Originally published in The Hill on May 14, 2026. Read the original article.
On April 29, the House Oversight and Government Reform Committee advanced nine anti-fraud bills, most with bipartisan support. Two of them get close to the structural reform federal emergency programs have needed for decades. Neither gets all the way there.
I worked on the Paycheck Protection Program at the Small Business Administration as a loan specialist. By the time problematic loans came into focus, the money was already out the door. The government’s task was forgiveness review and integrity work on loans that had already been disbursed. I spent years on that reconstruction.
After my first article on emergency loan reform was published, I was asked if I had ever heard of the Green Book. I had not. When I looked it up, I found that the reforms I had identified from working in the program aligned with an internal control framework I did not know existed. The work had already taught me what the framework formally required.
The Government Accountability Office first issued its Standards for Internal Control in the Federal Government in 1983, commonly known as the Green Book. The framework is built around five components covering risk assessment, control activities, monitoring and the systems and accountability that hold them together. Congress has never required agencies to have it operational before emergency money moves.
After Hurricane Katrina, GAO estimated that improper or potentially fraudulent individual assistance payments totaled between $600 million and $1.4 billion. Twenty years later, the Paycheck Protection Program moved hundreds of billions of dollars in a matter of weeks. Section 1102 of the CARES Act established the program’s basic architecture, including reliance on borrower self-certification at the front end without independent verification at origination. The Small Business Administration’s implementing guidance operated within those statutory limits. That decision accelerated relief. It also generated years of cleanup.
The 2025 Green Book revision, effective for fiscal year 2026, strengthened the framework further and explicitly addressed emergency assistance programs. What is still missing is the requirement to have it operational before the next crisis.
The bills the House Oversight Committee advanced last week begin to address parts of this gap. TheTaxpayer Resources Used in Emergencies Accountability Act, or TRUE Accountability Act, would require the Office of Management and Budget to issue guidance for agency internal control plans during future emergency spending. The Zeroing Out Monetary Benefits Improperly Expended Act, or ZOMBIE Act, would mandate implementation of fraud risk management practices, including the GAO Fraud Risk Framework.
Both bills move in the right direction. But neither requires that the framework be operational before emergency disbursement authority is exercised.
Congress should make Green Book readiness a precondition for emergency disbursement authority across lending, grant and direct payment programs. Before a new emergency program begins sending money out, the administering agency should be required to certify that the five Green Book components are operational. Office of Management and Budget guidance issued during a crisis is not the same as a readiness certification before one. The first tells agencies what to do once spending begins. The second confirms the architecture exists before the first dollar moves.
The speed concern is real. In the spring of 2020, millions of small businesses had already temporarily closed within weeks of the COVID-19 shutdowns, and the pressure to move money was intense. Building controls during a crisis is too late. Building them in advance is the only way to have both speed and integrity when the next one hits.
Agencies can build these frameworks during normal operations. They can identify high-risk features in advance and establish documentation standards, escalation paths and accountability lines before emergency volume arrives. If Congress wants speed and integrity when the next crisis hits, the answer is preparation.
We do not deploy disaster relief without logistics plans already in place. Those systems are built in advance because everyone understands that figuring it out in the middle of a crisis costs more. Yet for emergency financial assistance, we keep building the plane while we are flying it.
The Green Book is the blueprint. The requirement to certify readiness needs to come before the next flight.
Traci Harig is a former GS-13 loan specialist at the U.S. Small Business Administration, where her work on the Paycheck Protection Program included forgiveness reviews, eligibility reviews, appeals, and support for federal investigations and False Claims Act matters.
The views expressed are my own, based on publicly available information and professional experience.
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