GAO Subaward Oversight Recommendations — Model Performance Plan
Translate the 32 agency recommendations and two matters for congressional consideration listed in Appendix III of GAO-27-108450 into a model performance plan for improving subaward oversight, fraud risk management, audit follow-up, and data quality.
Other Information
Source: Appendix III, Table 2, GAO-27-108450, published November 10, 2026. The source lists selected prior open recommendations from 11 reports issued between May 5, 2021, and June 16, 2026. GAO-27-108450 makes no new recommendations. This model does not represent a plan adopted by GAO or the affected agencies.
The 11 goals group entries by originating report, in Table 2 order. Each objective corresponds to exactly one source recommendation or matter for consideration. Original recommendation wording, report number, publication date, source recommendation number, and the affected agency are retained under each objective. Substantive qualifications in the original wording govern the associated targets.
Goal descriptions, short names, stakeholder-role statements, measurement dimensions, status descriptors, evidence suggestions, and decomposed target formulations are editorial interpretations of intended results. They introduce no new GAO recommendations. Qualitative criteria separate distinct assessable components of multipart recommendations.
The source lists these items as open on November 10, 2026. That is recommendation status, not evidence that no work had been performed. No actual implementation results, completion claims, baselines, budgets, calendar targets, or implementation deadlines are invented. No ActualResult is asserted. Originating report dates and audit-year references are context, not target dates; the 2023 and 2024 references in the single-audit recommendations are retained as stated.
The two matters for congressional consideration are modeled with targets of documented consideration. They do not assume Congress will enact the suggested authority. Their full proposed legislative scope is preserved in the objective and target descriptions.
The logical Organization and inferred Mission describe the scope and purpose of this model. Affected agencies and Congress are performers for their respective entries; partner responsibilities are limited to what the recommendation names. GAO is the recommendation author, not the performer charged with implementing another entity’s recommendation.
Prepared November 12, 2026. PublicationDate is the preparation date of this rendition for publication at https://stratml.us/docs/GAO-SOR.xml .
Companion regulatory model: https://stratml.us/docs/CFR2-SO.xml .
Source report: https://files.gao.gov/reports/GAO-27-108450/index.html
Submitter's Note: This StratML rendition has been compiled by ChatGPT at my request.
🏢Federal Subaward Oversight Improvement The logical multi-entity effort to address the selected GAO recommendations and consider the listed legislative matters; this is not a separately constituted organization or an adopted government-wide plan.
Stakeholders:
🏢 🏢 🏢 🏢 🏢 🏢 🏢 🏢 🏢 🏢 👥 | Source & SubmitterSource:https://files.gao.gov/reports/GAO-27-108450/index.html Period: to Published: |
Mission
To improve federal subaward oversight and safeguard program funds through implementation of selected GAO recommendations and consideration of related legislative opportunities.
Goal 1: CDBG-DR Fraud Risks 🔗
Improve assessment of CDBG-DR fraud risks through comprehensive analysis and stakeholder involvement.
Other Information
Originating report: GAO-21-177; published May 5, 2021; https://www.gao.gov/products/gao-21-177 . This grouping is editorial and preserves Table 2 order.
Objective 1.1: Fraud Risks 🔗
Assess comprehensively fraud risks to the Community Development Block Grant – Disaster Recovery (CDBG-DR) program, including identifying inherent fraud risks affecting it, assessing the likelihood and impact of inherent fraud risks, determining fraud risk tolerance, and examining the suitability of existing fraud controls. The assessment should also consider CDBG-DR’s risk environment and be informed by the fraud risks identified in this report.
Stakeholders:
🏢Department of Housing and Urban Development : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-21-177, published May 5, 2021; Recommendation 1; https://www.gao.gov/products/gao-21-177 .Appendix III Table 2 entry 1 in GAO-27-108450. Corresponding source rendition Objective 6.1.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Assistant Secretary for Community Planning and Development should comprehensively assess fraud risks to the Community Development Block Grant – Disaster Recovery (CDBG-DR) program, including identifying inherent fraud risks affecting it, assessing the likelihood and impact of inherent fraud risks, determining fraud risk tolerance, and examining the suitability of existing fraud controls. The assessment should also consider CDBG-DR’s risk environment and be informed by the fraud risks identified in this report. (Recommendation 1)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
1.1.1: Assessment
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Assessed | Assess inherent CDBG-DR fraud risks, their likelihood and impact, risk tolerance, and suitability of existing controls, considering the risk environment and risks identified in GAO-21-177. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 1.2: Stakeholders 🔗
Involve relevant stakeholders in the assessment process, including CDBG-DR grantees (states, territories, and local governments) that design and implement fraud controls.
Stakeholders:
🏢Department of Housing and Urban Development : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
👥CDBG-DR grantees : Participate in the fraud risk assessment, including states, territories, and local governments.Performer : Participate in the fraud risk assessment, including states, territories, and local governments. (Performer)
Other Information
Source: GAO-21-177, published May 5, 2021; Recommendation 2; https://www.gao.gov/products/gao-21-177 .Appendix III Table 2 entry 2 in GAO-27-108450. Corresponding source rendition Objective 6.2.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: In comprehensively assessing fraud risks to CDBG-DR, the Assistant Secretary for Community Planning and Development should involve relevant stakeholders in the assessment process, including CDBG-DR grantees (states, territories, and local governments) that design and implement fraud controls. (Recommendation 2)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
1.2.1: Participation
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Involved | Involve relevant stakeholders, including state, territorial, and local CDBG-DR grantees that design and implement fraud controls, in the assessment process. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Goal 2: Contractor Risks 🔗
Improve identification and management of contractor risks in CDBG-DR through guidance, data, monitoring, and training.
Other Information
Originating report: GAO-23-104382; published August 17, 2023; https://www.gao.gov/products/gao-23-104382 . This grouping is editorial and preserves Table 2 order.
Objective 2.1: Data 🔗
Develop guidance for CDBG-DR grantees and subrecipients on collecting complete and consistent data to better support applicant eligibility determinations and fraud risk management.
Stakeholders:
🏢Department of Housing and Urban Development : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-23-104382, published August 17, 2023; Recommendation 1; https://www.gao.gov/products/gao-23-104382 .Appendix III Table 2 entry 3 in GAO-27-108450. Corresponding source rendition Objective 6.3.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Assistant Secretary for Community Planning and Development should develop guidance for CDBG-DR grantees and subrecipients on collecting complete and consistent data to better support applicant eligibility determinations and fraud risk management. (Recommendation 1)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
2.1.1: Guidance
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop guidance for collecting complete and consistent data supporting applicant eligibility determinations and fraud risk management. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 2.2: Contracts 🔗
Update the Monitoring Handbook for CDBG-DR monitoring activities to provide additional guidance in the selection of contracts for review. This should include factors such as contractors that present increased risk to the CDBG-DR environment, including those where allegations of fraud, waste, or abuse have been made.
Stakeholders:
🏢Department of Housing and Urban Development : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-23-104382, published August 17, 2023; Recommendation 2; https://www.gao.gov/products/gao-23-104382 .Appendix III Table 2 entry 4 in GAO-27-108450. Corresponding source rendition Objective 6.4.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Assistant Secretary for Community Planning and Development should update the Monitoring Handbook for CDBG-DR monitoring activities to provide additional guidance in the selection of contracts for review. This should include factors such as contractors that present increased risk to the CDBG-DR environment, including those where allegations of fraud, waste, or abuse have been made. (Recommendation 2)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
2.2.1: Handbook
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Updated | Update the Monitoring Handbook with contract-selection guidance, including factors identifying increased risk and allegations of fraud, waste, or abuse. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 2.3: Risk Analyses 🔗
Identify ways to collect and combine contractor and subcontractor data across grantees and subrecipients to facilitate risk analyses, such as by expanding the Disaster Recovery Data Portal, Disaster Recovery Grant Reporting System, or other appropriate systems.
Stakeholders:
🏢Department of Housing and Urban Development : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-23-104382, published August 17, 2023; Recommendation 3; https://www.gao.gov/products/gao-23-104382 .Appendix III Table 2 entry 5 in GAO-27-108450. Corresponding source rendition Objective 6.5.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Assistant Secretary for Community Planning and Development should identify ways to collect and combine contractor and subcontractor data across grantees and subrecipients to facilitate risk analyses, such as by expanding the Disaster Recovery Data Portal, Disaster Recovery Grant Reporting System, or other appropriate systems. (Recommendation 3)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
2.3.1: Data Integration
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Identified | Identify ways to collect and combine contractor and subcontractor data across grantees and subrecipients for risk analyses, using suitable existing or expanded systems. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 2.4: Contractor Data 🔗
Develop and implement guidance for CDBG-DR grantees and subrecipients to collect contractor and subcontractor data to facilitate identification of contractor and cross-cutting fraud risks through approaches such as network analysis.
Stakeholders:
🏢Department of Housing and Urban Development : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-23-104382, published August 17, 2023; Recommendation 4; https://www.gao.gov/products/gao-23-104382 .Appendix III Table 2 entry 6 in GAO-27-108450. Corresponding source rendition Objective 6.6.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Assistant Secretary for Community Planning and Development should develop and implement guidance for CDBG-DR grantees and subrecipients to collect contractor and subcontractor data to facilitate identification of contractor and cross-cutting fraud risks through approaches such as network analysis. (Recommendation 4)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
2.4.1: Guidance
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop guidance for collecting contractor and subcontractor data to identify contractor and cross-cutting fraud risks through approaches such as network analysis. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
2.4.2: Implementation
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Implemented | Implement that guidance for CDBG-DR grantees and subrecipients. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 2.5: Data Elements 🔗
Develop guidance on data elements to be collected by grantees and subrecipients to determine if a contractor has been suspended, debarred, or excluded from working on government contracts.
Stakeholders:
🏢Department of Housing and Urban Development : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-23-104382, published August 17, 2023; Recommendation 5; https://www.gao.gov/products/gao-23-104382 .Appendix III Table 2 entry 7 in GAO-27-108450. Corresponding source rendition Objective 6.7.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Assistant Secretary for Community Planning and Development should develop guidance on data elements to be collected by grantees and subrecipients to determine if a contractor has been suspended, debarred, or excluded from working on government contracts. (Recommendation 5)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
2.5.1: Guidance
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop guidance identifying data elements needed to determine whether a contractor has been suspended, debarred, or excluded from government contracts. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 2.6: Training Attendance 🔗
Ensure that grantees and subrecipients have attended fraud-related training as required. This could include requesting and reviewing attendance documentation from the Department of Housing and Urban Development (HUD) Office of Inspector General (OIG) and grantees.
Stakeholders:
🏢Department of Housing and Urban Development : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-23-104382, published August 17, 2023; Recommendation 6; https://www.gao.gov/products/gao-23-104382 .Appendix III Table 2 entry 8 in GAO-27-108450. Corresponding source rendition Objective 6.8.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Assistant Secretary for Community Planning and Development should ensure that grantees and subrecipients have attended fraud-related training as required. This could include requesting and reviewing attendance documentation from the Department of Housing and Urban Development (HUD) Office of Inspector General (OIG) and grantees. (Recommendation 6)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
2.6.1: Attendance
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Ensured | Ensure required fraud-related training attendance by grantees and subrecipients; supporting documentation may be obtained from HUD OIG and grantees as the recommendation suggests. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 2.7: Training Availability 🔗
Ensure that grantees and subrecipients are made aware of available fraud-related training and make training available on demand to grantees and subrecipients. Coordinate with HUD OIG.
Stakeholders:
🏢Department of Housing and Urban Development : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
🏢HUD Office of Inspector General : Coordinate awareness and on-demand availability of fraud-related training.Performer : Coordinate awareness and on-demand availability of fraud-related training. (Performer)
Other Information
Source: GAO-23-104382, published August 17, 2023; Recommendation 7; https://www.gao.gov/products/gao-23-104382 .Appendix III Table 2 entry 9 in GAO-27-108450. Corresponding source rendition Objective 6.9.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Assistant Secretary for Community Planning and Development, in coordination with the HUD OIG, should ensure that grantees and subrecipients are made aware of available fraud-related training and make training available on demand to grantees and subrecipients. (Recommendation 7)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
2.7.1: Awareness
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Ensured | Ensure grantees and subrecipients are aware of available fraud-related training in coordination with HUD OIG. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
2.7.2: Availability
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Made Available | Make fraud-related training available on demand to grantees and subrecipients. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Goal 3: Grant Data 🔗
Improve grant data definitions by reviewing and revising Version 2.0 data elements as necessary.
Other Information
Originating report: GAO-24-106164; published January 25, 2024; https://www.gao.gov/products/gao-24-106164 . This grouping is editorial and preserves Table 2 order.
Objective 3.1: Grant Data 🔗
Review and revise as necessary the Version 2.0 grant data elements based on leading practices for the formulation of data definitions. Consult with the Director of OMB.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
🏢Office of Management and Budget : Consult with HHS on reviewing and revising grant data elements.Performer : Consult with HHS on reviewing and revising grant data elements. (Performer)
Other Information
Source: GAO-24-106164, published January 25, 2024; Recommendation 2; https://www.gao.gov/products/gao-24-106164 .Appendix III Table 2 entry 10 in GAO-27-108450. Corresponding source rendition Objective 6.10.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of the Department of Health and Human Services (HHS), in consultation with the Director of the Office of Management and Budget (OMB), should review and revise as necessary the Version 2.0 grant data elements based on leading practices for the formulation of data definitions. (Recommendation 2)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
3.1.1: Review
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Reviewed | Review Version 2.0 grant data elements against leading practices for data definitions in consultation with the OMB Director. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
3.1.2: Revision
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Revised as Necessary | Revise the data elements as necessary based on that review; retain the source’s conditional qualification rather than assuming every element must change. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Goal 4: Audit Reports 🔗
Improve consistent follow-up when BIE grantees do not submit timely single audit reports.
Other Information
Originating report: GAO-24-105451; published March 27, 2024; https://www.gao.gov/products/gao-24-105451 . This grouping is editorial and preserves Table 2 order.
Objective 4.1: Controls 🔗
Establish controls to ensure that staff consistently follow agency standard procedures when schools and other BIE grantees do not submit timely single audit reports.
Stakeholders:
🏢Bureau of Indian Education : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-24-105451, published March 27, 2024; Recommendation 1; https://www.gao.gov/products/gao-24-105451 .Appendix III Table 2 entry 11 in GAO-27-108450. Corresponding source rendition Objective 6.11.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Director of the Bureau of Indian Education (BIE) should establish controls to ensure that staff consistently follow agency standard procedures when schools and other BIE grantees do not submit timely single audit reports. (Recommendation 1)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
4.1.1: Controls
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Established | Establish controls ensuring that staff consistently follow BIE standard procedures when schools and other grantees do not submit timely single audit reports. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Goal 5: Single Audits 🔗
Improve the usefulness, quality, completeness, and risk analysis of single audits and FAC data.
Other Information
Originating report: GAO-24-106173; published April 22, 2024; https://www.gao.gov/products/gao-24-106173 . This grouping is editorial and preserves Table 2 order.
Objective 5.1: Funding and Timelines 🔗
Develop proposed funding and timelines for implementing the identified and prioritized features to enhance the usefulness of Federal Audit Clearinghouse (FAC) data for federal oversight through interagency agreements or other methods. Coordinate with federal agencies.
Stakeholders:
🏢General Services Administration : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
👥Federal agencies : Coordinate with GSA on proposed FAC enhancement funding and timelines.Performer : Coordinate with GSA on proposed FAC enhancement funding and timelines. (Performer)
Other Information
Source: GAO-24-106173, published April 22, 2024; Recommendation 3; https://www.gao.gov/products/gao-24-106173 .Appendix III Table 2 entry 12 in GAO-27-108450. Corresponding source rendition Objective 6.12.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Administrator of the General Services Administration (GSA) should, in coordination with federal agencies, develop proposed funding and timelines for implementing the identified and prioritized features to enhance the usefulness of Federal Audit Clearinghouse (FAC) data for federal oversight through interagency agreements or other methods. (Recommendation 3)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
5.1.1: Funding and Timelines
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop proposed funding and timelines for prioritized FAC enhancements, in coordination with federal agencies, through interagency agreements or other methods. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 5.2: Quality Review 🔗
Implement the government-wide single audit quality review by naming a federal agency to lead the review as required by the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Consult with federal agencies before implementation.
Stakeholders:
🏢Office of Management and Budget : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
👥Federal agencies : Participate in consultation on implementing the government-wide single audit quality review.Performer : Participate in consultation on implementing the government-wide single audit quality review. (Performer)
Other Information
Source: GAO-24-106173, published April 22, 2024; Recommendation 4; https://www.gao.gov/products/gao-24-106173 .Appendix III Table 2 entry 13 in GAO-27-108450. Corresponding source rendition Objective 6.13.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Director of OMB should, after consultation with federal agencies, implement the government-wide single audit quality review by naming a federal agency to lead the review as required by the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. (Recommendation 4)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
5.2.1: Leadership
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Named | Name a federal agency to lead the government-wide single audit quality review after consultation with federal agencies. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
5.2.2: Review
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Implemented | Implement the government-wide quality review as required by the Uniform Guidance. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 5.3: Audit Reports 🔗
Ensure that each of the federal agencies responsible for single audit oversight (cognizant and oversight agencies for audit) collects and reports to GSA a list of the recipients of its federal awards that should have submitted a single audit report for audit year 2023 and did not.
Stakeholders:
🏢Office of Management and Budget : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
👥Cognizant and oversight agencies for audit : Collect and report lists of recipients missing required audit-year-2023 reports.Performer : Collect and report lists of recipients missing required audit-year-2023 reports. (Performer)
Other Information
Source: GAO-24-106173, published April 22, 2024; Recommendation 5; https://www.gao.gov/products/gao-24-106173 .Appendix III Table 2 entry 14 in GAO-27-108450. Corresponding source rendition Objective 6.14.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Director of OMB should ensure that each of the federal agencies responsible for single audit oversight (cognizant and oversight agencies for audit) collects and reports to GSA a list of the recipients of its federal awards that should have submitted a single audit report for audit year 2023 and did not. (Recommendation 5)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
5.3.1: Missing Reports
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Ensured | Ensure each cognizant or oversight agency collects and reports to GSA a list of its recipients that should have submitted an audit-year-2023 single audit report and did not. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 5.4: Annual Process 🔗
Work with the Administrator of GSA to establish formal guidance implementing an annual process for each of the federal agencies to collect and report to GSA a list of its federal award recipients that should have submitted a single audit report and did not and to then communicate the guidance to federal agencies for single audits in 2024 and beyond.
Stakeholders:
🏢Office of Management and Budget : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
🏢General Services Administration : Work with OMB on guidance for annual missing-report lists.Performer : Work with OMB on guidance for annual missing-report lists. (Performer)
Other Information
Source: GAO-24-106173, published April 22, 2024; Recommendation 6; https://www.gao.gov/products/gao-24-106173 .Appendix III Table 2 entry 15 in GAO-27-108450. Corresponding source rendition Objective 6.15.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Director of OMB should work with the Administrator of GSA to establish formal guidance implementing an annual process for each of the federal agencies to collect and report to GSA a list of its federal award recipients that should have submitted a single audit report and did not and to then communicate the guidance to federal agencies for single audits in 2024 and beyond. (Recommendation 6)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
5.4.1: Guidance
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Established | Establish formal guidance with GSA for an annual agency process to collect and report lists of federal award recipients with missing required single audit reports. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
5.4.2: Communication
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Communicated | Communicate that guidance to federal agencies for single audits in 2024 and beyond. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 5.5: Combined Funds 🔗
Work with the Administrator of GSA to develop a method for determining federal award recipients that did not submit a single audit report but should have based on their combined funds received from multiple federal agencies and communicate this method to federal awarding agencies.
Stakeholders:
🏢Office of Management and Budget : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
🏢General Services Administration : Work with OMB to identify recipients requiring audits based on combined multi-agency funds.Performer : Work with OMB to identify recipients requiring audits based on combined multi-agency funds. (Performer)
Other Information
Source: GAO-24-106173, published April 22, 2024; Recommendation 7; https://www.gao.gov/products/gao-24-106173 .Appendix III Table 2 entry 16 in GAO-27-108450. Corresponding source rendition Objective 6.16.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Director of OMB should work with the Administrator of GSA to develop a method for determining federal award recipients that did not submit a single audit report but should have based on their combined funds received from multiple federal agencies and communicate this method to federal awarding agencies. (Recommendation 7)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
5.5.1: Method
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop with GSA a method for identifying recipients whose combined funds from multiple agencies required an audit that they did not submit. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
5.5.2: Communication
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Communicated | Communicate the method to federal awarding agencies. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 5.6: Auditors 🔗
Provide additional training to auditors and recipients to help ensure that they complete FAC data collection forms accurately, completely, and consistent with the audit report. Consult with professional audit organizations.
Stakeholders:
🏢General Services Administration : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
👥Professional audit organizations : Consult with GSA about additional FAC form training.Performer : Consult with GSA about additional FAC form training. (Performer)
Other Information
Source: GAO-24-106173, published April 22, 2024; Recommendation 8; https://www.gao.gov/products/gao-24-106173 .Appendix III Table 2 entry 17 in GAO-27-108450. Corresponding source rendition Objective 6.17.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Administrator of GSA should, upon consulting with professional audit organizations, provide additional training to auditors and recipients to help ensure that they complete FAC data collection forms accurately, completely, and consistent with the audit report. (Recommendation 8)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
5.6.1: Training
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Provided | Provide additional training to auditors and recipients after consulting professional audit organizations, to support accurate, complete FAC forms consistent with the audit report. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 5.7: Summary Information 🔗
Consult with federal agencies, the Council of the Inspectors General on Integrity and Efficiency (CIGIE), and relevant OIGs to discuss methods to help ensure that single audit report reviewers are verifying that the information in a single audit report aligns with the summary information entered on the FAC data collection form. These methods could include adding a procedure to conduct a final quality check in CIGIE’s Guide for Desk Reviews of Single Audit Reports.
Stakeholders:
🏢Office of Management and Budget : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Show Hide 1 member👥Federal agencies : Consult with OMB on report and FAC summary consistency checks.Performer : Consult with OMB on report and FAC summary consistency checks. (Performer)
🏢Council of the Inspectors General on Integrity and Efficiency : Consult on methods for report and summary consistency, including possible desk-review procedures.Performer : Consult on methods for report and summary consistency, including possible desk-review procedures. (Performer)
👥Relevant offices of inspector general : Consult on methods for verifying consistent audit information.Performer : Consult on methods for verifying consistent audit information. (Performer)
Other Information
Source: GAO-24-106173, published April 22, 2024; Recommendation 9; https://www.gao.gov/products/gao-24-106173 .Appendix III Table 2 entry 18 in GAO-27-108450. Corresponding source rendition Objective 6.18.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Director of OMB should consult with federal agencies, the Council of the Inspectors General on Integrity and Efficiency (CIGIE), and relevant OIGs to discuss methods to help ensure that single audit report reviewers are verifying that the information in a single audit report aligns with the summary information entered on the FAC data collection form. These methods could include adding a procedure to conduct a final quality check in CIGIE’s Guide for Desk Reviews of Single Audit Reports. (Recommendation 9)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
5.7.1: Consultation
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Consulted | Consult federal agencies, CIGIE, and relevant OIGs about methods ensuring reviewers verify agreement between single audit reports and FAC summary information; a final desk-review quality check is an example rather than a mandated method. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 5.8: Risks 🔗
Work with GSA and agency key management single audit liaisons to develop a strategy to use FAC data to identify government-wide risks to federal award funds, such as single audit reports that contain findings that are severe or have remained unresolved for multiple years. This strategy should include steps to analyze and respond to significant risks identified.
Stakeholders:
🏢Office of Management and Budget : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
🏢General Services Administration : Work with OMB to develop the FAC risk-analysis strategy.Performer : Work with OMB to develop the FAC risk-analysis strategy. (Performer)
👥Agency key management single audit liaisons : Participate in developing the risk identification and response strategy.Performer : Participate in developing the risk identification and response strategy. (Performer)
Other Information
Source: GAO-24-106173, published April 22, 2024; Recommendation 10; https://www.gao.gov/products/gao-24-106173 .Appendix III Table 2 entry 19 in GAO-27-108450. Corresponding source rendition Objective 6.19.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Director of OMB should work with GSA and agency key management single audit liaisons to develop a strategy to use FAC data to identify government-wide risks to federal award funds, such as single audit reports that contain findings that are severe or have remained unresolved for multiple years. This strategy should include steps to analyze and respond to significant risks identified. (Recommendation 10)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
5.8.1: Strategy
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop a strategy with GSA and agency key management single audit liaisons to identify government-wide risks using FAC data, including severe and persistent findings. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
5.8.2: Response
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Included | Include steps to analyze and respond to significant identified risks in that strategy. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Goal 6: Tribal Awards 🔗
Improve oversight of tribal awards through required audit submission, corrective action tracking, and follow-up metrics.
Other Information
Originating report: GAO-25-106741; published November 7, 2024; https://www.gao.gov/products/gao-25-106741 . This grouping is editorial and preserves Table 2 order.
Objective 6.1: Tribal Reports 🔗
Develop and implement procedures to identify tribal recipients that did not submit required single audit reports when due and follow up with those recipients.
Stakeholders:
🏢Department of the Treasury : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-106741, published November 7, 2024; Recommendation 1; https://www.gao.gov/products/gao-25-106741 .Appendix III Table 2 entry 20 in GAO-27-108450. Corresponding source rendition Objective 6.20.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of the Treasury should develop and implement procedures to identify tribal recipients that did not submit required single audit reports when due and follow up with those recipients. (Recommendation 1)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
6.1.1: Procedures
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop procedures to identify tribal recipients with overdue required single audit reports and follow up with them. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
6.1.2: Implementation
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Implemented | Implement those audit-submission and follow-up procedures. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 6.2: Corrective Actions 🔗
Develop and implement procedures for tracking the implementation of corrective action plans, including tracking repeat single audit findings, to ensure that tribal recipients take appropriate and timely action to correct single audit findings.
Stakeholders:
🏢Department of the Interior : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-106741, published November 7, 2024; Recommendation 2; https://www.gao.gov/products/gao-25-106741 .Appendix III Table 2 entry 21 in GAO-27-108450. Corresponding source rendition Objective 6.21.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of the Interior should develop and implement procedures for tracking the implementation of corrective action plans, including tracking repeat single audit findings, to ensure that tribal recipients take appropriate and timely action to correct single audit findings. (Recommendation 2)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
6.2.1: Procedures
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop procedures for tracking corrective action implementation and repeat findings to ensure timely and appropriate correction by tribal recipients. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
6.2.2: Implementation
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Implemented | Implement those corrective action tracking procedures. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 6.3: Metrics 🔗
Develop and implement procedures to use metrics to improve the effectiveness of the Department of the Treasury’s process for following up on audit findings, including developing baselines and targets, tracking the implementation of corrective action plans, and sharing the metrics with the Office of Capital Access’s Chief Operating Officer.
Stakeholders:
🏢Department of the Treasury : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
👥Office of Capital Access Chief Operating Officer : Receive audit-follow-up metrics.Performer : Receive audit-follow-up metrics. (Performer)
Other Information
Source: GAO-25-106741, published November 7, 2024; Recommendation 3; https://www.gao.gov/products/gao-25-106741 .Appendix III Table 2 entry 22 in GAO-27-108450. Corresponding source rendition Objective 6.22.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of the Treasury should develop and implement procedures to use metrics to improve the effectiveness of the Department of the Treasury’s process for following up on audit findings, including developing baselines and targets, tracking the implementation of corrective action plans, and sharing the metrics with the Office of Capital Access’s Chief Operating Officer. (Recommendation 3)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
6.3.1: Procedures
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Implemented | Develop and implement procedures using metrics to improve Treasury’s audit-finding follow-up process. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
6.3.2: Metrics
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop baselines and targets, track corrective action implementation, and share the metrics with the Office of Capital Access Chief Operating Officer. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Goal 7: Oversight Authority 🔗
Consider additional HHS oversight authority for TANF expenditure information.
Other Information
Originating report: GAO-25-107235; published December 12, 2024; https://www.gao.gov/products/gao-25-107235 . This grouping is editorial and preserves Table 2 order.
Objective 7.1: Oversight Authority 🔗
Consider granting HHS the authority to collect from states specific additional information needed to enhance its oversight authority, such as planned and actual Temporary Assistance for Needy Families (TANF) non-assistance expenditures, beyond what is provided for in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996.
Stakeholders:
🏢Congress : Carry out the action addressed to the responsible official or institution in the original matter for congressional consideration.Performer : Carry out the action addressed to the responsible official or institution in the original matter for congressional consideration. (Performer)
Other Information
Source: GAO-25-107235, published December 12, 2024; Matter for Consideration 1; https://www.gao.gov/products/gao-25-107235 .Appendix III Table 2 entry 23 in GAO-27-108450. Corresponding source rendition Objective 6.23.Classification: Matter for congressional consideration. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: Congress should consider granting HHS the authority to collect from states specific additional information needed to enhance its oversight authority, such as planned and actual Temporary Assistance for Needy Families (TANF) non-assistance expenditures, beyond what is provided for in the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. (Matter for Consideration 1)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
7.1.1: Consideration
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Considered | Consider granting HHS authority to collect specific additional state information, such as planned and actual TANF non-assistance expenditures, beyond the information authorized by the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. Record the consideration without assuming enactment. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted. Consideration is the modeled result; enactment is not assumed.
Goal 8: Subrecipient Information 🔗
Improve collection and reporting of Opioid Response grant subrecipient information.
Other Information
Originating report: GAO-25-106944; published December 17, 2024; https://www.gao.gov/products/gao-25-106944 . This grouping is editorial and preserves Table 2 order.
Objective 8.1: Subrecipient Information 🔗
Complete and implement a documented plan for collecting and reporting information about Opioid Response grant subrecipients.
Stakeholders:
🏢Substance Abuse and Mental Health Services Administration : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-106944, published December 17, 2024; Recommendation 1; https://www.gao.gov/products/gao-25-106944 .Appendix III Table 2 entry 24 in GAO-27-108450. Corresponding source rendition Objective 6.24.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Assistant Secretary for Mental Health and Substance Use should complete and implement a documented plan for collecting and reporting information about Opioid Response grant subrecipients. (Recommendation 1)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
8.1.1: Plan
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Completed | Complete a documented plan for collecting and reporting Opioid Response grant subrecipient information. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
8.1.2: Implementation
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Implemented | Implement that documented collection and reporting plan. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Goal 9: TANF Fraud Risks 🔗
Improve assessment and management of TANF fraud risks through guidance, procedures, communication, and portal capabilities.
Other Information
Originating report: GAO-25-107290; published January 28, 2025; https://www.gao.gov/products/gao-25-107290 . This grouping is editorial and preserves Table 2 order.
Objective 9.1: Guidance 🔗
Finalize HHS’s key guidance documents on fraud risk management—the Fraud Risk Management Implementation Plan and the Fraud Risk Assessment Portal Methodology—and clearly establish a process for conducting fraud risk assessments for HHS programs, including TANF, at regular intervals and when there are changes to the program or its operating environment.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-107290, published January 28, 2025; Recommendation 1; https://www.gao.gov/products/gao-25-107290 .Appendix III Table 2 entry 25 in GAO-27-108450. Corresponding source rendition Objective 6.25.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of HHS should finalize its key guidance documents on fraud risk management—the Fraud Risk Management Implementation Plan and the Fraud Risk Assessment Portal Methodology—and clearly establish a process for conducting fraud risk assessments for HHS programs, including TANF, at regular intervals and when there are changes to the program or its operating environment. (Recommendation 1)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
9.1.1: Guidance
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Finalized | Finalize the Fraud Risk Management Implementation Plan and Fraud Risk Assessment Portal Methodology. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
9.1.2: Process
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Established | Establish a clear process for assessing HHS program fraud risks, including TANF, regularly and when programs or their operating environments change. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 9.2: Procedures 🔗
Develop and document standard operating procedures for conducting regular fraud risk assessments tailored to TANF. This should include the roles and responsibilities of HHS entities involved in the process.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-107290, published January 28, 2025; Recommendation 2; https://www.gao.gov/products/gao-25-107290 .Appendix III Table 2 entry 26 in GAO-27-108450. Corresponding source rendition Objective 6.26.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of HHS should develop and document standard operating procedures for conducting regular fraud risk assessments tailored to TANF. This should include the roles and responsibilities of HHS entities involved in the process. (Recommendation 2)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
9.2.1: Procedures
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Documented | Develop and document standard operating procedures for regular TANF fraud risk assessments, including roles and responsibilities of involved HHS entities. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 9.3: Communication 🔗
Develop a process for direct and regular communication with state and local agencies, and their respective OIGs or auditors, about TANF fraud risks that includes an approach for soliciting information from these entities and document this process in its standard operating procedures for conducting fraud risk assessments tailored to TANF.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
👥State and local agencies and their OIGs or auditors : Communicate TANF fraud risk information through the recommended process.Performer : Communicate TANF fraud risk information through the recommended process. (Performer)
Other Information
Source: GAO-25-107290, published January 28, 2025; Recommendation 3; https://www.gao.gov/products/gao-25-107290 .Appendix III Table 2 entry 27 in GAO-27-108450. Corresponding source rendition Objective 6.27.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of HHS should develop a process for direct and regular communication with state and local agencies, and their respective OIGs or auditors, about TANF fraud risks that includes an approach for soliciting information from these entities and document this process in its standard operating procedures for conducting fraud risk assessments tailored to TANF. (Recommendation 3)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
9.3.1: Communication
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Developed | Develop a process for direct, regular communication and solicitation of information on TANF fraud risks from state and local agencies and their OIGs or auditors. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
9.3.2: Documentation
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Documented | Document the communication process in standard operating procedures for TANF fraud risk assessments. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 9.4: Portal Functionality 🔗
Update the design of HHS’s Fraud Risk Assessment Portal to have the functionality to allow users to assess the likelihood and impact of each fraud risk identified in a program, such as TANF; determine the related fraud risk tolerance; and include those results in the portal as part of their fraud risk assessments.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-107290, published January 28, 2025; Recommendation 4; https://www.gao.gov/products/gao-25-107290 .Appendix III Table 2 entry 28 in GAO-27-108450. Corresponding source rendition Objective 6.28.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of HHS should update the design of HHS’s Fraud Risk Assessment Portal to have the functionality to allow users to assess the likelihood and impact of each fraud risk identified in a program, such as TANF; determine the related fraud risk tolerance; and include those results in the portal as part of their fraud risk assessments. (Recommendation 4)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
9.4.1: Portal Functionality
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Updated | Update portal functionality to assess each identified program fraud risk’s likelihood and impact, determine tolerance, and include the results in portal assessments. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 9.5: Risk Assessments 🔗
Require users to assess the likelihood and impact of each fraud risk identified in a program, such as TANF; determine the related fraud risk tolerance; and include those results in the Fraud Risk Assessment Portal as part of their fraud risk assessments. Apply these requirements as part of finalizing HHS’s key fraud risk guidance documents.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-107290, published January 28, 2025; Recommendation 5; https://www.gao.gov/products/gao-25-107290 .Appendix III Table 2 entry 29 in GAO-27-108450. Corresponding source rendition Objective 6.29.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: As part of finalizing HHS’s key guidance documents on fraud risk management, the Secretary of HHS should require users to assess the likelihood and impact of each fraud risk identified in a program, such as TANF; determine the related fraud risk tolerance; and include those results in the Fraud Risk Assessment Portal as part of their fraud risk assessments. (Recommendation 5)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
9.5.1: Assessment Requirements
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Required | Require assessment of each identified program fraud risk’s likelihood and impact, determination of tolerance, and inclusion of the results in the portal as part of finalizing HHS fraud risk guidance. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 9.6: Additional Risks 🔗
Update the design of HHS’s Fraud Risk Assessment Portal to have the functionality to allow for the regular assessment of any additional fraud risks facing TANF, including those identified in GAO-25-107290.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-107290, published January 28, 2025; Recommendation 6; https://www.gao.gov/products/gao-25-107290 .Appendix III Table 2 entry 30 in GAO-27-108450. Corresponding source rendition Objective 6.30.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of HHS should update the design of HHS’s Fraud Risk Assessment Portal to have the functionality to allow for the regular assessment of any additional fraud risks facing TANF, including those we have identified. (Recommendation 6)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
9.6.1: Portal Functionality
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Updated | Update the portal to allow regular assessment of additional TANF fraud risks, including those identified in GAO-25-107290. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 9.7: Additional Assessments 🔗
Require users to regularly assess any additional fraud risks facing TANF. Apply this requirement as part of finalizing HHS’s key fraud risk guidance documents.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-107290, published January 28, 2025; Recommendation 7; https://www.gao.gov/products/gao-25-107290 .Appendix III Table 2 entry 31 in GAO-27-108450. Corresponding source rendition Objective 6.31.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: As part of finalizing HHS’s key guidance documents on fraud risk management, the Secretary of HHS should require users to regularly assess any additional fraud risks facing TANF. (Recommendation 7)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
9.7.1: Assessment Requirements
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Required | Require users to assess additional TANF fraud risks regularly as part of finalizing HHS fraud risk guidance. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Goal 10: TANF Compliance 🔗
Improve TANF compliance through audit backlog reduction and timely penalties or corrective compliance plans.
Other Information
Originating report: GAO-25-107291; published April 4, 2025; https://www.gao.gov/products/gao-25-107291 . This grouping is editorial and preserves Table 2 order.
Objective 10.1: Audit Backlog 🔗
Ensure that the Administration for Children and Families develops and implements a strategy to eliminate the accumulated TANF audit backlog, to ensure that management decisions are issued within the required time frame.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
🏢Administration for Children and Families : Develop and implement the TANF audit-backlog elimination strategy.Performer : Develop and implement the TANF audit-backlog elimination strategy. (Performer)
Other Information
Source: GAO-25-107291, published April 4, 2025; Recommendation 2; https://www.gao.gov/products/gao-25-107291 .Appendix III Table 2 entry 32 in GAO-27-108450. Corresponding source rendition Objective 6.32.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of HHS should ensure that the Administration for Children and Families develops and implements a strategy to eliminate the accumulated TANF audit backlog, to ensure that management decisions are issued within the required time frame. (Recommendation 2)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
10.1.1: Strategy
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Implemented | Ensure ACF develops and implements a strategy to eliminate the accumulated TANF audit backlog and support management decisions within the required time frame. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
10.1.2: Backlog
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Eliminated | Eliminate the accumulated TANF audit backlog. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Objective 10.2: Penalties 🔗
Develop, document, and implement additional procedures to timely impose penalties or alternatively obtain corrective compliance plans for states that are not meeting TANF program requirements.
Stakeholders:
🏢Department of Health and Human Services : Carry out the action addressed to the responsible official or institution in the original GAO recommendation.Performer : Carry out the action addressed to the responsible official or institution in the original GAO recommendation. (Performer)
Other Information
Source: GAO-25-107291, published April 4, 2025; Recommendation 3; https://www.gao.gov/products/gao-25-107291 .Appendix III Table 2 entry 33 in GAO-27-108450. Corresponding source rendition Objective 6.33.Classification: Prior agency recommendation. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: The Secretary of HHS should develop, document, and implement additional procedures to timely impose penalties or alternatively obtain corrective compliance plans for states that are not meeting TANF program requirements. (Recommendation 3)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
10.2.1: Procedures
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Implemented | Develop, document, and implement additional procedures to impose timely penalties or alternatively obtain corrective compliance plans for states not meeting TANF requirements. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted.
Goal 11: Data Standards 🔗
Consider explicit Treasury authority for government-wide recipient eligibility data standards and interoperability requirements.
Other Information
Originating report: GAO-26-107466; published June 16, 2026; https://www.gao.gov/products/gao-26-107466 . This grouping is editorial and preserves Table 2 order.
Objective 11.1: Data Standards 🔗
Consider assigning Treasury explicit authority to lead, in coordination with the Chief Data Officers Council and in consultation with OMB—and others, as needed—the development and implementation of government-wide data standards and interoperability requirements, including data definitions, dictionaries, validation rules, and disclosures, for recipient eligibility data sources, including relevant financial, award, spending, and payment data needed to support eligibility determinations throughout the award life cycle.
Stakeholders:
🏢Congress : Carry out the action addressed to the responsible official or institution in the original matter for congressional consideration.Performer : Carry out the action addressed to the responsible official or institution in the original matter for congressional consideration. (Performer)
Other Information
Source: GAO-26-107466, published June 16, 2026; Matter for Consideration 1; https://www.gao.gov/products/gao-26-107466 .Appendix III Table 2 entry 34 in GAO-27-108450. Corresponding source rendition Objective 6.34.Classification: Matter for congressional consideration. Status: open as listed in the November 10, 2026 source, not independently updated.Original wording: Congress should consider assigning Treasury explicit authority to lead, in coordination with the Chief Data Officers Council and in consultation with OMB—and others, as needed—the development and implementation of government-wide data standards and interoperability requirements, including data definitions, dictionaries, validation rules, and disclosures, for recipient eligibility data sources, including relevant financial, award, spending, and payment data needed to support eligibility determinations throughout the award life cycle. (Matter for Consideration 1)The performance criteria below model completion of the stated actions. They are not actual results, adopted agency commitments, or independently verified GAO closure criteria.
Performance Indicators
11.1.1: Consideration
| Type | Start Date | End Date | Status | Description |
|---|---|---|---|---|
| Target | Considered | Consider assigning Treasury explicit authority to lead government-wide recipient eligibility data standards and interoperability requirements in coordination with the CDO Council and consultation with OMB and others as needed. Include definitions, dictionaries, validation rules, and disclosures for relevant financial, award, spending, and payment data throughout the award life cycle. Record the consideration without assuming enactment. |
Other Information
Qualitative model target derived from the source recommendation. Evidence may include the relevant approved assessment, guidance, procedure, plan, consultation record, operating record, or legislative record. Record the evidence and observation date when reporting an ActualResult. No deadline or implementation result is asserted. Consideration is the modeled result; enactment is not assumed.