Civilian Pay – Other Defense Organization (ODO)

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Program level Payment Integrity results

Sponsoring agency: Department of War

PROGRAM METRICS

$10,305 M

in FY 2024 outlays, with a

95.4%

payment accuracy rate

PROGRAM METRICS

$11,128 M

in FY 2025 outlays, with a

98.3%

payment accuracy rate

  • Improper payment estimates over time
    View as:

    Chart toggle amounts:
    Proper payments
    Overpayment
    Underpayment
    Technically improper
    Unknown

Payment Integrity results

  • FY 2024 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    10/2022 - 09/2023


    Confidence interval:

    90% to <95%


    Margin of error:

    +/-1.09

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Change Process
    Due to the delays with the system upgrades the DoD Education Activity (DoDEA) has implemented a manual compensating control since March 2024. Management has identified the following concerns with this compensating control: 1) It has become a burden on the DoDEA staff. Specifically, continuing this process would require digitally signing the CAC for over 12,000 documents a year. 2) This manual process carries a large risk of PII data spillage as the information included on the SF1190 and the DD1614, contains PII. 3) It is not cost beneficial nor an acceptable risk for DoDEA to continue with this compensating control.
    FY2024 Q4
    Completed
    Automation
    A DoDEA employee must complete a Standard Form(SF)-1190 in order to apply for authorization and payment for overseas allowances. A DoDEA employee must also complete a DD-1614 in order to apply for Non-TDY Travel. Completion of the SF-1190 and the DD-1614 provides the necessary information to determine the correct amount for all overseas and travel allowances. During the FY23 and FY24 audit, the SF-1190 and DD-1614 were provided and reviewed by DFAS. It was found that the SF-1190 did not have consistent signatures and dates due to system issues. DoDEA is in the process of completing a system modernization of the DoDEA Allowance Processing System (DAPS) which is to be housed on our internal ServiceNow network. With the upgrade, DoDEA will be adding the ability for CAC enabled signatures and dates. Unfortunately, the system upgrades were stalled and compensating controls were put in place.
    The corrective action was not fully completed this reporting period
    Not Completed
    Automation
    During the FY 2023 and FY 2024 Payment Integrity Audits, it was found that DoDEA did not have proper signatures on both the Standard Form (SF) 1190 and the Department of Defense (DD) Form 1614. In the DoDEA Allowance Processing System (DAPS) (SF1190) and the Travel Order Processing System (TOPS)(DD1614), a DoDEA employee must complete an SF1190 to apply for authorization and payment for overseas allowances. The DoDEA employee must also complete an DD-1614 to apply for Non-TDY Travel. Completion of the SF-1190 and the DD-1614 provides the necessary information to determine the correct amount for all overseas and travel allowances. DAPS and TOPS are older systems that do not have the ability to provide Common Access Card (CAC) signatures. However, DAPS and TOPS are DoDEA systems that have official signature cards on file and can only be accessed with appropriate vetted access and a CAC. It is important to note that DoDEA employees are being paid correctly and this is just a supporting documentation control finding. DAPS and TOPS are to be modernized in the coming years and will provide the capability to have CAC signatures on the SF1190 and DD1614.
    FY2026
    Planned
    Change Process
    The Department’s unknown payments within the Civilian Pay Other Defense Organization were primarily a result of the lack of sufficient key supporting documentation (KSD) to substantiate whether payments were proper or improper at the time of post-payment reviews. Specifically, with payments related to the Military Treatment Facilities (MTF) under the Defense Health Agency (DHA), the Department was undergoing a consolidation of components at the DHA and the Civilian Humans Resources Agency (CHRA) level. During the transition, certain individuals (and their roles) were reshuffled and re-purposed. This meant that the responsibility of retaining and subsequently providing supporting documentation, such as those necessary for post-pay review and analysis of improper and unknown payments had fallen to new personnel during FY 2024 who were unfamiliar with the procedure and process of procuring and providing supporting documentation. As a result, the effort involved in accessing the proper points of contact became arduous and the DHA was unable to do so in a timely enough fashion to obtain, review, and ultimately provide KSD to substantiate payments. Examples of the missing KSDs are travel orders, Foreign Allowances Application, Grant and Report (SF-1190), and Standard Form 50 (SF-50) Notification of Personnel Action to validate alimony garnishments, child support garnishments, market pay validation, location information, living quarters allowance (LQA). In FY 2025 DHA-MTF will evaluate and develop new processes to ensure the auditors and/or DFAS reviewers receive the correct key supporting documentation for the samples in a timely manner based off of the deliverable schedule.
    FY2025
    Planned

Overpayments

Based on the total amount of the overpayments, Other Defense Organizations (ODOs) management believes that the underlying reasons for these overpayments are within its control. Management conducted a review of representative overpayments and noted the following: 1) There were errors in the payment amount due to a discrepancy in the annual salary amount. 2) Employees were paid Danger Pay past the time of the Danger Pay end date. 3) Cost of Living Adjustments (COLA) payments were made at incorrect rates. 4) The Retention Incentive was paid after the end date. In response to the errors noted about the Department corrected the employee’s Standard Form 50 (SF-50) Notification of Personnel Action for the proper payment amount. A review of existing controls within the ODOs is being done to reduce instances of these overpayments. By implementing stronger internal controls these overpayments should be significantly reduced.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $1.33 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $1.33 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.0 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Within Agency Control Address/Location $1.33 M

Overpayment type Mitigation strategies taken Mitigation strategies planned
Overpayments within the agency’s control Automation, Change Process Automation, Change Process

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0.88 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.88 M

Eligibility element/information needed Eligibility amount
Address/Location $0.88 M

Mitigation strategies taken Mitigation strategies planned
Automation, Change Process Automation, Change Process

Technically improper payments

The Department reviewed instances of Technically Improper payments and noted the following causes: 1) The Foreign Allowances Application, Grant and Report (SF-1190) showing Posting Allowance does not have an approving signature. 2) The Request/Authorization for DoD Civilian Permanent Duty or Temporary Change of Station (TCS) Travel DD1614 had an image of an approving signature, not a legal wet or DoD digital signature. 3) There were Orders received from 2008 where the signature is an image and not a legal signature. 4) No Key Supporting Documents (KSDs) were provided to validate Living Quarters Allowances (LQA), the SF-1190, travel orders or other documentation was not provided. 5) The printed name and signature image do not match. Technical Improper payments for the ODO Civ Pay components are projected to total $145.99 Million. These Improper payments are defined in the OMB A-123 Appendix C. and represent a failure to meet the requirements of a proper payment.
The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $145.99 M

Mitigation strategies taken Mitigation strategies planned
Automation, Change Process Automation, Change Process

Additional information

$146.87 M

Unknown Payment Details

The Department’s unknown payments were primarily a result of the lack of sufficient key supporting documentation (KSD) to substantiate whether payments were proper or improper at the time of post-payment reviews. Specifically, with payments related to the Military Treatment Facilities (MTF) under the Defense Health Agency (DHA), the Department was undergoing a consolidation of components at the DHA and the Civilian Human Resources Agency (CHRA) level. During the transition, certain individuals (and their roles) were reshuffled and re-purposed. This meant that the responsibility of retaining and subsequently providing supporting documentation, such as those necessary for post-pay review and analysis of improper and unknown payments had fallen to new personnel during FY 2024. As a result, the effort involved in accessing the proper points of contact became arduous and the DHA was unable to do so in a timely enough fashion to obtain, review, and ultimately provide KSD's to substantiate payments. Examples of the missing KSDs are travel orders, Foreign Allowances Application, Grant and Report (SF-1190), and Standard Form 50 (SF-50) Notification of Personnel Action to validate market pay validation, location information and living quarters allowance (LQA).

The amount of payments that could either be proper or improper but the agency is unable to determine whether they were proper or improper as a result of insufficient or lack of documentation is $322.48 M


Cause of insufficient or lack of documentation & why the documentation is needed for determination of payment type
Payment cause Amount Description of the documentation that was not provided and explanation of why the program is unable to conclude whether the payment is proper or improper without that documentation
Applicants $322.48 M The key supporting documentation for some samples that was not provided includes the following: market pay validation, Foreign Allowances Application, Grant and Report (SF-1190), Standard Form 50 (SF-50) Notification of Personnel Action. As mentioned above, the vendor responsible for providing the documentation is CHRA. CHRA went through a consolidation period in which points of contact (POCs) and their roles were reshuffled. The time of submission of the missing key supporting documentation identified above varies depending on the life event. This CIV Pay Other Defense Organization program is unable to conclude that the payment made was properly supported without the proper key supporting documentation. Depending on the life event, the proper supporting documentation will prove out the eligibility criteria that needs to be validated. A proper court document for example would determine whether an alimony garnishment or child support payment for example are either proper or improper. Additionally, a main point of issue involved overseas entitlements. Historically, for the audit, CHRA made contact with the Overseas Entitlement office for key supporting documentation related to overseas employees. However, during this audit year, CHRA informed the DHA that they were unable to provide the documentation on time (likely due to the reshuffling of personnel).

Mitigation strategies taken Mitigation strategies planned
Automation,Change Process Automation,Change Process

Evaluation of corrective actions

In regard to unknown payments above the statutory threshold of $100M under the Military Treatment Facilities (MTF) under the Defense Health Agency (DHA), the Department underwent a consolidation of components at the DHA and the Civilian Humans Resources Agency (CHRA) level. During the transition, certain individuals (and their roles) were reshuffled and re-purposed. Due to a lack of training, the new personnel responsible for providing supporting documentation, such as those necessary for post-pay review and analysis of improper and unknown payments in FY 2024 were not sufficiently prepared to do so in a timely manner.

DoDEA has a PIIA CAP written to address a lack of adequate key supporting documentation. This corrective action is in process. DoDEA is in the process of completing a system modernization of the DoDEA Allowance Processing System (DAPS) which is to be housed on its internal ServiceNow network. With the upgrade, DoDEA will be adding the ability for CAC enabled signatures and dates. The completion of the system modernization will correct the improper payments that were due to technical reasons.

The Department fully expects the DoDEA system modernization will solve
their main cause for technically improper payments due to lack of the proper signature. With the system upgrade, DoDEA will be adding the ability for CAC enabled signatures and dates. Furthermore, the Department is confident that the Defense Health Agency Military Treatment Facilities will continue to reduce improper payments by fully implementing their new processes to ensure the auditors and/or DFAS reviewers receive the correct key supporting documentation for the samples in a timely manner based off of the deliverable schedule.

The Corrective Action Plan (CAP) is a combination of both mitigation strategies and corrective actions aimed at reducing the likelihood of Technically Improper or Unknown Payment errors occurring during the payment process. A CAP was developed to address the root cause of the Department’s unknown payments under the Civilian Pay – Other Defense Organizations program. The CAP will address unknown payments by developing training materials outlining the steps to be taken related to pulling key documents. The goal is to disseminate a standard and repeatable process and to establish a set of guidelines that will ensure that supporting material is readily available to substantiate payments during post-payment reviews.

In the DoDEA Allowance Processing System (DAPS) (SF1190) and the Travel Order Processing System (TOPS)(DD1614), a DoDEA employee must complete an SF1190 to apply for authorization and payment for overseas allowances. The DoDEA employee must also complete an DD-1614 to apply for Non-TDY Travel. DAPS and TOPS are to be modernized in the coming years and will provide the capability to have CAC signatures on the SF1190 and DD1614.

Each Corrective Action Plan (CAP) is dual signed by the Department Component responsible for the corrective actions and consolidated at the Department-level by both the Senior Executive responsible for the Component and the Department Payment Integrity Program Manager for accountability. Each milestone within the CAP are monitored and issued out from the Department to the DoD Components as deliverable requirements based off of the timelines established on the CAP. Furthermore, the Department Payment Integrity Portfolio Manager reviews the submission to ensure the documented progress will reduce Department improper payments effectively.

Future payment integrity outlook

Civilian Pay – Other Defense Organization (ODO) has established a baseline.

The Department’s Payment Integrity program - Other Defense Organization Civilian Pay’s reduction target is less than the estimated future Improper Payment and Unknown Payment rate. The Department is fully confident in the two ODO Civilian Pay corrective action plans. These CAPs will be effectively implemented by DoDEA and DHA-MTF and will be fully effective at considerably reducing the improper and unknown payment rates below the OMB statutory threshold in FY 2024.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $10,407.94 M
Current year +1 estimated future improper payments $118.56 M
Current year +1 estimated future unknown payments $161.24 M
Current year +1 estimated future improper payment and unknown payment rate 2.69 %
Current year +1 estimated future improper payment and unknown payment reduction target 2.6 %

The program's current year improper payment and unknown payment rate of 4.57 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

Internal Controls:
The Department has internal controls in place that support the reduction of improper payments in the Civilian Pay program to the levels the Department has targeted. Moreover, Federal Civilian Pay Services, which support the end-to-end delivery of payroll processing services received an unmodified (FY) 2024 SSAE No. 18 examination, which received a SOC 1 Type 2 report.

Human Capital:
The Department has the human capital it needs to reduce improper payments in the Civilian Pay program to the levels the Department has targeted.

Information Systems and Other Infrastructure:
Aside from the planned DoDEA system modernization which is critical to the reduction of technically improper payments as previously explained as part of the planned corrective actions. The Department has the information systems and other infrastructure it needs to reduce improper payments in the Other Defense Organization Civilian Pay program systems to the levels the Department has targeted.

The Department of Defense Education Activity (DoDEA) has requested resources during the most recent budget submission to provide a system modernization to DoDEA Allowance Processing System (DAPS). The modernization will allow the system to become audit compliant with information technology regulations as well as audit policies and procedures related to the review and approval of SF1190s.
DoDEA has multiple audits each year and a Resource Management (RM) Financial Analysis Branch (FAB) and Strategic and Excellence (SOE) Risk Management Internal Control (RMIC) Program which reviews internal controls to ensure DoDEA's compliance with laws, regulations, policies, and procedures.

Additional programmatic information

Accountability for detecting, preventing, and recovering improper payments

Within the Defense Finance and Accounting Service (DFAS), Civilian Pay operations are responsible for tracking OMB metrics, proper payment count and dollars. Metrics are tracked monthly and updates are provided to the Director of DFAS at least three times per year. A green rating for this metric is greater than or equal to 99.6%, yellow is less than 99.6% and greater than or equal to 99.0% and red is less than 99.0%. Management must provide narratives and/or Corrective Action Plans for Red and Yellow ratings. At the operational level, entitlement technicians are held accountable through appraisal standards which limit them to no more than 5 errors per quarter, certifying official appraisal standards hold them to no more than 1% of payments certified during the rating period identified as improper. In addition, certifying officials have pecuniary liability for loss of funds unless relieved. Managers have overall responsibility to ensure metric targets are met and maintained.

The Defense Payment Integrity Senior Accountable Officials Steering Committee (the Committee) was created in FY 2018 and it institutionalized a forum of accountability to oversee and guide the Department’s actions required by Appendix C of the OMB Circular Number A-123 to achieve full compliance with the Payment Integrity Information Act of 2019 (PIIA). The Committee is chaired by the Office of the Under Secretary of Defense (Comptroller)/Deputy Chief Financial Officer and co-chaired by the Defense Finance and Accounting Service, Deputy Director of Operations. It also includes Senior Executive Service representatives from the Military Services and defense agencies. The Committee provides oversight to the DoD Payment Integrity program and drives action for compliance with the PIIA. More specifically, the Committee evaluates the status of improper payments testing, the root causes of improper payments and appropriate actions to reduce them, payment recovery activities, and solutions to resolve DoD-wide audit findings and recommendations related to improper payments. Additionally, it supports Payment Integrity risk assessments, audits related to improper payments, reviews audit recommendations, and oversees the identification of root cause(s) and the development and implementation of corrective actions to address areas of noncompliance.

  • FY 2025 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    10/2023 - 09/2024


    Confidence interval:

    90% to <95%


    Margin of error:

    +/-0.63

Causes

The Department of Defense Education Activity (DoDEA) identified technically improper payments stemming from limitations within its legacy systems, the DoDEA Allowance Processing System (DAPS) and the Travel Order Processing System (TOPS). These systems lack the functionality to support electronic Common Access Card (CAC) signatures on key documents, specifically the Standard Form 1190 (SF1190) used for overseas allowances and the Department of Defense Form 1614 (DD-1614) used for non-temporary duty travel. The absence of legally authorizing signatures on these forms, while not indicating improper compensation, technically violates regulatory requirements and contributes to the classification of these payments as technically improper.

The root cause of these improper payments lies in the outdated nature of DAPS and TOPS. These systems were not designed to accommodate modern electronic signature technology, leading to inconsistent signature and date capture on the SF-1190 forms.

DoDEA is working to modernize DAPS and TOPS, housing them within the ServiceNow environment and adding CAC-enabled signature capabilities. However, delays have been encountered due to challenges in onboarding to the Defense Information Systems Agency (DISA) Identity, Credential, and Access Management (ICAM) solution, as DoDEA operates on a .edu environment. This modernization effort is crucial for long-term resolution. Interim solutions involving supporting documentation procedures are being explored to further support Payment Integrity reviews while DAPS and TOPS upgrades are being implemented.

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $2.69 M
Amount of overpayments outside the agency's control $0.0 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
Amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
Amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $2.69 M

Underpayment root cause Underpayment amount
Amount of underpayments $0.0 M

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $160.84 M

The amount that could either be proper or improper but the agency is unable to determine whether it was proper or improper as a result of insufficient or lack of documentation $28.91 M

Prevention

The Department of Defense Education Activity (DoDEA) has implemented and is planning several corrective actions to address technically improper payments stemming from limitations in its legacy systems, the DoDEA Allowance Processing System (DAPS) and the Travel Order Processing System (TOPS). These systems currently lack the functionality to support electronic Common Access Card (CAC) signatures on key documents like the Standard Form 1190 (SF1190) for overseas allowances and the Department of Defense Form 1614 (DD-1614) for non-temporary duty travel. These technically improper payments, exceeding $100 million in FY 2024 and FY 2025, prompted the creation of a Corrective Action Plan (CAP) mandated by the Payment Integrity Information Act (PIIA) of 2019 and OMB Circular A-123, Appendix C.

Initially, DoDEA implemented a compensating control, effective from March 2024, requiring the digital signing of SF1190s and DD-1614s outside of DAPS and TOPS, followed by uploading the signed forms into the systems. The target completion date of this milestone was 3/31/2024. However, this manual workaround proved to be unsustainable. DoDEA staff processes approximately 12,000 to 15,000 SF1190s and DD-1614s annually, making the manual process a significant burden and increasing the risk of Personally Identifiable Information (PII) data spills. Due to these concerns and a lack of cost-benefit, the compensating control was deemed unacceptable. Consequently, the internal quarterly audits planned for Q3 and Q4 of FY24, and Q1-Q4 of FY25 to check the effectiveness of the compensating control, were no longer relevant.

The primary long-term corrective action is the modernization of DAPS and TOPS. These systems will be integrated into DoDEA's ServiceNow environment, adding CAC-enabled signature capabilities. However, this modernization has faced delays due to challenges in onboarding to the Defense Information Systems Agency (DISA) Identity, Credential, and Access Management (ICAM) solution, as DoDEA operates on a .edu environment.

In the interim, the Department is investigating potential solutions for substantiating documentation related to technically improper payments caused by incorrect digitally signed forms. The goal is to draft procedures and specific guidance outlining additional supporting documentation to support Payment Integrity reviews while DAPS and TOPS are being upgraded. To ensure the effectiveness of the system upgrades, internal audits are planned for Q2 and Q3 of FY2026. Based on these reviews, milestones and corrective actions may be adjusted as needed.


The Department of Defense Education Activity (DoDEA) is addressing technically improper payments, exceeding $100 million in FY24, stemming from limitations in its legacy systems DAPS and TOPS, which lack the capability for electronic CAC signatures on key forms like SF1190s and DD-1614s. In response to this significant improper payment amount, a Corrective Action Plan (CAP) was developed, aligning with the Payment Integrity Information Act (PIIA) of 2019 and OMB Circular A-123, Appendix C.

Initially, a compensating control was implemented requiring manual digital signing and uploading of forms, but this proved unsustainable due to the burden on staff, PII spillage risk, and lack of cost-benefit. The core of the CAP involves modernizing DAPS and TOPS by integrating them into DoDEA's ServiceNow environment and adding CAC-enabled signature capabilities. While this modernization is delayed due to ICAM onboarding challenges, the Department is actively working to find solutions.

Additionally, the Department is collaborating to develop interim solutions for substantiating documentation related to technically improper payments, with procedures and guidance. These planned actions, including system modernization and interim documentation procedures, directly address the root cause of missing signatures and aim to prevent future improper payments, proportional to the substantial financial impact and regulatory non-compliance identified. Furthermore, internal audits are scheduled to assess the effectiveness of the system upgrades, demonstrating a commitment to ongoing monitoring and improvement.

The Department's corrective actions are implemented and prioritized based on the severity of the improper payments and the feasibility of the corrective measures. The primary focus is to address the root cause: the lack of electronic CAC signature functionality in the legacy DAPS and TOPS systems. The Corrective Action Plan (CAP) acknowledges that payments lacking proper signatures on SF1190s and DD-1614s are technically improper and contributed to the Civilian Pay – Other Defense Organizations (ODO) program exceeding the statutory threshold for improper payments in FY2025. This led to the initial implementation of a compensating control requiring manual digital signing and uploading of forms. However, recognizing the unsustainability of this approach due to staff burden, PII risks, and cost-ineffectiveness, DoDEA prioritized a long-term solution: modernizing DAPS and TOPS to integrate with ServiceNow and enable CAC signatures. This demonstrates a commitment to addressing the fundamental system deficiency rather than relying on temporary fixes.

The corrective actions are deemed adequate because they directly target the absence of legally authorizing signatures, the identified deficiency during Payment Integrity reviews. The system modernization aims to eliminate the manual workaround and ensure all required forms have proper electronic signatures. While the modernization faces delays due to ICAM onboarding issues, the Department is actively seeking solutions for substantiating documentation to support Payment Integrity reviews, ensuring a multi-pronged approach. The planned internal audits following the system upgrades demonstrate a commitment to verifying the effectiveness of the corrective actions and making necessary adjustments.

The effectiveness of these actions in reducing improper payments is not yet fully realized, as the core system modernization is still underway. The ineffectiveness of the compensating control made a process like internal audits and the check on the corrective action’s effectiveness obsolete. However, the Department anticipates a significant reduction in technically improper payments once the modernized DAPS and TOPS are fully operational. The interim solutions for supporting documentation will also contribute to reducing improper payments during the modernization period. The ongoing collaboration and the planned internal audits demonstrate a commitment to continuously monitoring and improving the effectiveness of these actions in minimizing improper payments and ensuring compliance with the PIIA and OMB Circular A-123, Appendix C.

Payment type Mitigation strategies taken Mitigation strategies planned
Overpayments Change Process Change Process
Technically improper payments Change Process Change Process
Unknown payments Change Process Change Process

Eligibility element/information needed Description of the eligbility element/information
Address/location Information regarding where the applicant/recipient lived, owned property, or was physically present in a specific location

Additional information

Reduction target

1.62 %

The Department of War (DoW) asserts that the Civilian Pay – ODO program possesses the requisite internal controls and human capital necessary to effectively mitigate improper and unknown payments to a level where further reduction expenditures would exceed the value of prevented or recovered improper payments. However, the Department currently lacks the necessary information system infrastructure to achieve this goal. The legacy DAPS and TOPS systems lack the functionality to support electronic Common Access Card (CAC) signatures, resulting in technically improper payments due to missing legally authorizing signatures. The DoW is actively working to resolve this deficiency through the modernization of DAPS and TOPS, integrating them into DoDEA's ServiceNow environment and adding CAC-enabled signature capabilities. Until these system modernizations are fully implemented, the Department will not be able to prevent the related technically improper payments.

Based on current information available to the Office of the Under Secretary of War (Comptroller) Payment Integrity Team, the Department did not include specific budget submissions explicitly dedicated to payment integrity enhancements in the most recent budget cycle. The Department acknowledges that ongoing system upgrades and maintenance across various financial management systems contribute indirectly to improving payment accuracy and reducing improper payments. The Department's budget strategy emphasizes leveraging existing resources and planned system enhancements to strengthen internal controls and improve data quality related to payments. Future budget submissions will continue to prioritize enhancements that promote payment integrity, incorporating lessons learned and evolving best practices.

Pursuant to the January 20, 2025, Presidential Memorandum entitled “Restoring Accountability for Career Senior Executives” and consistent with the President’s direction U.S. Office of Personnel Management (OPM) established new Senior Executive Service (SES) performance plans that all agencies must adopt beginning with the FY 2026 performance cycle. The “Faithful Administration of the Law and the President’s Policies” critical performance element has the highest weighted rating. Part of implementing these new directives that DoW mandates additional performance requirements specific to Financial Improvement and Audit Remediation (FIAR) standards.

SES members within the Secretary of War with ownership of the financial statement audit priorities will include specific performance requirements aligned to one or more of the annual audit priorities in their Achieving Organizational Goals critical elements. These requirements articulate specific, measurable, attainable, relevant and time-based performance measures that will support each organizational performance goal. As an example “Supports the annual financial statement audit by accelerating the path to an unmodified audit opinion.” SES members with a direct role must comply with the policies and regulations, implement internal control procedures, document transactions, submit auditor-requested materials timely, remediate high risk/priority material weaknesses, develop/update audit roadmaps and drive remediation strategy and plans targeted at achieving an unmodified opinion. They further direct continuous process and internal control improvements, identifies root cause(s) of issues and sustains up-to-date system internal controls. Additionally, SES members are accountable for driving government efficiencies within their organization to streamline proficiencies, quality work and cost-effective use of government resources. SES members with an indirect role must implement timely, effective and measurable corrective actions plans and maintain key supporting documentation to substantiate financial transactions to ensure their workforce is properly trained on their business effectiveness and are held accountable. All of which either directly and/or indirectly equips the DoW with the inherent ability and organizational leadership structure to achieve compliance with the Payment Integrity Information Act.

Furthermore, to provide high-level strategic direction and oversight, the Department of War Payment Integrity Senior Accountable Officials Steering Committee (the Committee) was established in FY 2018. This Committee, institutionalizes a forum of accountability designed to oversee and guide the Department’s actions required by Appendix C of OMB Circular A-123, aiming for full compliance with the PIIA. The Committee is chaired by the Office of the Under Secretary of War (Comptroller)/Deputy Chief Financial Officer and co-chaired by the Defense Finance and Accounting Service, Deputy Director of Operations and has SES representatives from the Military Services and War Agencies. The Committee evaluates the status of improper payment testing, analyzes the root causes of improper payments, oversees payment recovery activities, and drives the resolution of DoW-wide audit findings and recommendations related to improper payments. In addition, the Committee supports related audits, reviews audit recommendations, oversees risk assessments and supervises the identification of root causes and the development/implementation of corrective actions to address areas of non-compliance.

$160.84 M