Background ARNG is one of two reserve components of the Department of the Army;  it has units located in each of the 54 states, territories, and the District of  Columbia. The Secretary of the Army is responsible for creating  overarching policy and guidance for all of the components of the Army,  including ARNG. The Chief of NGB, among other responsibilities, acts as  the official channel of communication between the Department of the  Army and the 54 states, territories, and the District of Columbia in which  ARNG has personnel assigned and is responsible for ensuring that  ARNG personnel are accessible, capable, and trained to protect the  homeland and to provide combat resources to the Army. The Selected Reserve  Incentive Program During fiscal years 2010 through 2016, ARNG disbursed more than $1.8  billion in financial incentives to bolster its recruiting and retention efforts.  The ARNG program, called the Selected Reserve Incentive Program,  includes cash bonuses and other payments. The ARNG regulation for  Selected Reserve Incentive Programs includes over a dozen sub- categories of cash bonuses, such as those for newly enlisted soldiers,  active duty soldiers who join ARNG, and soldiers who re-enlist or extend  with ARNG. In addition to cash bonuses, ARNG makes incentive  payments as part of the Student Loan Repayment Program. Under this  type of incentive, ARNG disburses incentive payments directly to a third  party lender. The Director of ARNG is responsible for determining the overall policy for  the Selected Reserve Incentive Program and issued the regulation that  governs incentive procedures and eligibility criteria for soldiers entering  into an incentive agreement. On a periodic basis, ARNG updates the  policy for a specific fiscal year through a policy or an education and  incentive operational message. These updates, which are intended to  help ARNG meet its readiness requirements, can provide instructions on  the value and frequency of incentives, as well as directing the targeting of  incentives to address a particular skill or unit need. The updates can also  direct changes to eligibility requirements in order to enable a soldier to  receive an incentive. Each of the 54 states, territories, and the District of Columbia has a state  incentive manager in ARNG who provides oversight for authorization,  verification, validation, establishment, monitoring, and termination of all  incentive payments, including recoupment of incentives. State incentive  managers work with recruiting and retention personnel to assist in the use  of bonuses. For example, state incentive managers can ensure that the  contracts used by recruiting and retention personnel comply with ARNG  policy. Additionally, each ARNG unit has personnel who track information  on soldier performance, such as attendance, physical fitness, and  training. To manage these activities, ARNG uses the Reserve Component  Manpower System— an information system that houses manpower  readiness data and includes approximately 40 subsystems. Improper Payments in the  California ARNG A 2008 California National Guard audit revealed that Selected Reserve  Incentive Program incentives, including student loan repayments, were  being improperly paid to numerous California ARNG soldiers and that  some of these cases were results of fraud. In subsequent audits of  California ARNG, 17,485 soldiers were identified as having received a  bonus or student loan repayment in the period of 2004 through 2010 that  was potentially improper and subject to recoupment. By the end of 2016,  several follow-on reviews had identified improper incentive payments to  more than 1,400 soldiers. These investigations and audits determined that ARNG lacked internal  controls over its incentive process. For example, the state incentive  manager could authorize and approve an incentive and then forward the  payment request to the state’s U.S. Property and Fiscal Office, the office  responsible for authorizing payment. To improve the process, in 2010  ARNG established a contract for an Incentive Support Team to, among  other things, review soldier incentives. In 2011, ARNG developed a  module within the Reserve Component Manpower System called the  Guard Incentive Management System. The Guard Incentive Management  System was designed to aid in managing the incentive process across all  states by providing an online system to track, monitor, and prioritize all  incentive cases. The Guard Incentive Management System was also  intended to increase oversight through automated notifications and  reporting features and to add a budget control mechanism for NGB and  the states, among other things. In 2012, ARNG began a phased  implementation of the Guard Incentive Management System in each state  and territory. ARNG subsequently expanded the Guard Incentive  Management System to include the Student Loan Repayment Program. Process Before NGB  Establishes a Debt NGB goes through a process before it establishes and collects on a  debt. State incentive managers are responsible for ensuring that  soldiers receiving incentive payments are satisfying contractual  requirements. If the state incentive manager determines that the soldier  has violated the contract tied to the incentive payment, the state incentive  manager sends a certified letter to the soldier that (1) states the reason  the payment may potentially be determined to be improper and (2) lists  the steps that the soldier can take to adjudicate the issue. ARNG officials  informed us that, if the soldier does not respond to the letter within 45  days, a debt is established in Defense Finance and Accounting Service  systems. In response, the soldier may provide documents to address the  issue or, should documents already exist, may request that NGB make an  exception to policy—a determination by NGB that the circumstances of a  soldier’s case merit allowing the soldier to retain the incentive payment.  Incentive managers in some states told us that they will assist soldiers in  requesting an exception to policy and will sometimes request these  exceptions on their behalf in the case of events—such as a  reorganization of a state’s ARNG units—that could result in a large  number of soldiers not meeting the terms of their incentive contracts. If  these steps do not resolve the issue, the soldier can seek recourse  through the Army Board for the Correction of Military Records. Once  these options are exhausted, the debt is established in Defense Finance  and Accounting Service systems. ARNG Has  Implemented Internal  Controls to Prevent  Improper Payments  but Has Not Planned  for Future Significant  Changes That Could  Affect Its Internal  Controls  ARNG Has Implemented  Internal Controls to  Prevent Improper  Incentive Payments ARNG has implemented internal controls, including automated and  manual reviews, to prevent improper incentive payments, and it also  reviews its incentive programs on a periodic basis. First, ARNG has  implemented the Guard Incentive Management System and expanded its  use over time to oversee its incentive contracts through automation. In  2012, ARNG began using the Guard Incentive Management System to  manage the life cycles of contracts between ARNG and soldiers for  incentives and education entitlements, including those for the Selected  Reserve Incentive Program. When a soldier signs a contract with a  recruiter or retention officer, the Guard Incentive Management System  alerts the state incentive manager that an incentive is ready for review.  ARNG has also implemented automated rules in the Guard Incentive Management System—known as monitor rules—that continuously  monitor a soldier’s eligibility for an incentive. The system does this by  comparing the data it receives from multiple personnel systems against  the soldier’s contract. If any issues are found, the Guard Incentive  Management System will flag the incentive case for review by the state  incentive manager and will stop future payments until the issue is  resolved. In California, for example, we observed an incentive manager  reviewing a case that had been flagged for violating a monitor rule  because the soldier was no longer in the unit stipulated in the incentive  contract. The incentive manager told us that the soldier was informed of  the situation and that corrective action would be required before any  additional payments could be made. If a soldier is deemed ineligible or  loses eligibility at any time during this process, the state incentive  manager will stop payments and review the case to determine whether  the contract needs to be terminated. State incentive managers are also required to verify certain eligibility  criteria and personnel documents manually in the Guard Incentive  Management System. State incentive managers use checklists to review  a soldier’s incentive contract and unit orders to determine eligibility. The  Selected Reserve Incentive Program requires that incentive contracts of  more than three years be paid out in installments. State incentive  managers or their designees are required to manually review each  incentive contract before making an anniversary payment. During our site  visits, we observed state incentive managers using the Guard Incentive  Management System to review whether a soldier was eligible to receive a  payment. For example, in Nebraska we observed an incentive manager  using the Guard Incentive Management System to verify a soldier’s  contract period, unit assignment, and physical fitness test scores, among  other items, to confirm the soldier’s eligibility to receive a payment. In  Illinois, we observed an incentive manager using the Guard Incentive  Management System to verify a soldier’s identity, unit transfer orders, and  an eligible student loan before approving a student loan repayment for  further review at the national level. We also observed an incentive  manager in Illinois reviewing a soldier’s incentive contract, which was  being terminated because the soldier had failed to attend required drills.  ARNG personnel in each of the states we visited told us that the Guard  Incentive Management System provides a strong barrier against soldiers  receiving improper payments. The Guard Incentive Management System  also tracks and records each user’s actions on each incentive case to  provide an audit trail, which we observed in multiple states. In addition to reviews conducted at the state level, ARNG conducts  another review of incentive payments using the Guard Incentive  Management System. Once a contract has been reviewed at the state  level, state incentive managers forward it to the ARNG Incentive Support  Team for another review. The ARNG Incentive Support Team has  provided assistance to all 54 states, territories, and the District of  Columbia, by conducting reviews of 100 percent of incentive payments  and terminations, among other things. After the ARNG Incentive Support  Team’s review, ARNG officials perform a final review of an incentive  payment before it is certified. Specifically, ARNG officials review a  random sample of 10 percent of contracts from a batch of incentive  payments that the Guard Incentive Management System generates.  ARNG officials told us that if 25 percent or more of this 10 percent sample  is rejected because it contains errors, all of the contracts in the batch are  returned to the ARNG Incentive Support Team or their respective states  for additional review. If less than 25 percent are rejected, the individual  contracts with errors are returned to the ARNG Incentive Support Team  or their respective states for additional review. The remainder of the batch  passes ARNG review, and the Guard Incentive Management System  generates payment files electronically and transfers them to the Defense  Finance and Accounting Service, which disburses funds to the soldiers,  as shown in figure 1. Second, ARNG conducts periodic reviews of its incentive program.  Specifically, National Guard Regulation 600-7, Selected Reserve  Incentive Program—issued in August 2014—classifies incentive  programs as a high-risk function that should be evaluated every year to  mitigate risks, and that management controls must be evaluated at least  once every five years. Each of the six states we visited had either  conducted an internal review of its incentive program since 2016 or told  us that it had plans to conduct one within the next year. For example,  ARNG officials in Nevada had evaluated and certified the internal controls  of their incentive program in 2017, and ARNG officials in Delaware told us  that they plan to request an external evaluation of their incentive program  in 2018. ARNG Has Taken Steps to  Address Some  Weaknesses Affecting Its  Internal Controls but Has  Not Planned for Future  Significant Changes ARNG took steps to address some identified weaknesses to its internal  controls for managing soldier incentive contracts, but has not developed  and implemented a plan for future significant changes that could affect its  internal controls. For example, in October 2015, a previous contract to  support the ARNG Incentive Support Team expired, and performance of  the follow-on contract was delayed for approximately two years—until  September 2017—by actions related to two GAO bid protests. From  October 2015 to January 2016, ARNG used a 3-month bridge contract  with the previous contractor to provide support and enable the ARNG  Incentive Support Team to continue to perform 100 percent reviews.  However, in January 2016, the ARNG Incentive Support Team stopped  conducting 100 percent reviews of incentive contracts. At that time,  according to ARNG officials, ARNG increased their review of incentive  contracts from 10 percent to 30 percent to help mitigate the loss of the  100 percent review that the ARNG Incentive Support Team had  previously provided. On September 30, 2017, the current contract for the  ARNG Incentive Support Team was awarded and according to ARNG  officials, the ARNG Incentive Support Team reinstated 100 percent  reviews of soldier incentive contracts on December 8, 2017. ARNG also  adjusted their review of soldier incentive contracts from 30 percent back  to 10 percent. As another example, in April 2017, ARNG issued the fiscal year 2017  Selected Reserve Incentive Program policy. Among other things, the  policy changed the eligibility requirement for receiving an incentive  payment based on soldier performance on the Army Physical Fitness  Test. Under the previous policy, soldiers who failed two consecutive  fitness tests would be ineligible to receive an incentive. The fiscal year  2017 policy changed this requirement to two failures during the lifetime of  a soldier’s incentive contract, which could be up to six years. According to  ARNG officials, approximately 8,000 incentive contracts are affected by  this requirement. NGB requires the vendor managing the Reserve  Component Manpower System, which includes the Guard Incentive  Management System, to update the system with any policy changes.  However, ARNG officials told us that they had not updated the Guard  Incentive Management System with the fiscal year 2017 policy.  Therefore, the system’s automated reviews are unable to check for this  eligibility requirement. Additionally, according to ARNG officials, ARNG did not publish official  guidance regarding this discrepancy. Instead, ARNG informally discussed  with state incentive managers that the fiscal year 2018 policy, once  issued, would eliminate this requirement. ARNG officials told us that a  separate transition of vendors for the Reserve Component Manpower  System that began in 2016 had delayed their ability to update the Guard  Incentive Management System with the fiscal year 2017 policy. ARNG  had not anticipated that the vendor would be unable to update the Guard  Incentive Management System as a result of technical challenges  following the transition. ARNG officials also told us that they are currently  developing the fiscal year 2018 policy and would update the Guard  Incentive Management System with this policy when it is ready. On  December 6, 2017, we provided our observations to ARNG on the  inability of the Guard Incentive Management System to perform  automated monitoring on these 8,000 incentive contracts. According to  ARNG officials, on December 7, 2017, they submitted a formal change  request to the vendor to incorporate this rule in the Guard Incentive  Management System, and they expect the rule to be incorporated in  February 2018. ARNG has also taken steps to address unforeseen technical issues that  have affected its incentive program. For example, ARNG officials told us  that they have implemented several recommendations that were made as  part of the Army’s administrative investigation of the transition in vendors  managing the Reserve Component Manpower System, of which the  Guard Incentive Management System is a component. The investigation  determined that ARNG was not positioned to provide sufficient technical  oversight of the transition, and in September 2016, the investigation’s  report recommended that ARNG, among other things, assign a highly  skilled Information Technology subject matter expert to provide oversight  of all government and contractor activities related to the Reserve  Component Manpower System. ARNG officials also told us they had  since assigned this expert and had implemented other recommendations  from the investigation, but were not tracking progress on those recommendations. Additionally, ARNG officials told us that, as of October  2017, they were in the process of revising their performance work  statement for the current vendor. These revisions may include, among  other things, providing other types of technical support and reducing the  amount of time that the system would be unavailable to ARNG and  others. Finally, ARNG officials told us that they plan to use an existing  Information Technology steering committee to provide oversight for the  Reserve Component Manpower System; however, these same officials  told us that the steering committee had not met from May 2017 through  October 2017. While ARNG has taken steps to remedy some technical issues and  weaknesses in its internal controls, it has not demonstrated that it has  learned from its past experiences by planning for significant changes to  its incentive program that could affect its internal controls, such as its  information systems not functioning correctly or data related to incentive  contracts not being readily updated or available for an extended period of  time. These changes include, for example, the next vendor transition for  the Reserve Component Manpower System, which is expected to be re- competed in 2020. Additionally, as ARNG continues deployment of the  Integrated Personnel and Pay System – Army in 2018, it is anticipated  that aspects of the Reserve Component Manpower System will change.  Standards for Internal Control in the Federal Government states that  management should identify, analyze, and respond to significant changes  that could affect the entity’s internal control system. Because conditions  affecting the entity and its environment continually change, management  can anticipate and plan for significant changes by using a forward-looking  process to prepare for change. Planning for significant changes— including those cited earlier—requires time and coordination in advance  of the changes occurring. However, ARNG officials have been unable to  demonstrate their planning efforts to identify, analyze, and respond to any  significant changes to ARNG’s internal controls that may arise if, for  example, the contract is awarded to a new vendor or as the Reserve  Component Manpower System fully interfaces with the Integrated  Personnel and Pay System – Army. Without taking action to plan for  potentially significant changes to its internal controls for the Reserve  Component Manpower System, ARNG is at risk of not being prepared for  these changes that could contribute to the potential for making improper  payments. DOD Components  Have the Authority to  Waive Soldier  Incentive Debt, and  DOD Has Improved  the Availability of  Documentation to  Adjudicate Waiver  Cases  Two DOD Components  Have the Authority to  Waive ARNG Soldier  Incentive Debts for Military  Pay and Allowances The Defense Finance and Accounting Service (DFAS) and the Defense  Office of Hearings and Appeals (DOHA) have the authority to waive  erroneous incentive debts for ARNG soldiers. DFAS is a DOD  component that maintains records of soldiers’ debts and has the authority  to waive established debts of $10,000 or less. DOHA, another DOD  component, adjudicates waivers for debts of more than $10,000. For  established debts, DFAS will notify the soldier that a debt exists and will  be collected. In response, the soldier can submit a request to DFAS to  waive the debt. DFAS has the statutory authority to waive debts incurred  as a result of erroneous payments of up to $10,000 to members of the  armed services, including ARNG soldiers. If DFAS denies all or part of the  waiver request, it informs the waiver applicant of the right to file an appeal  of the denial to DOHA within 30 days. Soldiers can file for a waiver of  indebtedness from DFAS for a period of up to 5 years from the date an  erroneous payment is discovered. DFAS may not consider waiver  applications that it receives after that 5-year period. DOHA has the authority to review waiver cases forwarded by DFAS and  to adjudicate appeals from soldiers whose waiver applications have been  denied. According to DOHA officials, they review only cases in which (1)  the payment has been identified as erroneous, (2) a collection action has  been started, and (3) the soldier has been given rights under the Fair  Debt Collection Practices Act. DOHA officials told us that they do not  have authority over the establishment or collection of a debt or the  authority to conduct a hearing for a soldier contesting the validity of a  debt. However, DOHA officials told us that they will verify the correctness  of the debt before adjudicating a waiver case and may request  information from DFAS—such as documentation—including enlistment  contracts, payment vouchers, and leave and earnings statements.  Additionally, DOHA officials told us that they do not have the authority to  adjudicate debts for payments made under the Student Loan Repayment  Program—one type of payment under the Selected Reserve Incentive  Program—because of their determination that their authority to waive  debts for erroneously paid “pay and allowances” as defined in 32 U.S.C. §  716 and 10 U.S.C. § 2774(a) does not apply to payments to lenders for  educational expenses. Those cases are reviewed and adjudicated at the  discretion of the Secretary of the Army. If DOHA denies a soldier’s waiver  application, the soldier may request that DOHA reconsider its decision,  which DOHA officials told us is accomplished by an appeals panel of  three DOHA attorneys. The decision of this panel is final and ends the  waiver of indebtedness adjudication process, as depicted in figure 2. DOD Has Improved the  Availability of  Documentation to  Adjudicate Waiver Cases DOD has improved the availability of the documentation that is used to  adjudicate waiver cases for soldiers’ debts. DOHA officials told us that  adjudication was sometimes delayed because case files lacked  documentation. As part of our review of DOHA waiver case files, we  found several examples of ARNG cases involving Selected Reserve  Incentive Program debts that had been adjudicated between January  2014 and December 2016, in which DOHA adjudicators had to acquire  missing information, including documentation, from external sources  before adjudicating the case. For example, in one case from Alabama  that was adjudicated in 2014, it was 83 days before DOHA officials  received the documentation they needed. DOHA officials told us this  information included the soldier’s bonus agreement, leave and earnings  statements, and transfer orders. In another case from California that was  adjudicated in 2016, it took adjudicators 74 days to obtain additional information. DOHA officials told us this information included payment  vouchers. DOD’s use of the Guard Incentive Management System has facilitated  the availability of documentation needed to adjudicate waiver cases. For  example, the system stores incentive payment and eligibility  documentation, which may help to reduce delays in the adjudication of  waivers associated with missing documentation. Before making an  incentive payment, state incentive managers are required to inspect case  documentation in the Guard Incentive Management System to validate  the payment. During our site visits to selected states, we observed state  incentive managers using the Guard Incentive Management System to  review documents, such as re-enlistment contracts and unit orders. In  several cases, we observed state incentive managers identifying errors in  documents, and we observed their ability to correct these documents. For  example, in Nebraska we observed a case in which a soldier’s military  occupational specialty code in the Guard Incentive Management System  was not in line with what was in the incentive contract, because the unit  had been reorganized. We then observed a state incentive manager  confirming the soldier’s transfer orders and uploading this documentation  into the Guard Incentive Management System. Our observations are not  generalizable across all states or for all contracts, but they suggest that  documentation required to adjudicate waiver cases is now more readily  available and will continue to be in the future. DOD also updated its Financial Management Regulation to improve the  availability of documentation. DOHA officials told us that DOD had  updated the Financial Management Regulation in January 2016.  Specifically, Volume 16, Chapter 4, Section 040403 of the DOD Financial  Management Regulation instructs applicants to include in their waiver  requests (1) copies of all supporting documentation, (2) copies of leave  and earnings statements, (3) copies of notifications of personnel actions,  and (4) any statements from the applicant in support of the waiver  application. DOHA officials stated that this revision should reduce  documentation-related delays during their review of future waiver  submissions. Additionally, DOHA officials told us that they have taken  steps to train DFAS personnel, who are responsible for reviewing waiver  applications, in an effort to reduce delays. Conclusions ARNG has made progress in improving its internal controls since  widespread improper payments were identified in California in 2008. By  using the Guard Incentive Management System and requiring multiple  levels of review before incentives are paid, ARNG may have reduced the  likelihood of future widespread improper payments similar to what  occurred in California. However, it is important for ARNG to be forward  looking in preserving the integrity of its internal controls. ARNG has faced  challenges during the transition between vendors managing the system  that resulted in the weakening of internal controls, including those built  into the Guard Incentive Management System. To its credit, ARNG has  taken mitigating actions to prevent improper payments while attempting to  address those issues. These challenges, and the need for mitigating  actions, could have been prevented if ARNG had identified and prepared  in advance for challenges potentially resulting from the vendor transition.  If ARNG does not proactively identify, analyze, and plan to respond to  significant changes that could affect the internal controls to its incentive  program, there is an increased risk that additional weaknesses to its  internal controls could emerge and result in an increased likelihood of  improper payments. Recommendation We are making one recommendation to ARNG:  The Director of the Army National Guard should develop and implement a  plan to identify, analyze, and address any significant changes that could  affect internal controls for its Guard Incentive Management System.  (Recommendation 1) Agency Comments  and Our Evaluation We provided a draft of this report to ARNG for comment. In its comments,  reproduced in appendix I, ARNG concurred with our recommendation and  stated that they initiated a project to improve internal control measures as  significant changes are made to the Guard Incentive Management  System to align the system with policy. ARNG also stated that the project  would look at the time required to adjust incentives to effect change within  the organization and achieve its strength goals. ARNG expects the  project to be completed in August 2018. We believe this action would  meet the intent of our recommendation. We are sending copies of this report to the Secretary of Defense, the  Chief of the National Guard Bureau, and the Director of the Army National  Guard. In addition, the report is available at no charge on the GAO  website at http://www.gao.gov. If you or your staff have any questions about this report, please contact  me at (202) 512-9971 or kirschbaumj@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix II. Appendix I: Comments from the Army  National Guard Appendix II: GAO Contact and Staff  Acknowledgments GAO Contact Staff  Acknowledgments In addition to the contact named above, Tina Won Sherman (Assistant  Director), David Blanding Jr., Vincent Buquicchio, Wesley Collins, Joanne  Landesman, Amie Lesser, Jim Melton, and Paul Seely made significant  contributions to this report.
ARNG provides trained and equipped units ready to defend life and property in the 54 states, territories, and the District of Columbia. In 2011, the Army Audit Agency reported weaknesses in internal controls over soldier incentive payments in the California ARNG that led to some improper payments. DOD initially took actions to recoup some of these payments, but the National Defense Authorization Act for Fiscal Year 2017 allowed for the waiver or other forgiveness of debt. The National Defense Authorization Act for Fiscal Year 2017 included a provision for GAO to assess policies and procedures for minimizing and waiving the recoupment of improper payments. This report (1) evaluates the extent to which ARNG has implemented and planned to adjust the internal controls for its Selected Reserve Incentive Program to prevent improper payments and (2) describes which DOD organizations have the authority to waive ARNG incentive debts and steps taken to improve waiver documentation. GAO conducted site visits to six states based on the value of their incentive programs, reviewed documentation used to manage incentive programs, examined incentive debt waiver cases, and interviewed DOD officials. In response to the over $22 million in improper payments the California Army National Guard (ARNG) made in cash bonuses and other soldier incentives from 2004 through 2010, ARNG officials implemented some internal controls to prevent future improper incentive payments. These internal controls include automated and manual checks of soldier incentive contracts to verify soldiers' eligibility for incentive payments. For example, ARNG implemented automated rules in its Guard Incentive Management System—an online system that tracks incentive contracts—to monitor a soldier's eligibility for an incentive by comparing the data received from multiple personnel systems against the soldier's contract. If any issues are found, the Guard Incentive Management System will flag the incentive case for review by state ARNG officials and will stop future payments until the issue is resolved. While these internal controls have improved accountability over soldier incentive payments, ARNG is still in the process of completing further actions. For example, in April 2017, ARNG issued the fiscal year 2017 Selected Reserve Incentive Program policy. However, ARNG did not incorporate changes as a result of this policy into the Guard Incentive Management System to ensure that the automated checks captured these policy changes—including one that affects approximately 8,000 solider incentive contracts, according to ARNG officials. ARNG officials told us that they had not updated the Guard Incentive Management System with this policy because of technical challenges resulting from a transition in vendors for the Reserve Component Manpower System—an information system that houses the Guard Incentive Management System. ARNG officials also told us that they plan to update the Guard Incentive Management System to include the 2017 policy in February 2018. GAO also found that ARNG had not developed and implemented a plan for future significant changes that could affect its internal controls over soldier incentive payments. These changes include, for example, the end of the current vendor contract in 2020 to support the Reserve Component Manpower System and the Army National Guard's migration to the Integrated Personnel and Pay System – Army that is scheduled to occur in 2018. Standards for Internal Control in the Federal Government states that management should identify, analyze, and respond to significant changes that could affect an internal control system. Specifically, because conditions affecting an organization and its environment continually change, management needs to anticipate and plan for significant changes by using a forward-looking process to prepare for those changes. Without taking action to plan for such changes, ARNG puts itself at risk of making improper payments in the future. The Defense Finance and Accounting Service and the Defense Office of Hearings and Appeals review and adjudicate requests for waivers of incentive debt. DOD has taken two steps to improve the availability of documentation needed to adjudicate waiver cases. First, DOD has clarified the policy in its Financial Management Regulation on the documentation soldiers are required to provide. Second, officials review documentation in the Guard Incentive Management System before validating an incentive payment, which may reduce delays associated with missing documentation when processing waiver requests.