It doesn't make sense to me at all that the government would say it's being compassionate by not bothering to find out who the people are who received money they were ineligible for.
You might argue it's compassionate if you do the follow-up work, identify that there are certain people who had understandable circumstances, and therefore decide, transparently, to make a decision around not requiring payback in that particular case, but in what world is it compassionate to say we're just not going to bother to do the work? That seems more like laziness on the part of the government than compassion.
Your recommendation, then, is not to direct the government on policy; it's to make a recommendation on process, which is that the government do the follow-up work and then be transparent about what it plans to do next.
Is that correct?