OMB Properly Addressing Improper Payments

On May 23, the Office of Management and Budget (OMB) announced the launch of four new pilot projects designed to further crack down on improper payments from the federal government. The projects focus on implementing best practices and sharing information across state and local governments that help administer payment programs in the departments of Health and Human Services (HHS), Agriculture (USDA), Labor (DOL), and Treasury.

As recently detailed by Kellie Lunney of Government Executive, the projects "are a result of collaboration among more than 200 state and local officials and other stakeholders on ways to reduce waste, fraud, and abuse," called the Collaborative Forum, and include:

  • The Treasury Department working with states to help better collect outstanding federal debt through existing debt collection systems
  • DOL providing states with greater access to unemployment insurance databases to better identify persons not eligible for benefits
  • The Food and Nutrition Service (FNS) of the USDA facilitating the sharing of benefits information between states to make sure only those persons that qualify receive benefits
  • The Centers for Medicare and Medicaid Services (CMS), under HHS, sharing a Medicaid provider enrollment system with states in an attempt to help detect and prevent provider fraud

OMB estimates the pilot projects could help the federal government save upwards of $100 million annually. While those savings seem trivial compared to the estimated $125 billion in improper payments made in fiscal year (FY) 2010, the success of these pilot projects could demonstrate the viability of sharing information and best practices with state and local governments across all of the government's 13 "high-error" programs.

President Obama has made increasing government efficiency and accountability a top priority of his administration and, along with reforming the contracting process, reducing improper payments has been at the top of his list. Within his first year in office, Obama signed Executive Order (E.O.) 13520, which, along with the Improper Payments Elimination and Recovery Act of 2010 (IPERA), called for federal agencies to begin better quantifying the problem of improper payments.

Each federal agency that administered a program that paid out dollars through some kind of a benefit was to assess the benefit-paying programs' risk of making a payment error, estimate and report these amounts annually, and plan for and take corrective actions to address the errors. The public can track the government's progress on improper payments at PaymentAccuracy.gov, the website created to collect and disclose each agency's progress or lack thereof at reducing, as OMB Director Jack Lew says, checks going "to the wrong person for the wrong amount and for the wrong reason."

Of the four pilot projects, the efforts underway at DOL, USDA, and HHS seem to provide further evidence that the administration's so-called "do not pay" list is producing results and that work advancing the idea continues apace.

Representing four of PaymentAccuracy.gov's top seven high-error programs based on the percentage of payments improperly made, the National School Lunch Program (NSLP) (USDA), Unemployment Insurance (UI) (DOL), Medicaid (HHS), and the Supplemental Nutrition Assistance Program (SNAP) (USDA) seek to provide states with better information about who is and who is not qualified to receive benefits under their respective programs.

Similar to the federal "do not pay" list created last year to track "people and organizations that are ineligible to receive government benefits, contracts, grants, and loans," state and local government employees will look to federal agencies to provide comparable information so localities can better determine whether someone is eligible to receive food assistance, unemployment benefits, or medical insurance reimbursement.

One area where the federal "do not pay" list has shown results is Medicare. Though the combined fee-for-service and Medicare Advantage health insurance programs made close to $48 billion in improper payments in FY 2010, representing 24.6 percent of total Medicare payment dollars, fraud-fighting measures, including the federal "do not pay" list, helped bring down the total by over three percent from the previous year.

A recent Government Accountability Office (GAO) report, though noting that CMS still has much work to do on addressing further improper payments, praised the agency for its efforts "to tighten provider enrollment" and for the creation of "its Center for Program Integrity." The center, according to CMS, serves as a "focal point for all national and State-wide [sic] Medicare and Medicaid programs and [Children's Health Insurance Program (CHIP)] integrity fraud and abuse issues."

If the new pilot projects produce similar results and help bring improper payment levels down, then watch for the Obama administration to begin implementing lessons learned on a government-wide basis. One should note, however, that portions of the ongoing effort to reduce improper payments, particularly the operation of PaymentAccuracy.gov, could be threatened by the large cut to the Electronic Government Fund that passed Congress this spring.

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