Overpayment Recovery – All programs with overpayments must have a Recovery Audits and Activities Program regardless of which Phase they are operating in. However, a recovery audit should only be a part of the Recovery Audits and Activities Program if it is cost-effective. (See Section V.B of this guidance)
Compliance – Every year, each agency Inspector General (IG) reviews relevant IP and UP reporting and records pertaining to the programs within an agency to determine whether the agency complies with PIIA and OMB guidance. (See Section VI of this guidance)
Non-Compliance Actions – Each year than an IG determines a program is non-compliant, the agency has specific actions that must be taken. The agency actions required will depend on the number of consecutive years the program has been non-compliant. (See Section VI.D of this guidance) Reporting - At a minimum, there are reporting requirements that apply to all agencies with programs in Phase 1 as well as those with programs in Phase 2. (See Section VII of this guidance)
High-Priority Programs - To be a High-Priority program, a program must be reporting in Phase 2 AND report IPs resulting in monetary loss in excess of $100,000,000 annually. In addition to the reporting that all programs in Phase 2 must complete, High-Priority programs must provide quarterly Payment Integrity Scorecard reporting on www.paymentaccuracy.gov. (See Section VII.B of this guidance)
