Finding And Recapturing Improper Payments

This memorandum directs federal agencies to expand use of "Payment Recapture Audits" to identify and recover improper payments to contractors and other entities. The OMB Director must issue implementation guidance within 90 days and coordinate with the Council for Inspectors General on Integrity and Efficiency to review agency effectiveness.

Federal Register Open PDF 75 FR 12119

Impact dates

Jun 8, 2010
OMB Director develops guidance on actions agencies must take to carry out memorandum requirements

Key directives

Expand use of Payment Recapture Audits to extent permitted by law and where cost-effective
OMB Director to develop guidance within 90 days on actions agencies must take
OMB to coordinate with Council for Inspectors General on Integrity and Efficiency for IG review process
Guidance may include agency-specific targets for increasing recoveries

Who is ordered

Timeline

Immediate

Memorandum directs expansion of Payment Recapture Audits

Near term (90d)

OMB Director must develop guidance on implementation actions

Long term

Potential agency-specific recovery targets
Ongoing IG review of agency effectiveness

Risks & tensions

Contingency-based auditor compensation could create perverse incentives or conflicts of interest
Cost-effectiveness qualifier may limit actual implementation scope
Agency discretion under 'extent permitted by law' creates uncertainty in enforcement