) measuring the progress made toward remediating root causes and (2) communicating to agency leaders and key stakeholders the progress made toward remediating the root causes of improper payments.

    Agency Affected: Department of Defense

  7. Status: Open

    Comments: Department of Defense (DOD) officials concurred with this recommendation, stating that the DOD would review its procedures for improper payment recovery activities to ensure currency and accuracy and that it would also perform analyses to ensure that its recovery efforts are cost-effective. As of July 2015, DOD reported that the development of cost estimates for recovery auditing is ongoing. In addition, DOD officials indicated that only the United States Army Corps of Engineers (USACE) has developed an analysis to evaluate the cost effectiveness of performing recovery audits.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to implementing recovery audits, to develop and implement procedures to (1) identify costs related to the department's recovery audits and existing recovery efforts and (2) evaluate existing improper payment recovery efforts to ensure that they are cost effective.

    Agency Affected: Department of Defense

  8. Status: Open

    Comments: Department of Defense (DOD) officials, in concurring with this recommendation, stated that DOD would work with the applicable components to monitor the implementation of the revised Financial Management Regulation (FMR) chapter on recovery audits. According to DOD officials, this action would help to ensure that recovery audits are developed, or will demonstrate that it is not cost-effective to do these audits. As of July 2015, DOD is working to update the FMR chapter on recovery audits to reflect revised Office of Management and Budget (OMB) guidance issued in October 2014.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to implementing recovery audits, to monitor the implementation of the revised FMR chapter on recovery audits to ensure that the components either develop recovery audits or demonstrate that it is not cost effective to do so.

    Agency Affected: Department of Defense

  9. Status: Open

    Comments: Department of Defense (DOD) officials, in concurring with this recommendation, stated that DOD would develop and submit to the Office of Management and Budget (OMB) a payment recapture plan that fully complies with OMB guidance and is informed by a cost-effectiveness analysis. As of July 2015, DOD efforts to develop cost estimates for recovery audits are ongoing and that these efforts must be completed before a plan can be submitted to the OMB.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to implementing recovery audits, to develop and submit to OMB for approval a payment recapture audit plan that fully complies with OMB guidance.

    Agency Affected: Department of Defense

  10. Status: Open

    Comments: Department of Defense (DOD) officials, in concurring with this recommendation, stated that DOD would design and implement procedures to further ensure that its annual improper payment and recovery audit reporting is complete, accurate, and in compliance with the Improper Payments Elimination and Recovery Act (IPERA) requirements and Office of Management and Budget (OMB) guidance. In June 2015, DOD revised its FMR chapter on improper payments to require components to provide information needed to report on improper payment and recovery audit activities in its annual financial report in accordance with IPERA requirements and OMB guidance. According to DOD officials, DOD's fiscal year 2015 annual financial report is expected to reflect its implementation of the revised FMR.

    Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller) with regard to reporting to design and implement procedures to ensure that the department's annual improper payment and recovery audit reporting is complete, accurate, and in compliance with IPERA and OMB guidance.

    Agency Affected: Department of Defense

 

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