National Labor Relations Board

The NLRB is required by the PIIA to assess the disbursement process and estimate the approximate amount of improper payments every three years. In FY 2025, the NLRB PIIA assessment and review was performed by an independent consultant. The NLRB’s independent review evaluated the procedures in the Agency’s payment and disbursement processes and concluded that the NLRB’s programs were at a low risk for improper payments. Thus, improper payments for the NLRB’s programs did not exceed $10.0 million and 1.5 percent of the program total expenditures or $100.0 million of the total program expenditures. The Agency estimates the improper payments rate to be at most 1.5 percent and the improper payment amount to be no more than $4,636,376. In addition, the testing confirmed that Phase 2 testing for commercial vendor payments did not exceed the statutory thresholds, further supporting the low-risk designation for all NLRB programs. Based on these results, NLRB programs do not require additional Phase 2 testing for the purpose of producing an annual improper payment or unknown payment estimate, and no programs are subject to reporting as “susceptible to significant improper payments” in the FY 2025 submission. Therefore, the NLRB has effective procedures and controls in place for its payment and disbursement processes.