Court Services and Offender Supervision Agency for the District

CSOSA was compliant with the Payment Integrity Information Act of 2019 (PIIA). CSOSA maintains payment integrity through strong payment controls and continuous monitoring. CSOSA is in the third year of the assessment cycle. CSOSA performs risk assessments at least once every three years. The agency is considered to be in Phase 1 and is not likely to have an annual amount of improper payments (IP) plus annual unknown payments (UP) above the statutory threshold. The risk of improper payments has been low over the years as well as during the testing performed during the most recent risk assessment. Business processes have not changed during this cycle and the risk remains low.

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Recovery information

Why recovery audits are not cost effective in certain programs

To employ one GS 12 FTE to perform recapture audits will cost $93K to $122K per year. Given that the CSOSA has a very low risk of improper payment as a result of risk assessments done in FY2023, it is not cost beneficial for the CSOSA to employ an FTE to perform recapture audits. Another option is to contract out the recapture audits, below is a cost analysis using GSA contract rates for Castro & Company, LLC. Based on the analysis below, it would cost CSOSA at least $41K to recapture any improper payments. It is our determination then that it is not cost beneficial for the CSOSA to employ a contractor to perform recapture audits.

Supplemental Information

CSOSA and its financial system service provider, the Department of Interior-Interior Business Center (IBC), use the DNP Initiative to review payment eligibility for purposes of identifying and preventing improper payments. The DNP Validation is completed each weekend. The IBC receives an email from DNP notifying them that the Continuous Monitoring results are refreshed. The IBC will refresh the OFF report data the first workday of the week. IBC sends an email notification immediately after the data is made available. Upon receipt of this email notification, CSOSA Office of Financial Management (OFM) will run the OFF Report and format based on the three available reports: Matched to Vendor, Matched Vendors Tied to PO, and Matched Vendors Tied to AP. The three identified reports include vendors with matched results of “Possible”, “Probable”, and “Conclusive”. The information reported to the CSOSA Office of Procurement (Procurement) is based on those vendors with a “Conclusive” match result. OFM issues an email to Procurement on a weekly basis identifying those vendors who appeared on the DNP Report. Prior to submitting a new OFF Vendor Request form, the Agency must ensure the vendor is not referenced on the DNP List. The information is provided weekly by email to all credit cardholders to ensure they are not using any vendors identified on the DNP Report. CSOSA Accounts Payable staff are informed of this information as it pertains to reposting monthly bank statements and Budget Analysts are informed as well to assist them when approving requisitions. Prior to submitting a new Vendor Request form, CSOSA must ensure the vendor is not referenced on the DNP List. OFM informs IBC to end date positively identified vendors in OFF via email. CSOSA has neither identified a material amount nor realized a reduction of improper payments attributable to implementing the DNP Initiative capabilities. Rather, CSOSA’s DNP Initiative implementation has proven that CSOSA has robust and effective internal controls over ensuring that eligible entities receive Federal funds.

The Working System has not reduced/prevented improper payments:

CSOSA has not identitied incorrect information in the Working System.

CSOSA was found compliant during the most recent PIIA compliance review.

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Compliant programs:

  • Community Supervision Program
  • Pretrial Services Agency

Program name When was the last improper payment risk assessment conducted? Likely to be susceptible to significant improper payments? Substantial changes made to the assessment methodology used for the reporting cycle
Community Supervision Program *
Pretrial Services Agency *

* Assessment year is not displayed because one or more of the following statements is true:

  1. Not required to conduct a risk assessment under the Payment Integrity Information Act of 2019,
  2. Already assessed for improper payment risk under a different name in a prior reporting period, and/or
  3. New and planning to perform a risk assessment in the future.

Based on prior financial statement audits, a determination of strong internal controls from CSOSA internal controls testing, and the results of CSOSA internal testing of its FY 2023 payment transactions, CSOSA believes that the CSP and PSA programs have low inherent risks of improper payment.