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Management Challenges
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Any Recommendations
Any Open Recommendations
Reports
FDIC Examinations of Government-Guaranteed Loans
Develop and implement guidance to examination staff on the credit, operational (including fraud), liquidity, and compliance risks related to Government-guaranteed loans to ensure staff adequately plans and conducts examinations to identify and address emerging risks.
Develop and implement a training plan to ensure examination staff are trained on the requirements and risks of Government-guaranteed loan programs.
Update, develop, and distribute to FDIC examination personnel a list of FDIC examiners who have significant experience examining banks that specialize in Government-guaranteed loan programs to regional offices.
Develop and implement a process to obtain improved data regarding Government-guaranteed lending activities of FDIC-supervised financial
institutions.
Update the [redacted] MOU to include the sharing of loan portfolio information such as historical loan performance, status of guaranty, and loan-level risk characteristics.
Establish arrangements with other Federal agencies that administer Government-guaranteed loan programs to facilitate information sharing and
proactive identification of risk.
Develop and implement processes and procedures for the routine sharing, receipt, and storage of confidential information with Federal agencies that administer Government-guaranteed loan programs.
Develop and implement guidance to provide instruction to FDIC bank examination staff requiring communication and information sharing with Federal agencies that administer Government-guaranteed loan programs to ensure FDIC staff and the Federal agencies are aware of any emerging risks.
Determine whether other Federal agencies that administer Government-guaranteed loan programs have a list of FDIC-supervised banks with high risk factors associated with such programs and develop protocols to share information with relevant FDIC personnel, including examiners.
Develop and implement guidance to ensure relevant risk information exchanged with Federal Government agencies that administer Government-guaranteed loan programs is shared internally within the FDIC on an ongoing basis with the appropriate FDIC employees.
Develop and implement updated FDIC examination guidance to establish an appropriate timeframe for uploading complete supervisory business records to RADD.
Develop and implement guidance to examination staff to ensure the staff consistently evaluate Government-guaranteed loans in their review of loan classification, assessment of off-balance sheet risk, concentration risk, and ongoing monitoring.
Update and implement the Examination Profile Script to include additional questions on financial institution participation in Government-guaranteed loan programs in order to identify and address emerging risk.
Develop and implement additional items to the Safety and Soundness Request List to identify Government-guaranteed loans, the performance of those loans, and status of the guaranty.
Issue and implement guidance to require that examination staff conduct a fraud risk assessment on future Government-guaranteed loan programs involving FDIC-insured and FDIC-supervised financial institutions to inform policy decisions.
Ensure guidance on future Government-guaranteed loan programs includes all risks associated with such programs and has instructions to allow for consistency in supervisory activities.
Issue and implement guidance for examiners clarifying the FDIC supervisory expectations for reviewing bank PPP activities, including the level of PPP loan volume triggering a heightened review, how examiners should assess the PPP activities of banks that have existing BSA/AML weaknesses, and protocols for examination staff to communicate observed weaknesses.
Revise and implement FDIC guidance and practices for assessing concentrations and loan classification to ensure uniform application with the other Federal bank regulators of supervisory approaches to banks
Coordinate with the other Federal bank regulators to ensure uniform application of supervisory approaches to banks regarding concentrations and loan classification.
Additional Actions Are Needed to Reduce Accounts Management Function Inventories to Below Pre‑Pandemic Levels
Ensure that all sites understand and begin immediately stamping the ICT received date after correspondence screening is completed, and that individual and business documents are screened with equal importance.
Coordinate with the Information Technology organization to explore adding Taxpayer Relations inventories into the CII, so that all Accounts Management inventory is located in the same inventory management system.
The Commissioner, Wage and Investment Division, should establish time frames for and a process to measure correspondence screening timeliness at each site.
The Commissioner, Wage and Investment Division, should rescind the requirement that only the TEs and the CSRs perform correspondence
screening and encourage all sites to use mail clerks, after providing them with adequate training.
The Commissioner, Wage and Investment Division, should ensure prompt completion of the ICT review to determine if additional scanners will be
purchased.
Discontinue correspondence screening via telework and ensure at all sites that screening must be conducted in the same IRS facility where documents are being scanned by the ICT.
Identify and address the cause of Accounts Management function employees incorrectly routing cases to other IRS functions and work with other IRS functions to update their Internal Revenue Manuals to make it clear that incorrectly routed documents should be returned to the
originating employee.
We recommended that management take steps to hire as many mail clerks as possible.
The Commissioner, Wage and Investment Division, should establish goals for each of the Accounts Management function’s inventory types and develop a plan for addressing those goals to ensure a timely return to pre-pandemic inventory levels.
The Commissioner, Wage and Investment, should prioritize funding and implementation of automated processing of Forms 1040-X to increase efficiencies and reduce taxpayer burden.
The Commissioner, Wage and Investment Division, should implement temporary solutions for the processing of Forms 1040-X to reduce the backlogs, reduce taxpayer burden, and save IRS resources until an automated solution is implemented.
Coordinate with the Information Technology organization to prevent generating transcripts for manual refunds less than $100 and adjust the frequency that some transcripts are generated to help management get through the inventory more efficiently.
Temporarily relieve employees in the Accounts Management function from having to complete paperwork for barred statutes, so they can focus on eliminating the backlogged inventory and prevent future barred statutes.
The Bureau of Indian Affairs Great Plains Region Did Not Oversee CARES Act Funds Appropriately
We recommend that the BIA Great Plains Region develop and implement a process to acquire the delinquent CARES Act Federal Financial Reports and Annual Narrative Reports identified in the Attachment of this management advisory.
We recommend that the BIA Great Plains Region develop a process to identify and address any other delinquent CARES Act Federal Financial Reports and Annual Narrative Reports.
We recommend that the BIA Great Plains Region develop and implement written policies and procedures that describe the roles and responsibilities of BIA officials and the review processes for Federal Financial Reports and Annual Narrative Reports to ensure submitted reports are complete, accurate, and address areas of concern.
We recommend that the BIA Great Plains Region in accordance with developed and implemented written policies and procedures, provide and track annual training for BIA officials responsible for reviewing Federal Financial Reports and Annual Narrative Reports.
The Omaha Tribe Did Not Account for CARES Act Funds Appropriately
We recommend that the BIA resolve the unreasonable hazard pay costs of $29,574 by requiring the Omaha Tribe to perform an analysis of the costs incurred to applicable criteria and document its determination of reasonableness.
We recommend that the BIA resolve the questioned hazard pay costs of $27,841 for Payment 1 by requiring the Omaha Tribe to provide detailed reconciliation of incurred costs to supporting documentation.
We recommend that the BIA resolve the questioned costs of $182,388 for Payment 2 by requiring the Omaha Tribe to provide detailed complete supporting documentation for the hazard pay and indirect costs.
We recommend that the BIA review the Omaha Tribe’s revised policy regarding the custody of checks and document that proper controls have been implemented.
We recommend that the BIA resolve the questioned costs of $42,067 by requiring the Omaha Tribe to provide a detailed list of the questioned transactions and voided checks to the BIA for its files to ensure these transactions are not claimed for reimbursement.
We recommend that the BIA resolve the questioned costs of $10,792 by requiring the Omaha Tribe to reallocate these costs to the appropriate funding source.
We recommend that the BIA require the Omaha Tribe to revise its policy to ensure a complete property record for CARES Act-funded assets in accordance with 2 C.F.R. § 200.313(d)(1).
Backlogs of Tax Returns and Other Account Work Will Continue Into the 2023 Filing Season
The Bureaus of Indian Affairs and Indian Education Have the Opportunity To Implement Additional Controls To Prevent or Detect Multi-dipping of Pandemic Response Funds
We recommend that the Bureaus of Indian Affairs and Indian Education develop and implement policies, procedures, or guidance designed to prevent or detect <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education communicate the policies and procedures developed and train bureau personnel and Tribes on preventing and detecting <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education develop and implement policies, procedures, or guidance designed to prevent or detect <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education develop and implement policies, procedures, or guidance designed to prevent or detect <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education develop and implement policies, procedures, or guidance designed to prevent or detect <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education communicate the policies and procedures developed and train bureau personnel and Tribes on preventing and detecting <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education communicate the policies and procedures developed and train bureau personnel and Tribes on preventing and detecting <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
We recommend that the Bureaus of Indian Affairs and Indian Education communicate the policies and procedures developed and train bureau personnel and Tribes on preventing and detecting <span class="tx-tooltip" tabindex="0">
multi-dipping
<span class="tx-tooltip-text">
When a recipient receives money from multiple federal sources and uses it for the same purpose, this could be an indication of multi-dipping.
</span>
</span>
.
The Three Affiliated Tribes Did Not Account for CARES Act Funds Appropriately
We recommend that the BIA resolve the questioned costs of $237,270 by requiring the Three Affiliated Tribes to provide supporting documentation to ensure that the incurred costs are allowable, allocable, and reasonable.
We recommend that the BIA require the Three Affiliated Tribes to establish controls to ensure that it can determine the appropriate funding source for each CARES Act expense.
We recommend that the BIA resolve the questioned costs of $106,280 by creating and adjusting journal entries to reallocate the funds from the U.S. Department of the Interior to the U.S. Department of Health and Human Services.
We recommend that the BIA resolve the questioned costs of $89,623 by creating adjusted journal entries to reallocate the funds from the BIA CARES Act to the appropriate funding source.
Reporting on the Use of Coronavirus Response Funding Could Be Enhanced
Reporting on the Use of Coronavirus Response Funding Could Be Enhanced
The Chief Financial Officer should evaluate the feasibility of expanding the information captured in the IRS’s financial tracking system to include tracking budgeted and dedicated staffing by spend plan requirement area for future sources of supplemental funding.
American Rescue Plan Act: Accuracy of Advance Child Tax Credit Periodic Payments
As detailed previously, we provided the Director, Return Integrity and Compliance Services, Wage and Investment Division, with notifications and files detailing erroneous payments we identified and recommended that the IRS evaluate the discrepancies to identify why the payments were made to prevent additional periodic payments to ineligible taxpayers. In addition, we recommended that the IRS add a stop payment
transaction code to taxpayer accounts to prevent them from receiving additional improper advance Child Tax Credit payments.
On August 9, 2021, we notified the Director, Return Integrity and Compliance Services, Wage and Investment Division, of our concerns related to
eligible taxpayers who did not receive their advance Child Tax Credit payments. We recommended that the IRS evaluate the discrepancies to identify why periodic payments were not made to eligible taxpayers.
On June 29, 2021, we notified the Director, Return Integrity and Compliance Services, Wage and Investment Division, that the messaging provided on the IRS’s eligibility assistant tool and the presentation of information related to the advance Child Tax Credit payments on IRS.gov may be confusing to taxpayers. For example, the link to “Get Answers on the Advance Child Tax Credit” that is located on the IRS.gov main page takes taxpayers to the Advance Child Tax Credit Payments in 2021 web page; however, the links to get the questions and answers is at the bottom of the screen. We recommended that the IRS consider revising the messaging and presentation of information on its platforms to make it clear for taxpayers.
On January 28, 2022, we notified the Director, Return Integrity and Compliance Services, Wage and Investment Division, that we identified 2.2 million taxpayers who had their direct deposit information updated by the IRS between August 23 and October 5, 2021. We recommended that the IRS conduct an outreach effort to inform taxpayers of the possibility that their advance payments may have been sent to payroll allotment accounts. This outreach effort could include sending a separate letter to the impacted taxpayers.
The Director, Return Integrity and Compliance Services, Wage and Investment Division, should develop and implement processes and procedures to include data validation on incoming files from third-party sources prior to their use.