The Improper Payments Information Act (IPIA) of 2002, as amended by the Improper Payments Elimination and Recovery Act of 2010 和 Improper Payments Elimination and Recovery Improvement Act of 2012, requires agencies to periodically review all programs and activities and identify those that may be susceptible to significant improper payments, take multiple actions when programs and activities are identified as susceptible to significant improper payments, and annually report information on their improper payments monitoring and minimization efforts. The 办公室 Management and Budgets (OMB) Circular A-123, Managements Responsibility for Enterprise Risk Management and Internal Control (July 15, 2016), Appendix C, Requirements for 支付诚信 Improvement （2018年6月26日）, defines an improper payment（1） and provides guidance to agencies to comply with IPIA, as amended, and for agency improper payments efforts. The Department of Commerce (Department) has not itself identified any programs or activities susceptible to significant improper payments.
The Department recognizes the importance of maintaining adequate internal controls to ensure proper payments, 和 Departments commitment to continuous improvement in the overall disbursement management process remains high. Each of the Departments payment offices has implemented policies and procedures to detect and prevent improper payments. For FY 2020 and beyond, the Department will continue its efforts to ensure the integrity of its disbursements.
（1） 摘录： An improper payment is any payment that should not have been made or that was made in an incorrect amount under statutory, contractual, administrative, or other legally applicable requirements. Incorrect amounts are overpayments or underpayments that are made to eligible recipients (including inappropriate denials of payment or service, any payment that does not account for credit for applicable discounts, payments that are for an incorrect amount, and duplicate payments). An improper payment also includes any payment that was made to an ineligible recipient or for an ineligible good or service, or payments for goods or services not received (except for such payments authorized by law). In addition, when an agency's review is unable to discern whether a payment was proper as a result of insufficient or lack of documentation, this payment should also be considered an improper payment. A questioned cost should not be considered an improper payment until the transaction has been completely reviewed and is confirmed to be improper.
The term payment in this guidance means any disbursement or transfer of Federal funds (including a commitment for future payment, such as cash, securities, loans, loan guarantees, and insurance subsidies) to any non-Federal person, non-Federal entity, or Federal employee, that is made by a Federal agency, a Federal contractor, a Federal grantee, or a governmental or other organization administering a Federal program or activity. The term payment includes disbursements made pursuant to prime contracts awarded under the Federal Acquisition Regulation and Federal awards subject to the 2 C.F.R. Part 200 Uniform Administrative Requirements, Costs Principles and Audit Requirements for Federal Awards (Uniform Guidance) that are expended by recipients.
On February 9, 2018, the President signed into law the Bipartisan Budget Act of 2018, which provided supplemental appropriations to many federal agencies for disaster relief purposes, among others. The Economic Development Administration (EDA) was appropriated $600.0 million 和 National Oceanic and Atmospheric Administration (NOAA) was appropriated $400.1 million. 根据 OMB Memorandum M-18-14, Implementation of lnternal Controls and Grant Expenditures for the Disaster-Related Appropriations （二〇一八年三月三十〇日），该部门将被要求通过2019年6月30日为各EDA和诺阿提交统计抽样和估算计划OMB FY 2018和支出，计算和报告的年度不当支付估计，有EDA或NOAA支出突破万元$ 10.0 。然而，对于每个局支付不超过300万$ 10.0。因此，该部门没有提交统计抽样和估算计划OMB。部门，有效其FY 2020机构财务报告（AFR），将开始对EDA和诺阿接到如果一个财政年度支出超过该科亿$ 10.0灾难基金报告。
Executive Order 13520, Reducing Improper Payments and Eliminating Waste in Federal Programs，于2009年11月20日发出，以帮助联邦机构减少和防止通过提高透明度和改进问责机构的不当支付。该行政命令要求，其他要求，联邦机构的高优先级或风险敏感程序（不当支付的目的）为命名的不当支付的责任人员一起;监控任何这样的程序;建立减少不当支付的目标;并报告高美元的不当支付。该部门成立，根据需要，一个显着位置上的链接 主页 to internet-based resources on addressing improper payments, and also provides on this web page a web link to the U.S. Governments payment integrity web site (see PaymentAccuracy.gov website information discussed on this web page).
The Department does not have any programs/activities that OMB has determined to be a high-priority program with regard to improper payments under Executive Order 13520.
The Department does not have any programs/activities that have improper payments exceeding the statutory thresholds established under IPIA of 2002, as amended, and which is also defined in OMB Circular A-123, Appendix C, Part I, Definitions and Determinations, section B), item 1) as gross annual improper payments (i.e., the total amount of overpayments and underpayments) in the program exceeding （1） both 1.5 percent of program outlays and $10 million of all program or activity payments made during the fiscal year reported; or (2) $100 million (regardless of the improper payments percentage of total program outlays).
Agencies should track improper payments identified and recaptured through various agency endeavors. OMB Circular A-123, Appendix C, Part III, Prevention and Recovery, section C), item 4b) indicates the following possible sources of improper payments information:
Statistical samples and risk assessments;
Agency post-payment reviews;
Prior payment recapture audits;
办公室 督察长 reviews;
U.S. Government and Accountability Office reviews;
Reports from the public;
Results of agency audit resolution and follow-up process.
Department of Commerce 支付诚信 Annual Reporting
Detailed information on the Departments payment integrity monitoring, minimization, and recapture efforts is included in the Departments FY 2019 Agency Financial Report, Other Information (Unaudited) section, 支付诚信, at the following web link: //www.osec.doc.gov/ofm/OFM_出版物.html.
Below is a summary of key Department of Commerce payment integrity efforts.
Department of Commerce Key 支付诚信 Monitoring/Minimization Efforts
Quarterly Improper Payments and Recaptures Reporting
The Department has continuous processes in place and actively works with each of the Departments payment offices to identify and implement additional procedures to prevent and detect improper payments. In FY 2020, the Department continues with the bureaus quarterly reporting of improper payments, and payment recaptures data, to the Departments 办公室 Financial Management, along with identifying the nature of larger improper payments and identifying any necessary control enhancements.
Improper Payments Risk Assessments
The Department annually conducts an assessment of the effectiveness of internal control over financial reporting, in compliance with OMB Circular A-123, Appendix C. Furthermore, every three years, the assessment includes a review of internal controls over disbursement processes, including Department-wide sample testing of disbursements for improper payments and for appropriate internal control attributes. The most recent review performed indicated that internal controls over disbursement processes were sound.
Each of the Departments bureaus/reporting entities periodically completes or updates, over a one to three-year period (depending on the size of the entity), improper payments risk assessments covering all of its programs/activities as required by OMB Circular A-123, Appendix C. These improper payments risk assessments of the entities programs/activities also incorporate improper payments risk assessments every three years of the control, procurement, and grants management environments. The program/activity improper payments risk assessments performed in FY 2019 address improper payments risk factors set forth in OMB Circular A-123, Appendix C that should be addressed, which are: whether the program or activity reviewed is new to the agency; the complexity of the program or activity reviewed, particularly with respect to determining correct payment amounts; the volume of payments made annually; whether payments or payment eligibility decisions are made outside of the agency, for example, by a state or local government, or a regional federal office; recent major changes in program funding, authorities, practices, or procedures; the level, experience, and quality of training for personnel responsible for making program eligibility determinations or certifying that payments are accurate; the inherent risks of improper payments due to the nature of agency programs or operations; significant deficiencies in the audit reports of the agency including, but not limited to, the agency 督察长 or the U.S. General Accountability Office audit report findings, or other relevant management findings; and results from prior improper payment work.
None of the program/activity improper payments risk assessments performed in FY 2019 (or performed in prior fiscal years) revealed any programs or activities considered susceptible to significant improper payments.
Post-Payment Reviews and Other Procedures Performed
Sample Reviews of Department-wide Sustained Disallowed Costs
The Department last performed in September 2018 a periodic review of the statuses of recent Department-wide SDCs of $10 thousand or more, and intends to perform another review in FY 2020. SDCs could result, for example, from Single Audit Act audit reports related to grants/cooperative agreements, OIG audits or reviews, post-payment reviews, closeout reviews, grant/cooperative agreement-specific audits or reviews, and contracts/obligations-specific audits or reviews. The statuses of the SDCs provided by the contractor are utilized by the Department for its comprehensive payment integrity and overpayment recapture efforts, including reporting, monitoring, recapturing, and corrective actions; the statuses are further followed up on by the Department as appropriate.
Departmental Use of U.S. Department of the Treasury's Do Not Pay Portal for 支付诚信
根据 OMB Memorandum M-12-11 dated April 12, 2012, Reducing Improper Payments through the Do Not Pay List, 在2013年该部门实施的部门行政管理和预算局批准的计划进行定期（每周为主）预付款项的资格审查不支付门户网站数据库中的国内部门，非机密，非员工相关的非政府内部支出。该部门目前执行下的预付款检查不支付门户网站数据库：（一）死亡主文件（DMF）从社会保障管理部门和其他来源的数据;和（b）美国服务一般行政系统奖励管理（SAM）排除记录。
The prepayment checking performed by the Department excludes prepayment eligibility reviews of grantees under ASAP, as the U.S. Department of the Treasury (Treasury) performs continuous monitoring of the Do Not Pay portal of ASAP grantees. Bureau payment and acquisition offices, as appropriate, follow up on any vendors initially matched to the Do Not Pay portal databases checked, and perform further research as necessary to follow through and resolve any issues identified by the Do Not Pay portal matches. In most cases, the initial matches are subsequently determined by the Department to be false matches. Other Departmental offices are also consulted as appropriate.
Furthermore, the Departments payment offices receive, from the Do Not Pay portal, monthly reports listing any match results of payments made to the following databases: (a) DMF; and (b) SAM Exclusion Records. Payment offices research and follow up on matches, as appropriate, and submit to the Do Not Pay portal monthly Adjudication Reports summarizing the results of their efforts.
办公室 督察长 支付诚信 Efforts
For more information about the OIGs reports and activities, the following web link to OIGs 主页 is provided: //www.oig.doc.gov/Pages/default.aspx.
Treasury, in coordination with the U.S. Department of Justice and OMB, established the PaymentAccuracy.gov 网站创建发布关于美国信息的集中位置个人，组织和承包商做政府的不当支付。这个网站还提供了一个集中的地方，涉嫌欺诈，浪费的事件，和滥用可报告，并包含有关的信息（1）当前和历史的速率和不当支付量; （2）为什么不当支付发生; （3）什么机构在做，以减少和夺回不当付款。该网站还包含丰富的信息，指导，并链接到其他有用的资源用于处理不当支付。
This website contains additional information and data about the Departments improper payments, including improper payments information included in previous Departmental Agency Financial Reports that is no longer included in the Departments FY 2019 Agency Financial Report.