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.…

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.