Testimony Before the Pennsylvania House of Representatives State Government Committee | Council For Citizens Against Government Waste

Testimony Before the Pennsylvania House of Representatives State Government Committee


Testimony before The House State Government Committee

Pennsylvania House of Representatives

Public Hearing to discuss Improper Payments and Government Waste

Deborah Collier, Vice President of Policy and Government Affairs Citizens Against Government Waste

October 26, 2022


Chairman Grove, Democratic Chair Conklin, and members of the Committee,

Thank you for inviting me to testify before you to discuss improper payments and government waste.  My name is Deborah Collier, and I am the vice president of policy and government affairs at Citizens Against Government Waste (CAGW).  CAGW is a private, nonpartisan, nonprofit organization representing more than one million members and supporters nationwide, including 72,960 members and supporters in the Commonwealth of Pennsylvania.  Founded in 1984 by late industrialist J. Peter Grace and syndicated columnist Jack Anderson, CAGW was established to follow up on the work of the President’s Private Sector Survey on Cost Control, also known as the Grace Commission.  The organization’s mission is to eliminate waste, fraud, abuse, mismanagement, and inefficiency in government. 

Improper payments, as defined by the Improper Payments Information Act (IPIA) of 2002, are “payments that should not have been made or that were made in an incorrect amount, including both overpayments and underpayments.”[1]  The IPIA of 2002 was enacted to require the measurement of incorrect disbursements and incomplete or missing paperwork used for the calculation of payments.  According to the Congressional Research Service (CRS), “The law required agencies to identify each year programs and activities vulnerable to significant improper payments, to estimate the amount of overpayments or underpayments, and to report to Congress on steps being taken to reduce such payments.”  The focus of the legislation was more on reporting improper payments than what was being done to reduce the amount of improper payments.  That helps explain why despite the enactment of the IPIA, the amount of improper payments rose from $45 billion in fiscal year (FY) 2004 to $125 billion in FY 2010. 

Improper payments include any payments that were “made to ineligible recipients, duplicate payments, payments for a good or service not received, and payments that do not account for applicable discounts.”[2]   If an agency is unable to confirm the payment is made improperly at the time it was reviewed, the federal government considers the entire payment counting toward the improper payment rate, even if only a small portion of the payment was ultimately found to be improper. 

Federal agencies have been required to report the number of improper payments they issue each year since FY 2004 to the Office of Management and Budget (OMB).  Between FYs 2007 and 2010, improper payments increased from $42 billion to $121 billion.  This period of time included the enactment of the $792 billion American Recovery and Reinvestment Act in February 2009. 

Due in part to the increase in improper payments from FY 2004 to FY 2010, Congress enacted the Improper Payments Elimination and Recovery Act (IPERA; Pub. L. No. 111-204) in 2010, which required agencies to identify, estimate, report, and recover improper payments, with the intent of reducing improper payments by $50 billion by 2012.  Two years later, President Obama signed into law the Improper Payments Elimination and Recovery Audit Improvement Act (IPERIA; Pub. L. No. 112-248), which further expanded the efforts to bring improper payments under control.  IPERIA requires the OMB to identify a list of high priority items in the federal government that need increased oversight based on the high dollar value or error rate of improper payments, or if they are deemed more susceptible to improper payments.[3]  According to a 2014 notation on the OMB’s paymentaccuracy.gov website, the government “has avoided over $47 billion in improper payments over the past three years, almost hitting the President’s ambitious goal of avoiding $50 billion in improper payments by the end of FY 2012.”  While this achievement is laudable, the starting point for cutting improper payments was far greater than it needed to be. 

Despite the reduction in improper payments, Congress enacted the Federal Improper Payment Coordination Act (Pub. L. No. 114-109) in 2015, which amended IPERIA by expanding access to federal agency data to verify payment eligibility of recipients and payment amounts.  But in FY 2016, improper payments had risen to $144 billion, an increase of 33 percent over the $108 billion in FY 2013. 

Another attempt was made to resolve this wasteful spending in 2016, when Congress enacted the Fraud Reduction and Data Analytics Act (Pub. L. No. 114-186), requiring “agencies to implement financial and administrative controls related to fraud, including improper payments.”[4]  In FY 2017, the amount of improper payments decreased by 2 percent to $141 billion.[5]  

In 2019, Congress enacted the Payment Integrity Information Act of 2019 (Pub. L. No. 116-117), which revised several prior improper payment statutes, gave the OMB the authority to create “a pilot program to test potential accountability mechanisms for compliance with requirements regarding improper payments and the elimination of improper payments,” required “OMB to update its plan for improving the death data maintained by the Social Security Administration and improving federal agency use of death data,” and established “an interagency working group on payment integrity.”[6]  There was no explanation of why these commonsense and necessary proposals were not included in any of the prior statutes.

Despite the enactment of six bills over 17 years that are intended to reduce improper payments, the Government Accountability Office (GAO) stated that, “the government doesn’t fully understand the size of federal improper payments, partly because it doesn’t have complete, reliable, or accurate estimates.”[7]  And as more money is spent, the inability to prevent improper payments from being made leads to more money being identified as improper payments.  In FY 2021, improper payments totaled $281 billion, an increase of $75 billion, or 36.4 percent, over the $206 billion in FY 2020.  The GAO noted that “this estimate is likely understated since it doesn’t include improper payments related to COVID-19 funding (such as the Small Business Administration’s Paycheck Protection Program).”[8]  The GAO reported that estimated improper payments have totaled “about $2.2 trillion since FY 2003.”  Even in Washington, D.C., that is a lot of money.

As a result of the reporting requirements imposed by IPIA and subsequent laws, the OMB has been better able to track trends in improper payments across the federal government.  Agencies are also now required to conduct a risk assessment for improper payments for all new programs after 12 months of operation and develop corrective actions if those programs are found to be susceptible to improper payments. 

While the improper payments report for FY 2021 did not include all of the COVID-19-related funding, it is clear that much of the more than $4.5 trillion that Congress allocated in response to the pandemic was handed out without setting in place sufficient parameters to prevent waste, fraud, abuse, and mismanagement in programs like the Paycheck Protection Program (PPP) and the Pandemic Unemployment Insurance (PUI) program.[9] 

The effort to get funding into the hands of taxpayers occurred so quickly, there was little time taken to even implement simple measures that could have reduced improper payments, including a lack of security and oversight.  It was therefore not surprising when criminals, both foreign and domestic, were able to steal hundreds of billions of dollars that should have gone to Americans in need of help during the pandemic.[10]

The COVID-19 funds were sent out without adhering to existing anti-fraud measures in the programs, including the rule of two normally used for funding requests by the Small Business Administration (SBA), which administered the PPP loan program.  The rule requires two federal employees to sign off on any request for funding.  However, because Congress wanted to get funds into taxpayer hands as quickly as possible and help businesses survive, even this basic guardrail was not required for PPP loans.[11] 

On March 26, 2021, the Department of Justice (DOJ) issued an update on its efforts to combat COVID-19 related fraud, including PPP fraud, which involved at least 120 defendants, including one case where the defendant applied for 15 different PPP loans with eight different lenders, using 11 different companies, seeking a total of $24.8 million.  The defendant in the case received approximately $17.3 million dollars which were used to purchase multiple homes, jewelry, and luxury vehicles.  Other activities engaged in by the DOJ include pursuit of Economic Injury Disaster Loans (EIDL) fraud and UI fraud.[12] 

On May 17, 2022, Attorney General Merrick Garland established the COVID-19 Fraud Enforcement Task Force to build a partnership with agencies across the government to combat and prevent pandemic-related fraud.[13]  While the DOJ is to be commended for its efforts to combat fraudulent claims, many of these problems could have been avoided had Congress included appropriate guardrails and verification criteria for the funding.  Taxpayers should not have to wait for the horses to run away before Congress and federal agencies close the barn doors.

An April 27, 2022, the GAO assessment of programs funded for pandemic relief offered a series of recommendations to address “payment oversight, data collection, critical manufacturing and supply chain issues, and more.”  The GAO recommended that, “Congress consider in any future legislation appropriating COVID-19 relief funds designating all executive agency programs and activities making more than $100 million in payments from COVID-19 relief funds as ‘susceptible to significant improper payment.’”  The GAO also recommended that Congress amend the Payment Integrity Information Act of 2019 to designate that all new agency programs making more than $100 million in annual payments be included as “susceptible to significant improper payments” during their initial years of operation.[14]

With trillions of dollars going out to the states for programs included in the pandemic relief bills, the Infrastructure Investment and Jobs Act, and the Inflation Reduction Act, state governments must take every possible step to ensure that these funds are not squandered, wasted, or fraudulently misused for any purposes other than for which they are intended.  These actions are absolutely essential, as there is more federal money being made available to the states for more purposes than at any time since the Great Society programs under President Lyndon Johnson and the New Deal programs under President Franklin Delano Roosevelt.

As the trillions of dollars made available by Congress began to flow out of Washington, D.C., the OMB’s program scorecard, which determines the high priority programs at risk for improper payments estimated that between June 2020 and June 2021, the PPP and Unemployment Insurance (UI) “programs have estimates of improper payments resulting in monetary loss that exceed $100 million annually.”[15]  The OMB found that, “between fiscal year 2020 and fiscal year 2021, the Government-wide improper payment rate rose from 5.6% to 7.2%.”[16]  The OMB attributes this increase mostly improper payments in the Federal-State UI program, which was added to the GAO’s High-Risk List on June 22, 2022.[17]

The DOL already tracks improper payment accuracy rates in UI programs across the country, and reported that from July 1, 2018, through June 30, 2021, with an improper payment rate of 13.96 percent, the Commonwealth of Pennsylvania is among the 27 states with a UI improper payment rate greater than 13 percent.[18]  DOL estimates that Pennsylvania issued an estimated $1,111,216,052 in improper payments during that period through its UI program.[19]  According to the GAO’s report, the causes of overpayments included separation issues at 41.74 percent; benefit year earnings at 35.57 percent; other eligibility at 10.69 percent; able and available to work at 8.07 percent; and other issues at 3.94 percent.[20]

The GAO made several recommendations to reduce the number of improper payments in the UI program and suggested that the Department of Labor (DOL) should determine if legislative changes are needed to achieve quantifiable results in improper payment rates, including those related to fraud, improving efficiency in claims processing, and restoring pre-pandemic payment timeliness levels.[21]

On September 30, 2022, the DOL Office of Inspector General (DOL IG) released a report regarding the COVID-19 pandemic-related unemployment insurance payments.  This report highlighted the problems with tracking improper payments in three programs created in the Coronavirus Aid, Relief, and Economic Security (CARES) Act:  Pandemic Unemployment Assistance, Pandemic Emergency Unemployment Compensation, and Federal Pandemic Unemployment Compensation.  According to the report the three programs paid out $663.8 billion in UI benefits as of April 23, 2022.[22] 

According to the DOL IG, even though states and the Employment and Training Administration (ETA) made efforts to prevent improper payments, “they did not protect pandemic-related UI funds from historic levels of improper payments.”  The DOL IG attributes these improper payments in the UI programs to four factors: “(1) states did not always perform required procedures necessary to ensure claimants were eligible; (2) ETA’s guidance and oversight was not timely enough to prevent improper payments; (3) the PUA program’s initial reliance solely on self-certification left it vulnerable to improper payments; and, (4) ETA suspended the BAM program for the first 3 moths of the CARES Act.”[23] 

The DOL uses the Benefit Accuracy Measurement (BAM) program to identify and provide support to states to resolve deficiencies in their UI systems.  BAM is also used to estimate improper payments in a state’s UI program as required by the Payment Integrity Information Act of 2019.[24]

Another problem with pandemic-related payments arose from a longstanding issue at the Internal Revenue Service (IRS).  When tax refunds are issued to deceased individuals, it happens because the information is either not updated or not checked against SSA’s Death Master File database.  This database is a compilation of death reports that SSA receives from a variety of sources including family members, funeral homes, financial institutions, postal authorities, states, and federal agencies.[25]  However, this database is only as comprehensive as the information provided and would not include any unreported deaths.

A June 25, 2020, the GAO report found that $2.6 trillion had been appropriated through four separate bills to provide 150.4 million economic impact payments by the IRS and Department of the Treasury.  Because of the potential to waste taxpayer resources sending funds to deceased individuals, the GAO recommended that the IRS use the Social Security Master Death File to update its records and avoid improper payments.[26] 

According to the Treasury Inspector General for Tax Administration (TIGTA), which reviewed the distribution of CARES Act Economic Impact Payments (EIP), “as of July 16, 2020, the IRS had issued more than 4.4 million EIPs totaling nearly $5.5 billion to potentially ineligible individuals.”[27]  TIGTA identified 644,705 potentially eligible individuals who had not received payments totaling $1.6 billion, and that almost 1.1 million payments worth $1.4 billion had been paid to dead people.[28]  

In response to both the massive amounts of improper payments throughout federal agencies related to the trillions of dollars spent in response to the COVID-19 pandemic and as part of the ongoing effort to update and improve existing statutory authority, several bills have been introduced in 117th Congress.  S. 3221, the IRS Improper Payments Act, introduced by Sen. Mike Braun (R-Ind.), would require the OMB, the Department of Treasury, the DOJ, executive agencies and inspectors general to take specific actions to reduce improper payments and eliminate waste in federal programs.  The bill would also require any agency failing to meet high priority program reduction targets of the agency or failing to implement plans to reduce improper payments for not less than two consecutive years to submit a report describing the likely causes of the failure and proposing a remedial plan.[29]  S. 2742, the Recovering Fraudulent Claims Act, introduced by Sen. John Thune (R-S.D.), would create a task force to investigate fraud related to COVID-19 UI benefits, including fraud involving identity theft.[30]  

H.R. 8322, the STOP Fraud Act, introduced by Rep. Gerry Connolly (D-Va.), would create a new Federal Real Antifraud Unified Directorate within the OMB and require agencies to designate any program exceeding certain payments thresholds as a program susceptible to significant improper payments and implement proactive analytics for high-risk areas of each designate program.  The bill would also require an agency administering a high-priority program to develop a plan to implement anti-fraud controls that include digital identity-proofing solutions, threat intelligence, and proactive analytics.[31]  H.R. 7118, the Social Security Payment Integrity and Information Act of 2022, introduced by Rep. Angie Craig (D-Minn.), would require the SSA commissioner to begin sharing information furnished to the SSA with the agency operating the Do Not Pay working system, to prevent improper payments to deceased individuals through a cooperative agreement with the agency.[32]  

H.R. 6895, the Commission on Sustaining Medicare and Social Security Act of 2022, introduced by Rep. Gus Bilirakis (R-Fla.), would create a temporary Commission on Sustaining Medicare and Social Security in the legislative branch to report on the Medicare, Social Security retirement, and the Social Security Disability programs to address the impact of using alternative price indexes to determine cost-of-living adjustments; the impact of using alternative formulas to calculate certain Medicare premiums, prevent fraud, increase integrity and sustainability; and reduce improper payments in the programs.[33]  Finally, H.R. 8661, the Guaranteeing Unemployment Assistance and Reducing Deception Act introduced by Rep. Steven Horsford (D-Nev.), seeks to improve equity and accountability within state unemployment programs, recover fraudulent payments and prevent future fraud in UI programs.[34]  Since these bills have been introduced in both the House and Senate by both Democrats and Republicans, it appears that there is bipartisan support for cutting back on improper payments.

As the GAO noted in its summary of improper payments, the federal government is unaware of the total amount due to a lack of accurate information.  Several states have taken steps to make sure this does not occur.  Legislators in Ohio created the OhioCheckbook transparency program in the state treasurer’s office in 2014.  At the time it was deployed, the program encompassed about $408 billion in state spending, spanning seven fiscal years, including 112 million individual expenditures and 3.9 billion pieces of financial information. 

In 2015, the state treasurer reached out to Ohio’s local cities, counties, townships, and schools asking them to include their spending information on the OhioCheckbook.  Within a week, more than 100 local governments responded to the request.[35]  The OhioCheckbook dashboard provides an easily accessible and informative perspective on how and where state funds are being disbursed.  Currently, 352 cities and villages and 47 counties participate in the OhioCheckbook, improving accountability and transparency in government across the state.[36]  Knowing where and how much money is being spent makes it easier to prevent it from being wasted.

However, even with such efforts at the state level to combat waste, fraud, and abuse, improper payments continue across the country.  On September 27, 2022, WRTV in Indianapolis reported that the state of Indiana has been sending Automatic Taxpayer Refund checks to dead people.  However, the burden of returning these checks back to the state lays with the individual’s estate or surviving heirs, who must complete a form and return it to the state, along with the check and a copy of the death certificate.[37]  These automatic payments were issued based on a prior year’s tax return, and not necessarily checked against the information in SSA’s Death Master File.

CAGW has been a long-time proponent of the use of recovery audit contracts (RACs) to help the government identify and recover wasteful government spending and has long advocated for their use.  RAC programs use private-sector auditors that are paid on a commission basis for all underpayments and overpayments that they identify.  The government bears none of the risk of investing in the systems and personnel to conduct the program.  The evidence of their effectiveness suggests that RACs should be used as much as possible, but this has unfortunately not occurred throughout the federal government.

Between 2005 and 2008, the Centers for Medicare and Medicaid Services (CMS) operated a RAC demonstration project for Medicare Parts A and B, which recovered more than $900 million in overpayments to providers.  Congress enacted legislation to expand the program nationwide and make it permanent, a process that began in early 2009 and was fully implemented by September 2010.  In 2010, the scope of RACs was expanded to include Medicare Parts C and D, and states and territories were required to establish RAC programs for Medicaid as a proven, valuable tool in reducing improper payments. 

By December 31, 2012, RACs had corrected more than $4.2 billion in improper payments in the Medicare program, approximately 93 percent ($3.9 billion) of which were overpayments collected from providers, over the four-year period beginning with FY 2010 through the first quarter of FY 2013.  In short, the program works well and should have been continued.  Unfortunately, under pressure from providers, CMS suspended a significant portion of its audits, and considered changing rules governing some claims. 

RACs have an accuracy rate of 96 percent, making them the most successful tool Congress has implemented to reduce improper payments, and their use should be expanded.  CAGW estimates that by reducing Medicare Improper Payments by 50 percent over five years, the federal government could save $4.3 billion in one year and $21.5 billion over five years.[38]

The Commonwealth of Pennsylvania had also, as required by 42 U.S.C. Section 1395a(a)(42)(B)(i), established a RAC program for its fee-for-service Medicaid provider reviews, focusing on short-stay inpatient hospital services.  In 2019, the Pennsylvania Department of Human Services, Bureau of Program Integrity requested an exception to continuing the RAC program, which was granted by CMS effective June 1, 2019, for a period of two-years.  An extension of the two-year exception was granted by CMS effective June 1, 2021, through May 31, 2023.[39]

In addition to the extension of the RAC program, there are three bills that have been introduced in the Pennsylvania legislature that would increase the ability of the state to combat improper payments:  House Bill (HB) 104 and HB 108 from the 2021 legislative session, and HB 2482 from the 2022 legislative session.  HB 104 would implement a reporting program across state agencies to determine the number of improper payments made by agencies or contractors resulting in overpayment, underpayment, a payment to an ineligible individual, ineligible service, a duplicative payment or redundant service, or a payment for services not received.[40]  The bill would require agencies to “conduct an assessment of improper payments” to “determine whether the programs operated by the Commonwealth agency have a low, moderate or high risk of resulting in improper payments.”  Commonwealth agencies would be required to assess their programs and report every two years on the root cause of improper payments in high-risk programs and develop a plan to reduce the number of improper payments to no more than 3 percent for high-risk programs for the next occurring biennial assessment.[41] 

HB 108 makes improvements to the state’s existing Do-Not-Pay initiative established under IPERIA by requiring state agencies that expend federal funds to enter a memorandum of understanding (MOU) with the U.S. Treasury to participate in the initiative to help improve the data collected and promote the integrity of payments made by those agencies.[42]  The bill would require certain reporting requirements that include the “total number of improper payments identified by the Commonwealth agency after participation in the initiative.  The total number of improper payments prevented the Commonwealth agency as a result of participating in the initiative.  The total amount of improper payments identified and prevented by the Commonwealth agency after participating in the initiative.  The savings realized by the Commonwealth as a result of the Commonwealth agency’s participation in the initiative.  Any weaknesses in the internal financial controls of the Commonwealth agency identified through participation in the initiative.  Any changes to programs operated by the Commonwealth agency to improve payment accuracy and integrity resulting from participation in the initiative.  Recommendations to improve the Commonwealth’s agency’s payment accuracy and integrity, including legislative or regulatory changes required to prevent improper payments and improve payment accuracy and integrity.”[43]  This proposal tracks the GAO’s recommendation for improved accountability for improper payments in its April 27, 2022, report. 

HB 2482 amends The Fiscal Code, (P.L. 343, No. 176) to improve accountability for funds received from the federal government by requiring an analysis of internal controls used to prevent and eliminate improper payments and fraud.  The bill would create “a transparency portal on the agency’s publicly accessible Internet website,” to “provide current information about expenditures of Federal funding,” updated “from the close of the prior business day.”[44]  Upon final disbursement of the funds, the bill also requires a detailed report that provides the “number of eligible and ineligible entities to receive Federal funding.  The savings to the State Treasury as a result of identification of entities that are ineligible to receive money from Federal funding.  The results of the single audits of the program;” results of “any other Federal or state audit” of the program.  “The total amount of federal funding received in each county.”  And “the total improper payments under IPERA for Federal and state funding.”  The bill also establishes a Do-Not-Pay pilot program within the Treasury Department of the Commonwealth to ensure that an entity is eligible to receive payment.[45]

These bills will both increase transparency and accountability and help state agencies reduce the number of improper payments.  In addition, I urge the Committee to investigate the reasoning behind the request for an exception from the Department of Human Services from the RAC program for Medicaid services and determine whether this program should be re-implemented as a means to recover improper payments, as well as continue your efforts to combat waste, fraud, abuse, and mismanagement in government. 

Again, I appreciate the opportunity to testify before your committee and look forward to your questions.


[1] Congressional Research Service, “Improper Payments in High-Priority Programs: In Brief,” R45257, Updated July 16, 2018, https://crsreports.congress.gov/product/pdf/R/R45257.

[2] Ibid.

[3] Ibid., Congressional Research Service, “Improper Payments in High-Priority Programs: In Brief.”

[4] Ibid.

[5] Ibid.

[6] Payment Integrity Information Act of 2019, Pub. L. No. 116-117, S. 375, https://www.congress.gov/bill/116th-congress/senate-bill/375.

[7] Government Accountability Office, “Improper Payments,” Issue Summary, https://www.gao.gov/improper-payments.

[8] Ibid.

[9] James Eiler, “Subcommittee Hearing Tries to Shed Light on COVID-19 Relief Fraud,” The WasteWatcher, Citizens Against Government Waste, July 25, 2022, https://www.cagw.org/thewastewatcher/subcommittee-hearing-tries-shed-light-covid-19-relief-fraud.

[10] Ibid.

[11] Ibid.

[12] Department of Justice, Office of Public Affairs, “Justice Department Takes Action Against COVID-19 Fraud,” March 26, 2021, https://www.justice.gov/opa/pr/justice-department-takes-action-against-covid-19-fraud

[13] Department of Justice, Office of Public Affairs, “Justice Department Announces Director for COVID-19 Fraud Enforcement,” March 10, 2022, https://www.justice.gov/opa/pr/justice-department-announces-director-covid-19-fraud-enforcement.

[14] Government Accountability Office, “COVID-19: Current and Future Federal Preparedness Requires Fixes to Improve Health Data and Address Improper Payments,” GAO-22-105397, April 27, 2022, https://www.gao.gov/products/gao-22-105397.

[15] Office of Management and Budget, Program Scorecards, PaymentAccuracy.gov,  https://www.paymentaccuracy.gov/payment-accuracy-high-priority-programs/.

[16] Office of Management and Budget, The White House, “Updated Data on Improper Payments” December 30, 2021, https://www.whitehouse.gov/omb/briefing-room/2021/12/30/updated-data-on-improper-payments/#:~:text=An%20improper%20payment%20is%20a,the%20relevant%20statute%20or%20regulation.

[17] Government Accountability Office, “Unemployment Insurance: Transformation Needed to Address Program Design, Infrastructure, and Integrity Risks,” GAO-22-105162, June 7, 2022, https://www.gao.gov/products/gao-22-105162

[18] U.S. Department of Labor, “Unemployment Insurance Payment Accuracy by State,” https://www.dol.gov/agencies/eta/unemployment-insurance-payment-accuracy.

[19] U.S. Department of Labor, “Unemployment Insurance Payment Accuracy by State, Pennsylvania,” https://www.dol.gov/agencies/eta/unemployment-insurance-payment-accuracy/2021/PA.

[20] Ibid., Government Accountability Office, “Unemployment Insurance: Transformation Needed to Address Program Design, Infrastructure, and Integrity Risks.”

[21] Ibid.

[22] U.S. Department of Labor Office of Inspector General, Office of Audit, Report to the Employment and Training Administration, “COVID-19: ETA and States Did Not Protect Pandemic-Related UI Funds From Improper Payments Including Fraud or From Payment Delays,” Report Number: 19-22-006-03-315, September 30, 2022, https://www.oig.dol.gov/public/reports/oa/2022/19-22-006-03-315.pdf.

[23] Ibid.

[24] U.S. Department of Labor, Employment & Training Administration, “Unemployment Insurance Performance Management,” https://oui.doleta.gov/unemploy/bqc.asp.

[25] Social Security Administration, “SSA’s Death Information,” https://www.ssa.gov/dataexchange/request_dmf.html.

[26] Government Accountability Office, “Covid-19: Opportunities to Improve Federal Response and Recovery Efforts,” GAO-20-625, June 25, 2020, https://www.gao.gov/products/gao-20-625#fn44.

[27] Treasury Inspector General for Tax Administration, “American Rescue Plan Act:  Implementation of Advance Recovery Rebate Credit Payments,” Report Number: 2022-47-030, March 21, 2022, https://www.treasury.gov/tigta/auditreports/2022reports/202247030fr.pdf.

[28] Ibid.

[29] IRS Improper Payments act, S. 3221, 117th Congress (2021), https://www.congress.gov/117th-congress/senate-bill/3221.

[30] Recovering Fraudulent Claims Act, S. 2742, 117th Congress (2021), https://www.congress.gov/bill/117th-congress/senate-bill/2742.

[31] STOP Fraud Act, H.R. 8322, 117th Congress (2022), https://www.congress.gov/117th-congress/house-bill/8322.

[32] Social Security Payment Integrity and Information Act of 2022, H.R. 7118, 117th Congress (2022), https://congress.gov/bill/117th-congress/house-bill/7118.

[33] Commission on Sustaining Medicare and Social Security Act of 2022, H.R. 6895, 117th Congress (2022), https://www.congress.gov/bill/117th-congress/house-bill/6895.

[34] Guaranteeing Unemployment Assistance and Reducing Deception Act, H.R. 8661, 117th Congress (2022), https://www.congress.gov/bill/117th-congress/house-bill/8661.

[35] Curtis Kalin, “Ohio Checkbook Shows How Transparency is Supposed to Work,” The WasteWatcher, Citizens Against Government Waste, August 12, 2015, https://www.cagw.org/thewastewatcher/ohio-checkbook-shows-how-transparency-supposed-work.

[36] OhioCheckbook, Ohio Office of Budget and Management, Ohio Treasurer, https://checkbook.ohio.gov/.

[37] Kara Kenney, “Deceased taxpayers receiving Automatic Taxpayer Refund payments,” WRTV Indianapolis, September 27, 2022, https://www.wrtv.com/news/wrtv-investigates/deceased-taxpayers-receiving-automatic-taxpayer-refund-payments

[38] Sean Kennedy, “Prime Cuts,” Citizens Against Government Waste, October 2021, https://www.cagw.org/reporting/prime-cuts.

[39] Commonwealth of Pennsylvania, Department of Human Services, “Medicaid Recovery Audit Contractor Program History and 2021 Update,” https://www.dhs.pa.gov/about/Fraud-And-Abuse/Pages/RAC-Providers-Review.aspx.

[40] An Act Amending Title 71 (State Government) of the Pennsylvania Consolidated Statutes, providing for the assessment of improper payments by Commonwealth agencies and for public information on payments and programs of Commonwealth agencies, House Bill 104, Session of 2021, https://legiscan.com/PA/bill/HB104/2021.

[41] Ibid.

[42] An Act Amendment Title 71 (State Government) of the Pennsylvania Consolidated Statutes, providing for Improper Payments; and establishing Do-Not-Pay Initiative, House Bill 108, Session of 2021, https://legiscan.com/PA/bill/HB108/2021.

[43] Ibid.

[44] An act amending the act of April 9, 1929 (P.L. 343, No. 176), known as the Fiscal Code, providing for Federal funds oversight, House Bill 2482, Session of 2022, https://legiscan.com/PA/bill/HB2482/2021.

[45] Ibid.