Recovery Auditing: Reducing Overpayments, Achieving Accountability, and
the Government Waste Corrections Act of 1999 (Testimony, 06/29/99,
GAO/T-NSIAD-99-213).
Pursuant to a congressional request, GAO discussed House Resolution
1827, the Government Waste Corrections Act of 1999, and its relationship
to long-standing issues of government accountability for use of public
monies and overpayments and the role of recovery auditing in identifying
and recovering overpayments.
GAO noted that: (1) significant financial system weaknesses, problems
with fundamental recordkeeping and financial reporting, incomplete
documentation, and weak internal controls continue to prevent the
government from effectively managing many of its operations; (2)
significant among these problems is the inability of federal agencies to
determine the full extent of improper payments that occur in major
programs and that are estimated to involve billions of dollars annually;
(3) within the billions of dollars of improper payments is an unknown
amount of overpayments; (4) while neither the federal agencies nor GAO
have a good estimate of the extent of overpayments that occur each year,
GAO expects that they are significant; (5) the Department of Defense
(DOD) is conducting a recovery auditing demonstration program to
identify overpayments for subsistence, medical, and clothing items
purchased in fiscal years 1993 through 1995; (6) GAO evaluated the
demonstration program and concluded that the concept of recovery
auditing offers the potential to identify overpayments; (7) however, GAO
found that implementation problems have limited the program's success;
(8) as of June 1999, the recovery auditing contractor had identified
about $29 million in overpayments made to suppliers on purchase volumes
of roughly $6 billon; (9) collections by DOD amount to $2.6 million;
(10) DOD has been slow to expand the use of recovery auditing beyond the
initial demonstration program; (11) although contractors are sometimes
overpaid, they are not required to inform the government of the
overpayment or to return the money prior to the government issuing a
formal demand letter requesting repayment; (12) in effect, the
overpayment provides an interest free loan to the contractor; (13)
contractors should be required to notify the government of overpayments
when they become aware of them and to return the money promptly upon
becoming aware of the overpayments; (14) if they do not return the money
promptly, there should be some economic consequence; (15) federal
agencies need to concentrate on paying bills properly in the first
place; (16) however, recognizing that some overpayments are inevitable,
they also need to adopt best practices to quickly identify and recover
them; (17) the Government Waste Corrections Act of 1999 offers an
opportunity to use recovery auditing to identify overpayments and the
factors contributing to overpayments; (18) GAO supports the objectives
of this important legislation; and (19) some commercial companies have
used recovery auditing for many years as one mechanism to identify and
recover overpayments.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-NSIAD-99-213
TITLE: Recovery Auditing: Reducing Overpayments, Achieving
Accountability, and the Government Waste Corrections Act
of 1999
DATE: 06/29/99
SUBJECT: Proposed legislation
Audits
Overpayments
Accountability
Contractor payments
Financial management
Internal controls
Private sector practices
IDENTIFIER: DOD Recovery Auditing Demonstration Program
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NS99213t GAO United States General Accounting Office
Testimony Before the Subcommittee on Government Management,
Information and Technology, Committee on Government Reform, House
of Representatives
For Release on Delivery Expected at 2 p. m., EST Tuesday, June 29,
1999
RECOVERY AUDITING Reducing Overpayments, Achieving Accountability,
and the Government Waste Corrections Act of 1999
Statement of David M. Walker, Comptroller General of the United
States
GAO/T-NSIAD-99-213
GAO/T-NSIAD-99-213
Page 1 GAO/T-NSIAD-99-213
Mr. Chairman and Members of the Subcommittee: I appreciate the
opportunity to discuss House Report 1827, the Government Waste
Corrections Act of 1999, and its relationship to the long-
standing issues of government accountability for use of public
monies and
overpayments and the role of recovery auditing in identifying and
recovering overpayments. To put these issues in perspective, in
fiscal year 1998, federal executive departments and agencies
contracted for about $173 billion in goods and services. The
Department of Defense (DOD) spent about $115 billion, or about
two- thirds of this amount. In addition to direct contracting,
federal agencies indirectly pay out many more billions of dollars
annually for health care, education, and agricultural programs.
One of the most important issues facing the government today is
the need for greater accountability in managing the finances of
our national government. It is a significant problem at many
agencies, and one that has been the subject of frequent reports by
us and others. One key aspect of the problem is the difficulty the
government has in assuring proper payment of all its bills while
avoiding overpayments.
My testimony, today, will discuss the dimensions of the
overpayment problem, our past work on the DOD recovery auditing
demonstration program, and the Government Waste Corrections Act of
1999. My comments on the bill reflect my belief that there are
three principles that should guide a recovery auditing program.
First, there should be meaningful incentives for agencies to want
to participate in the program
and make it work. Second, there should be adequate safeguards to
ensure that the program is implemented in a manner intended by
Congress and that preserves the integrity of the congressional
appropriations process. Third, there should be transparency in the
conduct of the program that is,
there should be evaluation and reporting of program
implementation, in this case, to include how the recovered amounts
are used. In the context of these three principles, I will suggest
opportunities to strengthen House
Report 1827. Results in Brief Significant financial management
system weaknesses, problems with fundamental recordkeeping and
financial reporting, incomplete
documentation, and weak internal controls continue to prevent the
government from effectively managing many of its operations.
Significant among these problems is the inability of federal
agencies to determine the full extent of improper payments that
occur in major programs and that are
Lett er
Page 2 GAO/T-NSIAD-99-213
estimated to involve billions of dollars annually. Within the
billions of dollars of improper payments is an unknown amount of
overpayments.
While neither the federal agencies nor we have a good estimate of
the extent of overpayments that occur each year, given the poor
state of the financial and accounting records, we expect that they
are significant. We know, for example, that between fiscal year
1994 and 1998, contractors returned about $4. 6 billion in
overpayments to DOD.
At the direction of Congress, DOD is conducting a recovery
auditing demonstration program to identify overpayments for
subsistence, medical, and clothing items purchased in fiscal years
1993 through 1995. We evaluated the demonstration program and
concluded that the concept of recovery auditing offers the
potential to identify overpayments. However, we found that
implementation problems have limited the program's
success. As of June 1999, the recovery auditing contractor had
identified about $29 million in overpayments made to suppliers on
purchase volumes of roughly $6 billion. Collections by DOD amount
to $2. 6 million. While authorized to do so, DOD has been slow to
expand the use of recovery auditing beyond the initial
demonstration program.
Although contractors are sometimes overpaid, under current law,
they are not required to inform the government of the overpayment
or to return the money prior to the government issuing a formal
demand letter 1 requesting repayment. In effect, the overpayment
provides an interest free loan to the
contractor. Contractors should be required to notify the
government of overpayments when they become aware of them and to
return the money promptly upon becoming aware of the overpayments.
If they do not return the money promptly, there should be some
economic consequence.
Given the large volume and complexity of federal payments, federal
agencies need to concentrate on paying bills properly in the first
place. However, recognizing that some overpayments are inevitable,
they also need to adopt best practices to quickly identify and
recover them. The Government Waste Corrections Act of 1999 offers
an opportunity to use recovery auditing to identify overpayments
and the factors contributing to overpayments. We support the
objectives of this important legislation. Some commercial
companies have used recovery auditing for many years as one
mechanism to identify and recover overpayments. The extent to
1 A demand letter is a formal notification to the contractor that
it owes the government money.
Lett er
Page 3 GAO/T-NSIAD-99-213
which recovery auditing is applicable to the full range of federal
agency overpayments, however, remains an open question since its
use in the federal government has been limited. Thus, we strongly
support provisions of the bill that provide for model programs. In
this way, the government can assess the applicability of recovery
auditing to different types of
payments and develop best practices for its use on a wider scale.
In our view, with this use of model programs, plus strong monetary
incentives, it would be unnecessary to mandate recovery auditing
across the government. The Committee may also want to reexamine
the provisions in the bill relating to reallocation or use of
overpayment recoveries. While financial incentives are critical to
the program's success, incentives that are too large are
unnecessary and may undermine the program by creating
inappropriate incentives to making accurate and timely payments in
the first place. The Committee may want to provide for a
substantial portion of the recoveries to be returned to the
Department of the Treasury.
Poor Financial Controls Are a Governmentwide Problem
Across the government, improper payments, including overpayments,
occur in a variety of programs and activities, including those
related to contract management, federal financial assistance, and
tax refunds.
Reported estimates of improper payments total billions of dollars
annually. Such payments can result from incomplete or inaccurate
data that are used to make payment decisions, insufficient
monitoring and oversight, or other deficiencies in agency
information systems and internal controls. The risk of improper
payments is increased in programs involving (1) complex criteria
for computing payments, (2) a significant volume of transactions,
or (3) an emphasis on expediting payments. The reasons for
improper payments range from inadvertent errors to fraud and
abuse.
The full extent of improper payments, however, is unknown because
many agencies have not estimated the magnitude of improper
payments in their programs, nor have they considered this issue in
their annual performance plans. The use of appropriate performance
measures relating to improper payments can provide a management
focus on reducing related losses. For example, the Department of
Health and Human Services has reported a national estimate of
improper payments in its Medicare fee- for- service benefits since
fiscal year 1996. For fiscal year 1998, the Department reported
estimated improper payments of $12.6 billion, or more than
7 percent, of Medicare fee- for- service benefits down from about
$20 billion, or 11 percent, reported for fiscal year 1997 and
$23.2 billion, or
Page 4 GAO/T-NSIAD-99-213
14 percent, for fiscal year 1996. An analysis of improper Medicare
payments helped to implement several initiatives intended to
reduce improper payments. These initiatives significantly reduced
the incidence of improper Medicare payments. DOD Is a Case for
Recovery Auditing
Because it spends more contracting for goods and services than all
other agencies combined, it is particularly important that DOD
have sound controls to ensure that contract payments are proper,
accurate, and timely. In recent years, our reports have identified
hundreds of millions of dollars in improper DOD payments, interest
expense on late payments, and other financial management problems.
For example, in March 1994, we reported that during a 6- month
period in fiscal year 1993, the Defense Finance and Accounting
Service (DFAS) in Columbus, Ohio-- a principal DOD contract paying
activity-- processed $751 million in payments returned by defense
contractors. 2 Our examination of about one- half of these checks
disclosed that about 78 percent represented overpayments by the
government. We also found that while some contractors returned
overpayments, others did
not. In one case, an overpayment of $7.5 million was outstanding
for 8 years. We estimated that the government lost interest on the
overpayment amounting to nearly $5 million.
DOD continues to make substantial erroneous payments to its
contractors. For example, in the 5 years between fiscal year 1994
and 1998, defense contractors returned about $4.6 billion to DFAS
Columbus in fiscal year 1998, they returned $746 million. However,
some contractors were still retaining overpayments. For example, 4
of the 13 contractors we visited
during a recent review were retaining overpayments totaling about
$1. 1 million. At each location, contractor personnel told us that
they had a practice of retaining overpayments until the government
issued a demand
letter requesting the overpayments be returned. Under current law,
there is no requirement for contractors who have been overpaid to
notify the government of overpayments or to return overpayments
prior to the government issuing a demand letter for a refund. The
magnitude of overpayments defense contractors are retaining is not
known.
2 DOD Procurement: Millions in Overpayments Returned by DOD
Contractors (GAO/NSIAD-94-106, Mar. 14, 1994).
Page 5 GAO/T-NSIAD-99-213
DOD Is Taking Actions to Address Payment Problems
DOD is taking steps to address its payment problems. Its
initiatives include testing and adopting some best practices. In
the long term, it is developing procurement and payment systems
that will be linked by sharing common data. This linkage is
expected to allow one- time entry of contract data critical to
making correct payments. In the meantime, DOD is enhancing its
current technologies to further automate the payment process,
testing streamlined payment practices, and making efforts to
reduce the number of contract fund citations. But, as we state in
our recent high- risk report, 3 it is likely to be many years
before DOD gets its payment problems under
control. Additional Steps Could Be Taken Recognizing DOD's actions
and the fact that DOD continues to overpay its
contractors, one question is: are there additional steps that
might be taken to improve the process for both identifying and
collecting overpayments? The answer is yes.
First, we believe defense contractors, and for that matter, all
contractors should be required to promptly notify the government
of overpayments when they become aware of them. If they do not
return the money promptly, there should be some economic
consequence. This seems simple enough, but currently a contractor
is not required to tell the government that it has been overpaid,
nor is it required to return an overpayment until the government
becomes aware of the overpayment and issues a demand letter for
repayment. Many contractors do promptly return overpayments;
however, some do not. While we know the amount of overpayments
that contractors have returned to the government, we do not know
how much they are still keeping. Thus, as pointed out earlier, the
true magnitude of the overpayment problem is not known. In this
regard, we will shortly begin a review to assess the extent to
which defense contractors are retaining and not promptly returning
overpayments to the government.
Second, we believe that all federal agencies should take advantage
of best practices that commercial companies use to identify and
recover overpayments. One such practice is the use of recovery
auditing procedures. Clearly, the government's focus should be on
paying its bills properly in the first place. However, for both
private industry and
government agencies, some payments are processed incorrectly for a
variety of reasons. For instance, vendors make pricing errors on
their 3 Major Management Challenges and Program Risks, Department
of Defense (GAO/OCG-99-4, Jan. 1999).
Page 6 GAO/T-NSIAD-99-213
invoices, forget to include discounts that have been publicized to
the general public, neglect to offer allowances and rebates, or
miscalculate freight charges. Government payment activities may
also neglect to take discounts to which they are entitled. These
mistakes, when not caught, result in overpayments. Identifying and
recovering these types of overpayments is referred to as recovery
auditing.
Recovery Auditing Offers Potential to Identify and Recover
Overpayments
Recovery auditing started about 30 years ago, and it is used in
several industries, including the automobile, retail store, and
food service industries. Within DOD, the Army and the Air Force
Exchange Service and the Navy Exchange Service use recovery
auditing. An external audit recovery group may be the only group
used by an organization or it may be used in combination with an
internal group that examines invoices for overpayments prior to an
external group's review.
Recognizing its potential value to the government, the Fiscal Year
1996 National Defense Authorization Act required the Secretary of
Defense to conduct a demonstration program to evaluate the
feasibility of using recovery auditing to identify overpayments
made to vendors by DOD. Authority to expand the program was
provided in the Fiscal Year 1998 National Defense Authorization
Act.
The DOD demonstration program began in September 1996, when the
Defense Supply Center, Philadelphia (DSCP), competitively
contracted with Profit Recovery Group International (PRGI). The
contract covers purchases made during fiscal years 1993- 95 and
requires PRGI to identify
and document overpayments and to make recommendations to reduce
future overpayments. PRGI receives a fee of 20 percent of net
collected funds. The focus of the demonstration program is in
purchases of subsistence, medical and clothing items, items that
are typically found in retail merchandising. We reviewed the
program and concluded that recovery auditing offers potential to
identify overpayments, but implementation problems hindered DOD
from fully realizing the benefits of the program. 4 As of August
1998, PRGI had identified $19.1 million in overpayments. However,
recoveries of overpayments amounted to only $1.9 million, in large
part, because vendors
4 Contract Management: Recovery Auditing Offers Potential to
Identify Overpayments (GAO/NSIAD-99-12, Dec. 3, 1998).
Page 7 GAO/T-NSIAD-99-213
took issue with some of the overpayments. This caused the recovery
process to virtually stop for 8 months while the DSCP reviewed the
merits of the vendors' issues. DSCP concluded that the claims of
overpayment
were valid. However, according to the contracting officer, his
letter of final decision regarding vendors' indebtedness has not
been issued. PRGI continues to identify overpayments. As of June
1999, according to PRGI, it had completed 90 percent of its work
and identified $29.3 million in overpayments made to suppliers on
purchases of roughly $6 billion. Collections by DOD as of June
1999 amounted to $2. 6 million. According to PRGI, its overpayment
identification rate under the demonstration program is 0.48
percent of purchases reviewed, which is consistent with its
experience with new private sector clients before corrective
measures are implemented. PRGI told us that, as corrective
measures are implemented, the overpayment rate typically drops to
about 0.1 percent of purchases reviewed.
PRGI has also made recommendations to DFAS and DSCP to reduce
future overpayments, but, at the time of our review, DOD had not
implemented them. These recommendations ranged from reprogramming
payment systems to
providing contracting personnel additional training to help them
determine price reasonableness.
DOD Is Slow to Use Recovery Auditing Techniques
DOD has been slow to embrace recovery auditing. For example, in
House Report 105- 532, which related to a bill providing for
fiscal year 1999 DOD authorizations, DOD was directed to use
recovery auditing by selecting at least two commercial functions
within its working capital fund and issuing a competitive request
for proposal by December 31, 1998. We found,
however, that DOD had not done either. 5 While DOD issued an
August 1998 memorandum encouraging the use of recovery auditing,
and some activities have expressed an interest, no contracts had
been awarded at the time we completed our work in March 1999. In
June 1999, we checked with the recipients of the August 1998
memorandum and, with the exception of
the U. S. Transportation Command, which had just entered into a
contract for recovery auditing services, no other contracts had
been awarded. The Defense Commissary Agency said it has completed
a statement of work,
5 Contract Management: DOD Is Examining Opportunities to Further
Use Recovery Auditing (GAO/NSIAD-99-78, Mar. 17, 1999).
Page 8 GAO/T-NSIAD-99-213
and plans to have a contract by July 30, 1999. The Defense
Logistics Agency told us it issued a solicitation on May 28, 1999,
to expand the use of recovery auditing from the demonstration
program in place at DSCP to its
other four supply centers. The Defense Logistics Agency said it
plans to have a contract by August 31, 1999. Each of the services
and the Defense Information Services Agency also expressed an
interest in recovery auditing, and they are evaluating whether to
use it.
Issues Related to Using Recovery Auditing
While we believe that recovery auditing could be beneficial to DOD
and other federal agencies, there are some important
implementation issues that need to be considered as federal
agencies evaluate using recovery
auditing to identify and recover overpayments. First, it is not
clear how agencies should organize to perform recovery auditing.
Should it be contracted out? Should it be performed with in- house
personnel? Should some combination of the two be used? We believe
that agencies need to carefully consider the extent to which
recovery auditing is applicable to their operations and, if
applicable, if it would be cost- effective to undertake
moderate internal recovery auditing efforts to pick the low
hanging fruit before turning audit recovery efforts over to an
external group.
Second, it is important that there be (1) periodic reporting by
those performing recovery auditing on the factors causing
overpayments and on recommendations to reduce overpayments and (2)
a process to evaluate these recommendations and implement those
that make sense. One of the criticisms we made of the
demonstration program was that DOD did not implement the
contractor's recommendations to reduce overpayments.
Finally, it is important to recognize that the DOD demonstration
program has been focusing primarily on identifying overpayments
related to subsistence, medical, and clothing purchases. While
representing an audit base of about $7.2 billion, it is only a
small part of the dollars spent on contracts by DOD each year.
Most DOD expenditures are for purchases of major weapon systems.
The applicability of recovery auditing to these
types of contract payments is, at this time, unclear. The
Government Waste Corrections Act of 1999
The Government Waste Corrections Act of 1999 (H. R. 1827) would
require the use of recovery auditing by federal agencies and
provide incentives to improve federal management practices with
the goal of reducing overpayments.
Page 9 GAO/T-NSIAD-99-213
We believe the act is a positive step in the government's effort
to reduce overpayments and to obtain timely identification and
recovery of overpayments. The act addresses recommendations we
made in our recent report on DOD's demonstration program. One
recommendation was to give the head of an executive agency the
option to perform recovery auditing with internal staff, by
contract or through a combination of both internal staff and
contract.
We are also pleased to see that the bill requires a contractor to
provide periodic reports with recommendations on how to mitigate
overpayment problems and that as a part of the agency's management
improvement
program, the agency is to give first priority to addressing
problems that contribute to overpayments. Finally, the proposed
act allows applicable appropriations to be reimbursed for costs
incurred by government activities in supporting recovery audit
efforts and provides other incentives to support the use of
recovery
auditing. These features should help eliminate some of the
implementation problems we saw in the demonstration program.
Suggestions to Improve the Bill
While we are positive toward the concept of recovery auditing and
its potential for application in the federal government, the
government's experience with the use of recovery auditing has been
limited. Thus, we think it is a good idea to mandate further model
programs in civilian and defense agencies to determine the
applicability of recovery auditing and to develop best practices
for their use governmentwide. In conducting the
mandated model programs at least five are currently provided for
in the bill there should be sufficient diversity in where recovery
auditing is modeled to adequately test the concept among the
different types of payment activities. Beyond the mandated model
programs, we believe that the use of recovery auditing should, at
least for the time being, be available,
but not mandated, for other federal agencies. Currently, the bill
provides for mandatory use of recovery auditing by federal
agencies, in addition to the model programs. The Committee may
also want to reexamine the provisions in the bill relating to
reallocation or use of overpayment recoveries. While financial
incentives are critical to the program's success, incentives that
are too great are unnecessary and may undermine the program by
creating inappropriate incentives to making accurate and timely
payments in the first place. The Committee may want to provide for
a substantial portion of
Page 10 GAO/T-NSIAD-99-213
the recoveries to be returned to the Treasury. We will be happy to
discuss further technical comments with the Committee staff.
Conclusions In closing, Mr. Chairman, federal agency managers have
a fiduciary responsibility relating to, and are accountable for,
the proper use of federal funds. Our work has shown that, in
certain cases, these responsibilities are not being exercised
adequately and the result is billions of dollars a year in
improper payments, a portion of which represent overpayments that
may never be recovered. Federal agencies need to achieve more
effective control over their payment processes. The causes of the
payment problems are varied and many are long- standing. The
solutions can be found in the effective use of technology, the
establishment of sound
internal control and payment processes, and the wise use of human
capital. If federal agencies do not effectively tackle these
challenges, they will continue to risk erroneously paying
contractors and perpetuating other financial management problems.
Effectively addressing them, however, will require investment and
sustained commitment by top- level management.
Recovery auditing, which has a long- standing track record in the
private sector, offers a low- risk opportunity to identifying and
recovering overpayments. We strongly support provisions of House
Report 1827 that provide for model recovery auditing programs. In
this way, the government can assess the applicability of recovery
auditing to different types of
payments and develop best practices for its use on a wider scale.
In our view, with the use of model programs, plus strong monetary
incentives, it would be unnecessary to mandate recovery auditing
across the government. There may also be opportunities to employ
novel servicing arrangements, such as creating a center of
excellence in a federal agency to provide leadership to other
agencies in implementing recovery auditing.
The keys to the successful execution of governmentwide recovery
auditing programs are (1) meaningful incentives for agencies to
want to participate in the program and make it work, (2) adequate
safeguards to ensure achieving congressional intent and the proper
use of appropriations, and
(3) transparency in the conduct of the program. Mr. Chairman, this
concludes my statement. For the record, major contributors to this
testimony were David E. Cooper, Daniel J. Hauser, and Charles W.
Thompson. I will be glad to answer any questions you or the other
Members of the Subcommittee may have at this time.
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