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For plans applying for SFA after initiation of the full participant death audit (as agreed to with recommendation 2024-01-01), continue to implement the new death audit procedures prior to approving the applications. Implementing this recommendation could put an estimated $125 million of taxpayer dollars to better use.

For plans paid SFA prior to implementation of the Corporation’s full death audit procedure, continue to implement the new death audit procedures, and rectify with the plans the value attributed to deceased participants to include repayment to Treasury. The estimate from this recommendation results in approximately $250 million in questioned costs, including the $140 million identified in the sampled plans.