Millennium Challenge Corporation
The USAID Office of Inspector General (OIG) concluded that the Millennium Challenge Corporation (MCC) was compliant with the Payment Integrity Information Act of 2019 (PIIA) in the most recent compliance audit. PIIA requires agencies to review and assess all programs and activities with annual outlays greater than $10,000,000 for improper payment risk at least once every three years to identify those susceptible to significant improper payments. MCC last completed a risk assessment on its programs in FY 2023 on the Foreign Assistance Program (comprising of the Compact Assistance, Compact Development, and Threshold Fund), Due Diligence and Administration Funds and identified no programs which are likely suspectable to significant improper payments. These programs are still under threshold in FY 2025.
MCC evaluated all programs in FY 2025 to ensure no significant legislative changes and / or significant increases in funding to determine if the agency needed to reassess its risk posture and whether programs moved above the threshold levels set by PIIA. No programs were identified meeting this criterion. MCC will complete a risk assessment in FY 2026. MCC will continue to maintain a payment integrity environment with strong internal controls and low improper payments.
Recovery information
Please note: Overpayment amounts recovered are reported in the year they were recovered, not the year they were identified. Therefore it is possible in some years to have a recovery rate greater than 100%.
| Overpayment amount identified through recovery activities | $3.34 M |
| Overpayment amount recovered through recovery activities | $0.01 M |
| Recovery activities recovery rate | 0.3 % |
Why recovery audits are not cost effective in certain programs
MCC concluded recovery audits would not be cost effective and benefit MCC's internal control structure of all funds, based on the latest risk assessments conducted in FY 2023, MCC does not have any funds susceptible to significant improper payments. MCC conducts independent audits of assistance programs on an annual basis. These audits are reviewed for questioned costs and other improper payments and tracked as necessary. The other MCC funds historically have very low annual improper payments.
Supplemental Information
On a weekly basis, the shared service provider that MCC uses uploads MCC payment batches into the Do Not Pay portal. The Treasury returns the payment batches to IBC who upload the files in Oracle Federal Financials and advises that the files are available. MCC downloads the Payment Activity Report monthly from the Do Not Pay portal and reviews the list for items in need of adjudication. Flagged payments or payments listed as possible matches are reviewed with the respective MCC division making the payment before a determination is reported to Treasury on the portal. Although payments can be flagged, the system often either produces false positives or inaccurate probable matches. Therefore, MCC vendors are vetted in other databases such as SAM which is more often accurate prior to the award and payments. MCC did not identify any improper payments through the Do Not Pay initiative.
The Working System has not reduced/prevented improper payments:
MCC has not identitied incorrect information in the Working System.
MCC was found compliant during the most recent PIIA compliance review.
Show full list of compliant programs 
Compliant programs:
- Administrative Expenses - Millennium Challenge Corporation
- Compact Assistance
- Compact Development Funding
- Due Diligence
- MCC Foreign Assistance for Overseas Programs
- Threshold Programs
| 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 |
|---|---|---|---|
| Administrative Expenses - Millennium Challenge Corporation | 2023 |
 No
|
|
| Compact Assistance | 2023 |
No
|
|
| Compact Development Funding | 2023 |
No
|
|
| Due Diligence | 2023 |
No
|
|
| MCC Foreign Assistance for Overseas Programs | * | ||
| Threshold Programs | 2023 |
No
|
* Assessment year is not displayed because one or more of the following statements is true:
- Not required to conduct a risk assessment under the Payment Integrity Information Act of 2019,
- Already assessed for improper payment risk under a different name in a prior reporting period, and/or
- New and planning to perform a risk assessment in the future.
Given the nature of MCC’s operations improper payments identified in any specific year will vary based on the level of expenditure within individual countries and the status of the grant.