VETERANS 

PARALYMPICS 

PROGRAM

Improved Reporting 

Needed to Ensure 

Grant Accountability

Report to Congressional Committees

July 2012

GAO-12-703

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-703, a report to 

congressional committees

July 2012

VETERANS PARALYMPICS PROGRAM

Improved Reporting Needed to Ensure Grant 

Accountability

Why GAO Did This Study

The Veterans Benefits Improvement 

Act of 2008 established VA’s 

Paralympics Program to promote the 

lifelong health of disabled veterans and 

members of the Armed Forces through 

physical activity and sports. 

Additionally, the act authorized VA to 

provide a grant to USOC’s Paralympics 

Division, and allowed USOC to enter 

into subgrant agreements to provide 

adaptive sports activities to veterans 

and service members. The act also 

mandated GAO to report on the VA 

Paralympics program. 

GAO is required to (1) review how VA 

and its grantee and subgrantees used 

program funds to provide adaptive 

sports opportunities to veterans and 

service members; (2) assess how VA 

is overseeing its grantee’s and 

subgrantees’ use of funds; and (3) 

describe how veterans and service 

members have benefited from VA 

Paralympics activities. To do this, GAO 

reviewed relevant federal laws, 

regulations, guidance, agency reports, 

and a non-probability sample of 21 of 

76 subgrant files, consisting of data on 

about 56 percent of funds subgranted. 

GAO also conducted site visits to two 

states and interviewed veterans as well 

as agency and grantee officials. 

What GAO Recommends

GAO recommends that VA take 

additional actions to improve grantee 

and subgrantee reporting of 

expenditures, activities, and 

participants, as well as USOC’s 

monitoring of subgrantees. In 

commenting upon a draft of this report, 

VA agreed with these 

recommendations and reported that it 

was taking steps to implement them.

What GAO Found

The Department of Veterans Affairs (VA) and the U.S. Olympic Committee 

(USOC) primarily awarded program funds through subgrants to 65 national and 

community organizations that support adaptive sports opportunities. However, 

their respective program expenditure reporting was not consistent with federal 

internal control standards, making it difficult to know fully how program funds 

were spent. VA’s reporting of first-year program funding was problematic 

because it did not closely track costs until midway through the fiscal year. During 

the second fiscal year—2011—VA granted $7.5 million to USOC, which, in turn, 

awarded $4.4 million to subgrantees and spent the remainder primarily on 

operations and personnel. Subgrantees reported using funds for activities such 

as training and camps. GAO found, however, that USOC did not have sufficient 

reporting requirements in place for subgrantees to provide information on how 

VA funds were used separate from other sources of funding. 

VA relied upon self-reported, unverified information to oversee the grant program 

but is planning to make improvements. In fiscal year 2011, VA did not conduct 

any on-site or remote monitoring to verify how funds were used. Thus, VA lacked 

information on how well USOC and subgrantees managed grant funds, 

potentially exposing itself to paying for services not delivered. In 12 of 21 

subgrant files selected, USOC was not holding subgrantees accountable for 

meeting the terms of their agreements. For example, one subgrantee agreed to 

conduct 10 activities, but the file indicated only 4 were conducted. VA reported 

that it has plans to improve to oversight, including conducting on-site monitoring 

of grantees’ and subgrantees’ use of funds and having USOC verify financial 

reports for at-risk subgrantees, such as those with large subgrants. 

While program benefits were reported by subgrantees and participants, up until 

this point VA has not systematically measured how adaptive sports activities 

benefit the health and well-being of veterans and service members. Subgrantees 

primarily report anecdotal information on program benefits, such as individual 

success stories. VA collects information on the number of activities and 

participants from USOC. In 2011, over 10,000 participants were served through 

nearly 2,000 activities. However, these metrics are flawed due to double counting 

and other measurement issues. VA officials also recognize that the metrics do 

not comprehensively measure program benefits. Thus, VA and USOC have hired 

a contractor to conduct a study on the effects of adaptive sports on rehabilitation 

and reintegration of veterans and service members into the community.

Figures: VA-Funded Archery and Wheelchair Racing Competitions 

View GAO-12-703. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov.
Page i GAO-12-703 Veterans Paralympics Program

Letter 1 

Background 3

VA Grants and USOC Subgrants Were Awarded Primarily to 

Provide Adaptive Sports Opportunities, but Reporting on 

Expenditures Was Problematic 7

VA Relied on Self-Reported, Unverified Information to Oversee the 

Grant Program, but Is Taking Steps to Improve Oversight 16

Program Benefits Have Been Reported but VA Does Not 

Systematically Measure Them 20

Conclusions 24

Recommendations 25

Agency Comments and Our Evaluation 25

Appendix I Objectives, Scope and Methodology 27

Appendix II United States Olympic Committee’s Cost Definitions for 

Subgrantees’ Use of Funds 29

Appendix III Comments from the Department of Veterans Affairs 30

Appendix IV GAO Contact and Staff Acknowledgments 33

Related GAO Products 34

Table

Table 1: Fiscal Year 2011 VA Paralympics Program Funding 9

Figures 

Figure 1: VA Paralympics Program’s Organization Chart, Including 

Program Fund Recipients 5

Contents
Page ii GAO-12-703 Veterans Paralympics Program

Figure 2: Number of Subgrantees Providing Activities by Sport, 

Fiscal Year 2011 13

Figure 3: Fiscal Years 2011 and 2012 Projected Budget Estimates 

for Subgrantees 15

Figure 4: Examples of Anecdotal Reports on VA Paralympics 

Program Benefits 20

Abbreviations

IG Inspector General

GAO U.S. Government Accountability Office

OMB Office of Management and Budget

USOC United States Olympic Committee

VA Department of Veterans Affairs

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Page 1 GAO-12-703 Veterans Paralympics Program

United States Government Accountability Office

Washington, DC 20548

July 26, 2012

The Honorable Patty Murray

Chairman

Committee on Veterans’ Affairs

United States Senate

The Honorable Richard Burr

Ranking Member

Committee on Veterans’ Affairs

United States Senate

The Honorable Jeff Miller

Chairman

Committee on Veterans’ Affairs

House of Representatives

The Honorable Bob Filner

Ranking Member

Committee on Veterans’ Affairs

House of Representatives

In 2010, an estimated 3.4 million veterans had a disability due to servicerelated injuries and illnesses.1 Due to advances in battlefield medicine, a 

larger proportion of military personnel are surviving their wounds than in 

previous generations, though often with serious medical conditions 

including amputations, traumatic brain injuries, and post traumatic stress 

disorder. To promote the lifelong health of veterans and servicemembers 

with disabilities through regular participation in physical activity and 

sports, as well other related purposes, the Veterans Benefits 

Improvement Act of 20082

 

1

2010 American Community Survey data.

established the Office of National Veterans 

Sports Programs and Special Events within the Department of Veterans 

Affairs (VA). The act also authorized VA to provide monthly assistance 

allowances to veterans with disabilities participating in Paralympics 

competitions or training operated by the United States Olympic 

Committee (USOC). Additionally, the act authorized grants solely to 

2

Pub. L. No. 110-389, §§ 701-704, 122 Stat. 4145, 4180-85. 

 
 

Page 2 GAO-12-703 Veterans Paralympics Program

USOC3 to plan, develop, manage, and implement an integrated adaptive 

sports program4 for veterans and servicemembers with disabilities, 

including joint outreach with VA. The act also allows USOC to enter into 

partnership agreements with other organizations, essentially subgranting 

funds to conduct adaptive sports activities. VA conducts grant oversight to 

help ensure that USOC is effectively and efficiently providing adaptive 

sports opportunities, reliably managing its financial reporting, and is in 

compliance with applicable laws and regulations. Moreover, the act 

mandated GAO to submit a report of the VA Paralympics program by 

September 30, 2012.5

In response to our this mandate, our objectives are to (1) review how VA 

and its grantee and subgrantees used program funds to provide adaptive 

sports opportunities to veterans and servicemembers; (2) assess how VA 

is overseeing grantee’s and subgrantees’ use of funds; and (3) describe 

how veterans and servicemembers have benefited from VA Paralympics 

activities.

To address these issues, we analyzed both planned and final program 

budget expenditure data; reviewed program reports, guidance, and 

relevant federal laws and regulations; and interviewed VA and USOC 

officials and other program stakeholders about VA’s Paralympics program 

activities funded with fiscal years 2010, 2011, and 2012 appropriations. 

Because USOC is delayed by one fiscal year in its use of program funds, 

we reported their annual budget information separately from VA’s annual 

budget information. We assessed VA’s and USOC’s budget data and 

found them sufficiently reliable for our reporting purposes. As part of this 

analysis, we reviewed subgrantee plans for spending grant funds as 

reported to USOC. We do not provide information on subgrantees’ final, 

reported expenditures because we found that some subgrantees reported 

 

3

The act actually refers to the United States Paralympics, Inc, but in 2009, when VA was 

preparing its first grant agreement, it was informed that USOC had dissolved United 

States Paralympics, Inc. as a separate entity and that it had been superseded by the 

Paralympic Division of USOC. To ensure grants were used as provided under the law, VA 

reported that it awarded them directly to USOC.

4

According to VA, both of the terms “Paralympic” and “adaptive sports” can be used when 

referring to recreational sports for those with a physical or visual disability. However, 

“Paralympic” can also refer to elite-level competition. For simplicity, VA uses the term 

“adaptive sports” when referring to the programs it promotes. 

5

§ 704, 122 Stat. 4185.
 

Page 3 GAO-12-703 Veterans Paralympics Program

spending more than what they were granted, making it unclear to us 

which portion of their program costs were funded by VA. In addition, we 

reviewed a non-probability sample of 21 out of the 76 subgrant files 

maintained by USOC during a site visit to the organization’s headquarters 

in Colorado Springs, Colorado. These subgrant files included information 

on grant activities that occurred during fiscal year 2011 and were a mix of 

some that were selected based on their larger size as well as others that 

were randomly selected. In total, the sample files contained information 

on 56 percent of funds USOC provided in subgrants using fiscal year 

2010 dollars. We also interviewed subgrantees, regional stakeholders, 

and veteran program participants at a site visit to a VA adaptive sports 

program event in Chicago, Illinois in August 2011. (See appendix I for 

more details.)

We conducted this performance audit from June 2011 through July 2012 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence we obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

VA’s Office of National Veterans Sports Programs and Special Events’ 

mission is to motivate, encourage, and sustain participation and 

competition in adaptive sports among veterans and members of the 

Armed Forces with disabilities. This is to be accomplished through 

collaboration with VA clinical personnel as well as national and 

community-based adaptive sports programs. This office is responsible for 

the VA Paralympics program’s administration, including the grant award 

process, grant oversight, distribution of any monthly assistance 

allowances to eligible athletes, and program outreach. For fiscal years 

2010 through 2012, the federal law authorizes appropriations of $2 million 

for monthly assistance allowances for competitive athletes in training and 

$8 million for grants to USOC.

6

 

6

Sec 702(a), § 521A(g), 122 Stat. 4182-83 (codified at 38 U.S.C. § 521A(g), and 703(a) § 

322(d)(4), 122 Stat. 4184 (codified at 38 U.S.C. § 322(d)(4)).

The grant program will need to be 

reauthorized to continue in fiscal year 2014. VA officials stated that, in the 

first years of the Paralympics program—fiscal years 2010 and 2011—$10 

Background 
 

Page 4 GAO-12-703 Veterans Paralympics Program

million in federal funds were made available for each year.7 Prior to 

receiving this initial funding, the office had a troubled beginning. In 

February 2010, VA’s Inspector General (IG) found that the office’s initial 

director had abused agency resources and obstructed the IG 

investigation.8

The USOC is a non-profit organization that serves as the National 

Olympic and Paralympic Committees and, as such, is responsible for 

training, entering, and funding U.S. teams for the Olympic and Paralympic 

Games. Furthermore, the organization has a well-established history of 

providing adaptive sports opportunities to people with disabilities. To 

reach veterans and servicemembers throughout the United States, USOC 

subgrants VA funding to national and community organizations that 

provide adaptive sports opportunities. (See figure 1 for the VA 

Paralympics program’s organizational chart, including external 

organizations and individuals who receive program funds.)

Since then, VA officials reported that they hired a new 

office director, restructured the office housing the program, and 

addressed these issues of malfeasance.

The categories of subgrantees are:

• National Partners: national organizations that offer camps, clinics and 

on-going programs for veterans and servicemembers with disabilities 

through local chapters. Individual annual subgrant amounts range 

from $100,000 to $500,000.

• Athlete Development subgrant recipients: organizations that conduct a 

national network of camps and clinics to provide opportunities for 

veterans and servicemembers with disabilities to receive sport-

 

7 Although no appropriations were provided under the specific authorizations in the act, 

the program was funded from VA’s Office of Pubic and Intergovernmental Affairs’ general 

operating expenses account. Consolidated Appropriations Act, 2010, Pub. L. No. 111-117, 

123 Stat. 3034, 3300 (2009), Department of Defense and Full-Year Continuing 

Appropriations Act, 2011, Pub. L. No. 112-10, 125 Stat. 38, 174 – 76, and Consolidated 

Appropriations Act, 2012, Pub. L. No. 112-74, 125 Stat. 786, 1151.

8

At the time of the investigation, the duties associated with the Paralympics program were 

being handled by the director of the Office of National Programs and Special Events, 

which is now a part of the Office of National Veterans Sports Programs and Special 

Events. For more information about the investigation, see VA Office of Inspector General, 

Abuse of Authority, Misuse of Position and Resources, Acceptance of Gratuities, & 

Interference with an OIG Investigation, National Programs & Special Events (Washington, 

D.C.: February 5, 2010).
 

Page 5 GAO-12-703 Veterans Paralympics Program

specific instruction and assessment. These opportunities help 

participants meet U.S. Paralympics standards of performance for 

emerging athletes. Individual annual subgrant amounts range from 

$15,000 to $300,000.

• Model Community Partners: community organizations that provide 

leadership in various geographic regions for promoting adaptive 

sports and to help increase regional capacity for Paralympic sports. 

These organizations are allowed to further subgrant funds to other 

local organizations to provide direct services. Individual annual 

subgrant amounts range from $2,500 to $175,000.

• Olympic Opportunity Fund recipients: community organizations that 

aim to bring adaptive sports opportunities to their local communities. 

Individual annual subgrant amounts range from $5,000 to $45,000.

Figure 1: VA Paralympics Program’s Organization Chart, Including Program Fund Recipients
 

Page 6 GAO-12-703 Veterans Paralympics Program

As a condition of receiving these funds, USOC must permit VA to conduct 

the oversight VA determines is appropriate.9 Furthermore, the federal law 

requires USOC to submit to the Secretary of VA an annual report 

detailing its use of grant funds. 10 The reports are to include the number of 

veterans who participated in the adaptive sports program and the 

administrative expenses. USOC provided this first annual report to VA in 

November 2011. In turn, VA is required to report annually to Congress on 

the use of program funds for each year the Secretary makes grants to 

USOC. 11

Regular reporting of relevant, reliable, and timely information and regular 

monitoring are necessary for an entity to run and control its operations 

according to GAO’s Standards for Internal Controls in the Federal 

Government and OMB’s internal control framework for the federal 

government.

Additionally, VA and USOC officials agreed that USOC would 

submit quarterly progress reports throughout the year. During fiscal year 

2011, USOC provided quarterly reports that included descriptions of 

activities conducted by subgrantees, the number of veterans and 

servicemembers served in the activities, and anecdotal information on 

how participants benefited from activities.

12

 

9

Sec. 702(a), § 521A(b) (codified at 38 U.S.C. § 521A(b)).

This internal controls guidance states that program 

managers need both operational and financial data to determine whether 

they are meeting their strategic and annual performance plans and 

effectively and efficiently using resources. Monitoring of internal controls 

should occur within the normal course of business as well as through 

separate evaluations. Furthermore, members of the Domestic Working 

10Sec. 702(a), § 521A(j)(1) (codified at 38 U.S.C. § 521A(j)(1)).

11Sec. 702(a), § 521A(k) (codified at 38 U.S.C. § 521A(k)).

12Internal controls are defined as an integral component of an organization’s management 

that provides reasonable assurance that the following objectives are being achieved: 

effectiveness and efficiency of operations, reliability of financial reporting, and compliance 

with applicable laws and regulations. Internal control, which is synonymous with 

management control, helps government program managers achieve desired results 

through effective stewardship of public resources. For more information about GAO and 

OMB’s internal control frameworks, see Standards for Internal Control in the Federal 

Government. GAO/AIMD-00-21.3.1 (Washington, D.C., November 1999) and OMB 

Circular A-123 Revised.
 

Page 7 GAO-12-703 Veterans Paralympics Program

Group’s Grant Accountability Project13 —a task force of federal, state, and 

local audit organizations—found that subgrantees, many of which are 

small organizations, often lack training and experience in grant 

management. Therefore, the group suggested that government agencies 

provide guidance to subgrantees on how to conduct financial reporting 

that complies with federal and state requirements and auditing and 

accounting standards. The group also suggested that government 

agencies conduct ongoing monitoring of subrecipients as well as field or 

desk audits of potentially high-risk subgrantees.

 

13This project was conducted by the Domestic Working Group, which consists of 19 

federal, state and local audit organizations and is chaired by the Comptroller General of 

the United States. The purpose of the group is to identify current and emerging 

challenges of mutual interest and explore opportunities for greater collaboration within the 

community of intergovernmental auditors. The group issued a guide for better managing of 

governmental grants in October 2005.

VA Grants and USOC 

Subgrants Were 

Awarded Primarily to 

Provide Adaptive 

Sports Opportunities, 

but Reporting on 

Expenditures Was 

Problematic 
 

Page 8 GAO-12-703 Veterans Paralympics Program

In the first 2 years of the Paralympics program, VA granted most of its 

available funds for the program to USOC, but inconsistent with federal 

internal controls standards for reporting relevant and reliable information, 

we found weaknesses in VA’s administrative and personnel expenditure 

reporting. In fiscal year 2010, VA allotted $10 million for the Paralympics 

program.14

In fiscal year 2011, VA once again allotted $10 million for the Paralympics 

program. VA obligated a total of about $8.9 million, of which $7.5 million 

was granted to USOC. The remainder was spent on athletes’ monthly 

assistance allowances as well as agency administrative and personnel 

costs. (See table 1.)

VA granted $7.5 million to USOC and obligated about 

$400,000 to contract with a consulting firm to design an outreach strategy 

for informing eligible participants about the program. It is not clear, 

however, how much money VA spent, in total, on administrative and 

personnel costs associated with this program in fiscal year 2010, primarily 

because VA did not closely track these costs until midway through fiscal 

year 2011. VA officials told us that the Office of National Veterans Sports 

Programs and Special Events did not have a full-time program director 

and was not fully operational until about midway through fiscal year 2011, 

and as a result, VA did not establish accounting codes for the 

Paralympics program until that time. VA officials also said that some 

administrative and personnel costs were charged to other VA programs 

as general expenses, and therefore cannot be traced back to the 

Paralympics program. In addition, VA officials said they were unable to 

obligate the full amount of fiscal year 2010 funds available to athletes’ 

monthly assistance allowances before the end of the fiscal year, due to 

the delays in establishing the program.

 

14A VA official explained that the Office of National Veterans Sports Programs and Special 

Events is housed within the Office of Public and Intergovernmental Affairs and included in 

its overall budget report. VA Paralympics officials stated that, as a result, they assume 

they will receive $10 million from this total budget each fiscal year. They do not, however,

always obligate or spend that much. 

VA Awarded the Majority 

of Program Funds to 

USOC, but VA’s 

Administrative and 

Personnel Expenditure 

Reporting Had Weaknesses
 

Page 9 GAO-12-703 Veterans Paralympics Program

Table 1: Fiscal Year 2011 VA Paralympics Program Funding

Obligated Expended

Remaining 

Unobligated 

Amount 

VA Personnel Costs $11,753 $11,753 $0

VA Administrative Costs $322,817 $224,285 $98,532

Athletes’ Monthly Assistance 

Allowances $1,079,000 $675,906 $403,094

USOC Grant $7,500,000 $7,500,000 $0

Total $8,913,570 $8,411,944 $501,626 

Source: VA Budget Data as of September 30, 2011.

Note: Not all personnel costs for fiscal year 2011 are included in the number above because 

accounting codes for the program were not established until midway through the year.

VA planned to spend about $1.1 million in 2011 on monthly assistance 

allowances to assist competitive athletes with their training, but ultimately 

spent about $675,900. According to VA officials, fewer athletes than 

expected were able to apply for the allowance, so the Paralympics 

program returned some portion of the remaining funds to VA’s Office of 

Public and Intergovernmental Affairs general expense account.15 USOC 

officials explained that the monthly information an athlete must submit to 

obtain an allowance, such as a detailed training log, can be burdensome. 

USOC is working with VA to develop a new online reporting tool to help 

ease the burden of this monthly reporting requirement in an effort to 

encourage greater participation.16

 

15Program data show that the number of athletes who received payment from October 

2010 to September 2011 steadily grew from 40 to over 70. On average, these athletes 

received monthly payments of approximately $700. VA officials noted that the total of 

$675,906 for fiscal year 2011 included retroactive payments made to athletes in fiscal 

years 2010 and 2011. And while these retroactive payments are included in the total 

amount spent, they are not included in the calculation of average monthly payment ($700). 

In July 2012, following an expansion of allowable Paralympic sports, VA reported that 

participation increased to 91 athletes.

16An athlete’s initial application for monthly assistance allowances is partially managed by 

USOC. Indeed, USOC works with the athlete to submit to VA the necessary paperwork—

which includes information on their dependents and signatures from their coaches. The 

paperwork also demonstrates that the athletes have qualified for Paralympics training 

camps and competition. USOC also sets the military standards for each Paralympic sport 

activity. These military standards must be met for veteran athletes to be eligible to receive 

a monthly stipend. 
 

Page 10 GAO-12-703 Veterans Paralympics Program

VA also planned to spend about $334,500 on fiscal year 2011 

administrative and personnel costs associated with the Paralympics 

program, the majority of which was for contracted services. Specifically, 

within its administrative costs, VA contracted with a consulting firm to 

provide grants management services, including assistance with 

developing grant agreements, providing technical assistance, and 

developing performance measures for grantees. The contractor did not 

use all of the funding it obligated for this contract, and returned to VA 

approximately $98,500. According to VA, $11,753 in fiscal year 2011 

funds was spent on personnel for the Paralympics program. However, the 

salaries for the Director of the Paralympics program and other personnel 

who contributed to establishing the program are not fully reflected in 

these personnel costs; those salaries were funded through other VA 

programs because separate accounting codes for the Paralympics 

program were not established until midway through fiscal year 2011. 

Indeed, the Director of the Paralympics program was paid out of funds 

from the Office of National and Special Events. As a result, only those 

expenses that were incurred after the codes were established were 

reported on VA’s budget for the Paralympics program. In fiscal year 2012, 

VA’s total personnel and administrative costs are projected to increase to 

about $2.2 million as the fiscal year 2012 budget will now reflect activities 

and personnel from the Office of National and Special Events, which has 

been consolidated into the Office of National Veterans Sports Programs 

and Special Events.17

USOC was awarded a 1-year grant of $7.5 million by VA in fiscal year 

2010, to be used during fiscal year 2011. USOC was also awarded a 1-

year grant of $7.5 million in fiscal year 2011 to be used during fiscal year 

2012. In fiscal year 2011, USOC subgranted approximately $4.4 million to 

organizations to provide adaptive sports opportunities and used the 

remaining $3.1 million for its operations and personnel and administrative 

Specifically, in addition to the Paralympics 

activities, the Office of National Veterans Sports Programs and Special 

Events now funds five additional staff who travel to and administer six 

separate national events, as well develop related outreach literature for 

these events.

 

17As described earlier, the Office of National Veterans Sports Programs and Special 

Events is housed within the Office of Public and Intergovernmental Affairs. The old Office 

of National and Special Events had also been housed within this office.

USOC Used About Half of 

Its Grant to Provide 

Adaptive Sports 

Opportunities 
 

Page 11 GAO-12-703 Veterans Paralympics Program

costs.18

In fiscal year 2011, about half of the $1.5 million USOC spent on 

operations went towards outreach and awareness efforts as well as 

program support for the Paralympics sport programs, while the remaining 

half was used to provide training and technical assistance. For example, 

USOC works with VA medical centers and local organizations to help 

them develop relationships and expand opportunities for veterans and 

servicemembers with disabilities to engage in adaptive sports. USOC’s 

program budget shows that operation costs are projected to decrease to 

$1.1 million in fiscal year 2012. Fiscal year 2011 was the first year that 

USOC implemented a VA grant program. USOC officials told us the 

decrease in 2012 operations costs reflects the fact in fiscal year 2011, 

there were significant upfront, one-time costs to build the foundation of 

the program, such as designing outreach materials and regional training. 

USOC officials also said “lessons learned” from their experiences during 

that first year will allow them to plan more effectively going forward.

Some of USOC’s subgrantees did not use all of the funding they 

received for their adaptive sports programs, so they collectively returned 

about $50,000 to USOC. VA officials reported that USOC returned these 

remaining funds to VA.

USOC reports personnel costs separately from administrative costs. In 

fiscal year 2011, USOC spent about $1.3 million on personnel costs. 

Specifically, this funding went toward salaries, Social Security taxes, 

Medicare withholdings, and benefits for 17 program staff and additional 

temporary staff. The salaries of program staff ranged from about $20,000 

to $175,000 and covered positions including the administrative assistants, 

coaches, grant managers, and program director, among others. Further, 

in addition to having staff who are dedicated to administering the 

program, USOC has staff dedicated to the outreach and technical 

assistance efforts described above; they are responsible for designing 

and implementing USOC’s outreach materials and facilitating 

conferences, regional meetings/trainings, and other training and 

education activities for veterans.

In fiscal year 2012, USOC projects spending about $1.9 million to pay for 

the salaries of 12 program staff. As a percent of its budget, USOC’s 

 

18Specifically, USOC’s operations costs for fiscal year 2011 were $1.5 million; personnel 

costs were $1.3 million, and administrative costs were $253,000. 
 

Page 12 GAO-12-703 Veterans Paralympics Program

personnel costs are projected to increase from 18 percent in fiscal year 

2011 to 26 percent in fiscal year 2012. USOC officials said that the 

increase is due to its fiscal year 2011 grant with VA spanning a 17 month 

period of performance. This differs from the first grant USOC received 

which was for a 12 month period of performance.

In contrast, USOC’s allocated administrative costs19 are projected to 

decrease from $253,000 in fiscal year 2011 to $0 in fiscal year 2012. 20

Specifically, in fiscal year 2011 these funds went toward indirect costs 

such as rental expenses, supplies, event expenses, and utilities. A USOC 

official told us that they chose not to allocate any administrative costs in 

fiscal year 2012 because they want to allocate the most possible funding 

to programming that directly serves veterans. USOC reported that it plans 

to pay for administrative costs associated with the VA program through 

other funding sources.

Subgrantees reported using funds to provide opportunities in a range of 

activities—through camps, practice/trainings, and competitions—across 

29 adaptive sports. Cycling/handcycling and skiing were the most 

common activities. (See figure 2.)

 

19According to VA General Counsel guidance, the law governing the Paralympics program 

does not include personnel costs within its definition of administrative costs. For 

subgrantee use of funds, USOC defines administrative costs to include only costs 

associated with subawardees and the implementation and tracking of subaward programs.

20The federal law allows USOC to use up to 5 percent and subgrantees to use up to 10 

percent of grant or subgrant funding, respectively, for administrative expenses (Sec. 

702(a), § 521A(d)(4) and (5), 122 Stat. 4182 (codified at 38 U.S.C. § 521a(d)(4) and (5)). 

At the same time, there are no limits on the proportion of funding that can be used for 

operations or personnel costs. In fiscal year 2011, USOC’s administrative costs 

represented 3 percent of its total grant amount.

Subgrantees Provided a 

Range of Activities, but 

Determining Whether They 

Spent Funds As Planned 

Was Problematic
 

Page 13 GAO-12-703 Veterans Paralympics Program

Figure 2: Number of Subgrantees Providing Activities by Sport, Fiscal Year 2011

a

The “Skiing” category includes cross country and alpine skiing.

b

The “Other” category includes bowling, climbing, curling, fencing, judo, powerlifting, road racing, 

sitting volleyball, snowboarding, surfing, wheelchair racing, wheelchair rugby, and wheelchair tennis.

c

The “Boat Sports” category includes kayaking, rowing, and sailing.

d

Goal ball is an indoor game invented for participants with visual impairments in which opposing 

teams try to roll a ball with bells across the other team’s goal line.

e

The majority of USOC’s subgrantees received relatively small grants in 

fiscal year 2011; of the 76 grants USOC awarded to 65 organizations, 54 

were Olympic Opportunity Fund subgrants, awarded through a 

competitive process, ranging from $5,000 to about $45,000.

Sled hockey is similar to ice hockey in terms of general rules and concepts. It differs in that it allows 

participants with mobility limitations to sit on an adaptive sled, which is affixed with two skate blades 

and a runner in the front to form a tripod. The hockey stick has a pick on the end which participants 

use to propel the sled across the ice.

21

 

21Some subgrantees received more than one type of grant depending on the nature of the 

adaptive sports programming they planned to offer.

As 

previously described, Olympic Opportunity Fund subgrants provide 

adaptive sports to veterans’ local communities. For example, one 
 

Page 14 GAO-12-703 Veterans Paralympics Program

subgrantee reported using Olympic Opportunity funds to provide cycling 

and sled hockey activities, such as weekly hand cycling clinics and 

training sessions on adaptive equipment. Another subgrantee reported 

using Olympic Opportunity funds to hold a weekly power-lifting group, an 

indoor kayaking clinic, and a judo clinic.

The remaining 22 subgrants generally were larger, ranging from $15,000 

to $500,000, and were provided to Athlete Development organizations 

and National and Model Community Partners. These organizations 

provided a wider range of activity types through national networks, local 

chapters, or community organizations in various geographic regions. For 

example, one Athlete Development subgrantee reported holding an 

outreach clinic at a nearby VA hospital where they educated staff and 

potential participants about adaptive sports options and hosted a ski 

camp which included a sit-ski clinic, a race, and strength and conditioning 

training for a cross-country skiing marathon. In addition, a National 

Partner subgrantee reported using its funds to train and educate staff and 

program leaders on adaptive and Paralympic sports, and to conduct 

outreach and recruitment campaigns. This organization also awarded and 

administered subgrants to some of its local chapters to hold archery, 

cycling, fencing, wheelchair basketball, and swimming activities, among 

others.

All subgrantees’ grant agreements required them to report how VA funds 

were used to cover program expenses. As part of their agreements, 

subgrantees provided a projected budget detailing plans to spend 

program funds in six categories: personnel, operations, equipment, 

supplies, travel, and administrative costs (see appendix II for USOC’s 

cost definitions for subgrantees’ use of funds). Although subgrantees 

could not spend more than 10 percent of the total amount granted on 

administrative costs, no other category had spending limits. Of the 

approximately $4.4 million USOC awarded for fiscal year 2011, 

subgrantees projected using over half, or about $2.6 million, on 

operations and personnel costs. Subgrantees projected that these costs 

would remain about the same for fiscal year 2012. (See figure 3.)
 

Page 15 GAO-12-703 Veterans Paralympics Program

Figure 3: Fiscal Years 2011 and 2012 Projected Budget Estimates for Subgrantees

Note: USOC expenditure data reported equipment and supplies as one combined budget item.

Inconsistent with federal internal control standards, we found that during 

the first program year, USOC did not have reporting requirements or 

electronic reporting systems in place for subgrantees to provide 

information on how VA funds were used separate from other sources. As 

a result, there was a lack of reliable information on actual expenditures. 

Our review of a sample of subgrantees’ files raised concerns with how 

subgrantees reported their actual expenditures. In 7 of the 21 

subgrantees’ files we reviewed, it was difficult to determine how the 

subgrantees spent their grant funding, and 4 out of these 7 files reported 

spending more than they were actually granted by VA to provide adaptive 

sports activities. For example, in one case, a subgrantee received a grant 

for $35,000 but reported expenditures to USOC in excess of $89,000. In 

reviewing these files, we found that USOC had not determined what 

portion of the subgrantees’ program costs were funded with VA dollars.

While USOC provided a template to each subgrantee to report quarterly 

expenditures, the template did not explicitly request that a subgrantee 

only provide information on how VA funds were spent. When asked if they 

reconciled a subgrantee’s reported expenditures with planned 

expenditures, USOC officials told us they generally did not have enough 

time between the receipt of a subgrantee’s quarterly budget and the 

deadline to submit a quarterly report to VA to ensure that the budget 

information was accurate. This lack of follow-up is inconsistent with OMB 

internal controls guidance, which provides that management should 
 

Page 16 GAO-12-703 Veterans Paralympics Program

regularly reconcile and compare data within the normal course of 

business.

USOC officials said they were aware of reporting problems and, at the 

beginning of fiscal year 2012, were developing and implementing an 

electronic system that will allow subgrantees to report quarterly 

expenditures online, among other things. USOC officials told us such a 

system should help them process the reports more quickly. However, 

they acknowledged the system will not include controls to ensure 

subgrantees report only those costs specific to the VA grant. VA officials 

told us that they are aware that this electronic system has limitations and 

they have directed USOC to make the necessary improvements. In 

addition, VA reported that it provided guidance on how USOC could 

improve data processes, and USOC has agreed to send its grant 

management staff to training, both in effort to enhance USOC’s data 

reporting capabilities.

VA lacked information on how USOC and subgrantees used funds due to 

its reliance on self-reported, unverified quarterly reports from USOC.

Inconsistent with federal internal controls standards, VA officials stated

that they did not independently review or verify how grant funds were 

used due to a lack of staff to oversee the program in fiscal year 2011. In 

fact, VA did not hire staff dedicated to managing the Paralympics program 

until it had already granted funds to USOC. Specifically, in September 

2010, VA and USOC established a memorandum of agreement for the 

grant, but a Paralympics program director was not hired until February 

2011. The director, with the assistance of interns, reported spending the 

VA Relied on SelfReported, Unverified 

Information to 

Oversee the Grant 

Program, but Is 

Taking Steps to 

Improve Oversight

VA Lacked Information on 

How USOC and 

Subgrantees Used Funds
 

Page 17 GAO-12-703 Veterans Paralympics Program

rest of the fiscal year finalizing the office’s outreach campaign, 

administering the monthly assistance allowance program, and processing 

USOC’s fiscal year 2011 grant application.22

USOC officials told us their quarterly reports were primarily based on the 

quarterly reports they obtained from subgrantees, and therefore, the 

available information VA had for oversight may not have been accurate. 

USOC officials managing the grant program did not conduct any separate 

reviews to verify the information provided to them by subgrantees, and as 

mentioned earlier, did not make efforts to reconcile expenditure data in 

these quarterly reports as they were submitted. To gain additional 

information about how subgrantees were managing funds in the first 

program year, USOC’s Audit Division selected 2 of the 65 subgrantees, 

based on risk-related criteria, for review in the fall and winter of 2012, and 

the grant managing officials plan to use the information from those audits 

to develop future plans for oversight.

According to VA officials, 

another VA Paralympics staff person was hired in September 2011.

Furthermore, with the establishment of the Paralympics program, agency 

officials stated that grant management became a new administrative 

responsibility for the VA Office of Public and Intergovernmental Affairs as 

well as USOC and the subgrantees, and all of these program 

stakeholders needed time to learn about appropriate oversight 

mechanisms.

Our review of a sample of USOC’s files on subgrantees showed that 

USOC officials were not holding subgrantees accountable for meeting the 

terms of their subgrant agreements—a grant management problem about 

which VA was not in the position to know about given its lack of oversight.

We found that many subgrantee files lacked information on the status of

their grant expenditures and the activities the subgrantees agreed to 

conduct. USOC reported using a process in which quarterly reports are 

checked against subgrantees’ agreements to ensure completeness of 

agreed-upon activities. However, in 12 of the 21 subgrant files we 

reviewed, we did not find evidence that the subgrantees conducted all 

agreed-upon activities. For example, one National Partner had agreed to 

develop 27 programs related to handcycling, bowling, and trapshooting, 

but the reports we found mentioned that only 18 programs had been 

 

22As previously described, USOC spent program funds a full fiscal year later; therefore, its 

application for fiscal year 2011 funds was submitted to VA during fiscal year 2011. 
 

Page 18 GAO-12-703 Veterans Paralympics Program

completed. Another National Partner agreed to conduct 10 activities 

related to outreach, introducing adaptive sports at VA clinics, and 

identifying athletes for higher level of competition, but the case file 

indicated only 4 of these activities had been completed. Furthermore, in 

11 of the 12 files, we did not find any documentation explaining why the 

planned activities did not occur, nor did we find written permission from 

USOC to change the scope of agreed-upon activities.

In 5 of the 21 files we reviewed, we found that subgrantees transferred 

more than 20 percent of funds from one budget category to another 

without the written permission of USOC, as required by their grant 

agreements. For 2 of these files, we identified significant issues with the 

subgrantees’ financial management and reporting. Specifically, 1 file 

belonged to a subgrantee that received a $400,000 grant that was one of 

the organizations subjected to an audit by USOC’s Audit Division. The 

division officials found that, in addition to making unallowed transfers, the 

subgrantee had instances of non-compliance with OMB Circular A-122’s 

Cost Principles for Non-Profit Organizations (including unexplained 

personnel and administrative charges by five employees), did not 

consistently document and communicate requirements and responsibility 

related to the VA funds it subgranted to its member chapters, and did not 

clearly and formally document its methodology for determining and 

allocating administrative costs to the VA grant.23 Another subgrantee who 

made unallowed budget transfers also reported purchasing a van without 

the written permission of USOC, which is required by the grant agreement 

prior to making equipment purchases exceeding $5,000. This same 

subgrantee also received another $35,000 VA-funded grant for which it 

did not submit required expenditure reports.

VA officials recognized that their grant oversight has been limited and 

report that improvements are under development. In December 2011, VA 

established a monitoring plan that identifies the specific information 

USOC should report and requires USOC to establish a similar plan to 

oversee subgrantees. Specifically, VA’s plan requires USOC to submit 

quarterly reports and an annual report that include summary data on the 

activities provided, number of veterans served, levels of expended and 

 

23In its response to the Audit Division, the subgrantee agreed to avoid these problems 

with future grant funds. This subgrantee received another $400,000 grant from fiscal year 

2011 program funds.

VA Plans to Improve Its 

Grant Monitoring
 

Page 19 GAO-12-703 Veterans Paralympics Program

unexpended funds, and available assets, among other information. VA’s 

plan does not, however, require on-site or remote evaluations of USOC 

and the subgrantees, nor a review of USOC’s monitoring outcomes for 

subgrantees. When asked why such monitoring was not included in the 

plan, VA officials stated that they recognize that a lack of separate 

evaluations is a gap in their oversight and are working to address this 

limitation. For example, in fiscal year 2012, VA officials reported 

conducting on-site visits of USOC to discuss various aspects of grant 

management. VA plans to conduct additional on-site reviews of USOC 

and selected subgrantees later in the year.24

With input from VA, USOC finalized a monitoring plan of subgrantees in 

early 2012 that, in addition to reviewing subgrantee reports, will require 

USOC officials to audit financial data for subgrantees selected on riskbased criteria. USOC’s plan includes a checklist for reviewing and 

verifying information in these quarterly reports; the checklist mentions 

comparing the reports to the agreed-upon activities and conducting 

remote and on-site reviews. USOC aims to conduct enough site visits to 

review the use of half of all fiscal year 2011 funds. Furthermore, USOC 

plans to use risk-based criteria to select subgrantees for remote audits of 

financial data; these criteria will include the size of the subgrant award, 

additional granting of VA funds to other entities by the subgrantee, and 

the absence of a current audit report. The remote audits will include 

reviewing the subgrantees’ ledgers and comparing them to what was 

submitted in the quarterly reports and reviewing documentation that 

supports selected transactions to ensure that they are compliant with 

OMB guidance. However, given that we found that USOC was not holding 

subgrantees accountable—despite having an oversight process in 

Furthermore, officials are 

expecting that information from USOC’s subgrantee reviews will 

eventually be incorporated into subgrantee application packages, which 

they will review before finalizing future grant agreements. Also, after 

reviewing the first quarter reporting for fiscal year 2011 funds in January 

2012, VA officials reported asking USOC officials to provide more 

information about whether subgrantees were providing deliverables within 

the agreed-upon timeframes.

 

24In May 2012, VA officials reported that they are still developing their process for 

conducting on-site reviews of subgrantees. The officials also mentioned that an internal 

control expert from VA’s Office of Business Oversight has been assigned to advise them 

on all aspects of the grant process and they expect program changes will happen during 

the next grant cycle.
 

Page 20 GAO-12-703 Veterans Paralympics Program

place—VA will need to ensure its monitoring efforts include overseeing 

the implementation of USOC’s plans.

We found that many subgrantees and participants reported benefits from 

VA’s Paralympics program. Subgrantees primarily reported anecdotal 

information on program benefits in their quarterly reports to USOC, and 

USOC then provided some of these examples in their quarterly reports to 

VA. This anecdotal information included participant success stories, 

testimonials, and related news articles, and was consistently positive with 

regards to the program’s value in the first year. (See figure 4 for 

examples.)

Figure 4: Examples of Anecdotal Reports on VA Paralympics Program Benefits

“Kevin is a 21 year old Veteran with a SCI (paraplegia) injury incurred 6/2011. Kelly worked with Kevin on a 1:1 basis for 2 months to 

train on the hand cycle, eventually leading to him training on his own at home. Kevin signed up for the Marine Corps Marathon prior 

to his injury. After his injury in 6/2011, Kevin was determined to still compete in this marathon, but due to his injury, he was not able to 

run, so he wanted to handcycle. Kevin finished the Marine Corp Marathon this past October 2011 at a time of 2:18! It shows that with 

the right resources, guidance, and determination, nothing can keep someone from attaining their dreams (even if you have to adapt!). 

Kevin utilized one of the cycles that was purchased through this grant.” 

– Subgrantee quarterly report

“One athlete stated ‘I still find it hard to believe. Me, a C7 quadriplegic, on the water rowing. It feels so good to exercise, and be 

treated like an athlete. Rowing is a beautiful sport. And now it's my thing.’” 

– Subgrantee quarterly report 

“An alumni (army sergeant) told us that because of the confidence he gained the first year, he was able to remain sober for the past 

year (he had been abusing drugs and alcohol and had been arrested several times) and had started college.”

– Subgrantee quarterly report

“Benjamin is a Wounded Warrior from Arizona who . . . was no longer affiliated with a military facility, no longer active, suffering from 

depression and excessive weight gain and coping with a recent spinal cord injury. He came to our Winter Wounded Warriors Camp, 

Operation High Altitude accompanied by his mom and with a great deal of trepidation. He fell in love with the sport of Nordic skiing 

and was eager to come back to participate in our upcoming biathlon camp.” 

 – Subgrantee quarterly report

Program Benefits 

Have Been Reported 

but VA Does Not 

Systematically 

Measure Them

Some Participants Have 

Reported Improvements to 

Their Health and WellBeing 
 

Page 21 GAO-12-703 Veterans Paralympics Program

“I have been in a wheelchair for almost 3 years. I have known about the sports that are available and the resources but I only recently 

took advantage of them. The biggest benefit I have received from going to these events is being around people that ‘get you.’ I'm not 

saying that other people can't try to understand what it’s like to be in a chair but they will never really know unless they experience it 

themselves. . . . I've talked to dozens of vets about these events and they all said that these programs have become an integral part of 

their lives, as well as mine.”

 – Veteran Participant

“Thank you for the great opportunity, I was starting to feel kind of isolated and this event helped me in so many different ways. It was 

really good to meet a lot of the other vets and active duty wounded warriors. Thank you thank you thank you, it meant a lot.” 

– Veteran Participant

“[Skiing] allows you to focus on your abilities rather than your disabilities. You’re normal again. You can compete, get your competitive 

edge.” – Veteran Participant, Bi-lateral Leg Amputee

Sources: USOC fiscal year 2011 quarterly and annual program reports and subgrantee fiscal year 2011 grant files submitted to USOC

During our site visit to an adaptive sports event in Chicago, veterans we 

spoke with also told us how adaptive sports programs have improved 

their mental and physical health. All six veterans in one group interview 

agreed that the greatest benefit was to their mental health; they believe 

that adaptive sports are a tool that helps them deal with depression. They 

also said that participating in group activities with other veterans with 

disabilities made them feel less isolated in their challenges. Other 

veterans said that they had experienced social benefits, including a boost 

to their self-esteem; one veteran described how he developed long-term 

friendships during the competitions, and another described how these 

events show veterans that they can be physically active despite their 

disabilities. Veterans also told us that competitions motivated them to stay 

active on an on-going basis and improved their overall physical health. 

For example, some veterans said regular participation in athletic activities 

made them physically stronger in their remaining limbs and had improved 

their balance and dexterity. One veteran in particular told us that he had 

lost 68 pounds in 4 months due to his regular participation in Paralympic 

program activities.
 

Page 22 GAO-12-703 Veterans Paralympics Program

While VA requires USOC and its subgrantees to count the number of 

adaptive sports activities conducted and the number of participants 

served, these measurements are not always accurate.25 In its fiscal year 

2011 annual report to VA, USOC stated that over 10,000 veterans and 

servicemembers participated in nearly 2,000 activities. However, VA 

officials acknowledged that the participation and activity data are flawed. 

Indeed, in USOC’s quarterly reports to VA, USOC stated there is some 

double counting of unique veterans/servicemembers and activities due to 

partnerships and collaboration among the Paralympic community. For 

example, a veteran might attend activities sponsored by different 

subgrantees, and each subgrantee might then include that same veteran 

in their separate count. The extent of this double counting is unknown due 

to a lack of a systematic review of the activity and participant counts.

Although VA is required by law to report annually to Congress on the 

number of veterans who participated in adaptive sports activities and the 

administrative expenses, it has yet to do so. 26

Additionally, in our review of a sample of 21 subgrantee reports, we found 

some inconsistencies with how subgrantees count program participants 

and activities, further diminishing the reliability of these data. It was 

difficult to determine, in fact, how 16 out of the 21 were counting their 

participants or activities as many organizations had different 

interpretations of what qualified as a participant or activity. For example, 8 

out of the 21 subgrantee reports counted activities that did not have 

veteran or military participants—some of them even counted purchases of 

equipment as activities. Also, 6 out of the 21 subgrantees administered

more than one type of a VA Paralympics grant and submitted reports 

where it was difficult to determine which grant corresponded with which 

counts of activities and participants.

While subgrantees and program participants reported program benefits, 

VA has not yet systematically measured how adaptive sports activities 

specifically benefitted the health and well-being of veterans and 

servicemembers. A couple of USOC’s subgrantees conducted surveys 

 

25The authorizing legislation requires USOC to report on the use of grant funds, including 

the number of veterans who participated in the adaptive sports program. VA is, in turn, 

required to report to Congress annually on the use of funds. 38 U.S.C. § 521A(j)(1) and 

(k), respectively. 

26In commenting on a draft to this report, VA indicted that it anticipates providing a report 

to Congress on the Paralympics program for fiscal years 2010-2011 in August 2012.

Counts of Activities and 

Participants Are 

Inconsistent, but VA Is 

Taking Steps to Improve 

Measurement of Program 

Benefits 
 

Page 23 GAO-12-703 Veterans Paralympics Program

asking for feedback on specific events or activities, but VA has not 

conducted a program-wide survey or study to collect information about 

the various events and their benefits. Absent this measurement, VA 

largely relies on the anecdotal information supplied by subgrantees and 

program participants. Moreover, VA officials recognize that participant 

and activity counts do not comprehensively measure how participation in 

adaptive sports can improve a person with disabilities’ quality of life, 

including improved physical health, enhanced confidence and selfesteem, reduction in depression and improved relationships with family 

members and other members of the community.

VA wants to improve its measurement of Paralympics activity benefits. VA 

and USOC have, in turn, taken the initiative to hire a contractor to conduct 

a study on the effects of adaptive sports on rehabilitation and 

reintegration of veterans and servicemembers into the community, 

including five life domains (self-care, mobility skills, communication with 

family and friends, participation in society, and acceptance of disability) 

and the psychosocial outcomes, including self-esteem and quality of life. 

The study will include a survey of participants in VA adaptive sports 

activities, with questions focusing on uncovering key life and goal-setting 

concerns of participants as well as employment and educational goals 

and opportunities. VA and USOC are expecting the contractor to provide 

a preliminary report to Model Community Partners by the end of 

September 2012. They have also planned for the final results of this study 

to be shared with internal and external audiences, including government 

agencies, the research community, and the general public. In addition, VA 

and USOC have tasked the contractor to conduct an assessment of the 

VA Paralympics program that will include identification of issues, trends, 

obstacles, and barriers, which will assist USOC and subgrantees with 

managing expectations and program performance. VA and USOC have 

required the contractor to provide an annual report on this assessment by 

November 2012. VA officials told us they have also been assisting the 

Paralympic Research and Sport Science Consortium with facilitating 

research in Paralympic and adaptive sports. VA officials stated that this 

research is focused on activities that would both enhance Paralympic 

sports and capabilities to provide rehabilitative opportunities to Veterans 

and members of the Armed Forces with disabilities. In addition, VA 

officials stated that they are seeking feedback from Paralympic and 

adaptive sport communities, academia, research institutions, and other 

entities to try to develop metrics to measure effectiveness.

VA officials stated that the goals of its adaptive sports programming have 

changed in the past few years with the establishment of the Paralympics 
 

Page 24 GAO-12-703 Veterans Paralympics Program

program. Prior to the Paralympics program and its current leadership, the 

Office of Public and Intergovernmental Affairs focused on engaging 

veterans and servicemembers with disabilities in a few Paralympic sport 

competitions it sponsored once a year. However, with the Paralympics 

program and the Office of National Veterans Sports Programs and 

Special Events in place, VA has expanded its goals to include veteran 

participation in local and community adaptive sports programs throughout 

the year and for on-going sports participation to have an impact on the 

veterans’ overall physical and emotional well-being. Further, VA is 

working with other VA entities to incorporate Paralympic and adaptive 

sports into rehabilitative whole-life programs for Veterans and members 

of the Armed Forces with disabilities. For example, VA officials stated that 

they worked with some of their subgrantees to develop adaptive sports 

program-related training webinars and other support materials for VA 

entities such as recreation therapists, centers for blind and visually 

impaired, and Community Living Centers.

After veterans and servicemembers face life altering disabilities resulting 

from their service in the Armed Forces, the VA Paralympics program 

works to empower them to move forward in their next phase of life. In 

partnership with USOC and its subgrantees, VA has been able to 

introduce numerous participants to a variety of sports adapted for their 

physical conditions. Beyond providing access to recreational 

opportunities, veteran participants told us that adaptive sports have 

changed the way they think about their disabilities and provided them with 

opportunities to improve their physical health. As this program matures, it 

has the potential to provide greater access to adaptive sports and garner 

a wider range of benefits for participants. VA must, however, improve the 

program’s oversight and reporting to help ensure program funds are 

efficiently and effectively used. Although USOC is planning various 

oversight initiatives and is implementing an electronic reporting system for 

subgrantees, we found that USOC’s past efforts at financial accounting, 

subgrantee oversight, and reporting on participation and activities were 

weak, resulting in gaps in program knowledge about how program funds 

were actually spent, whether or not all promised activities occurred, and 

how many people benefitted from the activities. Moving forward, without 

this information, VA and policymakers will struggle to make informed 

decisions about the program’s future. VA officials report that they are 

building a stronger oversight structure, but to the extent USOC’s 

weaknesses remain, VA may miss opportunities to better use program 

resources to motivate, encourage, and sustain participation and 

competition in adaptive sports among veterans and servicemembers with 

disabilities.

Conclusions 
 

Page 25 GAO-12-703 Veterans Paralympics Program

To improve oversight within the VA Paralympics grant program, we 

recommend the Secretary of VA direct the National Director of the Office 

of National Veterans Sports Programs and Special Events to take the 

following three actions:

1. Require USOC to modify reporting requirements that will:

a. Direct subgrantees to only include VA Paralympics program 

funds in expenditure reports; and

b. Provide a consistent methodology for how subgrantees should 

count their program activities and participants, including 

explicit instruction on what should and should not be counted 

as an activity or participant.

2. Ensure USOC adds controls to its electronic reporting system that 

will require subgrantees to identify how VA grant funds were used 

separate from other funding sources subgrantees use to support 

adaptive sports activities.

3. Review the implementation of USOC’s monitoring plan after a 

reasonable period to ensure planned efforts were conducted.

VA provided us with comments on a draft of this report, which we have 

reprinted in appendix III. In its comments, VA agreed with our 

recommendations and reported that efforts were underway to address 

each of them. Specifically, VA reported that USOC has already agreed to 

direct subgrantees to only include information on VA Paralympics 

program funds in expenditure reports. Furthermore, USOC has agreed to 

send its grant management staff to training in an effort to improve its data 

reporting. Regarding USOC’s electronic reporting system, VA reported 

that USOC has included the requirement that subgrantees identify how 

VA funds were used separately from other funding sources, and VA will 

review the system before it goes on-line during the fourth quarter of 2012. 

VA indicated that USOC also plans to provide training to subgrantees on 

how to appropriately report on grant funds during this quarter. In 

response to our recommendation on following up on USOC’s monitoring 

plan, VA reported that, in April 2012, it began meeting with USOC to 

improve USOC’s subgrant monitoring program, which now includes 

weekly conference calls with VA. VA also provided technical comments, 

which were incorporated into the report as appropriate.

Recommendations 

Agency Comments 

and Our Evaluation
 

Page 26 GAO-12-703 Veterans Paralympics Program

We are sending copies of this report to relevant congressional 

committees, the Secretary of the Department of Veterans Affairs, the 

Chief of Paralympics, USOC, and other interested parties. The report will 

also be available at no charge on the GAO Web site at 

http://www.gao.gov. 

If you or your staffs have any questions about this report, please contact 

me at (202) 512-7215 or bertonid@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 IV. 

Daniel Bertoni

Director, Education, Workforce,

 and Income Security Issues
Appendix I: Objectives, Scope and 

Methodology

Page 27 GAO-12-703 Veterans Paralympics Program

The objectives of this report were to (1) review how VA and its grantee 

and subgrantees used program funds to provide adaptive sports 

opportunities to veterans and servicemembers; (2) assess how VA is 

overseeing grantees’ and subgrantees’ use of funds; and (3) describe 

how veterans and servicemembers have benefited from VA Paralympics 

activities. The mandated requirement to include a description of how the 

United States Paralympics, Inc. (which was superseded by the 

Paralympic Division of the United States Olympic Committee (USOC)) 

used grant funds from the Department of Veterans Affairs (VA) is 

provided under the first research objective. The other mandated 

requirements to include the number of veterans with disabilities who 

benefitted from such grants and how such veterans benefitted were 

addressed under the third research objective. To address the three 

objectives, we analyzed both planned and final program budget 

expenditure data; reviewed program reports, guidance, and relevant 

federal laws and regulations; and interviewed VA and USOC officials and 

other program stakeholders about VA’s Paralympics program activities 

funded with fiscal years 2010, 2011, and 2012 appropriations.

Specifically, to determine how VA and its grantees used program funds, 

we reviewed information on planned and actual program expenditures 

provided by VA and USOC and interviewed VA and USOC officials to 

better understand the purposes for which funds were used. VA started 

spending Paralympic program funds in fiscal year 2010, but did not have 

complete final expenditure information for that first program year. As a 

result, we discuss this incomplete expenditure data in our report findings. 

We obtained VA’s complete planned and final expenditure budget 

information on fiscal year 2011 funds, but could only report planned 

expenditures for fiscal year 2012, as their actual expenditures for that 

year had not yet been finalized at the writing of this report. USOC 

provided data to us on subgrantees’ planned and final expenditures. 

Subgrantees’ planned expenditures were based on subgrant agreements 

made by USOC and the subgrantee, and final expenditures were based 

on data from quarterly reports submitted by each subgrantee to USOC. 

To determine the reliability of VA and USOC data on planned and actual 

program expenditures for that year, we interviewed VA and USOC 

officials about their procedures for collecting and maintaining these data. 

In addition, we reviewed a nonprobability sample of 21 subgrant files to 

verify the accuracy of data reported to USOC and to better understand 

how USOC maintains these data. The sample included all types of USOC 

subgrants mentioned in the background of this report. Specifically, all of 

USOC’s National Partner subgrants were included, and if these National 

Partners were also awarded Olympic Opportunity Fund subgrants, those 

Appendix I: Objectives, Scope and 

Methodology 
Appendix I: Objectives, Scope and 

Methodology

Page 28 GAO-12-703 Veterans Paralympics Program

subgrants were also included. The sample also included Model 

Community Partners and other Olympic Opportunity Fund subgrantees 

which were selected randomly after being stratified according to their 

subgrant type and USOC-designated geographic region. Due to errors in 

the original list of subgrantees by subgrant type provided by USOC, our 

sample also included two Athlete Development subgrants. In total, the 

sample files contained information on 56 percent of funds USOC provided 

in subgrants using fiscal year 2010 dollars. Due to problems we found 

with subgrantee reporting, we did not report information on subgrantees’ 

actual expenditures. (See the body of the report for more information.)

We reported only those expenditure data we believe were sufficiently 

reliable for the purposes of our study. 

To determine how VA oversaw grantees’ use of funds, we interviewed VA 

and USOC officials and obtained and reviewed quarterly progress reports 

from USOC, examples of progress reports from subgrantees, and VA’s 

and USOC’s monitoring plans. Furthermore, we reviewed the same nonprobability sample of 21 subgrant files to obtain information on whether 

their activities were documented as required under USOC policies—

mentioned in subgrant agreements, subgrant applications, and interviews 

with the organization’s officials—and as promoted by GAO’s guidelines 

for internal controls and the Domestic Working Group’s Grant 

Accountability Project’s promising practices.

To determine how veterans and servicemembers have benefited from VA 

Paralympics program activities, we reviewed participant and activity 

counts in the same non-probability sample of 21 subgrantee files 

maintained by USOC. We found issues with double-counting of activities 

and participants, as well as issues of counting nonveteran/servicemember activities and participants. However, to be 

responsive to our mandate, we provided USOC’s total counts of activities 

and participants in the report along with a discussion of why these 

numbers are not reliable. We reviewed USOC quarterly and annual 

program reports to VA. We also interviewed VA and USOC officials as 

well as subgrantees, regional stakeholders, and veteran program 

participants at a site visit to a VA adaptive sports program event in 

Chicago, Illinois in August 2011.
Appendix II: United States Olympic 

Committee’s Cost Definitions for Subgrantees’ 

Use of Funds

Page 29 GAO-12-703 Veterans Paralympics Program

Type of Cost Definition

Administrative Costs associated with the subawardee and the implementation and tracking of the subaward programs

Equipment Costs of non-construction related purchases for special purpose equipment that is used for the purposes of the 

grant

Operations Includes, but is not limited to, costs of: advertising and public relations related to the federal grant; audit and 

related services; communication (e.g. telephone, postage); meetings and conferences; participant support; 

publication and printing; rental of building and equipment; and transportation

Personnel Includes, but is not limited to, costs of: salaries and wages, director and executive committee membership fees, 

incentive awards, fringe benefits, pension plans, allowances for off-site pay, incentive pay, location allowances, 

hardship pay, and cost-of-living differentials

Supplies Costs of materials, supplies, and fabricated parts necessary to carry out the grant

Travel Costs of expenses for transportation, lodging, subsistence, and related items incurred by employees in travel 

status on official business

Source: US Olympic Committee

Appendix II: United States Olympic 

Committee’s Cost Definitions for 

Subgrantees’ Use of Funds
Appendix III: Comments from the Department 

of Veterans Affairs

Page 30 GAO-12-703 Veterans Paralympics Program

Appendix III: Comments from the 

Department of Veterans Affairs
Appendix III: Comments from the Department 

of Veterans Affairs

Page 31 GAO-12-703 Veterans Paralympics Program
Appendix III: Comments from the Department 

of Veterans Affairs

Page 32 GAO-12-703 Veterans Paralympics Program
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 33 GAO-12-703 Veterans Paralympics Program

Daniel Bertoni, 202-512-7215, or bertonid@gao.gov

In addition to the contact named above, the following staff members 

made important contributions to this report: Brett Fallavollita, Assistant 

Director; Danielle Giese, Analyst-in-Charge; Kristy Kennedy; Nisha 

Hazra; and Juliann Gorse. Also, Shana Wallace provided guidance on the 

study’s methodology; Craig Winslow provided legal advice; James 

Bennett assisted with report graphics; and Susannah Compton provided 

writing assistance.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 
Related GAO Products

Page 34 GAO-12-703 Veterans Paralympics Program

VA Mental Health: Number of Veterans Receiving Care, Barriers Faced, 

and Efforts to Increase Access. GAO-12-12. Washington, D.C.: October 

14, 2011.

VA Education Benefits: Actions Taken, but Outreach and Oversight Could 

Be Improved. GAO-11-256. Washington, D.C.: February 28, 2011.

VA Health Care: Spending for and Provision of Prosthetic Items.

GAO-10-935. Washington, D.C.: September 30, 2010.

Standards for Internal Control in the Federal Government.

GAO/AIMD-00-21.3.1 Washington, D.C.: November 1, 1999.

Related GAO Products

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