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Tuesday, October 18, 2016

Expand the audits!

You know I hate audits, but today I'm going to call for more audits.  Or at least broader audits.  Hear me out, and I think you'll agree.

It all goes back to the Improper Payments Information Act, which is the source of the random audits.  The purpose of the act is to identify improper payments with an eye towards reducing improper payments.  What is an "improper payment"?
The term ‘‘improper payment’’—
(A) means any payment that should not have been made or that was made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements....
The current IPIA audits certainly identify overpayments, but I'm not aware of any checks on underpayments.  I'd like to see some audits of invoices that have been "passed zero" or reduced, to make sure that no underpayment took place.

And while we're at it, let's have some audits of FRNs denied or reduced by PIA.  Because the IPIA says:
The term ‘‘payment’’ means any payment (including a commitment for future payment...).
I'm not a lawyer, but that looks to me like a Funding Commitment Decision Letter is a payment.  (Isn't that why the FCDL triggers the ADA?)

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