Audit of the Millennium Challenge Corporation's Fiscal Year 2015 Compliance with the Improper Payment Elimination and Recovery Act of 2010

We recommend that the Millennium Challenge Corporation Department of Administration and Finance require MCC staff and contractors responsible for compliance with the Improper Payments Elimination and Recovery Act to take training on the requirements in Office of Management and Budget Circulars A-123 and A-136 pertaining to Improper Payments Elimination and Recovery Act compliance and reporting.

We recommend that the Millennium Challenge Corporation Department of Administration and Finance conduct an Improper Payments Elimination and Recovery Act risk assessment for fiscal year 2016 that includes all MCC programs.

We recommend that the Millennium Challenge Corporation Department of
Administration and Finance instruct MCC staff and contractors in writing to use current Office of Management and Budget guidance to conduct the fiscal year 2016 Improper Payments Elimination and Recovery Act risk assessment and report on it in the Agency Financial Report.

We recommend that the Millennium Challenge Corporation Department of
Administration and Finance assess whether the methodology and risk factors used in
the Improper Payments Elimination and Recovery Act risk assessment are relevant and sufficient to identify the risk of improper payments.

We recommend that the Millennium Challenge Corpordtlon Department of
Administration and Finance develop procedures on documenting and maintaining dear,complete records of (1) the risk ratings (including the payment transaction testing performed) for each program and risk factor, (2) payment transaction testing performed for the quantitative assessment, and (3) Millennium Challenge Corporation's review and approval of the overall risk assessment analysis.

We recommend that the Millennium Challenge Corporation Department of
Administration and Finance prepare a written oversight plan to verify contractor
compliance with Improper Payments Elimination and Recovery Act requirements.

We recommend that the Millennium Challenge Corporation Department of
Administration and Finance issue written guidance that defines the oversight roles and responslbllltfes for verifying that MCC meets the requirements in Office of Management and Budget Circulars A-123 and A-136 for Improper Payments Elimination and Recovery Act compliance and reporting

We recommend that the Millennium Challenge Corporation Department of
Administration and Finance instruct MCC staff and contrdctors in writing to use the most current Office of Management and Budget Circular A-136 and comply with all applicable Agency Pinancial Report reporting requirements for the fiscal year 2016 recapture payment audit programs and Do Not Pay Initiative.