President-elect Trump has announced the formation of a new Department of Government Efficiency (DOGE), chaired by Elon Musk and Vivek Ramaswamy. One of the areas of government efficiency highlighted by Musk and Ramaswamy on social media has been the problem of government fraud and misspending. In 2024, the nonpartisan Government Accountability Office (GAO) estimated that the federal government loses between “$233 billion and $521 billion annually to fraud.” Federal improper payments, which totaled $161 billion this year, are another obvious area of government inefficiency, with overall misspending totalling $2.7 trillion since 2003.
Preventing government fraud and curbing improper payments have been bipartisan priorities on Capitol Hill for decades (since the passage of the Improper Payments Information Act of 2002) and the focus of ongoing White House initiatives. Yet these problems persist.
To better understand these problems and what the next administration and Congress can do to solve them, I reached out to Linda Miller, the co-founder of the Program Integrity Alliance (PIA), who has a deep background leading federal activities aimed at preventing fraud and misspending.
Linda, thank you for sharing your time and expertise with us. To begin, please tell us about your past work and the mission of the Program Integrity Alliance.
PIA’s mission is to strengthen program integrity and fraud prevention in government through evidence-based, data-driven solutions. Our work reflects a dedication to a government that is both trusted and trustworthy.
My antifraud career spans over 16 years, including leadership roles such as Deputy Executive Director of the Pandemic Response Accountability Committee (PRAC), where I oversaw efforts to address the $5 trillion in pandemic-related government spending. I also served as an Assistant Director at GAO, where I led the development of the Framework for Managing Fraud Risks in Federal Programs.
Why are these problems so enduring, since preventing fraud and curbing improper payments have been long-standing bipartisan priorities on Capitol Hill and in presidential administrations?
Your question highlights a fundamental paradox: while reducing fraud and improper payments are often framed as bipartisan priorities, the systemic and practical challenges of addressing them are rarely met with sustained commitment or adequate resources. Despite bipartisan acknowledgment, the urgency to deliver public benefits often eclipses investments in preventive measures.
The persistence of these problems stems from structural inefficiencies as well as a pervasive mindset that activities to prevent fraud and improper payments are hindrances, as opposed to enablers, of an agency’s mission. Accountability at the top and performance metrics within agencies don’t offer sufficient incentives to change the status quo. The current norm is that agencies are under pressure to meet operational metrics, such as the speed of disbursement, rather than outcome-focused measures that promote program integrity.
And there is an array of systemic issues that contribute to the enduring nature of the problem. Fragmented data-sharing frameworks and outdated laws and rules, such as those governing privacy and data access, further hinder fraud prevention and perpetuate a compliance-oriented approach. This is one area that the PIA’s research is exploring to put forward practicable solutions and recommendations for legislative reform.
You worked at the Pandemic Analytics Center of Excellence and were involved in overseeing the massive spending that occurred during the COVID pandemic. Fraud and misspending were a major problem during that time, with $281 billion in improper payments reported in 2021, and it brought new attention to the need to strengthen program integrity. What can we learn from our experience during the pandemic?
The PRAC and others in the oversight community have published post-mortems that offer comprehensive accounts of what went wrong and what needs to change. Many of the lessons in those reports, such as validating information, modernizing IT systems, taking a risk-based approach, and so on, reflect the consequences of not acting on known challenges that predate the pandemic. Despite these recurring insights, systemic weaknesses remain, highlighting a troubling inability to turn lessons into lasting solutions. As the saying goes: history doesn’t repeat itself, but it often rhymes.
One of the main takeaways from the pandemic is the importance of validating self-certified information before agencies disburse funds. Programs like the Paycheck Protection Program (PPP) and Economic Injury Disaster Loans (EIDL) relied heavily on self-certification. I’d call this a hands-off approach to managing risks. It allowed sophisticated fraud actors, including organized crime rings and transnational criminal organizations, to exploit these programs through identity theft and falsified records.
The SBA [Small Business Administration] OIG estimated that the agency disbursed over $200 billion in potentially fraudulent funds related to these programs. So, on its own, this number suggests the improper payment estimate you quoted is substantially lower than the actual level of improper payments, including fraud. And this is just an estimate for the SBA.
Addressing this challenge requires more investments in new data and making use of existing data-sharing tools, like Treasury’s "Do Not Pay" system, which was underutilized during the pandemic. These kinds of tools are the foundation for agencies to build more advanced analytics and data-driven fraud prevention practices.
In recent testimony, you argued that the government needs to do a better job of using data and technology to prevent fraud and misspending. What do you have in mind? Can you point to any examples of what has been done well?
Treasury's Do Not Pay system exemplifies the progress that can be made by leveraging data to improve payment accuracy. Additionally, the PRAC’s Pandemic Analytics Center of Excellence (PACE) demonstrated how a centralized platform for fraud detection can enhance oversight and prevent improper payments. These successes highlight the transformative potential of targeted investments in data and analytics to address fraud effectively.
But we can’t expect agencies to tackle the growing complexities of fraud and improper payments on their own, nor should they have to. Building on the success of the PACE, there needs to be a dedicated entity in charge of a whole-of-government approach to data-driven program integrity and fraud prevention.
FY2024 saw a significant decrease in improper payments in FY2024, with an estimated decline of $161.5 billion. What do you think contributed to that decline?
We should give credit where it is due, as some agencies have made meaningful progress in addressing improper payments and fraud. For example, the Social Security Administration (SSA) has implemented measures like continuing disability reviews, which not only improve program integrity but also provide a significant return on investment, with estimates showing $9 saved for every $1 spent. These efforts demonstrate how targeted efforts can yield tangible results and reduce improper payments.
The reported decline in improper payments in 2024, while seemingly a step in the right direction, should be taken with a grain of salt. Stricter internal controls and targeted oversight likely contributed to the reduction, but the headline figures can be misleading. Improper payment rates are often expressed as a percentage of total spending, meaning that if overall spending increases faster than improper payments, the rate appears to decline even if the actual dollar amounts remain high or even increase. For instance, the Office of Management and Budget’s 2024 data showed that some programs with rising improper payment amounts still reported lower rates due to higher spending levels.
It is also important to understand what goes into improper payment figures. These numbers include payments made to the wrong recipient, in the wrong amount, or without proper documentation. The decline in improper payments does not automatically indicate less fraud; it could also result from changes in estimation methodologies or shifts in program funding. This underscores the need for more robust data and methodologies to provide a clearer picture of the progress being made and the challenges that remain.
What do you consider to be the role of the oversight community, including GAO and the Inspectors General, to help agencies prevent improper payments and fraud?
The oversight community has a vital and demanding role in ensuring government accountability. By identifying vulnerabilities and ensuring agencies adhere to standards and guidance, oversight bodies play a critical part in strengthening program integrity.
As agencies modernize and adopt AI, oversight bodies can further enhance their impact by promoting the responsible and effective use of new technologies, ensuring they are deployed with appropriate safeguards for privacy.
But the oversight community's role should complement, not replace, the fundamental responsibility of agencies to manage risks. Internal control standards and government-wide guidance have consistently placed the onus for program integrity and fraud risk management on agencies themselves. Yet, as seen in numerous GAO and OIG recommendations, agencies are too often falling short of fulfilling their responsibilities, leaving gaps in program integrity and fraud risk management unaddressed.
Does the oversight community need more resources or sustained focus on fraud prevention and program integrity? Do we need more collaboration between watchdogs and federal agencies?
Yes, the oversight community needs more resources and sustained focus to address fraud effectively. Inspectors General often face massive backlogs of fraud cases but lack sufficient staff and funding to address them. Collaboration between watchdogs and federal agencies is essential. For example, joint initiatives like the PACE demonstrated how data-sharing and coordination can amplify oversight efforts and improve fraud prevention outcomes.
What advice do you have for Musk and Ramaswamy and the new Department of Government Efficiency?
GAO estimates that fraud alone costs the government as much as half a trillion dollars annually. If the DOGE is looking for priorities, there are currently hundreds of open recommendations proposed by the GAO and Inspectors General (IGs) across the federal government that explicitly target ways the government can strengthen integrity and combat fraud. PIA is currently building a database to help track these recommendations and benchmark agency performance in addressing them.
Beyond improper payments, GAO’s annual report on opportunities to save money and reduce fragmentation, overlap, and duplication—now in its 14th year—proposes hundreds of other recommendations for Congress and the government to boost efficiency and save billions more in taxpayer money by their own estimates.
At the top of the list of priorities should be modernizing fraud prevention through digital technologies and data access. The private sector offers valuable lessons for government agencies in this regard, for example, banks effectively balance fraud prevention with customer experience using tools like predictive analytics and identity verification technologies.
But strengthening fraud prevention and program integrity requires more than just technology and data. It demands investment in people and skills. Without competent civil servants to utilize data and digital tools effectively, even the best technology is useless. Policies that reduce the government workforce or fail to attract early-career professionals with digital expertise risk undermining oversight and program integrity, just as they would in any other essential government function.
Do you have any recommendations for the members and leaders of the 119th Congress?
The new Congress has an opportunity to act on long-standing recommendations to strengthen program integrity and reduce vulnerabilities to fraud and improper payments. Revising the Payment Integrity and Information Act to focus on high-risk programs and mandating the use of advanced analytics builds on prior reform efforts to better allocate resources and modernize fraud prevention.
Most efforts to modernize program integrity require funding to succeed. Congress should consider establishing a centralized antifraud office to improve coordination, data-sharing, and accountability across federal programs. Such an office would unify fraud prevention efforts and equip agencies with the tools to proactively combat fraud.
Additionally, creating a Program Integrity Fund to support agency modernization—investing in technology, training, and data infrastructure—would provide the resources needed for systemic improvement. Coupled with a stronger focus on outcomes, through performance metrics and oversight hearings, these measures could incentivize proactive fraud prevention and deliver tangible results.
Congress also plays a key role in promoting access to data for fraud prevention while balancing data privacy concerns. PIA is conducting research to develop recommendations for legislative reform in this area, which we will share publicly in the coming months.
