Page 37 - Financial Report 2020

PRIVACY AND CIVIL LIBERTIES OVERSIGHT BOARD

end goal of determining whether the program is or is not susceptible to significant
improper payments.
PIIA requires agencies to review all programs and activities they administer and identify
those which may be susceptible to significant erroneous payments. For all programs and
activities in which the risk of erroneous payments is significant, agencies are to estimate
the annual amount of erroneous payments made in those programs. The PCLOB’s last risk
assessment, conducted in 2018, indicated that PCLOB’s single program was not susceptible
to significant improper payments. PCLOB will conduct its next risk assessment in 2021. The
PCLOB will perform another risk assessment sooner if a program has a significant change
in legislation or the agency receives a significant increase in its funding.

Although the Board is not susceptible to significant improper payments, the agency has a
responsibility to implement certain financial and administrative controls relating to fraud
and improper payments and to report to Congress annually on the implementation of
controls to mitigate and detect fraud, identification of risks and vulnerabilities to fraud
with respect to applicable processes, and the strategies, procedures, and other steps used
by the agency to curb fraud. The Fraud Reduction and Data Analytics Act of 2015, now
incorporated into PIIA, was first signed into law in June 2016 to improve financial and
administrative controls and procedures to identify, assess, and address fraud risks.
Application of the agency’s internal controls framework strengthens the agency
effectiveness in meeting agency goals and objectives, while improving fraud prevention
and detection of federal resources. PCLOB is a full participant in the Treasury’s “Do Not
Pay” program operating through the Do Not Pay Business Center. Payees under
consideration for payment are reviewed for eligibility through the pre-award component of
the business center, payments are then re-verified in the pre-payment component,
followed by post-payment data matching reviews. See the PCLOB’s 2020 Fraud Reduction
Report in the “Other Information” section of this agency financial report.

Debt Collection Improvement Act

PCLOB does not currently manage debt but continues to monitor provisions of the Debt
Collection Improvement Act of 1996; OMB Circular A-129, Policies for Federal Credit
Programs and Non-Tax Receivables; the Controller Alert, Improving Collection of Delinquent
Debt, issued Jan. 4, 2013; and other relevant laws to ensure compliance.

FY 2020 AGENCY FINANCIAL REPORT 28