Department of Veterans Affairs
 

Office of Inspector General
 

Informational Report
 

Community Based Outpatient
 

Clinic Cyclical Reports
 

FY 2011
 

Report No. 11-01406-177 May 31, 2011
 VA Office of Inspector General
 

Washington, DC 20420
 
To Report Suspected Wrongdoing in VA Programs and Operations:
 

Telephone: 1-800-488-8244
 

E-Mail: vaoighotline@va.gov
 

(Hotline Information: http://www.va.gov/oig/contacts/hotline.asp)
 
Community Based Outpatient Clinic Cyclical Reports FY2011 

Contents 

Page
 

Executive Summary ..............................................................................................i
 

Purpose 

Appendixes
 

.................................................................................................................1
 

Background ..........................................................................................................1
 

Review Purpose and Objectives .........................................................................1
 

Methodology .........................................................................................................3
 

Focused Topic Areas ...........................................................................................4
 

Mental Health Continuity of Care ................................................................................... 4
 

Short-Term Fee Basis ...................................................................................................... 6
 

Women’s Health .............................................................................................................. 6
 

Credentialing and Privileging .......................................................................................... 8
 

Skills Competency ........................................................................................................... 8
 

Environment and Emergency Management..................................................................... 9
 

Primary Care Management Module Review ................................................................... 9
 

Contract Reviews........................................................................................................... 10
 

Report Timeline ..................................................................................................11
 

A. OIG Contact and Staff Acknowledgments .............................................................. 12
 

B. Report Distribution................................................................................................... 13
 

VA Office of Inspector General 
Community Based Outpatient Clinic Cyclical Reports 

Executive Summary 

As requested in House Report 110-775, to accompany H.R. 6599, Military Construction, 

Veterans Affairs, and Related Agencies Appropriation Bill, fiscal year (FY) 2009, the 

VA Office of Inspector General (OIG) began a systematic review of Veterans Health 

Administration (VHA) community based outpatient clinics (CBOCs). The purpose of 

this report is to describe the study design of the forthcoming CBOC reviews. 

VA Office of Inspector General i 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

DEPARTMENT OF VETERANS AFFAIRS
 

Office of Inspector General
 

Washington, DC 20420
 

SUBJECT: Informational Report – Community Based Outpatient Clinic Cyclical 

Reports 

Purpose 

As requested in House Report 110-775, to accompany H.R. 6599, Military Construction, 

Veterans Affairs, and Related Agencies Appropriation Bill, fiscal year (FY) 2009, the 

VA Office of Inspector General (OIG) began a systematic review of Veterans Health 

Administration (VHA) community based outpatient clinics (CBOCs) in FY 2009. The 

purpose of this report is to describe the review design of the CBOC focused topic areas 

for April through September 2011. 

Background 

The Veterans’ Health Care Eligibility Reform Act of 1996 was enacted to equip VA 

with ways to provide veterans with medically needed care in a more equitable and 

cost-effective manner. As a result, VHA expanded the Ambulatory and Primary Care 

Services to include CBOCs located throughout the United States. CBOCs were 

established to provide more convenient access to care for currently enrolled users and to 

improve access opportunities within existing resources for eligible veterans not currently 

served. 

Veterans are required to receive one standard of care at all VHA health care facilities. 

Care at CBOCs needs to be consistent, safe, and of high quality, regardless of model (VA 

staffed or contract). CBOCs are expected to comply with all relevant VA policies and 

procedures, including those related to quality, patient safety, and performance. 

The Office of Healthcare Inspections has conducted reviews at 190 CBOCs, which have 

resulted in 18 published reports. 

Review Purpose and Objectives 

The purpose of the cyclical reviews is to assess whether CBOCs are operated in a manner 

that provides veterans with consistent, safe, high-quality health care in accordance with 

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Community Based Outpatient Clinic Cyclical Reports FY 2011 

VA policies and procedures. The objectives of the focused reviews for this identified 

review period are: 

1. Determine whether CBOCs	 comply with selected standards in VHA Handbook 

1160.011 regarding the management of mental health (MH) emergencies. 

a.	 Determine whether the CBOCs have a local policy/guideline defining how MH 

emergencies are handled. 

b. Determine whether the CBOCs are sharing/receiving information if a patient 

had a MH emergency and was treated at a community emergency department. 

2. Assess Short-Term Fee Basis authorization and follow up processes for outpatient 

radiology consults including computerized tomography (CT), magnetic resonance 

imaging (MRI), positron emission tomography (PET) scan, and mammography in an 

effort to ensure quality and timeliness of patient care in CBOCs. 

a.	 Determine the parent facility’s compliance with established standards, 

regulations, and policies in regards to the authorization of Short-Term Fee 

Basis consults for CBOCs. 

b. Determine whether the parent facility has a local policy or guideline defining 

how Short-Term Fee Basis consults are handled in CBOCs. 

c.	 Determine if VA providers appropriately ordered and followed up on ShortTerm Fee Basis outpatient radiology procedures (CT, MRI, PET scan, and 

mammography) in a timely manner. 

3. Determine whether CBOCs comply with selected VHA requirements regarding the 

provision of mammography services for women veterans. 

a.	 Determine whether screening mammograms were offered in a timely manner 

to women veterans receiving care at CBOCs and whether results were 

available in Computerized Patient Record System using required Breast 

Imaging Reporting and Data System [BI-RADS] code categories. 

b. Determine whether ordering providers and patients received notification of 

mammography results within timeframes established by VHA. 

c.	 Determine whether non-VA contract mammography facilities providing 

services for CBOC women veterans maintain required certification. 

d. Determine whether VHA facilities have	 established effective oversight of 

mammography services. 

e.	 Determine whether CBOCs have designated women’s health liaisons who 

collaborate with the parent facility Women Veterans Program Manager to 

ensure coordinated and comprehensive care for women veterans. 

4. Determine whether CBOC providers are appropriately credentialed and privileged in 

accordance to VHA Handbook 1100.19.2 

1 VHA Handbook 1160.1, Uniform Mental Health Services in VA Medical Centers and Clinics, September 11, 2008. 2 VHA Handbook 1100.19, Credentialing and Privileging, November 14, 2008. 

VA Office of Inspector General 2 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

5. Determine if the CBOCs have a skills competency assessment and validation policy 

and process in place and if individuals performing competency assessment and 

validation have the education, background, experience, or knowledge related to the 

skills assessed. 

a.	 Determine if staff competence is initially assessed and documented as part of 

orientation. 

b. Determine ongoing competency assessment and validation for skill-specific 

competencies. 

6. Determine whether CBOCs are in compliance with standards of operations according 

to VHA Handbook 1006.13 in the areas of: 

a.	 Environmental safety. 

b. Emergency plan. 

7. Determine whether	 primary care active panel management and reporting are in 

compliance with VHA policy4 in the areas of: 

a.	 Primary Care Provider (PCP) panel sizes. 

b. Patient assignment to PCP panels, with emphasis on patient assignment to 

more than PCP. 

c.	 Timing of patient removal from panels for inactivity. 

8. Determine whether primary care and MH	 services provided at contracted CBOCs are 

in compliance with the contract provisions and evaluate the effectiveness of contract 

oversight provided by the VA focusing on: 

a.	 Contract provisions related to payment for services, invoice format, and 

performance-based incentives and penalties. 

b. The invoice validation process. 

c.	 Timely access to care. 

Methodology 

CBOC inspections consist of four components: (1) CBOC site-specific information 

gathering and review; (2) medical record reviews for determining compliance with VHA 

performance measures, standards, and regulations; (3) on-site inspections; and (4) CBOC 

contract review and primary care management model review. 

The VISN and Facility Directors will be notified 7 weeks prior to the on-site visit of the 

CBOCs selected for review along with instructions for completing an on-line survey and 

a list of documents needed to conduct the topic area reviews. Through the survey we will 

3 VHA Handbook 1006.1, Planning and Activating Community-Based Outpatient Clinics, May 19, 2004. 4 VHA Handbook 1101.02, Primary Care Management Module (PCMM), April 21, 2009. 

VA Office of Inspector General 3 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

collect descriptive information of each CBOC to include the types of services provided 

and types of providers and auxiliary staff employed at the respective CBOC. 

The requested documents include: (1) CBOC local policies and standard operating 

procedures; (2) list of patients cared for in the specified CBOC who were referred for 

emergency MH services; (3) list of patients who were approved for fee basis services to 

receive imaging studies (CT, MRI, PET Scan and mammography); (4) list of female 

patients ages 50-69; (5) Primary Care Management Module (PCMM) data; and (6) copies 

of the CBOC contract and modifications for Primary Care Services, invoices, and 

payment schedules covering the 1st Quarter, FY 2011 for contracted CBOCs. We 

request that facility managers create a secured SharePoint or shared drive site and place 

the documents there for our review. 

Focused Topic Areas 

MH Continuity of Care 

According to VHA policy, healthcare facilities need to have professional oversight of the 

delivery of MH care in associated CBOCs.5 Also, there must be methods and procedures 

for ensuring communication between the leadership of MH services and the associated 

CBOCs. This requirement for oversight and communication is intended to ensure the 

ability of the CBOC to respond to patients’ MH needs. 

The MH services that must be provided in CBOCs vary according to their size. The size 

of the CBOC is determined by the number of unique veterans annually served. Very 

large CBOCs, those serving 10,000 or more unique veterans each year, are encouraged to 

provide MH intensive case management teams, psychosocial rehabilitation and recovery 

centers intensive outpatient programs for specialty substance abuse treatment services, 

and grant and per diem programs for homeless veterans. Very large CBOCs must 

provide MH services during evening hours at least 1 day per week to those who need 

them. Large CBOCs, those serving 5,000 or more unique veterans annually, must 

provide a substantial component of the MH services required by their patients, either 

onsite or by tele-mental health, but may supplement these services by referrals to 

geographically accessible VA facilities through sharing agreements, contracts, or feebasis mechanisms. Mid-sized CBOCs, those serving between 1,500 and 5,000 unique 

veterans annually, must provide general MH services, if needed by their patients, 

utilizing tele-mental health as necessary. Specialty services must be available to those 

who require them by using on-site services, sharing agreements, contracts, or referrals, as 

well as tele-mental health or fee-basis. Smaller CBOCs, those serving less than 1,500 

uniques veterans, are to provide access to the full range of general and specialty MH 

services to those who require them through on-site services, referrals, contracts, or feebasis, as well as tele-mental health. 

5 VHA Handbook 1160.01. 

VA Office of Inspector General 4 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

General MH services include: 

 Diagnostic and treatment planning evaluations for the full range of MH problems; 

 Treatment services using evidence-based pharmacotherapy or evidence-based 

psychotherapy; 

 Patient and family education; 

 Referrals as needed to inpatient and residential care programs; and 

 Consultations about special emphasis problems. 

Specialty MH services include: 

 Consultation and treatment services for the full range of MH conditions; 

 Evidence-based psychotherapy; 

 MH Intensive Case Management; 

 Psychosocial rehabilitation services including: 

o family education, 

o skills training and peer support, 

o compensated work therapy, and 

o supported employment;
 

 Post traumatic stress disorder teams or specialists;
 

 Military sexual trauma special clinics;
 

 Homeless programs; and
 

 Specialty substance abuse treatment services.
 

CBOCs must have a predetermined plan for responding to MH emergencies when they 

occur during the times of operation. Parent facilities must identify at least one accessible 

VA or community-based emergency department where veterans are directed for emergent 

care. Contracts, sharing agreements, or other appropriate arrangements with those 

facilities for sharing information must be identified. Financial arrangements for payment 

for authorized emergency services and necessary subsequent care must be addressed. 

We will review the respective facility policy as well as sharing agreements and/or 

contracts to determine if there is a plan to respond to MH emergencies. We will also 

review the medical records of 10 patients, unless fewer patients are available, who were 

referred for emergency non-VA MH services, to ensure that documentation related to the 

care received was documented in the medical record. The review of the medical records 

is to determine if local policy documentation requirements were met. 

VA Office of Inspector General 5 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

Short-Term Fee Basis 

VHA’s Chief Business Office, which is aligned under the Deputy Under Secretary for 

Health for Operations and Management, has primary responsibility for the Fee Program. 

Total annual payments for the Fee Program have grown from approximately $1.6 billion 

in FY 2005 to approximately $3.8 billion in FY 2009. 

The purpose of the Fee Program is to assist veterans who cannot easily receive care at a 

VA medical center (VAMC). The Program pays the medical care costs of eligible 

veterans who receive care from non-VA providers when the VAMCs are unable to 

provide specific treatments or provide treatment economically because of their 

geographical inaccessibility. This type of care is known as “Fee Basis” and it may 

include dental services, outpatient care, inpatient care, emergency care, and medical 

transportation. All VAMCs can use this program when needed. It is governed by federal 

laws containing eligibility criteria and other policies specifying when and why it can be 

used. With the exception of some emergencies, Fee Basis care must be authorized prior 

to veterans receiving the services from non-VA providers. Fee Basis care is not an 

entitlement program or a permanent treatment option. 

Short-Term Fee Basis consults are initiated for examinations or for complete episodes of 

treatment within a designated, concise period of time, usually 60 days. VA providers 

request Short-Term Fee Basis care for veterans by initiating a Fee Basis Consult using 

VA Form10-7079 in the Computerized Patient Record System. Veterans who are 

authorized for Short-Term Fee Basis care may select a qualified physician of their choice 

to render the services required. In the absence of this selection, facility staff will arrange 

for treatment by a qualified physician located within a reasonable distance of the 

veteran's residence. 

We will evaluate if VA providers appropriately ordered and followed up on outpatient 

radiology procedures (CT, MRI, PET scan, and mammography). We will request the 

facility’s local policies for Short-Term Fee Basis Care. We will also review the medical 

records of 50 patients, unless fewer patients are available, to evaluate if the facility 

followed applicable VHA policies.

6 

Women’s Health 

Breast cancer is the second most common type of cancer among American women, with 

approximately 207,000 new cases reported each year.7 Timely screening, diagnosis, 

6 Manual M-1, Part I, Chapter 18, Outpatient Care – Fee, July 20, 1995.
 

VHA Directive 2008-056, VHA Consult Policy, September 16, 2008.
 

VHA Handbook 1907.01, Health Information Management and Health Records, August 25, 2006.
 

VHA Directive 2009-019, Ordering and Reporting Test Results, March 24, 2009.
 

VHA CBO Procedure Guide 1601.F, Fee Service.
 7 American Cancer Society, Cancer Facts & Figures 2009.
 

VA Office of Inspector General 6 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

notification, interdisciplinary treatment planning, and treatment are essential to early 

detection, appropriate management, and optimal patient outcomes. Screening by 

mammography (an x-ray of the breast) has been shown to reduce mortality by 

20–30 percent among women age 40 and older. VHA has established gender specific 

performance measures in the facility and CBOCs. Breast cancer screening for women 

ages 50–69 is an ongoing CBOC preventive care performance measure. The breast 

cancer screening performance measure assesses the percentage of patients screened 

according to prescribed timeframes. The performance management system uses the best 

scientific evidence in clinical practice to reliably and efficiently achieve the highest 

quality health outcomes and sets national benchmarks for the quality of preventive and 

therapeutic healthcare services that exceed private sector performance. 

We will review the medical records of 30 randomly selected female patients between 

52 and 69 years of age who had mammograms, unless fewer patients are available 

determine compliance with VHA performance measures and selected VHA policies. 

VHA policy outlines specific requirements that must be met by facilities that perform 

mammography services for women veterans.8 When mammography services are 

obtained through contracts or sharing agreements, the VHA facility must ensure the 

provider is certified by the U.S. Food and Drug Administration (FDA) or a State that has 

been approved by FDA under 21 C.F.R. 900.21 to certify mammography facilities. 

VHA policy9 also requires: 

All VA medical facilities referring patients, under any circumstances, to 

outside (non-VA) mammography facilities must verify that the site(s) has a 

current and valid mammography MSQA [Mammography Quality Standards 

Act] certificate, issued by either FDA or an FDA-approved State. The 

retention of an FDA certificate is assurance the facility is appropriately 

accredited and certified to perform mammography. No patients can be 

referred to a mammography facility that is not FDA or VA-certified. 

Additionally, the CBOC and/or parent facility and contract mammography provider must 

have procedures to identify patients with breast implants and to ensure proper care for 

these patients prior to mammography. 

The CBOC must have assurance of timely result notification to ordering providers, as 

well as processes to ensure patients receive results with appropriate follow-up as needed. 

VHA requires oversight of the tracking and timeliness of follow-up of findings from 

breast cancer screening as a responsibility of the quality management team, in 

collaboration with the Women Veterans Program Manager, diagnostic services, and 

8 VHA Handbook 1330.01, Healthcare Services for Women Veterans, May 21, 2010. 9 VHA Handbook 1104.1, Mammography Standards, August 6, 2003. 

VA Office of Inspector General 7 
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Primary Care Service. CBOCs and independent clinics also must designate a Women’s 

Health clinical liaison to coordinate women’s issues with the parent facility. 

We will evaluate whether: (1) women veterans receiving care at CBOCs had a screening 

mammogram done at least every 2 years, (2) results were available in the patient’s 

medical record, (3) ordering providers and patients received notification of the results, 

(4) non-VA mammography facilities maintained required certification, (5) parent 

facilities established effective oversight of mammography services, and (6) the CBOCs 

designated a women’s health liaison. 

Credentialing and Privileging 

All VHA health care professionals who are permitted by law and the facility to provide 

patient care services independently must be credentialed and privileged. The 

credentialing and privileging (C&P) process is used by medical centers to ensure that 

clinical providers have the appropriate professional licenses and other qualifications to 

practice in a health care setting and that they practice within the scopes of their licenses 

and competencies. 

We will conduct an overall review to assess whether the medical center’s C&P process 

complies with VHA policy.10 We will review providers’ (maximum of five) C&P folders 

(electronic and paper). We will review the privileges granted and Scopes of Practice 

approved by the parent facility to ensure they were appropriate for services rendered at 

the assigned CBOC. During our review of providers’ folders, we will review servicespecific criteria to ensure that ongoing professional practitioner evaluations have been 

developed and approved that outline the minimum competency criteria for privileges with 

documented evidence of sufficient performance data to meet current requirements. 

Skills Competency 

VHA has a High Performance Development Model, which “provides a framework for the 

VHA to develop a highly skilled, customer-centered workforce for the 21st century.” By 

focusing on eight core competencies, the High Performance Development Model 

contributes to the development of a continuous supply of excellent leaders committed to 

VHA's mission.11 The program objectives and competency behaviors are broad and not 

inclusive of specific skills required to perform duties. 

Some CBOCs are located in communities far away from the clinical resources of their 

parent facilities, and CBOC staff members are performing a variety of skills. To ensure 

patient safety, it is important that staff are trained and maintain competence to perform 

the skills they are assigned. 

10 VHA Handbook 1100.19. 11 http://vaww4.va.gov/hpdm/ 

VA Office of Inspector General 8 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

We will evaluate the training records of patient care staff members to ensure that skillspecific competency was validated and documented. Additionally, we will evaluate 

facility policies to ensure that skill-specific competencies are assessed during orientation 

and that the policy addresses the education, background, experience, or knowledge 

related to those who assess the skills. 

Environment and Emergency Management 

Environment of care is crucial to achieving a safe patient care environment, reducing 

infection control risks and improving patient care outcomes. CBOCs must be maintained 

in a state of cleanliness that fully meets all VHA, Occupational Safety and Health 

Administration, and Joint Commission standards. We will conduct environment of care 

rounds at each CBOC to ensure that they adhere to Americans with Disabilities Act, 

National Fire Protection Association regulations, patient safety, and infection control 

guidelines. 

We will review each CBOC’s local emergency management policy and interview 

employees to ensure there is a plan in place to address patients who experience a medical 

or psychological emergency such as heart attack, hypoglycemic events, suicidal, or 

homicidal ideations. We will also ensure that staff are aware and can articulate the steps 

of handling a medical or psychological emergency. 

PCMM Review 

The application that runs on the Veterans Health Information Systems and Technology 

Architecture (VistA) is the primary means for VHA to track and manage patients in 

primary care panels. The PCMM Coordinator is responsible for ensuring that the 

information in the PCMM database is accurate and current. We will be reviewing 

compliance with VHA policy regarding patient assignment to and removal from a PCP 

panel.12 

We will accomplish this by: 

	 Inquiring with the PCMM Coordinator about the process used to maintain timely 

and accurate data in the PCMM. 

	 Reviewing the PCMM panel assignment process to determine if the facility checks 

to see if a patient is already assigned to a PCP panel at another facility prior to 

assigning a new patient to a PCP panel. 

	 Verifying that inactivation is performed if the patient expires, transfers, or has not 

been seen by his or her assigned PCP within PCMM established timeframes.13 

12 VHA Handbook 1101.02.
 13 Timeframes cannot exceed 12 months for newly assigned patients and 24 months for established patients.
 

VA Office of Inspector General 9 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

	 Using the VHA Support Service Center (VSSC) web site to run reports to analyze 

data reported by the parent facility. 

The accuracy of the data in the PCMM database is critical to ensuring that resources 

supporting primary care are appropriately allocated. PCMM is used to identify the PCP 

assigned to care for each patient. A patient should not have more than one PCP assigned; 

however, in certain approved cases it is appropriate. This application is an important tool 

in determining the total number of veterans that can be cared for in the VA health care 

system and align the supply of services with demand. 

We will perform inquiries of PCMM Coordinators to review the processes used to update 

PCMM patient panels for transfers to other facilities, deaths, and duplicate enrollments 

and software service patches are current. We will review reports from the VSSC for 

active and unique enrollees to compare against the number of invoiced enrollees. 

Additionally, we will review VSSC reports on duplicated PCP assignments to assess if 

the PCMM Coordinators were monitoring duplicate enrollees. 

Contract Review 

Approximately 23 percent of all CBOCs are contract. CBOC contracts are administered 

and monitored by the parent facility. A Contracting Officer’s Technical Representative 

(COTR) is delegated to provide oversight of the contractor providing care at the CBOC. 

We will conduct our reviews of primary care and MH CBOC contracts to evaluate the 

effectiveness of oversight provided by the COTR and the compliance with selected 

contract provisions relating to payment of services. 

We will verify that the number of enrollees or visits that are reported is consistent with 

what is actually supported with collaborating documentation. We will accomplish this 

by: 

	 Interviewing the COTR to gain an understanding of the invoice validation process. 

	 Reviewing invoices and supporting documentation focusing on accuracy of 

calculations, rates charged, and the number of enrollees or visits. 

	 Analyzing VistA, data to assess the reasonableness of invoice amounts. 

	 Comparing invoice amounts with what the VA actually paid by cross-checking 

with payments made and recorded in the Data Management System. 

	 Interviewing the Contracting Officer about contractual and performance matters. 

We will review the methodology for tracking and reporting the number of enrollees in 

compliance with the terms of the contract. Additionally, we will review paid capitation 

rates for compliance with the contract; form and substance of the contract invoices for 

VA Office of Inspector General 10 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

ease of data analysis by the COTR; and duplicate, missing, or incomplete social security 

numbers on the invoices. 

We will perform inquiries of COTRs to determine the scope of MH services provided, 

compliance with contract terms and conditions, contracted care pricing models, and 

processes used to validate MH billings. We will analyze VistA data for MH encounters 

to test accuracy of billings and determine the providers of care. Additionally, we will 

review the pricing models employed. 

Report Timeline 

A report will be issued approximately 60 days after the on-site inspection of the CBOC. 

The report will cover the inspection of three to five VAMCs’ CBOCs, which are usually 

two per medical center. Each report will cover our findings of the objectives described 

earlier in this report. The first report will be issued in June 2011 (CBOCs visited in April 

2011). 

At the end of the fiscal year, we will aggregate the data and issue a report. The FY 2011 

report will address 85 inspections conducted during the months of October 2010 through 

September 2011. However, this informational report addresses inspection activities 

planned for April through September 2011. 

JOHN D. DAIGH, JR., M.D.
 

Assistant Inspector General for
 

Healthcare Inspections
 

VA Office of Inspector General 11 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

Appendix A 

OIG Contact and Staff Acknowledgments 

OIG Contact	 For more information about this report, please contact the 

Office of Inspector General at (202) 461-4720. 

Acknowledgments	 Marisa Casado, RN 

Anthony M. Leigh, CPA 

Zhana Johnson, CPA 

Jennifer Reed, RN 

Marilyn Stones, BS 

VA Office of Inspector General 12 
Community Based Outpatient Clinic Cyclical Reports FY 2011 

Appendix B 

Report Distribution 

VA Distribution 

Office of the Secretary 

Veterans Health Administration 

Assistant Secretaries 

General Counsel 

Veterans Integrated Service Network Directors (1–23) 

Non-VA Distribution 

House Committee on Veterans’ Affairs 

House Appropriations Subcommittee on Military Construction, Veterans Affairs, and 

Related Agencies 

House Committee on Oversight and Government Reform 

Senate Committee on Veterans’ Affairs 

Senate Appropriations Subcommittee on Military Construction, Veterans Affairs, and 

Related Agencies 

Senate Committee on Homeland Security and Governmental Affairs 

National Veterans Service Organizations 

Government Accountability Office 

Office of Management and Budget 

This report is available at http://www.va.gov/oig/publications/reports-list.asp. 

VA Office of Inspector General 13