Requirements for payment integrity “should be more than a compliance exercise,” OMB has said in issuing guidance that it said is designed to “ensure that federal agencies focus on prevention and have the proper incentives to improve their improper payments rates.”
OMB memo M-18-20 revises Circular A-123’s Appendix C for the first time since 2014 “to transform the improper payment compliance framework to create a more unified, comprehensive, and less burdensome set of requirements,” in its words.
The appendix addresses topics such as the requirements under a series of laws aimed at reducing improper payments, conducting risk assessments, obtaining statistically valid estimates of annual improper payment amounts, reporting requirements, special considerations for high-priority programs, preventing and recovering improper payments, the Do Not Pay initiative, and more.
