Payment Integrity
Improper Payments The Improper Payments Information Act of 2002, as amended by the Improper Payments Elimination and Recovery Act of 2010 and the Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERIA), contains multiple requirements to reduce improper and erroneous payments made by the federal government. In addition, the Office of Management and Budget (OMB) Circular A-123, Appendix C, Requirements for Payment Integrity Improvement, also provides improper payment reporting guidance. As a legislative branch agency, the AOC is not subject to IPERIA, nor to the related OMB guidance. As a result, the AOC does not have a formal improper payments program and, therefore, the AOC does not provide payment accuracy data to the OMB for display on its website. Nonetheless, as part of its internal control program and assessment of risk, an internal control plan is in place to monitor payment accuracy. As part of this effort, the AOC refers to IPERIA and OMB Circular A-123, Appendix C for guidance. This monitoring is discussed in further detail in the Management’s Discussion and Analysis under Management Assurances and Other Financial Compliances.
By agency policy, the AOC conducts quarterly financial reviews of its jurisdiction-level program obligations and spending, including sensitive payment areas. Establishing an internal, quarterly financial monitoring and verification policy has improved the reliability of the information used in the AOC’s financial statements and budget execution reports. As part of this policy, the AOC issues a suite of quarterly reports for verification by the parties delegated with the authority for each AOC appropriation. The responsible parties must concur (either without exception or with noted exceptions) that all post-payment transactions charged to AOC funds are valid and properly recorded. These financial reports include: status of current funds, document detail for all requisitions and obligations, payroll detail, travel and training detail, and open obligations and receivers for all expired funds. The Chief Financial Officer manages the reviews and uses them to identify inaccurate payments and determine the effectiveness of controls over the obligation and payment process.
Sensitive payments are those where the dollar amounts involved are usually not significant but, if the payment were improper, the public disclosure may result in significant agency criticism. The AOC has identified purchase card expenditures, as well as travel and training transactions as areas of sensitive payments for routine review.
The AOC does not administer grant, benefit or loan programs. The AOC’s most significant expenses are payroll and benefits for its employees, which are administered by the U.S.
146 Section IV • Other Information
Department of Agriculture’s shared service provider, the National Finance Center. The AOC’s most substantial nonpayroll expenses are its payments to vendors for construction efforts, professional services and goods procured during the course of normal operations.
Do Not Pay Initiative
The U.S. Department of the Treasury’s Do Not Pay Initiative provides resources for agencies to review payment eligibility for purposes of identifying and preventing improper payments to vendors, thereby helping agencies comply with IPERIA. The AOC uses Treasury’s Invoice Processing Platform (IPP), a secure online platform, for centralizing its invoice payment process. The IPP partners with Treasury’s Do Not Pay business center to help prevent and reduce improper payments in a cost-effective manner for the federal agencies using this system. As such, through its IPP deployment, the AOC improves its payment accuracy with the Do Not Pay Initiative.
Fraud Reduction and Data Analytics Act
The Fraud Reduction and Data Analytics Act of 2015 was implemented to identify and assess fraud risks and design and implement control activities to prevent, detect and respond to fraud. As a legislative branch agency, the AOC is statutorily excluded from the Fraud Reduction and Data Analytics Act of 2015 and has not formally incorporated this law into its policy.
Reduce the Footprint
The Office of Management and Budget (OMB) provides guidance to CFO Act agencies to use federal real property as efficiently as possible. The intention is to have agencies set annual targets to reduce the total square footage of their domestic office and warehouse inventory space compared to a FY 2015 baseline. The Reduce the Footprint policy is intended to promote efficient spending to support agency operations.
As a legislative branch agency, the AOC is not subject to the Reduce the Footprint policy. However, because the AOC’s mission encompasses responsibility for a unique real estate portfolio, efficiency in management of its real estate is important to the agency. As a best practice and in the interest of transparency, the AOC presents its total managed square footage for the current fiscal year as compared to the FY 2015 baseline. The total square footage reported includes all real property under the AOC’s care. In addition to assigned and leased office and inventory storage facilities, the agency’s square footage includes a variety of other real property that is unique to the AOC and reflects its wide-ranging mission such as: congressional committee rooms, legislative chambers, a court chamber, exhibition space, a botanic conservatory, plant production facilities, a visitor center, gift shops, restaurants,
ARCHITECT OF THE CAPITOL
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