Department of Health and Human Services Met Many Requirements, but It Did Not Fully Comply With the Payment Integrity Information Act of 2019 for Fiscal Year 2025 OAS-26-17-042

Executive Summary

The Payment Integrity Information Act of 2019 (Public Law 116-117) (PIIA) was enacted on March 2, 2020, and requires the Offices of Inspector General (OIG) to review and report on agencies' annual improper payment information to determine compliance with PIIA.

The U.S. Department of Health and Human Services' (HHS) OIG engaged us to assist in its evaluation of the accuracy and completeness of HHS's improper payment reporting to determine if HHS is in compliance with PIIA and the applicable improper payment guidance.

We conducted a performance audit to determine whether HHS complied with the PIIA improper payment reporting requirements. We conducted our performance audit to determine whether HHS complied with PIIA based on the improper payment reporting requirements established by Office of Management and Budget (OMB) Circular A-123, Appendix C (M-21-19, March 2021); OMB Circular A-136 (July 2025); the OMB FY 2025 Payment Integrity Annual Data Call Instructions; and OMB Payment Integrity Question and Answer Platform.

The audit was conducted in accordance with Government Auditing Standards and the Council of the Inspectors General on Integrity and Efficiency (CIGIE) Guidance for Payment Integrity Information Act OIG Compliance Reviews (November 2025) required under PIIA.

As part of our performance audit, we evaluated compliance with PIIA for the following programs that were deemed susceptible to significant improper payments: Medicare Fee-for-Service (FFS), Medicare Advantage (Part C), Medicare Prescription Drug Benefit (Part D), Medicaid, Children's Health Insurance Program (CHIP), Advance Premium Tax Credit (APTC), Temporary Assistance for Needy Families (TANF), Foster Care, Child Care and Development Fund (CCDF), and Head Start. Of these programs, Medicare FFS, Medicare Part C, Medicare Part D, Medicaid, CHIP, APTC and CCDF were OMB-designated high-priority programs in 2025. As part of our procedures, we evaluated the improper payment sampling and estimation methodology for CCDF and Medicare FFS programs.

Additionally, we determined that internal control within the context of the performance audit objective is significant. Accordingly, we obtained an understanding of management's processes, evaluated the control environment, and determined whether HHS maintained adequate internal controls over the improper payment process.