Export-Import Bank of the U.S.

The Payment Integrity Information Act of 2019 (PIIA) requires agencies to review and assess all programs and activities they administer and identify those determined to be susceptible to significant improper payments. The Office of Management and Budget’s (OMB) Circular A-123, Appendix C, Requirements for Payment Integrity Improvement, requires that agencies assess all programs with annual outlays greater than $10,000,000 for improper payment (IP) risk at least once every three years. The Export-Import Bank of the United States (EXIM) supports compliance with PIIA and OMB guidance through its Payment Integrity program, which consists of four distinct components: Short-term Authorizations, Medium-term Authorizations, Long- term Authorizations, and Cash control Disbursements. Per OMB guidance, risk assessments of all EXIM programs are conducted every three years. In the interim years, risk assessments evaluating programs that experience significant legislative changes and/or significant increase in funding will be performed to determine if the agency continues to be at low risk for making significant improper payments, at or above the threshold levels set by OMB. In FY 2023, EXIM conducted a comprehensive risk assessment of all four programs and determined that none of its programs were risk-susceptible for making significant improper payments in the preceding year. Throughout FYs 2024 and 2025, EXIM remained compliant with PIIA and applicable OMB guidance, including Circular A-123, Appendix C, Requirements for Payment Integrity Improvement, revised as of March 5, 2021, and Circular A-136, Financial Reporting Requirements, revised July 14, 2025. In accordance with PIIA and OMB requirements, the next risk assessment of all four programs will be performed in FY 2026.

PIIA also requires Federal agencies to report annually on their efforts according to guidance promulgated by OMB. Annually, EXIM submits data to OMB as part of the Annual Data Call. It is collected and published on www.paymentaccuracy.gov,which provides current and historical information about improper payments made under Federal programs, as well as extensive information about how improper payments are defined and tracked. For detailed results of EXIM’s compliance efforts under PIIA, please refer to the PaymentAccuracy.gov website. As part of the Annual Data Call, EXIM also submits the agency’s designated Payment Integrity Point of Contact to OMB, as required.

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Recovery information

Why recovery audits are not cost effective in certain programs

EXIM reviewed all its programs and activities and determined that none are susceptible to significant improper payments at or above the threshold levels established by OMB. Recovery audits would require the agency to incur costs for contractors or other entities with specialized expertise, such as accounting professionals and fraud examiners, who use advanced tools and technologies to analyze payment records and supporting documentation. Therefore, it has been determined that it is not cost-effective to conduct recovery audits to identify and recover overpayments.

Supplemental Information

EXIM complies with all aspects of the Do Not Pay Initiative through its Character, Reputational, and Transaction Integrity (CRTI) process. All transactions within the three authorization-based payment programs (Short-Term, Medium-Term, and Long-Term) undergo CRTI checks. As part of CRTI, participant names are screened against a clearinghouse database containing over 400 databases and 20 directories to ensure compliance with various “Know Your Customer” (KYC) and EXIM due diligence requirements. Additionally, EXIM does not disburse funds directly to payees. Instead, payments are processed through the U.S. Department of the Treasury’s Secure Payment System. All disbursements undergo payment integration, during which the Do Not Pay portal automatically matches files against the Death Master File and the System for Award Management (SAM) exclusion records.

The Working System has not reduced/prevented improper payments:

The Working System strives to maintain accurate data. However, the past year, EXIM has identified incorrect information in the Working System .

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

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Compliant programs:

  • Cash-Control Disbursements
  • Long-Term Authorizations
  • Medium-Term Authorizations
  • Short-Term Authorizations

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
Cash-Control Disbursements 2023 No No
Long-Term Authorizations 2023 No No
Medium-Term Authorizations 2023 No No
Short-Term Authorizations 2023 No No