Office of Personnel Management

OPM is committed to advancing a transparent, accountable, and collaborative financial management environment to fulfill its Federal requirements and provide stakeholders with accessible and actionable financial information. An essential part of this commitment is the continuous improvement of payment accuracy in OPM’s programs. OPM continues to implement solutions to prevent, detect, and reduce improper payments while reducing its stakeholders’ unnecessary administrative burden.

OPM conducts improper payment risk assessments on a three-year cycle, or more often if there are significant changes in the program. OPM conducted improper payments risk assessments for two Phase I programs during FY 2023: Federal Employees Group Life Insurance and Federal Employees Health Benefits Community-Rated Activity; and four Phase I programs during FY 2024: Vendor Payments, Travel Cards, Purchase Cards, and Payroll. All of these programs remained Phase I programs. OPM continues to only have two Phase II programs: Retirement Services and Federal Employee Health Benefits Experience-Rated Carriers.

Retirement Services (RS) Program provides Federal employees, retirees, and their families with benefits that offer choice, value, and quality to be a competitive employer. In FY 2025, RS properly paid 99.67 percent of annuity payments and improperly paid 0.33 percent. RS is committed to reducing improper payments by utilizing effective internal controls, corrective actions, and extensive internal recovery efforts. However, system limitations are preventing OPM from expanding root causes category reporting per the FY 2025 OMB Circular A-136, Financial Reporting Requirements. Specifically, the current IT system supporting RS does not have the granularity to align with the OMB root cause categories. RS is aware of the principle causes for improper payments. RS remains committed to ensuring the rate of improper payments remains at 0.38 percent or less. The Fraud Branch was established under the RS Program to manage the integrity of the annuity roll. The Fraud Branch responds to inquiries of alleged fraud and data integrity breaches to safeguard the annuity rolls. The Branch answers fraud inquiries involving all phases of retirement processing including the proper routing of payments, the payment of life insurance, the provision of health benefits, the representative payee process, and medical review. The branch’s data integrity team monitors error reports and extracts data on an annuity to confirm and correct information to maintain accuracy. OPM conducted several matches (such as the Social Security Administration’s Death Master File) and annual surveys. Anomalies identified in these matches and surveys are researched by OPM and, if needed, referred to the OIG. Regular audits are performed to assess the accuracy of agency retirement packages. Each month, the audit result as well as the most common errors identified are reported to the agency benefits officers. In addition, internal audits are conducted monthly to determine the accuracy of newly adjudicated retiree and survivor claims under both CSRS and FERS. These audits are used to identify any training or systemic deficiencies.

For Federal Employees Health Benefits (FEHB) and Postal Service Health Benefits (PSHB) Programs, under the oversight of the Healthcare and Insurance, contracting officers exercise broad authority in their day-to-day oversight of FEHB and PSHB carriers through benefit and rate negotiations, contract compliance, review of large provider contracts and sub-contracts, defense of lawsuits, adjudication of disputed claims, and more. In FY 2025, FEHB Experience-Rated Carriers (ERC) activity is reporting a statistically valid improper and unknown payment estimated amount and rate. The ERC activity reports one year in arrears, based on the time necessary to collect, test, report and aggregate the data. Because the ERC activity reports in arrears, PSHB data is not included in the IP estimate being reported in 2025. Independent public accountants (IPAs) provide the data by conducting sampling, testing and reporting of transactions performed by carriers as required in the Financial Reporting and Audit Guide’s Agreed Upon Procedures. Based on the results of the sampling and testing for 2024, the FEHB ERCs properly paid 99.86 percent of payments and improperly paid 0.14 percent. The improper payment estimates include overpayments, underpayments, technically improper payments and unknown payments. The total amount of all improper and unknown payments is $94.8 million, including $26.9 million in overpayments, $44.5 million in technically improper and underpayments, and $23.4 million in unknown payments. ERCs reporting improper and unknown payments are required to submit corrective action plans designed to prevent or mitigate the causes of improper or unknown payments. The most common corrective actions planned and taken are training and process changes. ERCs are required to report on the status of all findings, including prior years’ findings. OPM will review and monitor those.

In the FY 2024 annual compliance audit, OPM OIG found that OPM’s FEHB Program was not in compliance with four of the ten Payment Integrity Information Act of 2019 (PIIA) reporting requirements: (1) Published improper payment and unknown payment estimates for programs susceptible to significant improper payments and unknown payments in the accompanying materials to the annual financial statement; (2) Published corrective action plans for each program for which an estimate above the statutory threshold was published in the accompanying materials to the annual financial statement; (3) Demonstrated improvements to payment integrity or reached a tolerable improper payment and unknown payment rate; (4) Reported an improper payment and unknown payment estimate of less than 10 percent for each program for which an estimate was published in the accompanying materials to the annual financial statement.

OPM developed a new Sampling and Estimation Methodology Plan with active engagement from agency stakeholders and FEHB ERC to meet the PIIA requirements. In FY 2024, OPM issued the 2024 FEHBP Financial Reporting and Audit Guide, which provides detailed requirements for the financial reporting for all FEHB ERC, including audit requirements and improper payment reporting. OPM has received statistically valid data from all FEHB ERC which estimates the IP amount for each Carrier. OPM has aggregated this data and projected a statistically valid IP estimate for the entire FEHB ERC activity and is reporting this estimate as required by PIIA as reported above.

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  • Office of Personnel Management improper payment estimates over time
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Recovery information

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Overpayment amount identified for recapture
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Recovery of overpayments

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 $321.75 M
Overpayment amount recovered through recovery activities $245.14 M
Recovery activities recovery rate 76.19 %

Why recovery audits are not cost effective in certain programs

PIIA allows agencies to exclude programs with other mechanisms to identify and recapture overpayments. The Retirement Program and the FEHB Program have extensive internal recovery mechanisms and anticipate achieving continued high recovery rates for improper payments. OPM's existing recovery mechanisms provide an efficient and effective means for identifying and recovering payments. OPM's Audit Resolution and Compliance group manages the audit resolution process, which includes recovery of improper overpayments.

OPM does not have a single centralized system for the payment of claims. OPM contracts with carriers who provide health benefits to enrolled FEHB members. OPM’s existing recovery mechanisms provide an efficient and effective means for identifying and recovering payments. Carriers are required to maintain robust internal controls to identify and recover overpayments. Carriers are audited by the Office of the Inspector General, which includes review and recovery of erroneous payments. OPM's Audit Resolution and Compliance group manages the audit resolution process, which includes recovery of improper overpayments.

Intentional monetary loss improper payments are more commonly referred to as financial fraud and are overpayments that occur on purpose. This agency reported $8.26M of confirmed fraud in this reporting cycle.

Supplemental Information

OPM's Retirement Services (RS) uses the Do Not Pay (DNP) Initiative, in conjunction with other methods, monthly to detect, prevent, and reduce improper payments. OPM's RS Fraud Analysts access the DNP portal monthly, pulling nationally reported deaths of annuitants through the following death data sources: Department of State (DOS); Department of War (DOW); American Infosource (AIS) – Probate, American Infosource (AIS) - Obituary; and the full Death Master File (DMF). There were over 50,000 hits/names/payments reviewed in FY 2025. All hits/names/payments were verified by Fraud Analysts through open and closed source investigative tools. In FY 2025, over 16,000 names were confirmed deceased and dropped for death, preventing over $14,800,000.00 in improper annuity payments from being issued. FEHB uses the Do Not Pay (DNP) portal once a year, in February/March, to check new carrier applicants in the FEHB Program. OPM did not identify any incorrect information.

FEHB uses the Do Not Pay (DNP) portal once a year, in February/March, to check new carrier applicants in the FEHB Program. OPM did not identify any incorrect information.

The Working System has reduced/prevented improper payments:

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

OPM was found non-compliant during the most recent PIIA compliance review.

Non-compliant programs:

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Compliant programs:

  • Federal Employees Health Benefits - Community Rated Carriers
  • Federal Employees’ Group Life Insurance (FEGLI)
  • Federal Retirement Services
  • Payroll - Office of Personnel Management
  • Purchase Cards - Office of Personnel Management
  • Vendor Payments - Office of Personnel Management

Actions recommended and planned to achieve compliance

FY 2024 annual compliance audit, OPM OIG found that OPM’s FEHB Program was not in compliance with four of the ten PIIA reporting requirements:
3. Published improper payment and unknown payment estimates for programs susceptible to significant improper payments and unknown payments in the accompanying materials to the annual financial statement.
4. Published corrective action plans for each program for which an estimate above the statutory threshold was published in the accompanying materials to the annual financial statement.
5b. Demonstrated improvements to payment integrity or reached a tolerable improper payment and unknown payment rate.
6. Reported an improper payment and unknown payment estimate of less than 10 percent for each program for which an estimate was published in the accompanying materials to the annual financial statement.

The OIG determination was based upon the FEHB Program not reporting an Improper Payment Estimate in FY 2023. The OIG recommended OPM issue an improper payment estimate for the Federal Employees Health Benefit program that will allow OPM to comply with PIIA reporting requirements in future reporting years.

OPM disagrees with three of the four findings of non-compliance, because requirements 4, 5b and 6 are not required unless an estimate has been published. OPM agrees the FEHB Experience-Rated Activity needs to publish an improper payment and unknown payment estimate to come into compliance with PIIA. To accomplish this, OPM developed a Sampling and Estimation Methodology Plan with active engagement from agency stakeholders and FEHB Experience-Rated Carriers. In FY 2024, OPM issued 2024 FEHBP Financial Reporting and Audit Guide, which provides detailed requirements for the financial reporting for all FEHB Experience-Rated Carriers, including audit requirements and improper payment reporting. OPM has received data from all FEHB Experience-Rated Carriers which estimates the IP amount for each Carrier. OPM has aggregated this data and projected a statistically valid IP estimate for the entire FEHB Experience-Rated Activity. OPM is reporting this IP estimate in this Data Call as required by PIIA.


Official(s) accountable for the progress of the agency coming into compliance

The Chief Financial Officer, the Associate Director for Healthcare and Insurance, as well as Associate Director for Retirement Services are the senior agency officials accountable for the progress of the agency in coming into compliance with PIIA.


Accountability mechanism tied to the success of the official designated in leading the efforts to come Into compliance

The performance agreements of accountable officials at OPM include program integrity efforts. These agreements set specific goals for improving compliance with PIIA. Success in achieving these goals can result in positive performance evaluations. Conversely, failure to meet program integrity targets may lead to negative performance reviews. This approach ensures that officials are incentivized to prioritize payment integrity and compliance across their respective divisions and 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
Federal Employees Health Benefits - Community Rated Carriers 2023 No No
Federal Employees Health Benefits - Experience Rated Carriers 2025 No No
Federal Employees’ Group Life Insurance (FEGLI) 2023 No No
Federal Retirement Services 2025 No Yes
Payroll - Office of Personnel Management 2024 No No
Purchase Cards - Office of Personnel Management 2022 No No
Vendor Payments - Office of Personnel Management 2024 No No