oversight

Report 2015-001-IPER - U.S. Equal Employment Opportunity Commission's Compliance with the Improper Payments Elimination and Recovery Act P.L. 111-204 (IPERA), as amended by the Improper Payments Elimination and Recovery Improvement Act P.L. 112-248 (IPE

Published by the Equal Employment Opportunity Commission, Office of Inspector General on 2015-05-13.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
                               Washington, D.C. 20507

Office of Inspector General

                                                  May13, 2015


MEMORANDUM


TO:              Committee on Homeland Security & Governmental Affairs
                 United States Senate
                 340 Dirksen Senate Office Building
                 Washington, DC 20510

                 Committee on Oversight and Government Reform
                 United States House of Representatives
                 2157 Rayburn House Office Building
                 Washington, DC 20515

                 Honorable Jenny R. Yang, Chair
                 U.S. Equal Employment Opportunity Commission
                 131 M St. NE
                 Washington, DC 20507

                 Beryl H. Davis
                 Director, Financial Management and Assurance
                 U.S. Government Accountability Office
                 441 G Street, NW, Room 5490
                 Washington, DC 20548

                 Honorable David Mader
                 Controller, Office of Federal Financial Management
                 Office of Management and Budget
                 725 17th Street, NW
                 Washington, DC 20503

FROM:            Milton A. Mayo, Jr.
                 Inspector General


SUBJECT:         U.S. Equal Employment Opportunity Commission’s Compliance with the
                 Improper Payments Elimination and Recovery Act P.L. 111-204 (IPERA), as
                 amended by the Improper Payments Elimination and Recovery Improvement Act
                 P.L. 112-248 (IPERIA) for FY 2014
OIG Report No. 2015-01-IPERA


The IPERIA1 requires agencies and entities, such as the U.S. Equal Employment Opportunity
Commission (EEOC), with improper payment estimates that do not meet the statutory thresholds
to report an estimate of the annual amount and rate of improper payments, as well as reduction
targets in their annual Agency Financial Reports (AFRs) or Performance and Accountability
Reports (PARs) per M-15-02 Part IA 9 Step 4c (page 16). These agencies also are required to
conduct a risk assessment to identify programs/activities that may be susceptible to significant
improper payments. If an agency determines that it is not at high risk for significant improper
payments, then risk assessments are required every 3 years. If no programs are at risk for
significant improper payments, the other requirements on annual reduction targets, corrective
action plans, etc. are not applicable. Additionally, small agencies should have a payment
recapture program in place.

The Office of Inspector General (OIG) is required by IPERA to determine and report by May 15,
2015, on whether the EEOC is in compliance with the Improper Payments Information Act.

Based on our findings, we determined the agency has complied with the Improper Payments
Information Act (IPIA), as amended by IPERIA. To satisfy our reporting requirements, we
communicated with the agency’s Chief Financial Officer (CFO) to determine whether a risk
assessment was conducted to identify programs/activities in the agency that may be susceptible
to significant improper payments and whether the agency has a payment recapture program in
place. The CFO indicated that the agency conducted an agency-wide risk assessment via a
statistical sampling of vendor and travel payments in FY 2014. Additionally, the agency relied
on the results of the FY 2014 financial audit, which did not uncover duplicate/improper
payments, and agency internal controls in place relating to payments. The CFO concluded that
the agency is not at risk for significant improper payments and determined that there were no
significant improper payments made during FY 2014. The agency plans to continue performing
in house-risk assessments. As a result of the CFO’s response, the requirement for annual
reduction targets, corrective action plans, etc., is not applicable. Additionally, in regard to having
a payment recapture program in place, the CFO indicated that if any improper payments arise in
the future, the agency will establish an accounts receivable and follow the procedure of
collection. The agency has a process in place to refer all valid debts for collection through the
U.S. Department of Treasury’s FedDebt system. Further, both the FY 2014 Financial Statement
Audit and the agency’s Performance and Accountability Report (PAR) are posted on the
agency’s website.




1
 The IPERIA, which was signed into law by President Obama on January 10, 2013 amends the Improper
Payments Elimination and Recovery Act (IPERA; P.L.111-204) of 2010 and the Improper
Payments Information Act (IPIA; P.L. 107-300) of 2002, and directed the Office of Management
and Budget (OMB) to issue implementing guidance to agencies. On October 20, 2014, OMB
issued revised government-wide implementation guidance, OMB Memorandum, M-15-02,
Appendix C to Circular A-123 Requirements for Effective Estimation and Remediation of
Improper Payments.


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OIG Report No. 2015-01-IPERA


Willie A. Eggleston, Senior Auditor, is available to answer any questions regarding our review
and determination. He may be reached at (202) 663-4372 or by email at
willie.eggleston@eeoc.gov.




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