Background Key Requirements and Guidance on Agency Analysis of Improper Payments and Corrective Actions to Remediate Them IPIA requires executive branch agencies to take various steps regarding improper payments in accordance with guidance issued by OMB, including the following: 1. reviewing all programs and activities and identifying those that may be susceptible to significant improper payments; 2. developing improper payment estimates for those programs and activities that agency risk assessments, OMB, or statutes identify as being susceptible to significant improper payments; 3. analyzing the root causes of improper payments and developing corrective actions to reduce them; and 4. reporting on the results of addressing the foregoing requirements. Figure 1 illustrates these steps, as well as the major components of analyzing root causes of improper payments and developing corrective action plans to remediate them. IPIA requires agencies with programs susceptible to significant improper payments to report a description of the causes of the improper payments identified, actions that the agency has planned or taken to correct those causes, and the planned or actual completion dates of those actions. It also requires agencies to report program-specific improper payment reduction targets that OMB has approved. OMB M-18-20 provides guidance to agencies for implementing IPIA requirements, including their responsibilities for preventing and reducing improper payments. The guidance directs agencies that have developed estimates for improper payments to categorize them by root causes, including the percentage of the total estimate for each category. According to the guidance, this level of specificity helps lead to more effective corrective actions and more focused prevention strategies. Table 2 summarizes OMB’s root cause categories. OMB M-18-20 directs agencies with programs deemed susceptible to significant improper payments to implement a corrective action plan that responds to their root causes to prevent and reduce them. As such, OMB directs that an agency must understand the true root cause of its improper payments in order to develop targeted, effective corrective actions, which are proportional to the severity of the associated amount and rate of the root cause. OMB M-18-20 also directs agencies to annually measure the effectiveness and progress of individual corrective actions by assessing results, such as performance and outcomes. In performing such measurements, OMB states that agencies should determine if any existing corrective actions can be intensified or expanded to further reduce improper payments and to identify annual benchmarks for corrective actions that agencies implement over multiple years. Agencies may use these benchmarks to demonstrate progress in implementing the actions or their initial effect on preventing and reducing improper payments. Characteristics of Programs Reviewed and Related Improper Payment Estimates The eight programs we reviewed serve a variety of purposes and are administered by various agencies across the federal government, as discussed below. Supplemental Nutrition Assistance Program The Department of Agriculture’s (USDA) Supplemental Nutrition Assistance Program (SNAP) is the largest federally funded nutrition assistance program, providing benefits to about 40 million people in fiscal year 2018. SNAP is intended to help low-income households obtain a more nutritious diet by providing them with benefits to purchase food from authorized retailers nationwide. SNAP recipients receive monthly benefits on an Electronic Benefit Transfer (EBT) card and redeem them for eligible food at authorized food stores. The Food and Nutrition Act of 2008 established SNAP as a federally funded, state-administered program. States, following federal guidelines, are responsible for program administration. States determine applicant eligibility, calculate benefit amounts, issue EBT cards to recipients, and investigate possible recipient program violations. USDA’s Food and Nutrition Service (FNS) pays the full cost of SNAP benefits and shares 50 percent of administrative costs with the states. As part of oversight responsibilities, FNS develops program regulations and monitors states to ensure that they comply with program rules. FNS is also directly responsible for authorizing and monitoring retail food stores where recipients may purchase food. In accordance with IPIA, USDA has annually reported an improper payment estimate for SNAP since fiscal year 2004. In its fiscal year 2019 AFR, USDA reported an improper payment estimate of approximately $4 billion, or 6.8 percent of SNAP outlays of $59.1 billion. Direct Loan Program The Department of Education’s (Education) William D. Ford Federal Direct Loan (Direct Loan) program authorizes Education to make loans, through participating schools, to eligible undergraduate and graduate students and their parents. The Direct Loan program comprises four types of loans: Subsidized Stafford, Unsubsidized Stafford, PLUS, and Consolidation loans. Evidence of financial necessity is required for an undergraduate student to receive a Subsidized Stafford loan; however, borrowers at all income levels are eligible for the other three types. Education originates the loans and disburses them through each borrower’s school. Once a loan is disbursed, Education assigns a servicer responsible for communicating with the borrower, providing information about repayment, and processing payments from the borrower. Education first reported an improper payment estimate for the Direct Loan program in fiscal year 2013. In its fiscal year 2019 AFR, Education reported an improper payment estimate of approximately $483 million, or 0.5 percent of Direct Loan program outlays of $92.9 billion. Pell Grant Program Education’s Pell Grant program—the single largest source of grant aid for postsecondary education—awards federally funded grants to low-income undergraduate and certain post-baccalaureate students who are enrolled in a degree or certificate program and have a federally defined financial need. Students are eligible to receive Pell Grants for no more than 12 semesters (or the equivalent). To qualify, an applicant must, in addition to satisfying other requirements, demonstrate financial need and not have obtained a bachelor’s degree or a first professional degree. Grant amounts depend on the student’s expected family contribution, the cost of attendance (as determined by the institution), the student’s enrollment status (full-time or part-time), and whether the student attends for a full academic year or less. Education first reported an improper payment estimate for the Pell Grant program in fiscal year 2004. In its fiscal year 2019 AFR, Education reported an improper payment estimate of approximately $646 million, or 2.2 percent of Pell Grant program outlays of $28.9 billion. Children’s Health Insurance Program The Department of Health and Human Services’ (HHS) Children’s Health Insurance Program (CHIP) expands health coverage to uninsured children who are ineligible for Medicaid but cannot afford private coverage. The states and the federal government jointly fund CHIP benefit payments and administrative expenses. HHS’s Centers for Medicare & Medicaid Services (CMS) oversees the program; however, each state administers the program and sets its own guidelines regarding eligibility and services according to federal guidelines. HHS first reported an improper payment estimate for CHIP (based on one-third of the states) in fiscal year 2008. In its fiscal year 2019 AFR, HHS reported an improper payment estimate of approximately $2.7 billion, or 15.8 percent of CHIP outlays of $17.3 billion. Earned Income Tax Credit The Earned Income Tax Credit (EITC) administered by the Department of the Treasury (Treasury) is a credit that offsets taxes owed by eligible taxpayers, and because the credit is refundable, EITC recipients need not owe taxes to receive a benefit. If the taxpayer’s credit exceeds the amount of taxes due, the Internal Revenue Service (IRS) issues a refund of the excess to the taxpayer. To claim the EITC, the taxpayer must work and have earnings that do not exceed the phaseout income of the credit. Additional eligibility rules apply to any children that a taxpayer claims for calculating the credit. Among other criteria, a qualifying child must meet certain age, relationship, and residency requirements. Treasury first reported an improper payment estimate for EITC in fiscal year 2003. In its fiscal year 2019 AFR, Treasury reported an improper payment estimate of approximately $17.4 billion, or 25.3 percent of EITC outlays of $68.7 billion. Prosthetic and Sensory Aids Service Through its Prosthetic and Sensory Aids Service (PSAS), the Department of Veterans Affairs’ (VA) Veterans Health Administration (VHA) provides prosthetics to veterans who have experienced the loss or permanent impairment of a body part or function. The items VA provides include those worn by the veteran, such as an artificial limb or hearing aid; those that improve accessibility, such as ramps and vehicle modifications; and devices surgically placed in the veteran, such as hips and pacemakers. In general, veterans enrolled in the VA health care system with a medical need for a prosthetic service or item are eligible; however, additional eligibility criteria for certain services or items may apply. PSAS officials in VA’s central office provide overall administration of VA’s provision of prosthetic items, including allocating funding among various networks, monitoring spending, and establishing and monitoring mechanisms to evaluate the agency’s performance. PSAS processes prescriptions and provides the prescribed items to individual veterans. PSAS government credit card holders, typically at VA medical centers, perform administrative actions—such as obtaining additional information from the prescribing clinician, obtaining price quotes from contractors, and creating purchase orders—to process prescriptions. PSAS also has staff who provide clinical services to veterans, such as evaluating prosthetic needs and designing and fitting artificial limbs. VA first reported an improper payment estimate for PSAS in fiscal year 2017. In its fiscal year 2019 AFR, VA reported an improper payment estimate of approximately $60 million, or 2.1 percent of PSAS outlays of $2.9 billion. Old Age, Survivors, and Disability Insurance Program The Social Security Administration’s (SSA) Old Age, Survivors, and Disability Insurance program (OASDI), collectively referred to as Social Security, provides cash benefits to eligible U.S. citizens and residents. OASDI is financed largely on a pay-as-you-go basis. Specifically, OASDI payroll taxes, paid each year by current workers, are primarily used to pay benefits provided during that year to current beneficiaries. OASDI consists of two separate insurance programs that SSA administers under the Social Security Act. Old Age and Survivors Insurance (OASI) provides benefits to retired workers, their families, and survivors of deceased workers. The monthly benefit amount depends on a worker’s earnings history and the age at which he or she chooses to begin receiving benefits, along with other factors. Benefits are paid to workers who meet requirements for the time they have worked in covered employment—that is, jobs through which they have paid Social Security taxes. Disability Insurance (DI) provides cash benefits to working-age adults who are unable to work because of long-term disability. SSA generally considers individuals to have a disability if (1) they cannot perform work that they did before and cannot adjust to other work because of their medical condition(s) and (2) their disability has lasted or is expected to last at least 1 year or is expected to result in death. Further, individuals must have worked and paid into the program for a minimum period of time to qualify for benefits. To ensure that only beneficiaries who remain disabled continue to receive benefits, SSA is required to conduct periodic continuing disability reviews in certain circumstances. SSA first reported an improper payment estimate for OASDI in fiscal year 2004. In its fiscal year 2019 AFR, SSA reported an improper payment estimate of approximately $2.7 billion, or 0.3 percent of OASDI program outlays of $948 billion. Supplemental Security Income Program SSA’s Supplemental Security Income (SSI) is a federal income supplement program funded by general tax revenues (not Social Security taxes). The program provides payments to low-income aged, blind, and disabled persons—both adults and children—who also meet financial eligibility requirements. For adults, a disability is defined as the inability to engage in any substantial gainful activity because of any medically determinable physical or mental impairment(s) that can be expected to result in death or has lasted or can be expected to last for a continuous period of not less than 12 months. To ensure that only recipients who remain disabled continue to receive benefits, SSA is required to conduct periodic continuing disability reviews in certain circumstances. To be eligible to receive monthly SSI payments, the adult individual’s (or married couple’s) or child’s (and parent’s) monthly countable income has to be less than the monthly federal SSI benefit amount. The amount of the monthly SSI payment is then determined based on the countable income. In most cases, countable income received in the current month affects the SSI payment amount 2 months later. Furthermore, countable resources—such as financial institution accounts—must not exceed the maximum allowable threshold. While recipients are required to report changes in their income and financial resources, SSA also conducts periodic redeterminations to verify that recipients are still eligible for SSI. SSA first reported an improper payment estimate for SSI in fiscal year 2004. In its fiscal year 2019 AFR, SSA reported an improper payment estimate of approximately $5.5 billion, or 9.7 percent of SSI program outlays of $56.9 billion. Selected Agencies Generally Used Improper Payment Estimation Methodology Results as the Basis for Identifying Root Causes of Improper Payments Five Out of Six Agencies Used Improper Payment Estimation Methodology Results as the Basis for Identifying Root Causes of Selected Programs’ Improper Payments We found that five out of six agencies—USDA, Education, HHS, VA, and SSA—used the results of their improper payment estimation methodologies as the basis for identifying the root causes of improper payments for the selected programs we reviewed. Specifically, the agencies generally used a two-step process to identify root causes of improper payments. First, the agencies reviewed a sample of payments to identify which payments were improper and to establish an improper payment rate. Second, the agencies analyzed the improper payment results to determine the causes of error. Further details on each agency’s process are provided below. USDA: According to USDA’s fiscal year 2018 AFR, FNS used SNAP’s Quality Control System to identify improper payments and determine improper payment rates for fiscal year 2018. According to agency officials, SNAP improper payment root causes occur at the state level. According to agency officials, as required by the Food and Nutrition Act of 2008 and subsequent program regulations, FNS requires states to conduct root cause analyses and develop corrective action plans because of the unique circumstances in each state owing to flexibilities under statute and regulations. SNAP’s Quality Control system uses a two-tier approach to report improper payments. In the first tier, each month, state agencies follow federal sampling requirements to select samples of households that participated in SNAP in their states and conduct quality control reviews to determine whether each selected household was eligible and received the right amount of benefits. In the second tier of the process, Federal SNAP staff select a subsample of the state data for review to confirm the validity of the states’ findings. Federal SNAP staff use that subsample data to aggregate the root cause information at a nationwide level in order to categorize the data into the OMB root cause categories for fiscal year 2018 reporting. Education: According to Education’s fiscal year 2018 AFR, Education conducted a risk-based, nonstatistical sample and estimation methodology, which OMB approved, to estimate Pell Grant and Direct Loan improper payment rates for fiscal year 2018 reporting. As part of this estimation process, Education analyzed identified improper payments to determine improper payment root causes. HHS: According to HHS’s fiscal year 2018 AFR, HHS estimated the CHIP improper payment rate for fiscal year 2018 reporting through the Payment Error Rate Measurement (PERM) program. CHIP improper payment root causes were identified at both the agency and state levels. Specifically, to determine improper payment root causes at the agency level, HHS analyzed the issues identified during the PERM review and identified primary drivers of the national PERM rate for CHIP. HHS also provided improper payment results to each state and required them to conduct more in-depth state-level root cause analyses as part of developing their corrective action plans. VA: According to VA’s fiscal year 2018 AFR, VA conducted a statistical sample and estimation methodology to estimate the PSAS improper payment rate for fiscal year 2018 reporting. VA then analyzed the improper payments identified during testing to determine improper payment root causes. SSA: According to SSA’s fiscal year 2018 AFR, SSA conducts stewardship reviews each fiscal year to estimate the improper payment rates for OASDI and SSI. Although SSA considers the stewardship review data sufficient to provide statistically reliable data on the overall payment accuracy of OASDI and SSI, SSA considered deficiency data from the most recent 5 years of stewardship reviews to determine improper payment root causes for each program for its fiscal year 2018 reporting. Treasury Used 2006 through 2008 Tax Year Data to Identify Reported Root Causes of Fiscal Year 2018 EITC Improper Payments Treasury identified the root causes of EITC improper payments for fiscal year 2018 reporting based on the most recent detailed 3-year EITC compliance study IRS conducted, using data from tax years 2006 through 2008. IRS officials acknowledged that using older data creates additional potential for error; however, they stated that IRS is only able to conduct in-depth compliance studies on major refundable income tax credits, including EITC, on a rotating basis. IRS also conducted in-depth EITC compliance studies for tax years 1997 and 1999. These studies and IRS’s 2006 through 2008 compliance study, identified income misreporting and qualifying child errors as the main sources of errors. Therefore, agency officials indicated that Treasury is comfortable with using the 2006 through 2008 data as the basis for determining the root causes of fiscal year 2018 EITC improper payments. However, Treasury has reported changes to the tax environment since 2008, including legislative revisions that may have affected taxpayer compliance behavior. Specifically, EITC-related changes include expanding the credit to a third child, establishing new criteria for claiming a qualifying child, and amending the “age test” for qualifying children, among others. Furthermore, the 2006 through 2008 compliance study did not take into account the Protecting Americans from Tax Hikes Act of 2015 program integrity provisions that required tax filers to provide Form W-2 payer information to IRS for verification earlier than in previous tax years. Federal internal control standards state that management should use quality information to achieve the entity’s objectives. As part of these standards, management obtains relevant data from reliable internal and external sources in a timely manner and uses quality information to make informed decisions and evaluate the entity’s performance in achieving objectives and addressing risks. Quality information is appropriate, current, complete, accurate, accessible, and provided on a timely basis. Although a specific delivery date has not been set, agency officials stated that IRS plans to conduct another in-depth EITC compliance analysis within the next 2 years. We agree with Treasury’s plan to conduct another EITC compliance analysis using more timely data. However, until Treasury conducts an EITC improper payment root cause analysis using more timely data, it will be uncertain whether identified root causes are sufficiently relevant to inform decisions and evaluate risks. Specifically, continued use of outdated information to evaluate EITC improper payments increases the risk that Treasury may not be identifying these payments’ true root causes and therefore will lack quality information needed to develop appropriate corrective actions and reduce them. Most Selected Agencies Developed Corrective Actions That Correspond to Identified Root Causes of Improper Payments Four Out of Six Agencies Developed Corrective Actions That Correspond to Identified Root Causes of Improper Payments for the Selected Programs Four out of six agencies—Education, HHS, VA, and SSA—developed corrective actions that correspond to identified root causes of improper payments for the selected programs we reviewed, in accordance with OMB guidance. Specifically, we found that Education and VA developed corrective actions corresponding to each root cause of improper payments identified for fiscal year 2018 in Education’s Direct Loan and Pell Grant programs and VA’s PSAS, respectively. In addition, HHS stated that it developed corrective actions that corresponded to the root causes it determined to be significant to CHIP improper payments for fiscal year 2018, prioritizing large dollar over smaller dollar value root cause categories. Corrective action plans for CHIP improper payments were developed at both the agency and state levels. According to agency officials, CMS helped individual states develop and implement state-specific PERM corrective action plans to address the errors identified in each state. In addition, because each state’s errors do not necessarily represent errors that are the main drivers of the national PERM rate, CMS developed agency-level corrective action plans focused on those drivers, which typically occurred across multiple states. We also found that SSA’s corrective actions corresponded to root causes of improper payments identified in OASDI and SSI for fiscal year 2018. However, SSA did not develop corrective actions corresponding to three of the six major root causes it identified for OASDI improper payments based on its stewardship review findings. Agency officials explained that SSA’s corrective action development process was decentralized among the different SSA components, and therefore, there was no formalized process for components to develop corrective actions for all identified root causes. SSA has since developed a new standardized improper payment strategy and updated procedures to implement the strategy for fiscal year 2020. Although the scope of our review focused on processes in place for fiscal year 2018, we found that the updated procedures, if effectively implemented, will address our concerns because they include control activities designed to help ensure that corrective actions that SSA develops and implements correspond to the identified root causes of improper payments, as directed by OMB guidance. Specifically, the updated procedures direct SSA components to identify root causes of improper payments and develop mitigation strategies for each; conduct cost-benefit analyses for such strategies; and after considering these analyses, determine and prioritize necessary corrective actions. USDA Did Not Develop Agency Corrective Actions That Correspond to Identified Root Causes of SNAP Improper Payments In contrast to HHS, which developed both agency- and state-level corrective actions for its state-administered CHIP, USDA did not develop agency-level corrective actions corresponding to the root causes of SNAP improper payments. USDA’s IPIA corrective action plan guidance directs its components, including FNS, to develop corrective actions that correspond to the identified root causes of improper payments for programs that are susceptible to significant improper payments. Instead of developing agency-level SNAP corrective actions, FNS requires the states to develop state-level corrective actions. Additionally, FNS provided technical assistance and support to the individual states to help them improve payment accuracy. As part of this assistance, agency officials stated that FNS regional offices provided routine formal training and guidance to the states and conducted site visits. According to agency officials, FNS did not develop agency-level corrective actions corresponding to the root causes of SNAP improper payments because FNS requires the states to develop individual state- level corrective actions. Additionally, because of varying root causes and the uniqueness of issues identified among the states, agency officials believe that state corrective actions may not easily aggregate to the state level. However, FNS’s procedures did not include a process to analyze state-level root causes to identify similarities and develop agency-level corrective actions, if warranted, to help address them. According to agency officials, FNS has made significant improvements in the last few years regarding its controls over SNAP. The officials said that FNS has also implemented major changes in oversight in the last few fiscal years to address previously identified deficiencies among the states. While these changes may be valuable in improving agency oversight and states may have unique circumstances that could lead to varying state-identified root causes of improper payments, FNS is ultimately responsible for preventing and reducing improper payments within SNAP. OMB guidance directs agencies to develop and implement appropriate corrective actions that respond to the root causes of improper payments to prevent and reduce them. OMB guidance also directs agencies to ensure that managers; programs; and, where applicable, states are held accountable for reducing improper payments. Additionally, federal internal control standards state that management should establish and operate activities to monitor the internal control system and evaluate the results and remediate identified internal control deficiencies on a timely basis. As part of these standards, management retains responsibility for monitoring the effectiveness of internal control over the assigned processes that external parties, such as state agencies, perform. Without considering similarities of root causes of SNAP improper payments among the states, USDA will be uncertain whether developing and implementing agency-level corrective actions (in addition to state-level actions) would also help to effectively reduce them. Treasury Did Not Develop Corrective Actions That Correspond to Identified Root Causes of EITC Improper Payments Instead of developing corrective actions corresponding to the identified root causes of EITC improper payments for fiscal year 2018, Treasury addressed improper payments through IRS’s compliance programs and through outreach and education efforts to taxpayers and preparers. According to agency officials, although some of the outreach efforts are indirectly related to root causes identified, it is difficult to link those efforts to the reduction of errors that result from being unable to authenticate eligibility—which Treasury considers the biggest issue in the EITC program—because of the complexity of statutory eligibility requirements. Although Treasury uses information from SSA and HHS to help IRS verify residency and relationship information for parents and children, Treasury’s strategy for addressing the root causes of EITC improper payments does not include continuing efforts to identify and reach out to additional agencies to (1) determine how they verify information for certain eligibility-based programs and whether they use strategies that Treasury could adopt or (2) identify other potential data sources that could be used to verify EITC information or confirm that other data sources do not exist. According to agency officials, such inquiries are not included because the eligibility requirements for EITC are not always the same as requirements for other government programs. Additionally, Treasury’s fiscal year 2018 AFR states that because of the nature of EITC, corrective actions implemented by IRS alone will not significantly reduce EITC improper payments. For example, according to Treasury officials, legislative changes are needed to help address certain EITC improper payments. While Treasury has made certain legislative proposals related to providing IRS greater flexibility to address correctable errors and increasing oversight of paid tax return preparers, it has not made proposals to help address EITC eligibility criteria issues. Additionally, Treasury’s strategy does not include identifying and proposing legislative changes needed to help reduce EITC improper payments related to these or other issues, such as those related to the inability to authenticate taxpayer eligibility discussed above. OMB guidance directs agencies to develop and implement appropriate corrective actions that respond to the root causes of improper payments to prevent and reduce them. Further, federal internal control standards state that management should use quality information to achieve the entity’s objectives. As part of these standards, management designs a process that uses the entity’s objectives and related risks to identify the information requirements needed to achieve the objectives and address the risks and obtains relevant data from reliable internal and external sources in a timely manner based on the identified information requirements. While we recognize the unique eligibility requirements for EITC, until Treasury coordinates with other agencies to identify potential strategies or data sources that may help in determining eligibility, it will be uncertain whether Treasury can leverage additional sources to help verify data. Additionally, without identifying and proposing legislative changes to help resolve such issues, Treasury will be at risk of continuing to be unable to significantly reduce EITC improper payments. All Six Agencies Communicated Improper Payment Corrective Action Plan Information to Internal Stakeholders, but Several Did Not Monitor Progress or Measure Effectiveness All six agencies responsible for the programs we reviewed communicated with internal agency stakeholders regarding their improper payment corrective action plan information, in accordance with OMB guidance and federal internal control standards. However, as shown in table 3, three of the four agencies—Education, HHS, and SSA—that developed corrective actions corresponding to the identified root causes either did not establish planned completion dates, monitor the progress, or measure the effectiveness of their corrective actions. In fact, we found that VA was the only agency that measured the effectiveness of each corrective action for the selected program (PSAS) that we reviewed. As previously discussed, USDA and Treasury did not develop agency corrective actions corresponding to the identified root causes of improper payments for their selected programs and therefore did not establish planned related completion dates, monitor progress, or measure the effectiveness of such corrective actions. Selected Agencies Have Processes in Place to Communicate with Internal Stakeholders regarding Corrective Action Plan Information All six agencies we reviewed communicated information regarding the selected programs’ corrective action plans to internal stakeholders, consistent with OMB guidance and federal internal control standards. OMB M-18-20 directs agencies to ensure that managers, accountable officers (including the agency head), and program officials are held accountable for reducing improper payments. Additionally, federal internal control standards state that management should internally communicate the necessary quality information to achieve the entity’s objectives. As part of these standards, management communicates quality information down, across, up, and around reporting lines to all levels of the entity. We found that the six agencies communicated information, at least annually, to such internal stakeholders, including the relevant agency head, chief financial officer (CFO), and program managers. For example, some selected agencies—Education, HHS, VA, and SSA—provided briefings to the agency head and the CFO’s office regarding the status of the selected program’s improper payment corrective action activities during fiscal year 2019 for the corrective actions reported for fiscal year 2018. USDA and Treasury required their components to annually submit deliverables to the office of the CFO and coordinate accordingly with the Office of the Secretary as part of their fiscal year 2018 AFR reporting process. Two Agencies Established Planned Completion Dates for the Selected Programs’ Corrective Actions We found that two of the six agencies we reviewed—Education and VA— established planned completion dates for the selected programs’ corrective actions. Two agencies—HHS and SSA—did not consistently establish planned completion dates for all the selected programs’ corrective actions, as required by IPIA. Two agencies—USDA and Treasury—did not develop agency corrective actions corresponding to the identified root causes of improper payments for their selected programs and therefore did not establish planned completion dates for such corrective actions. Further details on each agency’s process are provided below. USDA: As previously discussed, FNS did not develop corrective actions at the agency level to address SNAP’s root causes of improper payments and, as a result, did not have planned completion dates for such corrective actions. However, in the event that FNS develops agency-level corrective actions, USDA’s IPIA corrective action plan guidance includes a directive for each corrective action to have an estimated completion date. Education: Education established planned completion dates for all Direct Loan and Pell Grant corrective actions that were not legislative proposals. For example, in fiscal year 2018, Education did not report a planned completion date for Federal Student Aid’s (FSA) corrective action related to proposed legislative changes, as the timeline for the legislative process is subject to external factors outside of Education’s control. HHS: HHS did not consistently establish planned completion dates for agency-level CHIP corrective actions. According to agency officials, most agency-level CHIP corrective actions are unlikely to have completion dates because the work is ongoing. We agree with HHS’s determination that establishing completion dates for ongoing corrective actions was not relevant. HHS provided a spreadsheet of CHIP’s corrective actions, which included a column of target completion dates. However, this column was not consistently filled out for actions that were not considered either ongoing or voluntary state processes. HHS officials stated that although HHS has a process for its improper payment corrective action plans, this process is not documented in formal policies and procedures. Instead, HHS uses OMB guidance as its policies and procedures. Lack of formally documented policies and procedures may have contributed to the inconsistencies in HHS establishing planned completion dates for agency-level CHIP corrective actions. Treasury: As previously discussed, instead of developing corrective actions to address root causes of EITC improper payments, Treasury addressed improper payments through IRS’s compliance programs and through outreach and education efforts to taxpayers and preparers. According to agency officials, Treasury did not establish planned completion dates for its compliance programs and outreach efforts because these activities were ongoing in nature and completed every year as part of IRS operations. We agree with Treasury’s determination that establishing completion dates for EITC ongoing compliance activities was not relevant. In the event that Treasury develops corrective actions for EITC improper payments, Treasury’s corrective action plan guidance includes a directive for each corrective action to have an estimated completion date. VA: VA established relevant planned completion dates for each PSAS corrective action. In addition, each task associated with each corrective action had a planned completion date. SSA: SSA did not consistently establish relevant completion dates for each OASDI and SSI corrective action. For example, SSA’s corrective action plans included sections for “target completion.” However, based on our review, these sections were not filled out consistently. According to agency officials, the process for developing and implementing its corrective actions was inconsistent because of SSA’s decentralized corrective action plan process. As previously discussed, SSA developed a new standardized improper payment strategy that if effectively implemented will address these concerns. Specifically, SSA’s procedures to implement this strategy include control activities designed to help ensure that the agency establishes planned completion dates for each corrective action, as required by IPIA. IPIA requires agencies to report on the planned or actual completion date of each action taken to address root causes of improper payments. Federal internal control standards state that management should design control activities to achieve objectives and respond to risks and implement control activities through policies. Further, federal internal control standards state that management should remediate identified internal control deficiencies on a timely basis. As part of these standards, management monitors the status of remediation efforts so that they are completed on a timely basis. Additionally, federal internal control standards state that management should implement its control activities through policies. Without documented policies and procedures for its improper payment corrective action plan process, including the establishment of planned completion dates, HHS lacks assurance that corrective action plan–related activities will be performed consistently. Additionally, without planned completion dates, HHS cannot demonstrate that it is effectively implementing and completing corrective actions timely and therefore cannot ensure that they will help reduce improper payments. Two Agencies Currently Do Not Have a Documented Process in Place to Monitor the Progress of Implementing the Selected Programs’ Corrective Actions Three of the four agencies—Education, HHS, and VA—that developed corrective actions corresponding to the identified root causes monitored the progress of the selected programs’ corrective actions, in accordance with OMB guidance. However, HHS’s process was not documented in policies and procedures. SSA did not monitor the progress for all relevant OASDI and SSI corrective actions but has since implemented policies and procedures to monitor such progress. USDA did not develop corrective actions at the agency level that corresponded to the identified root causes of improper payments for SNAP and therefore did not monitor the progress of such corrective actions. In addition, USDA’s corrective action plan guidance does not direct the agency to monitor the progress of its corrective actions. Although Treasury did not have corrective actions that corresponded to the root cause of improper payments, it did monitor the progress of its compliance and outreach efforts that are intended to help reduce EITC improper payments. Further details on each agency’s process are provided below. USDA: As previously discussed, FNS did not develop corrective actions at the agency level to address SNAP’s root causes of improper payments and, as a result, did not monitor the progress of such corrective actions. In addition, USDA’s IPIA corrective action plan guidance does not direct the agency to monitor the progress of its corrective actions. Without agency-level corrective actions to address the root causes of SNAP improper payments and a documented process to monitor the progress of implementing such agency-level corrective actions, USDA may miss opportunities to reduce SNAP improper payments. Education: Education monitored the progress of implementing each Direct Loan and Pell Grant corrective action. We found that Education maintained a spreadsheet to track the implementation status of each corrective action annually. Specifically, the status of each corrective action was updated to either “complete” or “open” for the annually recurring and long-term, multiyear corrective actions. The actions marked as “complete” had actual completion dates. Actions that Education considered ongoing, such as needed updates to help clarify verification requirements to the “Question and Answer” section of FSA’s website, were updated as “not applicable.” HHS: HHS monitored the progress of implementing each of its agency-level CHIP corrective actions. Specifically, HHS tracked the progress of implementing the corrective actions in a spreadsheet that included status updates for each agency-level corrective action. Agency officials stated that this information was updated approximately two to three times each fiscal year through an online interface; however, this process was not documented in policies and procedures. Without a properly documented process and related control activities, HHS is at increased risk that it may not consistently monitor the progress of CHIP corrective actions and has less assurance that such actions are implemented and completed timely. Treasury: Treasury did not develop corrective actions that corresponded to the root causes of EITC improper payments and, as a result, did not monitor the progress of such corrective actions. However, Treasury did monitor its compliance programs and outreach efforts that are intended to help reduce EITC improper payments during fiscal year 2018. VA: VA monitored the progress of implementing each PSAS corrective action. Specifically, we found that VA monitored the progress for each corrective action each month by calculating a completion percentage based on the status of tasks associated with each corrective action. SSA: SSA did not monitor the progress of implementing each OASDI and SSI corrective action. According to agency officials, the monitoring of corrective actions was inconsistent and evaluation of corrective actions was limited because of SSA’s decentralized corrective action plan process. As previously discussed, SSA developed a new standardized improper payment strategy that if effectively implemented will address these concerns. Specifically, SSA’s procedures to implement this strategy include control activities designed to help ensure that the agency monitors the progress of its corrective actions, as directed by OMB guidance. OMB guidance directs agencies to measure the progress of each individual corrective action annually. Federal internal control standards state that management should establish and operate activities to monitor the internal control system and evaluate the results and remediate identified internal control deficiencies on a timely basis. As part of these standards, management monitors the status of remediation efforts so that they are completed on a timely basis. Additionally, federal internal control standards state that management should implement its control activities through policies. Without monitoring the progress of its corrective actions, USDA cannot demonstrate that it is effectively implementing and completing its corrective actions timely and therefore cannot ensure that they will contribute to a reduction in improper payments. Further, unless HHS documents its process in policies and procedures, it will lack assurance that the progress of its corrective actions is monitored consistently and that such actions are implemented and completed timely. One Out of Six Agencies Measured the Effectiveness of Corrective Actions for the Selected Programs We found that one out of six agencies we reviewed—VA—measured the effectiveness of the selected programs’ corrective actions, including the establishment of reduction targets in accordance with OMB guidance. Education, HHS, and SSA did not measure the effectiveness of their corrective actions for the selected programs. In addition, USDA and Treasury did not develop agency corrective actions corresponding to the identified root causes of improper payments for their selected programs and therefore did not measure the effectiveness of such corrective actions. Further details on each agency’s process are provided below. USDA: As previously discussed, FNS did not develop agency-level corrective actions to address root causes of SNAP improper payments. Instead, FNS provided technical assistance and support to the individual states. According to agency officials, FNS cannot link each technical assistance initiative it provides to the states to the effect these efforts have on reducing payment integrity errors, as the technical assistance provided to the states can vary significantly. Additionally, USDA’s IPIA corrective action plan guidance did not include direction for the agency to measure the effectiveness of its corrective actions. Without agency-level corrective actions to address the root causes of SNAP improper payments and a documented process to measure the effect that agency actions have on improper payments, USDA will be unable to demonstrate whether such actions are effective in reducing improper payments and may risk continuing ineffective actions. In addition, as permitted by OMB, USDA did not establish a reduction target for SNAP improper payments because it lacked a sufficient baseline to accurately project future improper payment rates. USDA plans to reestablish reduction targets for fiscal year 2021 reporting. Education: Education’s policies and procedures state that to measure the effectiveness of the corrective actions, FSA solicits input from the corrective action owner, including, among other items, whether measuring and monitoring of the effectiveness of the corrective action has been established and a description of anecdotal evidence available to confirm the effectiveness of the corrective action. However, based on the procedures, it is unclear how the corrective action owners will conduct this analysis to demonstrate effectiveness. Education provided an example of communication to a corrective action owner requesting, among other items, that the corrective action owner (1) confirm that existing actions are focused on the true root causes of the improper payments and are actually reducing improper payments and (2) verify that existing corrective actions are achieving the intended purposes and results. Education officials informed us that although these items were discussed in stakeholder meetings, FSA was unable and did not attempt to quantify the direct effect of any one corrective action on the improper payment estimates. Education’s fiscal year 2018 AFR states that FSA does not attempt to quantify the reduction of the improper payment estimates in terms of percentage or amount due to Pell Grant and Direct Loan corrective actions. It further states that quantifying of results is not feasible because Education uses a nonstatistical alternative estimation methodology. However, according to Education’s fiscal year 2019 AFR, Education implemented a statistical estimation methodology for the fiscal year 2019 estimates. Education believes that the new methodology will allow FSA to better measure the effectiveness of corrective actions over time as FSA collects a baseline of statistically valid improper payment estimates. According to agency officials, FSA is currently refining its process for measuring the effectiveness of corrective actions based on its new statistical estimation methodology. However, until Education revises and documents its process to include measuring the direct effect that its Pell Grant and Direct Loan corrective actions have on improper payments, it will be unable to demonstrate whether the corrective actions are effective in reducing the associated improper payments and may risk continuing ineffective actions. As part of its overall payment integrity reporting in fiscal year 2018, Education established program-wide reduction targets for Pell Grant and Direct Loan. However, according to agency officials, because it used an OMB-approved nonstatistical methodology, Education’s confidence in using these results to establish reduction targets for the upcoming fiscal year was limited. Specifically, Education’s fiscal year 2018 AFR states that imprecision and volatility in the improper payment estimates continue to limit its ability to establish accurate out-year reduction targets. Therefore, for fiscal years 2016 through 2018, Education set the upcoming fiscal year reduction targets to match the current fiscal year reported improper payment rate for each program. According to agency officials, Education plans to consider the feasibility of setting meaningful reduction targets moving forward with its new statistical methodology. HHS: HHS did not measure the effectiveness of its corrective actions for CHIP improper payments. In addition, as discussed above, HHS does not have formal documented policies and procedures for its improper payment corrective action plan process. According to agency officials, establishing a one-to-one relationship between specific corrective actions and resulting changes in the improper payment rates is difficult because of the complexity of factors involved that lead to them. However, until HHS develops and implements a documented process to measure the effect that CHIP corrective actions have on improper payments, it will be unable to demonstrate whether the corrective actions are effective in reducing the associated improper payments and may risk continuing ineffective actions. As permitted by OMB’s implementing guidance, HHS did not establish a program-wide reduction target for CHIP improper payments for fiscal years 2019 or 2020, and does not anticipate setting one for 2021 because it lacks a sufficient baseline to accurately project future improper payment rates. According to agency officials, HHS plans to establish a CHIP reduction target for fiscal year 2022 reporting. Treasury: Treasury did not develop specific corrective actions to address root causes of EITC improper payments, so it could not measure the effectiveness of its corrective actions. Agency officials recognized that the current actions on their own will be unable to significantly reduce the amount of EITC improper payments. As approved by OMB, Treasury did not establish a program-wide reduction target for EITC improper payments for fiscal year 2018 reporting. However, Treasury set a reduction target for EITC improper payments in its fiscal year 2019 AFR, per OMB guidance. VA: VA has documented procedures in place to measure the effectiveness of its corrective actions for PSAS improper payments. As part of this process, VA set reduction targets and timelines for reducing the errors associated with each corrective action. VA maintained a timeline spreadsheet showing the corrective action reduction targets by year and the percentage of improper payments it expects to be reduced once each corrective action is fully implemented. VA updated the spreadsheet at the end of fiscal year 2019 with the current results of the effectiveness measure for corrective actions reported in fiscal year 2018. In addition, VA also set a program-wide reduction target for PSAS improper payments. SSA: SSA did not measure the effectiveness of its corrective actions for OASDI and SSI improper payments. According to agency officials, SSA did not have procedures to collect the necessary data and therefore was unable to measure the effectiveness of its corrective actions. SSA’s procedures for its new standardized improper payment strategy (discussed above) direct responsible components to define the metrics and information necessary to evaluate the corrective actions and to determine if the actions are effectively reducing improper payments. However, it is still unclear which metrics will be used to determine the effect that OASDI and SSI corrective actions have on the corresponding root causes to demonstrate effectiveness. Until SSA develops and implements a documented process to measure the effect that the OASDI and SSI corrective actions have on improper payments, it will be unable to demonstrate whether the corrective actions are effective in reducing the associated improper payments and may risk continuing ineffective actions. As part of its overall payment integrity reporting in fiscal year 2018, SSA established program-wide reduction targets for both programs. However, some of SSA’s reduction targets have remained constant since fiscal year 2004 reporting. Agency officials stated that although SSA believes OASDI’s payment accuracy rate is exceptionally high, if SSA’s mitigation strategies help decrease improper payments, it would consider changing the reduction target. For SSI, agency officials stated that SSA believes that SSI’s program complexity and reliance on self-reporting have made meeting the current accuracy goal challenging. Agency officials further stated that if planned mitigation strategies help decrease improper payments, SSA would consider changing the SSI reduction target. OMB guidance directs agencies to measure the effectiveness of each individual corrective action annually. Agencies may measure the effectiveness of corrective actions by assessing the results of actions taken to address the root causes, such as the performance and outcomes of these processes. In addition, OMB guidance states that for long-term, multiyear corrective actions, agencies should identify annual benchmarks used to demonstrate the initial effect on improper payment prevention and reduction. For corrective actions already in place, agencies should be able to describe how they evaluate these actions’ effectiveness and the results. Federal internal control standards state that management should establish and operate activities to monitor the internal control system and evaluate the results. As part of these standards, management performs ongoing monitoring of the design and operating effectiveness of the internal control system as part of the normal course of operations. Additionally, federal internal control standards state that management should implement its control activities through policies. Unless USDA, Education, HHS, and SSA develop and implement a process that clearly links corrective actions to effectively addressing improper payments, they will be uncertain whether the actions are actually reducing improper payments and the agencies may risk continuing ineffective actions. Further, unless these processes are documented in policies and procedures, agencies will lack assurance that the effectiveness of their corrective actions is measured consistently. Conclusions Developing corrective action plans that respond to identified root causes of improper payments is a critical component in government-wide efforts to reduce improper payments. Agency processes to monitor the progress and measure the effectiveness of such plans are also essential to evaluating their efforts to address improper payments. However, certain agencies have not effectively taken these steps for the selected programs we reviewed. For example, USDA and Treasury have not developed agency-wide corrective actions that correspond to the identified root causes of improper payments in their SNAP and EITC programs, respectively, that would better position these agencies to reduce and prevent them. Also, HHS lacks important information to monitor its efforts to address CHIP improper payments because it does not consistently establish planned completion dates for agency-level corrective actions. Additionally, USDA, Education, HHS, and SSA do not have sufficient processes in place to measure the effectiveness of corrective actions to address improper payments for the selected programs we reviewed. Unless agencies develop corrective action plans that correspond to the root causes of improper payments and implement processes to effectively monitor progress and measure their effectiveness, their ability to ensure that their actions will reduce improper payments will be limited. Recommendations for Executive Action We are making the following seven recommendations—one each to Education, HHS, and SSA and two each to USDA and Treasury. The Administrator of FNS should develop and implement a process, documented in policies and procedures, to analyze SNAP state-level root causes to identify potential similarities among the states and develop and implement SNAP agency-level corrective actions, if appropriate, to help address them. (Recommendation 1) The Secretary of Agriculture should revise USDA’s procedures to include processes for monitoring the progress and measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect USDA’s corrective actions have on reducing improper payments. (Recommendation 2) The Secretary of Education should revise and document Education’s process for measuring the effectiveness of its corrective actions based on its new statistical estimation methodology for Direct Loan and Pell Grant improper payments. This process should clearly demonstrate the effect Education’s corrective actions have on reducing improper payments. (Recommendation 3) The Secretary of Health and Human Services should document in policies and procedures HHS’s improper payment corrective action plan process. As part of these procedures, HHS should include processes for (1) establishing planned completion dates, (2) monitoring the progress of implementing corrective actions, and (3) measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect HHS’s corrective actions have on reducing improper payments. (Recommendation 4) The Secretary of the Treasury should determine whether Treasury’s current improper payment root cause analysis provides sufficiently relevant information that can be used as a basis for proposed corrective actions in reducing EITC improper payments and, if not, update the analysis using more timely data to ensure their reliability for identifying root causes of EITC improper payments. (Recommendation 5) The Secretary of the Treasury should update Treasury’s strategy for addressing the root causes of EITC improper payments to include (1) coordinating with other agencies to identify potential strategies and data sources that may help in determining EITC eligibility and (2) determining whether legislative changes are needed, and developing proposals as appropriate, to help reduce EITC improper payments, such as those related to the inability to authenticate taxpayer eligibility. (Recommendation 6) The Commissioner of SSA should develop and implement a process, documented in policies and procedures, to measure the effectiveness of SSA’s corrective actions for OASDI and SSI improper payments. This process should clearly demonstrate the effect SSA’s corrective actions have on reducing improper payments. (Recommendation 7) Agency Comments and Our Evaluation We provided a draft of this report for comment to OMB, USDA, Education, HHS, Treasury, VA, SSA, and the Council of the Inspectors General on Integrity and Efficiency (CIGIE). We received written comments from five agencies—USDA, Education, HHS, VA, and SSA—which are reproduced in appendixes I through V and summarized below. The Assistant Director of Treasury’s Risk and Control Group also provided comments in an email, which are summarized below. Treasury, HHS, VA, and SSA also provided technical comments, which we incorporated as appropriate. CIGIE and OMB liaisons informed us that CIGIE and OMB had no comments on the report. In its written comments, USDA stated that it generally agrees with our findings and recommendations. USDA stated that FNS has agency-level corrective actions that correspond to the identified root causes and establishes planned completion dates, monitors the progress, and measures the effectiveness of SNAP’s corrective actions. However, USDA officials did not provide documentation or other information supporting such agency-level corrective actions and efforts. Rather, as discussed in our report, FNS provides technical assistance and support to the states to help them improve payment accuracy and requires them to develop state-level corrective actions. Because FNS’s initiatives do not address specific root causes, we continue to believe that USDA does not have agency-level corrective actions that correspond to the identified root causes of SNAP improper payments. In regard to our recommendation to FNS to develop and implement a process to analyze SNAP state-level root causes and take other related actions, FNS stated that it already has an existing process and recommended that we revise our recommendation to indicate that its existing process should be formalized. In our report, we acknowledge that under statutory requirements and program regulations, FNS requires the states to identify the root causes and develop corrective actions that address them. However, USDA did not provide any evidence that FNS analyzes the states’ root causes to identify similarities and develop corrective actions at the agency level. Therefore, we continue to believe that our recommendation to FNS to develop and implement this process is valid to help ensure that it develops corrective actions at the agency level, if appropriate, and to help reduce improper payments within SNAP. In regard to our recommendation to revise USDA’s procedures, USDA stated that it will develop a proposed action plan to revise its procedures for monitoring the progress and measuring the effectiveness of improper payment corrective actions and the revised process will focus on the impact corrective actions have on the corresponding root causes of improper payments. The actions USDA described, if implemented effectively, would address our recommendation. In its written comments, Education neither concurred nor disagreed with our recommendation, stating that FSA will continue to evaluate and refine its processes to measure corrective actions and the effectiveness of these actions. Further, Education stated that FSA’s measurement of corrective action effectiveness and root cause identification will gain additional precision as FSA collects annual improper payment data and builds upon the new baseline of statistically valid improper payment estimates. Education stated that FSA annually measures the overall effectiveness of its corrective action plans collectively against the improper payment reduction targets, rather than measuring the effectiveness of each individual corrective action. However, as discussed in our report, OMB guidance directs agencies to measure the effectiveness of each individual corrective action annually. We continue to believe that our recommendation to Education is valid to help ensure that Education’s corrective actions are effective in reducing improper payments. In its written comments, HHS stated that it does not concur with our recommendation. Specifically, HHS stated that the portion of our recommendation providing that HHS’s process for measuring the effectiveness of corrective actions should clearly demonstrate their impact on the corresponding root causes of improper payments is operationally impossible and not required by OMB guidance. We acknowledge that given the unique circumstances across federal agencies concerning improper payments, OMB guidance provides some flexibility for how agencies are to measure the effectiveness of their corrective actions. However, if agencies’ corrective actions are effective, they should ultimately reduce improper payments. Without being able to demonstrate whether corrective actions are effective in reducing the associated improper payments, agencies will be uncertain if their actions are actually reducing improper payments and may risk continuing ineffective actions. While we acknowledge that OMB guidance does not explicitly require agencies to demonstrate the impact corrective actions have on the corresponding root causes of improper payments, agencies are required to analyze the root causes of improper payments and develop corrective actions to reduce improper payments. As such, we clarified this portion of our recommendation to indicate that HHS’s process should clearly demonstrate the effect corrective actions have on reducing improper payments, to better align with the purpose of corrective action plans. We also made this revision to our recommendations to USDA, Education, and SSA. In its written comments, VA stated that PSAS supported improper payments statutory requirements by completing annual audit reviews, identifying root causes, and developing a national program action plan to reduce improper payments. VA also stated that PSAS reduced improper payments from 39.7 percent in fiscal year 2018 to 2.1 percent in fiscal year 2019 and continues to make improvements through enhanced audit reviews and consultation with PSAS sites. In its written comments, SSA stated that it concurs with our recommendation and will determine the most cost-effective strategies to remediate the underlying causes of payment errors and monitor, measure, and revise the strategies as needed. The actions SSA described, if implemented effectively, would address our recommendation. In emailed comments, the Assistant Director of Treasury’s Risk and Control Group neither concurred nor disagreed with our recommendations. In regard to our recommendation to update its strategy for addressing root causes of EITC improper payments, Treasury stated that each year it indicates in its corrective action plan that IRS will continue to work with Treasury to develop legislative proposals that will improve refundable credit compliance and reduce erroneous payments. Treasury also stated that its fiscal year 2020 budget request included two legislative proposals that may improve refundable credit compliance and reduce erroneous payments and that both proposals have been in the President’s Budget for several years now. We acknowledge these legislative proposals in our report, and note that although Treasury has made certain legislative proposals, it has not made proposals to specifically help address EITC eligibility criteria issues. Additionally, as noted in the report, Treasury’s strategy does not include identifying and proposing additional legislative changes needed to help reduce EITC improper payments. Therefore, we continue to believe that our recommendation to Treasury is valid to help ensure that Treasury addresses EITC eligibility issues, which Treasury identifies as the primary root cause for EITC improper payments. We are sending copies of this report to the appropriate congressional committees, the Director of the Office of Management and Budget, the Secretary of Agriculture, the Secretary of Education, the Secretary of Health and Human Services, the Secretary of the Treasury, the Secretary of Veterans Affairs, the Commissioner of the Social Security Administration, and other interested parties. In addition, this report is available at no charge on the GAO website at http://www.gao.gov. If you or your staffs have any questions about this report, please contact me at (202) 512-2623 or davisbh@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 VI. Appendix I: Comments from the Department of Agriculture Appendix II: Comments from the Department of Education Appendix III: Comments from the Department of Health and Human Services Appendix IV: Comments from the Department of Veterans Affairs Appendix V: Comments from the Social Security Administration Appendix VI: GAO Contact and Staff Acknowledgments GAO Contact Staff Acknowledgments In addition to the contact named above, Matthew Valenta (Assistant Director), Stephanie Adams (Auditor in Charge), William Beichner, Susanna Carlton, Virginia Chanley, Anthony Clark, Lindsay Hollup, James Kernen, and Diana Lee made key contributions to this report.