U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Washington, D.C. 20507
Office of Inspector General
May13, 2015
TO: Committee on Homeland Security & Governmental Affairs
United States Senate
340 Dirksen Senate Office Building
Washington, DC 20510
Committee on Oversight and Government Reform
United States House of Representatives
2157 Rayburn House Office Building
Washington, DC 20515
Honorable Jenny R. Yang, Chair
U.S. Equal Employment Opportunity Commission
131 M St. NE
Washington, DC 20507
Beryl H. Davis
Director, Financial Management and Assurance
U.S. Government Accountability Office
441 G Street, NW, Room 5490
Washington, DC 20548
Honorable David Mader
Controller, Office of Federal Financial Management
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
FROM: Milton A. Mayo, Jr.
Inspector General
SUBJECT: U.S. Equal Employment Opportunity Commission’s Compliance with the
Improper Payments Elimination and Recovery Act P.L. 111-204 (IPERA), as
amended by the Improper Payments Elimination and Recovery Improvement Act
P.L. 112-248 (IPERIA) for FY 2014 OIG Report No. 2015-01-IPERA
The IPERIA1 requires agencies and entities, such as the U.S. Equal Employment Opportunity Commission (EEOC), with improper payment estimates that do not meet the statutory thresholds
to report an estimate of the annual amount and rate of improper payments, as well as reduction targets in their annual Agency Financial Reports (AFRs) or Performance and Accountability
Reports (PARs) per M-15-02 Part IA 9 Step 4c (page 16). These agencies also are required to conduct a risk assessment to identify programs/activities that may be susceptible to significant
improper payments. If an agency determines that it is not at high risk for significant improper payments, then risk assessments are required every 3 years. If no programs are at risk for
significant improper payments, the other requirements on annual reduction targets, corrective action plans, etc. are not applicable. Additionally, small agencies should have a payment
recapture program in place.
The Office of Inspector General (OIG) is required by IPERA to determine and report by May 15, 2015, on whether the EEOC is in compliance with the Improper Payments Information Act.
Based on our findings, we determined the agency has complied with the Improper Payments Information Act (IPIA), as amended by IPERIA. To satisfy our reporting requirements, we
communicated with the agency’s Chief Financial Officer (CFO) to determine whether a risk assessment was conducted to identify programs/activities in the agency that may be susceptible
to significant improper payments and whether the agency has a payment recapture program in place. The CFO indicated that the agency conducted an agency-wide risk assessment via a
statistical sampling of vendor and travel payments in FY 2014. Additionally, the agency relied on the results of the FY 2014 financial audit, which did not uncover duplicate/improper
payments, and agency internal controls in place relating to payments. The CFO concluded that the agency is not at risk for significant improper payments and determined that there were no
significant improper payments made during FY 2014. The agency plans to continue performing in house-risk assessments. As a result of the CFO’s response, the requirement for annual
reduction targets, corrective action plans, etc., is not applicable. Additionally, in regard to having a payment recapture program in place, the CFO indicated that if any improper payments arise in
the future, the agency will establish an accounts receivable and follow the procedure of collection. The agency has a process in place to refer all valid debts for collection through the
U.S. Department of Treasury’s FedDebt system. Further, both the FY 2014 Financial Statement Audit and the agency’s Performance and Accountability Report (PAR) are posted on the
agency’s website.
Willie A. Eggleston, Senior Auditor, is available to answer any questions regarding our review and determination. He may be reached at (202) 663-4372 or by email at
Endnote
1 The IPERIA, which was signed into law by President Obama on January 10, 2013 amends the Improper Payments Elimination and Recovery Act (IPERA; P.L.111-204) of 2010 and the Improper
Payments Information Act (IPIA; P.L. 107-300) of 2002, and directed the Office of Management and Budget (OMB) to issue implementing guidance to agencies. On October 20, 2014, OMB
issued revised government-wide implementation guidance, OMB Memorandum, M-15-02, Appendix C to Circular A-123 Requirements for Effective Estimation and Remediation of
Improper Payments.