oversight

Report 2016-0004-AOIG - U.S. Equal Employment Opportunity Commission's FY 2015 Compliance with the Improper Payments Information Act (IPIA), as amended by the Improper Payments Elimination and Recovery Act P.L. 111-204 (IPERA), and the Improper Payments

Published by the Equal Employment Opportunity Commission, Office of Inspector General on 2016-05-11.

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

                                                 May 11, 2016

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 FY 2015 Compliance with
                 the Improper Payments Information Act (IPIA), as amended by the Improper
                 Payments Elimination and Recovery Act P.L. 111-204 (IPERA), and the
                 Improper Payments Elimination and Recovery Improvement Act P.L. 112-248
                 (IPERIA)
OIG Report No. 2016-04-AOIG


The IPERIA 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.

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 requirements1, 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 2015. Additionally, the agency relied
on the results of the FY 2015 financial statement 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 2015. 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
2015 Financial Statement Audit and the agency’s Performance and Accountability Report (PAR)
are posted on the agency’s website.

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.


cc: Cynthia Pierre, Chief Operating Officer
    Mona Papillon, Deputy Chief Operating Officer


1
  OMB Memorandum 15-02 Appendix C to Circular A-123, Requirements for Effective Estimation and
Remediation of Improper Payments states that Inspectors General should review the agency’s AFR or
PAR (and any accompanying information) for the most recent fiscal year to determine compliance under
IPERA. There are six requirements that an agency must meet to be in compliance with the IPIA. Among
these are that agencies must publish an AFR or PAR and conduct program specific risk assessments if
required.

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