VA Office of Inspector General

OFFICE OF INVESTIGATIONS &

OFFICE OF AUDITS AND EVALUATIONS

Veterans Benefits 

Administration 

Administrative Investigation 

Inappropriate Use of 

Position and Misuse of 

Relocation Program and 

Incentives
 

September 28, 2015

 15-02997-526 
ACRONYMS AND ABBREVIATIONS 

AVO Appraised Value Offer 

BMA Broker’s Market Analysis 

CSEMO Corporate Senior Executive Management Office 

FTR Federal Travel Regulation 

FY Fiscal Year 

GS General Schedule 

OIG Office of Inspector General 

OPM U.S. Office of Personnel Management 

PCS Permanent Change of Station 

SES Senior Executive Service 

TDY Temporary Duty 

TQSE Temporary Quarters Subsistence Expense 

VA Department of Veterans Affairs 

VARO Veterans Affairs Regional Office 

VBA Veterans Benefits Administration 

WTA Withholding Tax Allowance 

To Report Suspected Wrongdoing in VA Programs and Operations: 

Telephone: 1-800-488-8244 

Email: vaoighotline@va.gov
 

(Hotline Information: www.va.gov/oig/hotline)
 
TABLE OF CONTENTS 

Summary ......................................................................................................................................... 1 

Introduction..................................................................................................................................... 3 

Background..................................................................................................................................... 3 

Results and Recommendations ....................................................................................................... 8 

Issue 1 Were Ms. Rubens’ Relocation Expenses Allowable Under Federal and 

VA Policy?........................................................................................................ 8 

Issue 2 Was Ms. Rubens’ Salary Retention Appropriate? .......................................... 12 

Issue 3 Has VBA Misused VA’s PCS Program? ........................................................ 13 

Issue 4 Did Ms. Rubens and Ms. Graves Use Their Positions of Authority for 

Their Own Personal Benefit?.......................................................................... 18 

Appendix A VBA Reassignments Expense Tables ............................................................. 28 

Appendix B VA Chief of Staff Comments ......................................................................... 34 

Appendix C OIG Contact and Staff Acknowledgments ..................................................... 39 

Appendix D Report Distribution ......................................................................................... 40 
 

DEPARTMENT OF VETERANS AFFAIRS
 

Office of Inspector General 

Washington, DC 20420
 

To: Deputy Secretary of Veterans Affairs 

Subject: Administrative Investigation: Inappropriate Use of Position and Misuse 

of Relocation Program and Incentives in the Veterans Benefits 

Administration 

Summary 

Ms. Diana Rubens was reassigned from her position as Deputy Under Secretary for Field 

Operations to the position of Director, Philadelphia and Wilmington VA Regional 

Offices (VAROs)1

, effective June 1, 2014. VA paid $274,019.12 related to Ms. Rubens’ 

Permanent Change of Station (PCS) move. Although we determined the PCS relocation 

expenses paid for Ms. Rubens’ move were generally allowable under Federal and VA 

policy, we found that Ms. Rubens inappropriately used her position of authority for 

personal and financial benefit when she participated personally and substantially in 

creating the Philadelphia VARO vacancy and then volunteering for the vacancy. 

Ms. Rubens told us she expressed an interest in replacing the former Philadelphia VARO 

Director when he retired in December 2011. In March 2014, she informed the Under 

Secretary for Benefits of her “desire to take advantage of the Philly Director opening” for 

herself, and the Under Secretary assured her that she would “be all in to help and make it 

happen.” We also identified issues related to Ms. Rubens’ PCS move. Specifically, we 

identified issues with the timeliness of VA’s approval of Ms. Rubens’ participation in the 

Appraised Value Offer (AVO) program, as well as a 17−day extension for temporary 

quarters subsistence expense (TQSE) allowance. In addition, Ms. Rubens claimed and 

was reimbursed $76.50 for alcoholic beverages, which is prohibited, and $47 for meal 

and tip expenses that were not supported by required receipts. 

As part of our assessment of VA’s relocation expense program (PCS program), we 

reviewed records related to the Veterans Benefits Administration’s (VBA) reassignment 

of 7 General Schedule (GS) Grade 15 employees who were promoted to Senior Executive 

Service (SES) positions and 15 SES employees who moved to different SES positions in 

fiscal years (FYs) 2013, 2014, and 2015. VBA management used moves of senior 

executives as a method to justify annual salary increases and used VA’s PCS program to 

1 Philadelphia VARO leadership has remotely managed the Wilmington VARO since 2003. 

VA Office of Inspector General 1 
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pay moving expenses for these employees. Annual salary increases totaled about 

$321,000, and PCS relocation expenses totaled about $1.3 million. Additionally, VBA 

paid $140,000 in unjustified relocation incentives. In total, VA spent about $1.8 million 

on the reassignments. While we do not question the need to reassign some staff to 

manage a national network of VAROs, we concluded that VBA inappropriately utilized 

VA’s PCS program for the benefit of its SES workforce. 

Ms. Kimberly Graves was reassigned from her position as the Director of VBA’s Eastern 

Area Office to the position of Director, St. Paul VARO, effective October 19, 2014. VA 

paid $129,467.56 related to Ms. Graves’ PCS move. We determined that Ms. Graves 

also inappropriately used her position of authority for personal and financial benefit when 

she participated personally and substantially in creating the St. Paul VARO vacancy and 

then volunteering for the vacancy. 

Mr. Antione Waller, former St. Paul VARO Director, told us Ms. Graves initiated 

discussion with him about relocating to the Philadelphia VARO. Once he expressed a 

willingness to accept the reassignment, she did an apparent “bait and switch.” She told 

him that the Philadelphia position was no longer available and he would be considered 

for the Baltimore VARO Director position. When he said he was not willing to move to 

Baltimore, Ms. Graves told him, “you will probably get another call, this probably won’t 

be the last conversation about Baltimore.” In an email, Ms. Beth McCoy, who at the time 

was the Assistant Deputy Under Secretary for Field Operations and Ms. Rubens’ 

subordinate, told Ms. Graves that she spoke to Mr. Waller and told him his name was 

already submitted to the VA Secretary for Baltimore, so “saying no now is not a clean or 

easy option.” Once the St. Paul Director position was vacant, Ms. Graves said she 

contacted Ms. Rubens and said, “I’d like to throw my name in for consideration for 

St. Paul ... I feel like I’ve done my time and I’d like to put my name in.” 

Ms. Rubens’ and Ms. Graves’ reassignments resulted in a significant decrease in job 

responsibilities, yet both retained their annual salaries—$181,497 and $173,949, 

respectively. Based on Federal regulations, we determined VA could not reduce their 

annual salaries upon reassignment despite the decrease in the scope of their 

responsibilities. However, a senior executive’s annual salary can be reduced if the 

individual receives a less than fully successful annual summary rating, fails to meet 

performance requirements for a critical element, or, as a disciplinary or adverse action 

resulting from conduct related activity. 

We made criminal referrals to the U.S. Attorney’s Office, District of Columbia, regarding 

official actions orchestrated by Ms. Rubens and Ms. Graves. Formal decisions regarding 

prosecutorial merit are pending. We provided 12 recommendations to VA to increase 

oversight of VA’s PCS program and to determine the appropriate administrative actions 

to take, if any, against senior VBA officials. 

VA Office of Inspector General 2 
 

Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Introduction 

In March 2015, the Chairman and Ranking Member of the House Committee on 

Veterans’ Affairs and the Chairman and Ranking Member of the Senate Committee on 

Veterans’ Affairs requested the VA Office of Inspector General (OIG) investigate 

allegations concerning financial benefits and preference given at VA. An anonymous 

complainant alleged that Ms. Rubens, Philadelphia VARO Director, improperly received 

$288,206.77 in relocation expenses for transferring from VBA Headquarters to her 

current position at the VARO and retained her high-level SES salary, despite the position 

being two levels lower on VA’s SES pay scale. Chairman Jeff Miller, House Committee 

on Veterans’ Affairs, said VA confirmed Ms. Rubens relocation expenses were “in the 

ballpark” of $300,000, which raised questions about a potential abuse of the PCS 

Program across VA. The OIG was also asked to conduct a broader review of this 

program. 

To assess the allegations and review of VA’s PCS program, we interviewed 

Mr. Jose Riojas, former VA Chief of Staff; Ms. Allison Hickey, Under Secretary for 

Benefits; Mr. Danny Pummill, Principal Deputy Under Secretary for Benefits; 

Ms. Beth McCoy, Deputy Under Secretary for Field Operations; Mr. Willie Clark, 

Eastern Area Director; Mr. Robert McKenrick, Los Angeles VARO Director; 

Ms. Rubens; Ms. Graves; Mr. Waller; and other VA and VBA employees. We also 

reviewed personnel, payroll, email, expense, relocation, and travel records, as well as 

Federal laws and regulations and VA policy. 

Background 

Relocation Expenses 

The Federal Travel Regulation (FTR) states that an employee transferring in the interest 

of the Government from one agency or duty station to another for permanent duty that is 

at least 50 miles from their old duty station is eligible for relocation expense allowances. 

The distance between Washington, DC, and Philadelphia, PA, is about 140 miles. There 

are mandatory and discretionary relocation expenses and once an agency makes the 

decision to pay or reimburse relocation expenses, all the expenses deemed mandatory 

must be paid or reimbursed. Mandatory PCS benefits for eligible employees include the 

following: 

VA Office of Inspector General 3 
 

Administrative Investigation: Inappropriate Use of Position and 

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 En route travel 

 Household goods 

 Temporary storage 

 Real estate expenses 

 Miscellaneous expense allowance 

 Relocation income tax allowance 

Employees can also be eligible for TQSE allowance, which is considered a discretionary 

expense. TQSE allowance is intended to reimburse an employee reasonably and 

equitably for expenses incurred when occupying temporary quarters. For approved 

employees, an authorizing official may approve TQSE for a period up to 60 consecutive 

days. Under compelling circumstances acceptable to the agency, up to an additional 

60-day TQSE period may be granted in 30-day increments. Under no circumstances can 

the agency grant extensions beyond 120 days. 

Appraised Value Offer Program 

As part of the relocation program, Federal agencies, including VA, can offer some 

employees assistance through the AVO program, which is designed to help employees 

sell their primary residence. Each VA administration, such as VBA, defines which 

employees are authorized to participate in the AVO program. Ms. Hickey told us that all 

VBA SES employees are offered AVO benefits when making a PCS move. VA had a 

contract with Brookfield Global Relocation Services2

 (Brookfield) to provide employees 

approved for the AVO program assistance selling their home. 

Once an employee is approved to participate in the AVO program, two separate real 

estate agents conduct a broker’s market analysis (BMA), which is used to describe the 

current marketplace and provide an assessment of the most probable selling price for the 

employee’s home. Once the BMAs are completed, Federal policy requires the employee 

to list their home within 105 percent of the average most likely sales price from the 

two BMAs for at least 60 days. 

While the property is for sale, two separate appraisals are conducted to estimate the value 

of the home. This is done by comparing the home to the sales of similar properties in the 

surrounding area. Appraisers also consider location, size, age, condition, and 

marketability of the home. Upon completion of the appraisals, Brookfield makes an offer 

to purchase the employee’s home based on the average of the two appraised values. This 

is intended to serve as a “back-up offer” for instances when the employee cannot sell 

2

 This was a VA contract procured through the U.S. General Services Administration’s Federal Supply Schedule. 

VA Office of Inspector General 4 
Administrative Investigation: Inappropriate Use of Position and 

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their home. If the home does not sell after being on the market for 60 days, the employee 

may accept the AVO. 

Senior Executive Service 

The SES was established by the Civil Service Reform Act of 1978 and became effective 

in July 1979. The Act established the SES as a distinct personnel system that applies the 

same executive qualification requirements to all of its members. The system was 

designed to provide greater authority to agencies to manage their executive resources. 

The SES includes most managerial, supervisory, and policy positions classified above 

GS Grade 15 or equivalent positions in the Executive Branch of the Federal Government. 

The National Defense Authorization Act for FY 2004 established a performance-based 

pay system for SES. The pay range has a minimum and maximum rate of pay for all 

SES positions. The VA Secretary has the authority to set the pay rate for the VA’s SES 

employees; however, pay cannot be set lower than the minimum or higher than the 

maximum rates. Table 1 details minimum and maximum rates of pay for SES employees 

during FYs 2013 through 2015. 

Table 1. SES Rates of Pay (Government-wide) 

FY Minimum Rate of Pay Maximum Rate of Pay 

2013 $119,554 $179,700 

2014 $120,749 $181,500 

2015 $121,956 $183,300 

Source: U.S. Office of Personnel Management 

In 2004, VA established a pay band structure for SES pay. VA categorized their 

SES positions into three different pay bands based on the scope of responsibility for each 

position. The following is a summary of VA’s three pay bands for SES: 

	 Pay Band 1: Higher complexity SES positions (for example, VA Chief of Staff) 

	 Pay Band 2: Medium complexity SES positions (for example, Deputy Assistant 

Secretaries) 

	 Pay Band 3: Lower complexity SES positions (for example, Associate Deputy 

Assistant Secretaries) 

VA Office of Inspector General 5 
 

 

Administrative Investigation: Inappropriate Use of Position and 

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Table 2 details minimum and maximum rates of pay for VA SES by pay band during 

FYs 2013 through 2015. 

Table 2. SES Rates of Pay by Pay Band (Specific to VA) 

FY/Pay Band Minimum Rate of Pay Maximum Rate of Pay 

2013 

Pay Band 1 $119,554 $179,700 

Pay Band 2 $119,554 $173,600 

Pay Band 3 $119,554 $165,300 

2014 

Pay Band 1 $120,749 $181,500 

Pay Band 2 $120,749 $175,400 

Pay Band 3 $120,749 $167,000 

2015 

Pay Band 1 $121,956 $183,300 

Pay Band 2 $121,956 $177,154 

Pay Band 3 $121,956 $168,700 

Source: VA Corporate Senior Executive Management Office 

VA’s Corporate Senior Executive Management Office (CSEMO) reported that VBA had 

70 SES positions as of June 30, 2015—22 positions were Pay Band 1, 9 positions were 

Pay Band 2, and 39 positions were Pay Band 3. 

Ms. Diana Rubens, (SES) Director, VAROs Philadelphia, PA, and Wilmington, DE 

In 2008, Ms. Rubens became the Deputy Under Secretary for Field Operations. This was 

a VBA Headquarters-based SES, Pay Band 1, position located in Washington, DC. In 

this position, she was responsible for the oversight of the 4 Area Offices3

 and 56 VAROs 

within VBA. VBA’s area and regional offices employ over 18,000 people and administer 

benefit programs that pay over $70 billion annually to veterans and their beneficiaries. 

3 In July 2015, VBA restructured its four Area Offices (Eastern, Southern, Central, and Western) into five District 

Offices (North Atlantic, Southeast, Midwest, Continental, and Pacific). For the purposes of this report, we refer to 

Area Offices because that was VBA’s organizational structure at the time of the VBA reassignments. 

VA Office of Inspector General 6 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

In 2014, Ms. Rubens volunteered to become the Director, Philadelphia VARO. In 

May 2014, she was reassigned from her VBA Headquarters position to the position of 

Director, Philadelphia and Wilmington VAROs, with an effective date of June 1, 2014. 

This is an SES, Pay Band 3, position and involves a significant decrease in job 

responsibilities. She went from being responsible for oversight of 4 Area Offices and 

56 VAROs to being responsible for only 2 VAROs. Although she volunteered for a 

position with reduced responsibilities, she retained her $181,497 annual salary when she 

transferred. VA also paid a total of $274,019.12 in PCS relocation expenses, including 

AVO-related costs, for Ms. Rubens and her dependent. 

Ms. Kimberly Graves, (SES) Director, VARO St. Paul, MN 

In 2010, Ms. Graves became the Director of VBA’s Eastern Area Office. This was an 

SES, Pay Band 1, position, and she was responsible for oversight of 16 VAROs across 

14 states. In 2014, she volunteered to become the Director, St. Paul VARO. Ms. Graves 

was reassigned from the Eastern Area Director position to the position of Director, 

St. Paul VARO in October 2014. This is an SES, Pay Band 2, position and involves a 

significant decrease in job responsibilities. She went from being responsible for 

oversight of 16 VAROs to being responsible for only 1 VARO. Although she 

volunteered for a position with reduced responsibilities, she retained her $173,949 annual 

salary when she transferred. VA also paid a total of $129,467.56 in PCS relocation 

expenses, including AVO-related costs, for Ms. Graves. 

VA Office of Inspector General 7 
 

Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Results and Recommendations 

Issue 1: Were Ms. Rubens’ Relocation Expenses Allowable Under 

Federal and VA Policy? 

VA paid a total of $274,019.12 related to Ms. Rubens’ PCS move. As of July 16, 2015, 

obligations totaling $6,984.10 remained open, which may be expensed in the future. 

Therefore, VA could pay as much as $281,003.22 in relocation expenses once all PCS 

claims are processed and finalized. 

Ms. Rubens was directly paid a total of $33,261.29 for her PCS move, as follows: 

 $13,062.75 in TQSE allowance—includes lodging, meals, tips, and dry cleaning 

 $10,524 in real estate expenses 

 $67.68 in en route travel expenses 

 $8,306.86 in withholding tax allowance (WTA) 

 $1,300 in miscellaneous expense allowance 

VA incurred additional expenses totaling $240,757.83 for Ms. Rubens’ PCS move, most 

of which related to home sale assistance under the AVO program. Table 3 summarizes 

expenses paid by VA for Ms. Rubens’ PCS move. 

Table 3. Ms. Rubens Relocation Expenses 

Distribution of PCS Relocation Expenses Amount Paid Percent of Total 

Amount Paid To Ms. Rubens (TQSE, Real Estate, En 

Route Travel, WTA, and Miscellaneous Expenses) 

$33,261.29 12% 

Amount Paid To Brookfield (FY 2014 Home Sale Fee4 

was 27.5% of the Average Appraised Value of $770,000) 

$211,750.00 77% 

Amount Paid To Relocation Management Worldwide, 

Inc. (Transportation and Storage of Household Goods) 

$16,302.83 6% 

Amount Paid To VA’s Financial Services Center5

 (6% of 

the amount paid to Brookfield) 

$12,705.00 5% 

Totals $274,019.12 100% 

Source: VA PCS Travel Division 

4

 In FY 2014, the home sale acquisition fee was 27.5 percent for PCS moves where employees accepted the 

Appraised Value Offer—it was not specific to Ms. Rubens’ PCS move.

5

 VA’s Financial Services Center charged a fee of 6 percent of the Brookfield Home Sale invoice. This fee is 

charged to cover the cost of administering the PCS Home Sale Relocation contract. The Financial Services Center 

also pays a portion of this fee to VA’s Technology Acquisition Center for assisted acquisition services. 

VA Office of Inspector General 8 
 

Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Once senior VA managers approved her PCS move, relocation expenses paid to 

Ms. Rubens were generally allowable under Federal and VA policy. The majority of 

Ms. Rubens’ PCS expenses—nearly $224,500—were related to her participation in the 

AVO program. The Under Secretary for Benefits and VA Chief of Staff approve or deny 

AVO benefits as part of a VBA employee’s PCS move. The Under Secretary for 

Benefits, Ms. Hickey, told us that all SES employees are offered AVO benefits when 

making a PCS move. Ms. Hickey said she signs the approval for AVO benefits for 

SES employees, which obligates VBA funds for the AVO benefits. 

We identified the following issues related to Ms. Rubens’ PCS move: 

	 Approval of Ms. Rubens’ AVO benefits was not timely. 

	 Request and approval of a 17−day extension for TQSE allowance and storage of 

household goods was not timely. 

	 Ms. Rubens submitted receipts for reimbursement of meal expenses that included 

alcoholic beverages. 

	 Ms. Rubens was paid unauthorized expenses for meals and tips during a period when 

her dependent was on temporary duty (TDY) travel. 

AVO Approval Not Timely 

On May 27, 2014, Ms. Rubens signed a document accepting a reassignment to the 

Philadelphia VARO. At that point, her participation in the AVO program had not been 

approved. Two days later, on May 29, 2014, Ms. Rubens signed another document 

stating she would not accept a transfer to the Philadelphia VARO unless AVO benefits 

were approved. As a result, on the same day, Mr. Pummill issued a memo to Ms. Hickey 

requesting approval for Ms. Rubens’ participation in the AVO program. Ms. Hickey; 

Ms. McCoy (a subordinate of Ms. Rubens at the time6

); Ms. Julie Murphy, Director of 

the VBA Office of Human Resources; and Mr. Jamie Manker, Director of the VBA 

Office of Resource Management signed off on the approval document the same day. The 

effective date of Ms. Rubens reassignment to the Philadelphia VARO was June 1, 2014. 

On June 3, 2014, after the effective date of Ms. Rubens reassignment, Mr. Riojas, VA’s 

Chief of Staff at the time, approved AVO benefits for Ms. Rubens. She told us she did 

not know whether she would have accepted the reassignment without AVO benefits. 

However, inconsistent with this assertion, we determined she volunteered for the 

reassignment and accepted the reassignment prior to being approved for AVO benefits. 

6

 Prior to her move to VARO Philadelphia, Ms. Rubens was the Deputy Under Secretary for Field Operations, and 

Ms. McCoy was the Assistant Deputy Under Secretary for Field Operations. Ms. Rubens was Ms. McCoy’s direct 

supervisor. 

VA Office of Inspector General 9 
 

 

Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Temporary Quarters Extension Not Timely 

Ms. Rubens was approved for TQSE allowance as part of her reassignment package. Her 

authorizing official, Ms. Graves (a subordinate of Ms. Rubens at the time she volunteered 

for the reassignment7

), initially approved TQSE for a period of 30 consecutive days 

(July 9 through August 7, 2014). On July 31, 2014, Ms. Rubens sent a memo requesting 

approval for a 30−day extension (August 8 through September 6, 2014) of TQSE. 

Ms. Graves also approved this request. 

On September 9, 2014, 3 days after Ms. Rubens completed her approved 30-day 

extension in temporary quarters, she sent a memo requesting approval for an additional 

17-day extension (September 7 through September 23, 2014) in temporary quarters due 

to compelling circumstances. Even though this request was submitted after Ms. Rubens’ 

approved temporary quarters period ended, Ms. Graves approved the extension. The 

approval documentation indicated the 17 days were needed to accommodate the 

settlement date on Ms. Rubens’ newly constructed home. Additional expenses for this 

17-day period totaled $3,655 for TQSE and $727.67 for the storage of household goods. 

Claims for Meals and Tips Included Alcoholic Beverages 

Ms. Rubens was paid a total of $13,062 in TQSE related to her PCS move, which 

included meals and tips. Per diem meals are defined as expenses for breakfast, lunch, 

dinner, and related tips and taxes—specifically excluded are alcoholic beverages, 

entertainment expenses, and any expenses incurred for other people. Based on our 

review of receipts submitted by Ms. Rubens, we determined that she claimed and was 

reimbursed $76.50 for alcoholic beverages. 

Unauthorized Meals and Tips Expenses During TDY 

Based on travel records, Ms. Rubens’ dependent, also a VBA employee, was on TDY 

from September 2 through September 4, 2014. According to the FTR, when claiming 

TQSE, the employee (Ms. Rubens) must provide a receipt for every authorized expense 

over $75 (not $150 in this case because Ms. Rubens’ dependent was on TDY). 

Ms. Rubens claimed TQSE expenses of $92 on September 2, 2014; $88 on 

September 3, 2014; and $92 on September 4, 2014. Ms. Rubens did not provide itemized 

receipts as required for these days. Therefore, we question $47 in meals and tips that 

exceeded $75 per day. 

7

 Prior to her move, Ms. Rubens was the Deputy Under Secretary for Field Operations, and Ms. Graves was the 

Eastern Area Director. Ms. Rubens was Ms. Graves’ second-level supervisor. 

VA Office of Inspector General 10 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Conclusion 

We determined that because senior VA managers authorized Ms. Rubens reassignment 

the PCS relocation expenses paid for her move were generally allowable under Federal 

and VA policy. While the expenses were generally allowable because senior 

VA managers approved Ms. Rubens relocation, we have concerns over Ms. Rubens’ 

involvement in creating the director’s vacancy at the Philadelphia VARO (see Issue 4 for 

further details). We also identified issues with the timeliness of the approval for 

Ms. Rubens’ participation in the AVO program, as well as a 17-day extension for 

TQSE allowance and storage of household goods. In addition, Ms. Rubens claimed and 

was reimbursed $76.50 for alcoholic beverages and $47 in meals and tips expenses that 

were not supported by required receipts. Controls over the approval process need to be 

strengthened to ensure subordinate employees, or those who were recently subordinate 

employees, do not approve PCS travel expenses and to ensure all requests for benefits are 

timely. 

Recommendations 

Recommendation 1. We recommended the Deputy Secretary review the Department’s 

request and approval process for the Appraised Value Option program and make 

improvements as deemed appropriate. 

Recommendation 2. We recommended the Deputy Secretary review the Department’s 

request and approval process for temporary quarters subsistence expense allowance and 

make improvements as deemed appropriate. 

Recommendation 3. We recommended the Deputy Secretary consult with the Office of 

General Counsel to determine whether Ms. Rubens should be issued a bill of collection 

for $123.50 to recoup the improper reimbursements paid to her for alcoholic beverages 

and unauthorized meals and tips. 

Management Comments and OIG Response 

The Chief of Staff concurred with our recommendations and stated the Deputy Secretary 

will take action by the end of the year to address the recommendations. We will monitor 

VA’s progress and follow up on VA’s implementation actions until all actions are 

completed. The Chief of Staff’s full response is included in Appendix B. 

VA Office of Inspector General 11 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Issue 2: Was Ms. Rubens’ Salary Retention Appropriate? 

Ms. Rubens’ reassignment documentation included information pertaining to her annual 

salary. It showed her position as the Deputy Under Secretary for Field Operations was a 

Pay Band 1 position with an annual salary of $181,497. Her new assignment as Director 

of the Philadelphia VARO was a Pay Band 3 position with a maximum annual salary of 

$167,000. However, upon being reassigned, Ms. Rubens retained her $181,497 annual 

salary even though the scope of her responsibilities significantly decreased. 

According to Federal regulations, the SES rate of basic pay for a career senior executive 

may only be reduced if the senior executive has received a less than fully successful 

annual summary rating, or has otherwise failed to meet the performance requirements for 

a critical element. Additionally, SES pay may be reduced without the employee’s 

consent by the SES agency as a disciplinary or adverse action resulting from 

conduct-related activity, including but not limited to misconduct, neglect of duty, or 

malfeasance. 

Conclusion 

From FY 2009 to the time of Ms. Rubens’ reassignment, she was rated better than fully 

successful on all performance appraisals. Therefore, we concluded that Ms. Rubens met 

all critical performance elements. Additionally, during our review and interviews, we did 

not identify any instances of disciplinary or adverse action taken against Ms. Rubens. 

Based on applicable Federal regulations, we determined VA could not reduce her annual 

salary upon reassignment despite the decrease in scope of her responsibilities. 

VA Office of Inspector General 12 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Issue 3: Has VBA Misused VA’s PCS Program? 

As part of our assessment of VA’s PCS program, we reviewed VBA reassignments of 

7 GS-15 employees who were promoted to SES positions and 15 SES employees who 

moved to different SES positions in FYs 2013, 2014, and 2015 (total of 23 reassignments 

as one SES employee was reassigned twice—once in FY 2013 and again in FY 2015). 

VBA management used moves of senior executives as a method to justify annual salary 

increases and used VA’s PCS program to pay moving expenses for most of these 

employees. We reviewed financial details associated with these moves to assess the costs 

of the moves, as well as potential abuse of VA’s PCS program. Included in our analysis 

for each reassignment was the following: 

 Annual salary increases 

 Relocation incentives 

 Relocation expenses 

 AVO expenses 

Annual Salary Increases 

We determined that VBA used reassignments through VA’s PCS program as a way to 

increase SES pay. From FY 2010 to 2013, U.S. Office of Personnel Management (OPM) 

guidelines precluded all SES employees from receiving annual pay increases. During 

this period, the maximum SES annual salary remained at $179,700, as established by 

OPM Federal pay guidelines. Further, in 2012, the VA Secretary determined no VBA 

executives would receive performance awards based on concerns over the backlog of 

veterans’ disability claims. 

We interviewed Mr. Pummill on May 13, 2015. We asked whether salary increases and 

relocation incentives were a way to get around pay freezes and bans on performance 

bonuses. Mr. Pummill said, “I would say that’s probably true.” He stated further that the 

VA Chief of Staff at the time said that an SES employee’s salary could be increased as 

long as the executive was moving to a different location. 

We also interviewed Ms. Hickey on May 13, 2015. We asked whether salary increases 

and relocation incentives were a way to get around pay freezes and bans on performance 

bonuses. Ms. Hickey stated that the salary increases were about “level-setting pay.” She 

stated further, “it was more about resetting from my perspective base pay to get 

everybody—get the ends of the bands into more of a—more even, more fair model.” 

Twenty-one of the 23 reassignments included salary increases. These VBA 

reassignments resulted in annual salary increases totaling about $321,000 (average 

VA Office of Inspector General 13 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

increase was $15,286). We identified concerns with the salary increases as they did not 

seem to consistently reflect changes in the positions’ scope of responsibility. For 

example: 

	 In FY 2014, VBA reassigned Mr. Duane Honeycutt from Director, Chicago VARO, 

to the position of Director, Milwaukee VARO. The Milwaukee VARO has a broader 

mission than the Chicago VARO as it includes one of the three VBA Pension 

Management Centers. With this reassignment to a more complex VARO, 

Mr. Honeycutt received a 9 percent annual salary increase—from $151,772 to 

$165,300. 

	 In FY 2014, VBA reassigned Mr. Antione Waller from Director, St. Paul VARO, to 

the position of Director, Baltimore VARO. The St. Paul VARO has a broader 

mission than the Baltimore VARO, as it includes one of the three VBA Pension 

Management Centers and one of the nine VBA Regional Loan Centers. Therefore, 

this was a transfer to a less complex VARO, yet Mr. Waller received a 20 percent 

annual salary increase—from $139,683 to $167,000. 

Additionally, the VBA reassignments led to new vacancies in offices the SES employees 

left. We found that when VBA filled these vacant SES positions, the selectees often 

received significant annual salary increases over what their predecessors were paid. For 

example: 

	 When VBA transferred Mr. Pritz Navaratnasingam from Director, Houston VARO, to 

the position of Director, Seattle VARO, his annual salary increased to $167,000— 

$30,417 (22 percent) more than the previous Seattle Director. 

	 When VBA transferred Mr. Honeycutt from Director, Chicago VARO, to the position 

of Director, Milwaukee VARO, his annual salary increased to $165,300— 

$22,028 (15 percent) more than the previous Milwaukee Director. 

	 When VBA transferred Ms. Mitzi Marsh from Director, Wichita VARO, to the 

position of Director, St. Louis VARO, her annual salary increased to $152,569— 

$11,169 (8 percent) more than the previous St. Louis Director. 

For additional information on annual salary increases associated with the 23 VBA 

reassignments, see Table 6, on pages 28–29, in Appendix A. 

Relocation Incentives 

OPM policy states an agency may pay a relocation incentive to a current employee who 

must relocate to accept a position in a different geographic area if the agency determines 

the position is likely to be difficult to fill in the absence of an incentive. In addition to 

VA Office of Inspector General 14 
 

 

 

Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

annual salary increases, VBA paid seven employees relocation incentives when they 

moved to new positions. The seven relocation incentives totaled $140,000. However, we 

determined that VA did not properly justify the incentives. Specifically, of the 

seven relocation incentives: 

	 Five (71 percent) were not justified because job vacancies were not announced or the 

positions were filled before candidates who applied were considered. We determined 

that an agency cannot make a determination whether a position is difficult to fill if the 

agency does not actively search for or consider applicants for the position. 

	 Two (29 percent) were not timely justified. VA policy requires justification of a 

relocation incentive prior to including a statement on the vacancy announcement that 

an incentive may be authorized. We determined the relocation incentive justifications 

were signed 4 and 5 months after the job announcements were posted, respectively. 

Both job announcements included a statement that a relocation incentive may be 

authorized. 

The Under Secretary for Benefits and the VA Chief of Staff at the time approved VBA’s 

relocation incentive justifications and payments. In each of the seven instances above, 

Ms. Hickey and/or Mr. Riojas signed documentation approving the payment of relocation 

incentives. For additional information on relocation incentives associated with the seven 

VBA reassignments, see Table 7, on page 30, in Appendix A. 

PCS and AVO-Related Expenses 

In addition to annual salary increases and relocation incentives, VBA paid relocation 

expenses for 20 of the 23 reassignments, as well as AVO-related expenses for 118

 of the 

moves. Specifically, VBA spent about $582,000 on relocation expenses and about 

$710,000 on AVO-related expenses for these moves—totaling about $1.3 million. 

Included in this were the $274,019.12 in relocation and AVO-related expenses related to 

Ms. Rubens’ reassignment from VBA Headquarters to the Philadelphia VARO. The 

following are additional examples of significant PCS and AVO-related expenses 

associated with the VBA reassignments. 

	 When VBA transferred Ms. Graves from Eastern Area Director to the position of 

Director, St. Paul VARO, VA paid $23,361.56 in relocation expenses and $106,106 in 

AVO-related expenses—total $129,467.56. 

8

 Even though AVO benefits were paid for 11 of the moves, the AVO option was approved for 12 moves— 

1 individual did not use AVO benefits even though approved to do so. 

VA Office of Inspector General 15 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

	 When VBA transferred Mr. Navaratnasingam from Director, Houston VARO, to the 

position of Director, Seattle VARO, VA paid $41,563.69 in relocation expenses and 

$41,403.60 in AVO-related expenses—total $82,967.29. 

	 When VBA transferred Mr. Patrick Prieb from Director, Seattle VARO, to the 

position of Director, San Diego VARO, VA paid $22,863.73 in relocation expenses 

and $69,562.50 in AVO-related expenses—total $92,426.23. 

	 When VBA transferred Ms. Julianna Boor from Assistant Director, Seattle VARO, to 

the position of Director, Oakland VARO, VA paid $45,964.21 in relocation expenses 

and $48,972 in AVO-related expenses—total $94,936.21. 

	 When VBA transferred Ms. Lisa Breun from Director, Des Moines VARO, to the 

position of Director, Little Rock VARO, VA paid $52,651.69 in relocation expenses 

and $95,733.90 in AVO-related expenses—total $148,385.59. 

While these reassignments resulted in significant costs to VA, these expenses were 

allowable under the Federal relocation program. For additional information on PCS and 

AVO-related expenses associated with these 20 VBA reassignments, see Table 8, on 

page 31, in Appendix A. 

Conclusion 

VBA spent about $1.8 million for the 23 reassignments we reviewed from FYs 2013, 

2014, and 2015—including annual salary increases, relocation incentives, PCS expenses, 

and AVO-related expenses. While the PCS expenses and AVO-related expenses were 

allowable under Federal and VA policy, we determined that VBA used moves of senior 

managers as a means to justify annual salary increases and used VA’s PCS program to 

pay moving expenses for these employees. Annual salary increases totaled about 

$321,000, and PCS relocation expenses totaled about $1.3 million. Additionally, VBA 

paid $140,000 in unjustified relocation incentives. While we do not question the need to 

reassign some staff to manage a national network of VAROs, we concluded that VBA 

inappropriately used VA’s PCS relocation program for the benefit of its SES workforce. 

For additional information on total expenses associated with the 23 VBA reassignments, 

see Table 9, on pages 32-33, in Appendix A. 

Recommendations 

Recommendation 4. We recommended the Deputy Secretary strengthen the approval 

process to include requiring an independent review of the Department’s Permanent 

Change of Station program to ensure moves and expenses are appropriate and justified. 

VA Office of Inspector General 16 
 

Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Recommendation 5. We recommended the Deputy Secretary require the Veterans 

Benefits Administration to establish policies and procedures to standardize its practices 

regarding annual salary increases when reassigning Senior Executives’ positions. 

Recommendation 6. We recommended the Deputy Secretary consult with the Office of 

General Counsel to determine whether bills of collection should be issued to recover 

unjustified relocation incentives paid by the Veterans Benefits Administration for Senior 

Executive reassignments. 

Recommendation 7. We recommended the Deputy Secretary consult with the Office of 

General Counsel to determine what actions may be taken to hold the appropriate Senior 

Officials accountable for processing and approving payments of unjustified relocation 

incentive payments. 

Management Comments and OIG Response 

The Chief of Staff concurred with our recommendations and stated the Deputy Secretary 

will take action by the end of the year to address the recommendations. We will monitor 

VA’s progress and follow up on VA’s implementation actions until all actions are 

completed. The Chief of Staff’s full response is included in Appendix B. 

VA Office of Inspector General 17 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Issue 4: Did Ms. Rubens and Ms. Graves Use Their Positions of 

Authority for Their Own Personal Benefit? 

In June 2014, Ms. Rubens moved from her VBA Headquarters position as Deputy Under 

Secretary for Field Operations to the position of Director, Philadelphia VARO (detailed 

in Issues 1 and 2 of this report). Ms. Rubens replaced Mr. Robert McKenrick who was 

reassigned to the position of Director, Los Angeles VARO. Based on our review of the 

details surrounding this reassignment, we determined Ms. Rubens inappropriately used 

her position of authority for personal and financial benefit when she participated 

personally and substantially in creating an opportunity for her own transfer to the 

Philadelphia VARO. We determined that Ms. Rubens had ties to the Philadelphia area. 

In a May 28, 2015, interview, we asked Ms. Rubens if the challenge of the mission in 

Philadelphia was the only reason she was interested in becoming the director there. 

Ms. Rubens said, “No. I grew up in Delaware ... it’s near home.” Table 4 provides a 

timeline of actions and evidence that supports our conclusion. 

Table 4. Timeline of Ms. Rubens’ Reassignment 

Date Event 

December 2011 Mr. Thomas Lastowka retired as the Philadelphia VARO Director on 

December 31, 2011. 

In a May 28, 2015, interview, Ms. Rubens told us she communicated to 

VBA leadership an interest in replacing Mr. Lastowka as the Philadelphia 

VARO Director at the time he retired. Specifically, she said, “I actually 

had expressed an interest at that time in coming to Philadelphia.” 

However, she said, “there was not an appetite for that within VBA for me 

to depart DC at the time.” Ms. Rubens explained that Ms. Hickey, 

“hadn’t been there a super long time and was still trying to make sure she 

had a sense of VBA and all the issues and I think at that point she, 

because I had a pretty good handle on the field overall, wanted to keep me 

there at that point.” 

March 2012 

Robert McKenrick was selected as the Philadelphia VARO Director on 

March 11, 2012. In an April 21, 2015, interview, Mr. McKenrick told us 

he was the Director of Federal Security Officers at LaGuardia Airport for 

the Transportation Security Administration prior to joining VA. We 

determined he did not have prior VA experience at the time he was hired 

in 2012. 

VA Office of Inspector General 18 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Date Event 

June 2013– 

February 2014 

In a June 10, 2015, interview, Mr. McKenrick told us that he was selected 

to be on the review panel tasked with filling the vacant Los Angeles 

VARO Director position, as well as other job openings. 

Despite a combined 168 applicants, 5 of whom were considered “best 

qualified,” the first 2 Los Angeles VARO Director job announcements 

did not result in hiring a director. A third job announcement was made; 

however, the certificate was suspended prior to rating and ranking the 

112 individuals who applied. According to the former VBA Deputy 

Chief of Staff, the hiring effort was suspended at the direction of 

Ms. Rubens’ office. 

In the June 10, 2015, interview with OIG staff, Mr. McKenrick told us he 

spoke with Ms. Rubens about the hiring challenges for the Los Angeles 

position. He said that when Ms. Rubens asked if he was interested in 

taking the Los Angeles job, he said, “I would have to be direct reassigned, 

meaning I’m not jumping up and down saying send me to L.A., send me 

to L.A.” 

Mr. McKenrick further explained that, while he was interested in the 

challenges at Los Angeles, he did not want to go there. Specifically, he 

said, “Just being interested says it’s interesting, it’s unique, it’s different. 

Well, would you go? Only if you direct reassigned me, only if you told 

me I absolutely had to go, that that was in the best interest of the agency, 

absent being removed or whatever the letter said, you’re subject to 

adverse action or something.” Mr. McKenrick said, “It’s not a volunteer 

in my mind. I’m not volunteering. I’m saying it’s interesting and I want 

to understand it ...” 

Mr. McKenrick told us that he did not apply to any of the announcements 

for the Los Angeles position and that he preferred to stay in Philadelphia. 

When asked if it would be fair to say he told Ms. Rubens that he wanted 

the job, Mr. McKenrick said, “No.” When asked if he was disappointed 

in his reassignment to Los Angeles, Mr. McKenrick said, “That’s fair.” 

Mr. McKenrick indicated to us that his interpretation of the reassignment 

memo he ultimately received was that he accept the reassignment or he 

would lose his job. 

In a May 28, 2015, interview with OIG staff, Ms. Rubens told us that 

Mr. McKenrick showed an interest in the Los Angeles VARO Director 

position by saying he felt “he could help the organization by going out 

there ...” Ms. Rubens said, “he thought it would be good for him and his 

... family to relocate.” However, in the June 10, 2015, interview, 

Mr. McKenrick told us that he had financial and family concerns about 

relocating to Los Angeles. Specifically, he said, “It puts me further away 

from my children.” 

VA Office of Inspector General 19 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Date Event 

Email records reflected that Ms. Graves, who was the Eastern Area 

Director at the time, was also involved in the earliest discussions related 

to Mr. McKenrick being reassigned to the Los Angeles position in 

February 2014. For example, we found Ms. Graves exchanged emails 

with Mr. David Leonard, Detroit VARO Director, regarding the 

possibility of Mr. McKenrick going to Los Angeles. Specifically, in an 

email dated February 24, 2014, Ms. Graves emailed Mr. Leonard, “May 

be calling you to ask about LA ...” (the subject line was “Mac”). 

Mr. Leonard replied, “Already did. Good Talk.” 

March 2014 

On March 20 and 21, 2014, Ms. Rubens discussed with Ms. Hickey her 

interest in the Philadelphia VARO Director opening even though 

Mr. McKenrick’s reassignment package had not been sent to Mr. Riojas 

for approval. Specifically, Ms. Rubens and Ms. Hickey exchanged the 

following email messages: 

 Ms. Rubens, email dated March 20, 2014: “I talked with him 

(Mr. Pummill) this morning about my desire to take advantage of 

the Philly Director opening. For me.” (Emphasis added.) 

 Ms. Hickey, email dated March 20, 2014: “I think the world of you 

and will support you any way you need ... Please know that in this 

decision for you–I will be all in to help and make it happen. 

(Emphasis added.) I would like to talk to you about it all to 

understand better if I could have helped before now to take better 

care of you.” 

 Ms. Hickey, email dated March 21, 2014: “When can I expect to see 

Philly open?” 

April 2014 

During early April 2014, Ms. Rubens requested, through Brookfield, a 

Broker’s Market Analysis on her home in the Washington, DC, 

metropolitan area. Prior to any reassignment packages being initiated by 

VA, Ms. Rubens took steps to determine the market value of her house. 

Therefore, it is probable that Ms. Rubens knew that she would soon be 

relocated to the Philadelphia VARO position even before Mr. McKenrick 

vacated the position when he was reassigned to Los Angeles. 

May 5, 2014 

CSEMO sent a memo to Mr. Riojas requesting approval to reassign 

Ms. Rubens from Deputy Under Secretary for Field Operations to the 

position of Philadelphia VARO Director. On the same date, CSEMO sent 

a memo to Mr. Riojas requesting approval to reassign Mr. McKenrick 

from the position of Philadelphia VARO Director to the position of 

Los Angeles VARO Director. 

May 6, 2014 Mr. Riojas approved Ms. Rubens’ reassignment to Philadelphia (6 days 

before approving Mr. McKenrick’s reassignment to Los Angeles). 

May 12, 2014 

Mr. Riojas approved Mr. McKenrick’s reassignment to Los Angeles. We 

found Ms. Rubens’ reassignment to Philadelphia was approved before 

Mr. McKenrick was given a chance to review and consider his 

reassignment package. 

VA Office of Inspector General 20 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Date Event 

May 15, 2014 

CSEMO sent memos to both Ms. Rubens and Mr. McKenrick stating that 

Mr. Riojas was considering their reassignments. 

Ms. Rubens signed the memo acknowledging receipt on the same day. 

She requested her annual salary remain at $181,497, and she receive full 

PCS benefits. 

In an email, Ms. Rubens told Ms. Graves that, “Mac (Mr. McKenrick) 

should have gotten his waiver to sign today. He has 5 days to sign.” 

In another email, Ms. Rubens directed Ms. Graves (her subordinate) to 

contact Mr. McKenrick to discuss his reassignment benefits. Specifically, 

Ms. Rubens said, “and make sure he asks the questions he needs to ask 

about pay ... don’t want any surprises ...” 

May 19, 2014 

Mr. McKenrick signed the May 15th memo acknowledging receipt. He 

requested his annual salary increase to $167,000, he receive full value of 

relocation incentive (25% of current annual salary, or about $41,000), and 

he receive full PCS benefits. 

In an email to Mr. Pummill, Ms. Rubens stated, “I find myself in an 

uncomfortable position of having an opportunity to return to the field 

when he vacates Philly. For that reason, I can’t engage further with Mac 

on these issues.” 

May 27, 2014 

Ms. Rubens and Ms. Graves had email correspondence regarding 

Mr. McKenrick relocating. Specifically, Ms. Rubens wrote, “Ok Boss – 

(as Ms. Rubens move meant she would go from being Ms. Graves boss to 

being her subordinate) looks like I’m coming, as Mac (Mr. McKenrick) 

will choose one of the ... options—I went with the most expedient!” 

Ms. Graves replied, “Woo hoo! Have you talked with him about dates?” 

Ms. Rubens responded, “Remember – I can’t be in the middle of his move 

– so you may want to check with Willie (Mr. Clark).” At this time, 

Mr. Clark was VBA’s Western Area Director. 

CSEMO sent memos to both Ms. Rubens and Mr. McKenrick stating that 

Mr. Riojas had decided to reassign them. Mr. McKenrick was approved 

for a $20,000 relocation incentive. Although these moves were ultimately 

processed as management directed, we determined that Ms. Rubens 

volunteered for her reassignment. When asked about Ms. Rubens move 

being categorized as management directed, Ms. Hickey replied this was 

language she was not familiar with but it was her understanding this was 

“the common process that CSEMO does.” 

May 29, 2014 

Even though Ms. Rubens had already signed and accepted her 

reassignment, on this date, she signed a form stating that she would not 

accept the reassignment unless the AVO option was approved as part of 

her PCS move. Ms. Hickey approved the AVO option the same day. 

VA Office of Inspector General 21 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Date Event 

June 1, 2014 

Mr. McKenrick and Ms. Ruben’s reassignments became effective. 

Ms. Rubens maintained her rate of pay despite the reduced scope of 

responsibilities. 

June 3, 2014 Mr. Jose Riojas, VA’s Chief of Staff at the time, approved AVO benefits 

for Ms. Rubens (after the effective date of her reassignment). 

Source: Interviews; employee email, personnel, and relocation records 

In October 2014, Ms. Graves was reassigned from her position as Eastern Area Director 

to the position of Director, St. Paul VARO. Ms. Graves replaced Mr. Antione Waller 

who was reassigned to the position of Director, Baltimore VARO. We found a similar 

pattern for this reassignment. Based on our review of the details, we determined 

Ms. Graves inappropriately used her position of authority for personal and financial 

benefit when she participated personally and substantially in creating an opportunity for 

her own transfer to the St. Paul VARO. We determined that Ms. Graves had ties to the 

St. Paul area. From 1997 – 1998, Ms. Graves was the Assistant Veterans Service Center 

Manager at the St. Paul VARO. Further, during a May 28, 2015, interview with OIG 

staff, Ms. Graves stated that the move to St. Paul got her closer to her mother. 

Table 5 provides a timeline of actions and evidence that supports our conclusion. 

Table 5. Timeline of Ms. Graves’ Reassignment 

Date Event 

March–April 2014 

In a June 10, 2015, interview, Mr. Waller told us that Ms. Graves asked 

if he “had any thoughts about getting back to the east coast.” Mr. Waller 

said, “we start talking about ... Philadelphia.” After taking a weekend to 

think about it, Mr. Waller said he gave Ms. Graves a call back and said, 

“I would be interested if there was an opportunity ... to go to 

Philadelphia.” About a week later, Mr. Waller said, “I was ... told that 

... the situation had ... changed ... then the conversation was ... directed 

at ... would I be interested in Baltimore ...” Mr. Waller said, “it wasn’t 

shared with me why the Philadelphia ... was not on the table for 

discussion. She (Kim Graves) said you would probably ... hear more in 

the future about that ...” 

March 6–7, 2014 

We identified several emails in which Ms. Graves showed concern over 

the language in the Baltimore VARO Director announcement. In an 

email dated March 6, 2014, Ms. Graves stated, “my concern is that, as 

written, there is no guarantee of an incentive.” In an email dated 

March 7, 2014, Ms. Graves stated, “I think what we want is ... a 

relocation incentive of 25% IS authorized.” As the Eastern Area 

Director, we would expect Ms. Graves to be involved in developing the 

announcement. However, we question why Ms. Graves would want to 

guarantee a 25 percent relocation incentive before determining whether 

the position would be difficult to fill. 

VA Office of Inspector General 22 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Date Event 

In an interview on June 10, 2015, Mr. Waller told us “I would say ... 

almost all of my conversations ... were with ... Kim Graves” in response 

to our question about who he had discussions with regarding the 

Baltimore VARO Director position. 

The Baltimore VARO Director position was announced one time, but 

March 10–25, none of the 131 applicants were considered. In the June 10, 2015, 

2014 interview, Mr. Waller stated that he did not apply to the vacancy 

announcement. 

March 14, 2014 

Ms. Graves emailed Mr. Waller regarding the Baltimore position. Based 

on the email, we determined that Ms. Graves had already discussed the 

position with Mr. Waller, despite the job announcement being open for 

only 4 days. In a May 28, 2015, interview, Ms. Graves told us that 

Mr. Waller contacted her unexpectedly and, “suggested that he would be 

willing, or was interested in being considered for the position.” 

Ms. Graves said that Mr. Waller asked, “Do you have somebody in line 

for Baltimore. I’m interested in being considered.” Additionally, as 

noted previously, Mr. Waller told us he did not apply for the position. In 

the June 10, 2015, interview with OIG staff, Mr. Waller stated that 

Ms. Graves initiated discussions with him related to the Baltimore 

position. 

In the June 10, 2015, interview with OIG staff, Mr. Waller said that he 

was not interested in the Baltimore VARO Director position. He said, 

“they made it clear that this would not be the last conversation we have 

about Baltimore” after he told Ms. Graves he did not want the Baltimore 

job. When asked if Mr. Waller felt he could have said no to Baltimore, 

he said, “I said no for ... at least three phone calls and ... then it got to 

... Diana Rubens, and I just ... felt like there was ... a lot of pressure ... 

for me to ... consider that position.” Mr. Waller said he “felt that ... at 

that point ... there was ... just a lot of interest, a lot of ... conversation 

and pressure to ... consider ... that position ... and it just felt like it was 

no longer ... just a conversation about me considering.” “So ... 

ultimately I just ... tried to make the best of a very, very difficult 

situation.” In a May 28, 2015, interview with OIG staff, Ms. Rubens 

confirmed that Mr. Waller was “not initially ... enthusiastic at the 

opportunity.” 

During a May 13, 2015, interview, Ms. Hickey expressed concerns about 

the toll the Baltimore job would have on the Director. We asked whether 

Ms. Graves was considered for this position and she replied she was “not 

going to go put her into a problem RO ...” She further stated Baltimore 

“was going to suck the last ounce of blood” out of whoever went into the 

Baltimore Director’s position. She also acknowledged that getting 

Mr. Waller to Baltimore involved “heavy twisting” and was “just a 

fraction short of mandated ... we sweetened the pot.” 

VA Office of Inspector General 23 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Date Event 

March 30–31, 

2014 

Ms. Beth McCoy, then the Assistant Deputy Under Secretary for Field 

Operations sent Ms. Graves an email asking whether there was “anything 

more from Mr. Waller?” Ms. Graves responded, “I haven’t talked to him 

again with expectation that either you or Diana was going to reach out.” 

Ms. McCoy told Ms. Graves she would give him a call and later wrote, 

“I talked to him today. Told him his name had gone all the way up to the 

Sec[retary] level, who thought it was a great idea. So saying no now is 

not a clean or easy option. I suggested he make a list of what his 

requests would be for him to take the job as far as salary, relo[cation], 

support. I suggested Diana give him overnight to think about it and 

discuss with his wife.” 

Based on Mr. Waller’s statements that he said no to the reassignment to 

Baltimore multiple times until Ms. Rubens called and the content of 

email discussions, it appears there was a coordinated effort by 

Ms. Graves, Ms. McCoy, and Ms. Rubens to put pressure on Mr. Waller 

to accept a reassignment to Baltimore. 

April 2014 

Mr. Waller said that he had a face-to-face conversation with Ms. Rubens 

and Ms. Graves to discuss his relocation incentive. Mr. Waller said that 

a 

3-year/$36,000–$40,000 (or a total of $108,000–$120,000) incentive was 

discussed with Ms. Graves and Ms. Rubens. 

May 13–14, 2014 

Ms. Graves signed the Justification and Authorization of Recruitment 

and Relocation Incentives document for Mr. Waller’s eventual 

reassignment to the position of Director, Baltimore VARO. 

A VBA Executive Management Officer told us that Mr. Waller signed a 

Relocation Service Agreement that was sent to him at the direction of 

Ms. Graves. The agreement indicated Mr. Waller would receive a 3-year 

relocation incentive payment of 22 percent of his annual salary— 

$36,740 a year, totaling $110,220—for his transfer to the position of 

Director, Baltimore Regional Office. Ms. Graves, as recommending 

official, and Ms. Rubens, as approving official, signed the service 

agreement on the same day. Ultimately, Mr. Waller received $40,000 

over 2 years rather than $110,220 over 3 years; he indicated that he 

believed the incentive amount was reduced at the Department-level, not 

the VBA-level based on a CSEMO recommendation to the Chief of 

Staff. 

May 30, 2014 Ms. Rubens sent a memo to the Under Secretary for Benefits requesting 

AVO benefits for Mr. Waller. 

June 2014 

On June 24, 2014, CSEMO sent a memo to Mr. Riojas requesting 

approval to reassign Mr. Waller to Baltimore. On the same day, 

Mr. Riojas approved the reassignment. 

On June 25, 2014, CSEMO sent a memo to Mr. Waller notifying him 

VA Office of Inspector General 24 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Date Event 

that Mr. Riojas was considering reassigning him to Baltimore. On 

June 27, 2014, Mr. Waller acknowledged receipt of this memo. On the 

same memo, Mr. Waller requested additional time to respond to the 

notice of reassignment in order to give Mr. Pummill additional time to 

address and resolve his concerns. 

On June 26, 2014, Mr. Waller met with Mr. Pummill to discuss his 

immediate concerns. In the June 10, 2015, interview, Mr. Waller told us 

that he had conversations with Mr. Pummill about his financial package, 

including his relocation incentive. 

July 14, 2014 

CSEMO sent a memo to Mr. Riojas requesting approval to reassign 

Mr. Waller to Baltimore with different financial considerations. 

Specifically, the updated approval request now included a $40,000 

relocation incentive to be paid in two equal installments. On the same 

day, Mr. Riojas approved Mr. Waller’s updated relocation incentive. [In 

addition to the relocation incentive, Mr. Waller received a salary increase 

of $27,317.] 

CSEMO sent a memo to Mr. Waller notifying him that he was being 

reassigned to Baltimore. On the same day, Mr. Waller acknowledged 

receipt of the memo and waived his right to 60-day written notice. 

Ms. Graves sent Mr. Waller his reassignment approval form via email. 

In a May 28, 2015, interview, we asked Ms. Graves how she ended up in 

St. Paul. She responded, “I started considering it, and very frankly, I 

woke up one morning and said ... I need to do something different.” 

We asked Ms. Graves how she initiated the move. She said, “I called 

Diana Rubens who was still in her role. I called her and I said I’d like to 

throw my name in for consideration for St. Paul. I’ve done my time 

(Emphasis added) and I’d like to put my name in.” 

Based on these comments, we determined that Ms. Graves volunteered 

for the position of Director, St. Paul VARO. 

July 18, 2014 

In an email, Mr. Christopher Holly, former VBA Deputy Chief of Staff, 

requested that Ms. Graves send her resume to him so he could start her 

reassignment paperwork for St. Paul. 

July 27, 2014 Mr. Waller became the Baltimore VARO Director. 

September 16, 

2014 

The Under Secretary for Benefits sent a memo to Mr. Riojas nominating 

Ms. Graves to the position of Director, St. Paul VARO. 

October 1, 2014 CSEMO sent a memo to Mr. Riojas to obtain approval to reassign 

Ms. Graves to St. Paul. 

October 8, 2014 Mr. Riojas approved the reassignment of Ms. Graves to St. Paul. 

October 10, 2014 CSEMO notified Ms. Graves that Mr. Riojas was considering 

VA Office of Inspector General 25 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Date Event 

reassigning her to St. Paul. Ms. Graves acknowledged receipt of the 

memo. She requested her annual salary remain at $173,949, and she 

receive PCS benefits, including AVO. 

On this same date, CSEMO sent another memo to Ms. Graves notifying 

her that she was being reassigned to St. Paul. Ms. Graves accepted her 

reassignment and waived her right to 60-day written notice on the same 

day. 

October 19, 2014 Ms. Graves became the St. Paul VARO Director. Ms. Graves 

maintained her rate of pay despite the reduced scope of responsibilities. 

Source: Interviews; employee email, personnel, and relocation records 

Conclusion 

We determined that Ms. Rubens and Ms. Graves inappropriately used their positions of 

authority for personal and financial benefit when they participated personally and 

substantially in creating opportunities for their own transfers to positions they were 

interested in filling. We made criminal referrals to the U.S. Attorney’s Office, District of 

Columbia, regarding official actions orchestrated by Ms. Rubens and Ms. Graves. 

Formal decisions regarding prosecutorial merit are pending. Our analysis of available 

evidence indicated two directors appear to have been inappropriately coerced to leave 

positions they were not interested in leaving to create vacancies for Ms. Rubens and 

Ms. Graves. Ms. Rubens and Ms. Graves were in positions that allowed them to effect 

these transfers and, therefore, misused their positions of authority for their own personal 

benefit. We also determined Ms. McCoy, while serving as the Assistant Deputy Under 

Secretary for Field Operations, inappropriately assisted Ms. Graves in putting pressure on 

Mr. Waller to transfer by indicating to him that there was no clean or easy way to say no 

to the reassignment since his name had been raised to the VA Secretary. 

Recommendations 

Recommendation 8. We recommended the Deputy Secretary confer with the Office of 

Human Resources and Administration, the Office of Accountability Review, and the 

Office of General Counsel to determine the appropriate administrative action to take, if 

any, against Ms. Rubens. 

Recommendation 9. We recommended that the Deputy Secretary consult with the 

Office of General Counsel to determine whether a bill of collection should be issued to 

Ms. Rubens to recoup the $274,019 paid for expenses related to her relocation. 

Recommendation 10. We recommended the Deputy Secretary confer with the Office of 

Human Resources and Administration, the Office of Accountability Review, and the 

VA Office of Inspector General 26 
Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Office of General Counsel to determine the appropriate administrative action to take, if 

any, against Ms. Graves. 

Recommendation 11. We recommended that the Deputy Secretary consult with the 

Office of General Counsel to determine whether a bill of collection should be issued to 

Ms. Graves to recoup the $129,468 paid for expenses related to her relocation. 

Recommendation 12. We recommended the Deputy Secretary confer with the Office of 

Human Resources and Administration, the Office of Accountability Review, and the 

Office of General Counsel to determine the appropriate administrative action to take, if 

any, against Ms. Hickey, Mr. Pummill, and Ms. McCoy. 

Management Comments and OIG Response 

The Chief of Staff concurred with our recommendations and stated the Deputy Secretary 

will take action by the end of the year to address the recommendations. We will monitor 

VA’s progress and follow up on VA’s implementation actions until all actions are 

completed. The Chief of Staff’s full response is included in Appendix B. 

LINDA A. HALLIDAY
 

Deputy Inspector General 

VA Office of Inspector General 27 
 

 

 

 

 

Appendix A Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

VBA Reassignments 

Expense Tables 

This appendix contains tables that detail expenses paid by VA related to the 23 VBA 

reassignments discussed in Issue 3 of this report. 

Table 6. Annual Salary Increases for VBA Reassignments 

VBA Reassignment/Transfer Old Salary New Salary Salary 

Increase 

FY 2015 

Beth McCoy (From Assistant Deputy Under Secretary for 

Field Operations to Deputy Under Secretary for Field 

Operations) 

$163,500 $181,500 $18,000 

(11%) 

Kimberly Graves (From Eastern Area Director to Director, 

St. Paul VARO) $173,949 $173,949 $0 (0%) 

Pritz Navaratnasingam (From Director, Houston VARO, to 

Director, Seattle VARO) $156,555 $167,000 $10,445 

(7%) 

Willie Clark (From Western Area Director to Eastern Area 

Director) $167,715 $181,497 $13,782 

(8%) 

Jonathan Skelly (From Director, Salt Lake City VARO, to 

Western Area Director) $166,953 $175,000 $8,047 (5%) 

Marlon Waldrop (From Director, San Juan VARO, to 

Director, Houston VARO) $143,208 $161,109 $17,901 (13%) 

Suzanne Nunziata* (From Assistant Director, St. Petersburg 

VARO, to Director, Chicago VARO) $137,846 $158,523 $20,677 

(15%) 

Mitzi Marsh* (From Director, Wichita VARO, to Director, 

St. Louis VARO) $137,846 $152,569 $14,723 

(11%) 

FY 2014 

Duane Honeycutt (From Director, Chicago VARO, to 

Director, Milwaukee VARO) $151,772 $165,300 $13,528 (9%) 

Cory Hawthorne (From Director, St. Louis VARO, to 

Director, Montgomery VARO) $141,400 $159,600 $18,200 

(13%) 

Robert McKenrick (From Director, Philadelphia VARO, to 

Director, Los Angeles VARO) $163,620 $167,000 $3,380 (2%) 

Diana Rubens (From Deputy Under Secretary for Field 

Operations to Director, Philadelphia VARO) $181,497 $181,497 $0 (0%) 

Patrick Prieb (From Director, Seattle VARO, to Director, 

San Diego VARO) $136,583 $157,070 $20,487 (15%) 

Antione Waller (From Director, St. Paul VARO, to Director, 

Baltimore VARO) $139,683 $167,000 $27,317 

(20%) 

Julianna Boor* (From Assistant Director, Seattle VARO, to 

Director, Oakland VARO) $134,827 $159,600 $24,773 

(18%) 

Ezra Safdie (From Director, Office of Administration and 

Facilities, to Director, Office Management) $173,500 $179,700 $6,200 (4%) 

Anthony Milons* (From Assistant Director, New York 

VARO, to Director, Cleveland VARO) $146,792 $161,471 $14,679 

(10%) 

VA Office of Inspector General 28 
 

Appendix A Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

VBA Reassignment/Transfer Old Salary New Salary Salary 

Increase 

FY 2013 

Beth McCoy (From Central Area Director to Assistant 

Deputy Under Secretary for Field Operations) $144,720 $163,500 $18,780 

(13%) 

Danny Pummill (From Director, VBA/DoD [Department of 

Defense] Programs to Principal Deputy Under Secretary for 

Benefits) 

$171,912 $179,700 $7,788 (5%) 

Robert Granstrom (From Director, Milwaukee VARO, to 

Central Area Director) $143,272 $165,300 $22,028 

(15%) 

Lisa Breun* (From Director, Des Moines VARO, to Director, 

Little Rock VARO) $128,900 $141,790 $12,890 (10%) 

Leanne Weldin* (From Director, Huntington VARO, to 

Director, Columbia VARO) $125,109 $137,620 $12,511 

(10%) 

Darryl Brady* (From Director, Hartford VARO, to Director, 

Jackson VARO) $150,423 $165,300 $14,877 

(10%) 

Total Annual Salary Increase $321,013 

Source: VA Corporate Senior Executive Management Office 

*Identifies employees who moved from the GS-15 level to an SES position 

VA Office of Inspector General 29 
 

 

 

Appendix A Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Table 7. Relocation Incentives for VBA Reassignments 

VBA Reassignment/Transfer Salary 

Increase 

Relocation 

Incentive 

FY 2015 

Suzanne Nunziata (From Assistant Director, St. Petersburg 

VARO, to Director, Chicago VARO) $20,677 $15,000 

FY 2014 

Robert McKenrick (From Director, Philadelphia VARO, to 

Director, Los Angeles VARO) $3,380 $20,000 

Patrick Prieb (From Director, Seattle VARO, to Director, 

San Diego VARO) $20,487 

$20,000 

($10,000 in FY 2014 and 

$10,000 in FY 2015) 

Antione Waller (From Director, St. Paul VARO, to Director, 

Baltimore VARO) $27,317 

$40,000 

($20,000 in FY 2014 and 

$20,000 in FY 2015) 

Julianna Boor (From Assistant Director, Seattle VARO, to 

Director, Oakland VARO) $24,773 $25,000 

FY 2013 

Beth McCoy (From Central Area Director to Assistant 

Deputy Under Secretary for Field Operations) $18,780 $10,000 

Robert Granstrom (From Director, Milwaukee VARO, to 

Central Area Director) $22,028 $10,000 

(paid in FY 2014) 

Totals $137,442 $140,000 

Source: VA Corporate Senior Executive Management Office 

VA Office of Inspector General 30 
 

 

 

 

 

 

Appendix A Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Table 8. Relocation and AVO-related Expenses for VBA Reassignments 

VBA Reassignment/Transfer Relocation 

Expenses 

AVO 

Expenses 

Total PCS 

Expenses 

FY 2015 

Kimberly Graves (From Eastern Area Director to 

Director, St. Paul VARO) $23,361.56 $106,106 $129,467.56 

Pritz Navaratnasingam (From Director, Houston VARO, 

to Director, Seattle VARO) $41,563.69 $41,403.60 $82,967.29 

Willie Clark (From Western Area Director to Eastern 

Area Director) $14,650.69 $0 $14,650.69 

Jonathan Skelly (From Director, Salt Lake City VARO, 

to Western Area Director) $3,111.80 $0 $3,111.80 

Marlon Waldrop (From Director, San Juan VARO, to 

Director, Houston VARO) $35,771.66 $0 $35,771.66 

Suzanne Nunziata (From Assistant Director, 

St. Petersburg VARO, to Director, Chicago VARO) $27,758.38 $0 $27,758.38 

Mitzi Marsh (From Director, Wichita VARO, to Director, 

St. Louis VARO) $25,847.99 $31,052.70 $56,900.69 

FY 2014 

Duane Honeycutt (From Director, Chicago VARO, to 

Director, Milwaukee VARO) $27,502.36 $31,164 $58,666.36 

Cory Hawthorne (From Director, St. Louis VARO, to 

Director, Montgomery VARO) $25,303.71 $33,946.50 $59,250.21 

Robert McKenrick (From Director, Philadelphia VARO, 

to Director, Los Angeles VARO) $19,710.71 $0 $19,710.71 

Diana Rubens (From Deputy Under Secretary for Field 

Operations to Director, Philadelphia VARO) $49,564.12 $224,455.00 $274,019.12 

Patrick Prieb (From Director, Seattle VARO, to Director, 

San Diego VARO) $22,863.73 $69,562.50 $92,426.23 

Antione Waller (From Director, St. Paul VARO, to 

Director, Baltimore VARO) $30,579.25 $2,396.259

 $32,975.50 

Julianna Boor (From Assistant Director, Seattle VARO, 

to Director, Oakland VARO) $45,964.21 $48,972 $94,936.21 

Anthony Milons (From Assistant Director, New York 

VARO, to Director, Cleveland VARO) $17,106.02 $0 $17,106.02 

FY 2013 

Beth McCoy (From Central Area Director to Assistant 

Deputy Under Secretary for Field Operations) $36,739.47 $0 $36,739.47 

Robert Granstrom* (From Director, Milwaukee VARO, 

to Central Area Director) $8,310.51 $0 $8,310.51 

Lisa Breun (From Director, Des Moines VARO, to 

Director, Little Rock VARO) $52,651.69 $95,733.90 $148,385.59 

Leanne Weldin (From Director, Huntington VARO, to 

Director, Columbia VARO) $23,687.18 $25,376.40 $49,063.58 

Darryl Brady (From Director, Hartford VARO, to 

Director, Jackson VARO) $50,208.30 $0 $50,208.30 

Totals $582,257.03 $710,168.85 $1,292,425.88 

Source: VA Corporate Senior Executive Management Office 

* Approved for the AVO option, but did not use those benefits 

9

 Mr. Waller was approved for the AVO program, however opted out after starting the program. As a result, VA 

incurred AVO cancellation costs in the amount of $2,396.25. Cancellation costs consisted of costs associated with 

the home appraisals, home inspections, property assessments, and title fees. 

VA Office of Inspector General 31 
 

 

 

 

 

 

 

 

Appendix A Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Table 9. Total Expenses for VBA Reassignments 

VBA Reassignment/Transfer Salary 

Increase 

Relocation 

Incentive 

PCS 

Expenses 

Total 

Expenses 

FY 2015 

Beth McCoy (From Assistant Deputy 

Under Secretary for Field Operations to 

Deputy Under Secretary for Field 

Operations) 

$18,000 $0 

$0 

(No Move 

Involved) 

$18,000 

Kimberly Graves (From Eastern Area 

Director to Director, St. Paul VARO) $0 $0 $129,467.56 $129,467.56 

Pritz Navaratnasingam (From Director, 

Houston VARO, to Director, Seattle 

VARO) 

$10,445 $0 $82,967.29 $93,412.29 

Willie Clark (From Western Area Director 

to Eastern Area Director) $13,782 $0 $14,650.69 $28,432.69 

Jonathan Skelly (From Director, Salt Lake 

City VARO, Western Area Director) $8,047 $0 $3,111.80 $11,158.80 

Marlon Waldrop (From Director, San Juan 

VARO, to Director, Houston VARO) $17,901 $0 35,771.66 $53,672.66 

Suzanne Nunziata (From Assistant 

Director, St. Petersburg VARO, to Director, 

Chicago VARO) 

$20,677 $15,000 $27,758.38 $63,435.38 

Mitzi Marsh (From Director, Wichita 

VARO, to Director, St. Louis VARO) $14,723 $0 $56,900.69 $71,623.69 

FY 2014 

Duane Honeycutt (From Director, Chicago 

VARO, to Director, Milwaukee VARO) $13,528 $0 $58,666.36 $72,194.36 

Cory Hawthorne (From Director, St. Louis 

VARO, to Director, Montgomery VARO) $18,200 $0 $59,250.21 $77,450.21 

Robert McKenrick (From Director, 

Philadelphia VARO, to Director, 

Los Angeles VARO) 

$3,380 $20,000 $19,710.71 $43,090.71 

Diana Rubens (From Deputy Under 

Secretary for Field Operations to Director, 

Philadelphia VARO) 

$0 $0 $274,019.12 $274,019.12 

Patrick Prieb (From Director, Seattle 

VARO, to Director, San Diego VARO) $20,487 $20,000 $92,426.23 $132,913.23 

Antione Waller (From Director, St. Paul 

VARO, to Director, Baltimore VARO) $27,317 $40,000 $32,975.50 $100,292.50 

Julianna Boor (From Assistant Director, 

Seattle VARO, to Director, Oakland 

VARO) 

$24,773 $25,000 $94,936.21 $144,709.21 

Ezra Safdie (From Director, Office of 

Administration and Facilities, to Director, 

Office Management) 

$6,200 $0 

$0 

(No Move 

Involved) 

$6,200 

Anthony Milons (From Assistant Director, 

New York VARO, to Director, Cleveland 

VARO) 

$14,679 $0 $17,106.02 $31,785.02 

VA Office of Inspector General 32 
 

 

Appendix A Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

VBA Reassignment/Transfer Salary 

Increase 

Relocation 

Incentive 

PCS 

Expenses 

Total 

Expenses 

FY 2013 

Beth McCoy (From Central Area Director 

to Assistant Deputy Under Secretary for 

Field Operations) 

$18,780 $10,000 $36,739.47 $65,519.47 

Danny Pummill (From Director, 

VBA/DoD [Department of Defense] 

Programs to Principal Deputy Under 

Secretary for Benefits) 

$7,788 $0 

$0 

(No Move 

Involved) 

$7,788 

Robert Granstrom (From Director, 

Milwaukee VARO, to Central Area 

Director) 

$22,028 $10,000 $8,310.51 $40,338.51 

Lisa Breun (From Director, Des Moines 

VARO, to Director, Little Rock VARO) $12,890 $0 $148,385.59 $161,275.59 

Leanne Weldin (From Director, 

Huntington VARO, to Director, VARO 

Columbia, SC) 

$12,511 $0 $49,063.58 $61,574.58 

Darryl Brady (From Director, Hartford 

VARO, to Director, Jackson VARO) $14,877 $0 $50,208.30 $65,085.30 

Totals $321,013 $140,000 $1,292,425.88 $1,753,438.88 

Source: VA Corporate Senior Executive Management Office 

VA Office of Inspector General 33 
Appendix B Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

VA Chief of Staff Comments
 

Department of 

Veterans Affairs Memorandum 

Date: September 22, 2015 

From: Chief of Staff (00A) 

Subj: OIG Draft Report, Administrative Investigation: Inappropriate Use of Position 

and Misuse of Relocation Program and Incentives in VBA (OIG Project No. 

2015-02997-R1-0164) 

To: Deputy Inspector General (50A) 

1. I have reviewed the draft report and concur with the report’s 

recommendations. Attached is the Department’s corrective action plan for 

recommendations 1-12. 

2. Thank you for the opportunity to review the draft report. If you have any 

questions, please contact Meghan Flanz, Acting Deputy General Counsel 

for Legal Operations and Accountability, at (202) 461-7661. 

(original signed by:) 

Robert L. Nabors II 

1 

VA Office of Inspector General 34 
 

Appendix B Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Comments to OIG Administrative Investigation Report: 

Inappropriate Use of Position and Misuse of Relocation Program
 

And Incentives in VBA
 

The following comments are submitted in response to the recommendations 

in the Office of Inspector General’s report. 

OIG Recommendations 

Recommendation 1. We recommend that the Deputy Secretary review the 

Department’s request and approval process for the Appraised Value Option 

program and make improvements as deemed appropriate. 

VA Response: Concur. The Deputy Secretary will work with the Assistant 

Secretary for Human Resources and the Acting Assistant Secretary for 

Management to determine whether and what improvements should be made 

for the request and approval process for the Appraised Value Option 

program. 

Target date for completion: December 31, 2015 

Recommendation 2. We recommend that the Deputy Secretary review the 

Department’s request and approval process for temporary quarters 

subsistence expense allowance and make improvements as deemed 

appropriate. 

VA Response: Concur. The Deputy Secretary will work with the Assistant 

Secretary for Human Resources and the Acting Assistant Secretary for 

Management to determine whether and what improvements should be made 

to the Department’s request and approval process for temporary quarters 

subsistence expense allowance. 

Target date for completion: December 31, 2015 

Recommendation 3. We recommend that the Deputy Secretary consult 

with the Office of General Counsel to determine whether Ms. Rubens should 

be issued a bill of collection of $123.50 to recoup the improper 

reimbursements paid to her for alcoholic beverages and unauthorized meals 

and tips. 

VA Response: Concur. The Deputy Secretary will consult with the Office of 

General Counsel to determine whether a bill of collection should be issued to 

Ms. Rubens 

Target date for completion: October 31, 2015 

2 

VA Office of Inspector General 35 
 

Appendix B Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Recommendation 4. We recommend that the Deputy Secretary strengthen 

the approval process to include requiring an independent review of the 

Department’s Permanent Change of Station program to ensure moves and 

expenses are appropriate and justified. 

VA Response: Concur. The Deputy Secretary will consult with the General 

Counsel, the Assistant Secretary for Human Resources, and the Acting 

Assistant Secretary for Management to determine how best to complete an 

independent review of the Department’s Permanent Change of Station 

program. 

Target date for completion: October 31, 2015 

Recommendation 5. We recommend that the Deputy Secretary require the 

Veterans Benefits Administration to establish policies and procedures to 

standardize its practices regarding annual salary increases when reassigning 

Senior Executives’ position. 

VA Response: Concur. The Deputy Secretary will consult with the Under 

Secretary for Benefits and the Assistant Secretary for Human Resources to 

determine whether and how to standardize practices regarding annual salary 

increases for reassigned Senior Executives across VBA and/or the 

Department. 

Target date for completion: December 31, 2015 

Recommendation 6. We recommend that the Deputy Secretary consult 

with the Office of General Counsel to determine whether bills of collection 

should be issued to recover unjustified relocation incentives paid by the 

Veterans Benefits Administration for Senior Executive reassignments. 

VA Response: Concur. The Deputy Secretary will consult with the Office of 

General Counsel to determine whether bills of collection should be issued to 

VBA Senior Executives to recover unjustified relocation incentives. 

Target date for completion: October 31, 2015 

Recommendation 7. We recommend that the Deputy Secretary consult 

with the Office of General Counsel to determine what actions may be taken 

to hold the appropriate Senior Officials accountable for processing and 

approving payments of unjustified relocation incentive payments. 

VA Response: Concur. The Deputy Secretary will consult with the Office of 

General Counsel and the Office of Accountability Review to determine what 

3 

VA Office of Inspector General 36 
 

Appendix B Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

actions may be taken to hold the appropriate Senior Officials accountable for 

unjustified relocation incentive payments. 

Target date for completion: October 31, 2015 

Recommendation 8. We recommend that the Deputy Secretary confer with 

the Office of Human Resources and Administration, the Office of 

Accountability Review, and the Office of General Counsel to determine the 

appropriate administrative action to take, if any, against Ms. Rubens. 

VA Response: Concur. The Deputy Secretary will consult with the Office of 

Human Resources and Administration, the Office of General Counsel, and 

the Office of Accountability Review to determine whether and what action 

may be taken against Ms. Rubens. 

Target date for completion: October 31, 2015 

Recommendation 9. We recommend that the Deputy Secretary consult with 

the Office of General Counsel to determine whether a bill of collection should 

be issued to Ms. Rubens to recoup the $274,019 paid for expenses related to 

her relocation. 

VA Response: Concur. The Deputy Secretary will consult with the Office of 

General Counsel to determine whether a bill of collection should be issued to 

Ms. Rubens to recoup the $274,019 paid for expenses related to her 

relocation. 

Target date for completion: October 31, 2015 

Recommendation 10. We recommend that the Deputy Secretary confer 

with the Office of Human Resources and Administration, the Office of 

Accountability Review, and the Office of General Counsel to determine the 

appropriate administrative action to take, if any, against Ms. Graves. 

VA Response: Concur. The Deputy Secretary will confer with the Office of 

Human Resources and Administration, the Office of Accountability Review, 

and the Office of General Counsel to determine the appropriate 

administrative action to take, if any, against Ms. Graves. 

Target date for completion: October 31, 2015 

4 

VA Office of Inspector General 37 
Appendix B Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Recommendation 11. We recommend that the Deputy Secretary consult 

with the Office of General Counsel to determine whether a bill of collection 

should be issued to Ms. Graves to recoup the $129,468 paid for expenses 

related to her relocation. 

VA Response: Concur. The Deputy Secretary will consult with the Office of 

General Counsel to determine whether a bill of collection should be issued to 

Ms. Graves to recoup the $129,468 paid for expenses related to her 

relocation. 

Target date for completion: October 31, 2015 

Recommendation 12. We recommend that the Deputy Secretary confer 

with the Office of Human Resources and Administration, the Office of 

Accountability Review, and the Office of General Counsel to determine the 

appropriate administrative action to take, if any, against Ms. Hickey, 

Mr. Pummill, and Ms. McCoy. 

VA Response: Concur. The Deputy Secretary will confer with the Office of 

Human Resources and Administration, the Office of Accountability Review, 

and the Office of General Counsel to determine the appropriate 

administrative action to take, if any, against Ms. Hickey, Mr. Pummill, and 

Ms. McCoy. 

Target date for completion: December 31, 2015 

5 

VA Office of Inspector General 38 
Appendix C Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

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 Nick Dahl, Director 

Linda Fournier, Director 

Domingo Alvarez 

Stephen Bracci 

Michael Derick 

Karen Hatch 

David Orfalea 

William Tully 

Ann Wolf 

VA Office of Inspector General 39 
Appendix D Administrative Investigation: Inappropriate Use of Position and 

Misuse of Relocation Program and Incentives in VBA 

Report Distribution 

VA Distribution 

Office of the Secretary 

Veterans Health Administration 

Veterans Benefits Administration 

National Cemetery Administration 

Assistant Secretaries 

Office of General Counsel 

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 

VA Office of Inspector General 40