Department of Veterans Affairs 

Office of Inspector General 

Audit of 

Veterans Benefits Administration's 

Pension Maintenance Program 

Administered by the Pension 

Maintenance Centers 

Report No. 05-03180-111 March 30, 2007

VA Office of Inspector General 

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

Call the OIG Hotline – (800) 488-8244 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Table of Contents 

Page 

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

Introduction ..........................................................................................................1

Purpose............................................................................................................................. 1

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

Scope and Methodology .................................................................................................. 2

Results and Conclusions ....................................................................................4

Pension Claims Processing Needed Strengthening ......................................................... 4

Appendixes

A. Sampling Methodology and Estimates .................................................................... 15

B. Monetary Benefits in Accordance with IG Act Amendments................................. 18

C. Under Secretary for Benefits Comments ................................................................. 19

D. OIG Contact and Staff Acknowledgments .............................................................. 25

E. Report Distribution................................................................................................... 26

VA Office of Inspector General 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Executive Summary 

Introduction 

In January 2002, the Veterans Benefits Administration (VBA) consolidated its pension 

maintenance processing from 58 regional offices to 3 Pension Maintenance Centers 

(PMCs) in an effort to make claims processing more efficient. The VA Office of 

Inspector General (OIG) conducted an audit of the PMC’s processing controls to 

determine whether VBA’s consolidation efforts resulted in accurate and timely 

processing of pension awards. 

Results 

While VBA informed us that the consolidation of pension claims to three centers had 

achieved efficiencies, our audit showed some internal controls could be strengthened. 

VBA could improve: (1) the accuracy of processing beneficiary income adjustments, 

(2) the accuracy of processing Eligibility Verification Reports (EVRs), (3) the timely 

processing of Compensation and Pension (C&P) system messages, and (4) the accuracy 

of scanning and filing documents into Virtual VA (VVA). We estimated, based on the 

conditions we identified, that 7,570 (5.2 percent) of 146,463 beneficiaries received 

inaccurate award payments totaling $13.4 million. Of the $13.4 million, beneficiaries 

received $9.4 million in overpayments and $4.0 million in underpayments. We also 

identified unmitigated risks that could lead to inaccurate pension claims that needed 

management attention. 

Recommendations 

We recommended the Under Secretary for Benefits ensure PMCs use standardized 

procedures among the PMCs for processing income adjustments, EVRs, and monitoring 

employee accuracy rates. We also recommended that appropriate training be provided 

and that procedures be developed and implemented to more timely process C&P system 

messages, and ensure required documents are imaged into VVA. 

Under Secretary for Benefits Comments 

The Under Secretary for Benefits agreed with the recommendations in the report with 

some qualifications to the findings and provided acceptable implementation plans. The 

Under Secretary reported VBA has implemented process changes and enhanced training 

programs at the PMCs. (See Appendix C, pages 19–24, for the full text of the Under 

Secretary’s comments.) He also provided technical comments that we incorporated into 

our report where appropriate. We will follow up on the implementation of planned 

improvement actions until they are complete. 

VA Office of Inspector General i 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

While agreeing with our recommendations, the Under Secretary qualified that a 

distinction should be made between errors resulting in inaccurate monetary benefit 

amounts compared with errors not affecting monetary benefit amounts. We agree with 

the Under Secretary’s comment that a distinction should be made between the two types 

of errors, and we have made this distinction throughout the report. (This distinction is 

first made on page 4.) Our audit of 563 pension claims where beneficiaries reported 

either changes in income, medical expenses, the number of dependents, or other 

miscellaneous changes concluded that PMC employees made income adjustment or 

processing errors in 106 (19 percent) of the audited pension claims. Our report points out 

of the 106 income adjustment or processing errors, 60 of them resulted in either 

overpayments or underpayments. This represents 11 percent of the pension claims 

audited and does not clearly represent the extent of the control weakness. The remaining 

46 processing errors did not result in changes of monetary benefits. (See Appendix A, 

pages 15–17, for a detailed analysis of errors resulting in overpayments and 

underpayments.) 

The Under Secretary also reported VBA does not have specific accuracy targets for 

income adjustments or EVRs. While we agree with the Under Secretary’s comments, 

regional office Directors’ performance appraisal plans established a target error rate of 13 

percent in FY 2004 and a target error rate of 12 percent in FY 2005 for pension claims 

processing. Our audit revealed that improved accuracy was needed. For example, at the 

St. Paul PMC our audit showed that improved accuracy was needed for 55 (32 percent) of 

172 audited income adjustments and improvement was needed for 43 (40 percent) of 108 

audited EVRs processed. Standardizing procedures among the PMCs for processing 

income adjustments, EVRs, and monitoring employee accuracy rates would serve to 

improve the accuracy and timeliness of processing pension claims.

 (original signed by:)

BELINDA J. FINN 

Assistant Inspector General 

for Auditing 

VA Office of Inspector General ii 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Introduction 

Purpose 

We conducted an audit of key pension maintenance processing controls over Improved 

Disability Pension, Improved Death Pension, and Parents’ Dependency and Indemnity 

Compensation (PDIC) to determine whether VBA’s consolidation efforts resulted in 

accurate and timely processing of pension awards. 

Background 

VA pension programs generally provide monthly payments to veterans or surviving 

dependents of deceased wartime veterans who die as a result of a disability unrelated to 

military service. VBA operates three income-based programs that are still accepting 

applications—Improved Disability Pension, Improved Death Pension, and PDIC. 

Improved Disability Pension is a benefit paid to wartime veterans who are permanently 

and totally disabled or age 65 or older and have limited income and net worth. Improved 

Death Pension is a benefit paid to eligible dependents of a deceased veteran who served 

during a wartime era. Basic eligibility depends upon the veteran being discharged from 

service under other than dishonorable conditions and having served during wartime; the 

surviving spouse or unmarried child of a deceased veteran must have countable income 

and net worth below a limit set by Federal law. PDIC is a monthly payment to a parent 

or parents of a veteran based on a veteran’s service-connected death and income 

limitations. C&P Service estimated VBA paid $2.6 billion in pension benefits to 335,900 

veterans in fiscal year (FY) 2005. 

Consolidation of Pension Maintenance Activities. In May 2001, VA established the 

Claims Processing Task Force to identify actions to reduce the C&P claims backlog and 

make processing more efficient. One of their recommendations was for VBA to 

consolidate the maintenance portion of pension processing.1

 In January 2002, VBA 

consolidated the processing of pension work at three PMCs located at Philadelphia, PA; 

Milwaukee, WI; and St. Paul, MN. The consolidation of pension maintenance was 

phased in over time with full implementation in July 2003. Pension maintenance 

operations were consolidated in order to centralize processing of all running pension 

awards, achieve a more effective use of limited human resources, improve technical 

accuracy, and allow regional offices to concentrate on compensation claims processing. 

VBA expected to make logistical improvements and enhance service to claimants by 

consolidating the program and improving the accuracy and timeliness of award 

processing. These actions were expected to reduce overpayment amounts. 

 

1

 This issue is discussed in VA Claims Processing Task Force: Report to the Secretary of Veterans Affairs, 

October 2001. 

VA Office of Inspector General 1 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

VBA’s Evaluation of Pension Work Processes. In July 2003, VBA performed an 

evaluation of work processes and the use of imaging technology related to pension 

maintenance activities.2

 Overall, VBA believed that consolidation achieved efficiencies. 

However, VBA determined that because they had not developed a clear and integrated 

business plan, they found dissimilar business processes among the three PMCs as well as 

inconsistent utilization of the VVA technology. The evaluation also disclosed that 

expected performance improvements had not yet been realized with centralization. 

Scope and Methodology 

To address the objectives of the audit, we reviewed employees’ efforts to timely and 

accurately process: (1) eligibility verifications, (2) income adjustments, (3) grants of 

special monthly pension benefits, (4) C&P system messages, (5) accrued benefits, 

(6) waivers and compromises based on pension overpayments, and (7) electronic imaging 

of veteran information. Our audit excluded a review of hospital adjustments, except to 

examine whether Systematic Analysis of Operations (SAOs) were performed; and thirdparty computer matching. We excluded hospital adjustments due to prior audit coverage, 

and third-party computer matching because we plan to perform a separate audit of this 

PMC responsibility at a future date. 

We interviewed employees with pension responsibilities at VBA headquarters located in 

Washington, D.C.; three PMCs located in Philadelphia, Milwaukee, and St. Paul; the 

Austin Automation Center in Austin, TX; and the Hines Information Technology Center 

located in Hines, IL. We assessed compliance with VBA and Office of Management and 

Budget (OMB) policies and public laws that addressed pension programs. We reviewed 

medical expense reports, Social Security benefits, pension awards, self-reported 

beneficiary information, reports of contact, and award notifications. 

The period of review was January 1, 2004, through June 30, 2005, with the exception of 

our review of C&P system messages. For C&P system messages, our review period was 

from July 2005 to December 2005. This occurred because VBA did not maintain data on 

C&P system messages prior to July 2005 and after December 2005. We conducted onsite 

work from November 28, 2005, to May 4, 2006. In planning and performing the audit, 

we relied on computer-generated data from VBA’s C&P Master Record and Work-InProgress databases. To test the reliability of this data, we compared relevant electronic 

data with veterans’ claims data. We found the computer-generated data to be sufficiently 

reliable for our audit objectives. 

To accomplish the audit we used computer sampling technology, and randomly selected a 

sample of 1,666 cases out of the 242,471 claims for the review period. Table 1 on the 

following page illustrates the sample size by processing action. (See Appendix A, pages 

15–17, for a detailed description of our sampling methodology.) 

 

2

 This issue is discussed in VBA’s Pension Maintenance Center Study, August 28, 2003. 

VA Office of Inspector General 2 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

 Table 1. Sample Size by Processing Action 

Processing Action End Product Work Codes 

Number of 

Claims Sample Size 

Eligibility Verification Reports 050 and 155 141,537 345 

Income Adjustments-Income Change 150 and 157 78,821 563 

Dependency Change 130 and 137 3,581 100 

Special Monthly Pensions 120 and 127 835 114 

Accrued Benefits 165 and 167 130 98 

Committee on Waivers and Compromises 293 17,567 446 

Totals 242,471 1,666 

In addition, we reviewed 1,666 electronic folders (e-folders) for completeness, and we 

reviewed SAO reports for FYs 2004 and 2005. We reviewed 100 percent of the C&P 

system messages provided by VBA for the review period. 

Our assessment of internal controls focused only on those controls related to our audit 

objective of evaluating whether the PMCs were accurately and timely processing pension 

awards. Our assessment was not intended to form an opinion on the adequacy of VBA’s 

internal controls overall; we do not render such an opinion. In all other aspects, the audit 

was conducted in accordance with Generally Accepted Government Auditing Standards. 

VA Office of Inspector General 3 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Results and Conclusions 

Pension Claims Processing Needed Strengthening 

Findings 

Controls to monitor the accuracy and timeliness of processing pension claims needs 

strengthening. We determined controls over processing income adjustments and 

eligibility verifications at two of the three PMCs could be improved by standardizing 

procedures, improving monitoring, providing consistent training, and clarifying 

procedures for processing specialized awards. Improving these controls will increase the 

accuracy of payments made to veterans and/or beneficiaries, reduce overpayments that 

only serve to burden claimants who need to reimburse VA, and ensure all amounts due 

are paid timely. Based on audit tests, we estimated 7,570 (5.2 percent) of 146,463 

beneficiaries received inaccurate awards totaling $13.4 million. Of the $13.4 million, 

beneficiaries received $9.4 million in overpayments and $4.0 million in underpayments. 

The net effect of overpayments and underpayments was $5.4 million of overpayments. 

(See Appendix A, pages 15–17, for a detailed analysis of errors resulting in 

overpayments and underpayments.) 

We also determined that improvement in accuracy and timeliness was needed for 

processing C&P system messages, and scanning and filing required documents into 

VVA. 

OMB Circular No. A-123, Management’s Responsibility for Internal Control, dated 

December 21, 2004, requires managers to develop and maintain effective internal 

controls. Effective internal controls provide assurance that significant weaknesses in the 

design or operation of internal controls that could adversely affect the agency’s ability to 

meet its objectives would be prevented or detected in a timely manner. 

Beneficiary Income Adjustments Need to be Made in Accordance with VBA 

Policies. Our audit of 563 pension claims where beneficiaries reported either changes in 

income, medical expenses, the number of dependents, or other miscellaneous changes 

concluded that PMC employees made income adjustment or processing errors in 106 

(19 percent) of the audited pension claims. Of the 106 income adjustment or processing 

errors, 60 of them resulted in overpayments or underpayments. The remaining 46 

processing errors did not result in changes of monetary benefits. VBA policy provides 

that income may be adjusted periodically based on changes in income, marital and 

dependency status, allowable deductible expenses such as unreimbursed medical 

expenses paid by the beneficiary, and continuing medical expenses.3

 Regional Office 

 

3 VBA Manual 21-1, Part IV, Authorization Issues, Chapter 16, “Income and Net Worth,” dated December 30, 2004. 

VA Office of Inspector General 4 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Directors’ performance appraisal plans established a target error rate of 13 percent in 

FY 2004 and a target error rate of 12 percent in FY 2005 for pension claims processing. 

Table 2 that follows illustrates that errors exceeded VBA’s 13 percent target error rate for 

the Improved Disability Pension program at the St. Paul and Philadelphia PMCs and the 

St. Paul PMC error rate exceeded the target rate for the Improved Death Pension 

program. PDIC program error rates exceeded standards at all three PMCs. 

 Table 2. Adjustment Processing by PMC and Pension Program 

PMC and Pension Program Number of Claims 

Processed Needing 

Improvement 

Number of Claims 

Audited 

Error Rate 

St. Paul 

 Improved Disability Pension 32 108 30% 

 Improved Death Pension 7 34 21% 

 PDIC 16 30 53% 

 Subtotal 55 172 32% 

Philadelphia 

 Improved Disability Pension 27 130 21% 

 Improved Death Pension 2 30 7% 

 PDIC 8 30 27% 

 Subtotal 37 190 19% 

Milwaukee 

 Improved Disability Pension 5 139 4% 

 Improved Death Pension 2 32 6% 

 PDIC 7 30 23% 

 Subtotal 14 201 7% 

Totals 106 563 19% 4

Our analysis disclosed that miscalculation of unreimbursed medical expenses, 

prospective medical expenses, and income resulted in 86 (81 percent) of the 106 errors. 

Table 3 on the following page summarizes the adjustments by category. 

 

4

 The error rate is not weighted; therefore, it does not reflect the size of the pension programs. 

VA Office of Inspector General 5 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

 Table 3. Income Adjustments Needing Improvement by Category 

PMC

Adjustment Category Total

St. 

Paul Philadelphia Milwaukee 

Unreimbursed Medical Expenses Inaccurately Calculated 39 17 18 4 

Prospective Medical Expenses Incorrectly Projected 29 20 4 5 

Income Incorrectly Calculated 18 6 8 4 

Incorrect Effective Date Used 5 5 

Dependency Not Correctly Developed 3 2 1 

Incorrect End Product Code Used 3 2 1 

Policies Regarding Special Monthly 

 Pension Improperly Applied 

 3 1 2 

Claimant Not Provided Due Process 3 1 1 1 

Missing Signature on Award 2 2 

Report of Contact Incomplete 1 1 

Totals 106 55 37 14 

St. Paul PMC. Our audit showed that improved accuracy was needed for 55 (32 percent) 

of 172 audited income adjustments. We attributed 25 (45 percent) of the 55 errors to 

staff following conflicting procedures that were incorrectly released without approval. 

For example, VBA policy states vitamins should not be allowed as a medical expense 

without a physician’s prescription.5

 We obtained an internal e-mail from a Supervisory 

Veterans Service Representative (VSR), dated April 28, 2005, stating that VSR’s should 

“...accept vitamins as a medical expense without a doctor’s prescription as long as they 

are reasonable.” In December 2003, C&P Service issued a memorandum barring the 

partial allowance of Supplementary Medical Insurance Benefit (SMIB).6

 We determined 

that some staff continued authorizing partial allowance of SMIB upon making income 

adjustments. 

Philadelphia PMC. We determined that improved accuracy was needed for 37 

(19 percent) of 190 audited income adjustments. Of these 37 income adjustment errors, 

29 (78 percent) of the 37 errors could have been avoided by establishing a more 

comprehensive training program. Even though PMC managers provided training related 

to most aspects of pension maintenance in FYs 2004 and 2005, managers did not provide 

any training related to the proper calculation of medical expenses, use of the Social 

Security Administration’s database to identify Medicare premiums, or the PDIC program. 

Increasing supervisory oversight could also reduce errors. There were eight instances 

where final award actions were taken prior to the complete development of claims: actual 

miles for claimed transportation costs were not obtained, the purpose of a claimed 

expense was not determined, the source of reported income was not identified, and the 

date income earned was not verified. 

 

5 VBA Manual 21-1, Part IV, Authorization Issues, Chapter 16, Addendum A, dated December 15, 1995. 6

 C&P Service Memorandum to the Regional Office Directors, dated December 5, 2003. 

VA Office of Inspector General 6 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Milwaukee PMC. Income adjustment error rates at the Milwaukee PMC were the lowest 

of the three PMCs. Our audit showed that improved accuracy was needed for 14 

(7 percent) of 201 audited income adjustments. For example, improvements were needed 

in calculating medical expenses and income and providing claimants with due process. 

We attributed 7 (50 percent) of the 14 errors to the infrequent processing of PDIC claims. 

Prior to our audit, the PMC manager recognized that infrequent processing of PDIC 

claims was an issue. As a result, he assigned select employees to process these claims in 

an attempt to improve accuracy. We did not identify a systemic reason for the remaining 

errors. 

As a result of the 106 income adjustment or processing errors, we estimated inaccurate 

awards totaling $6.8 million. Of the $6.8 million, we determined beneficiaries received 

$3.1 million in overpayments and $3.7 million in underpayments. (See Appendix A, 

pages 15–17, for a detailed analysis of errors resulting in overpayments and 

underpayments.) 

Improved Accuracy Needed for EVR Processing. Our audit showed improved 

accuracy was needed for the processing of 81 (23 percent) of 345 audited EVRs. As a 

condition to receive a pension, VA may require a beneficiary to provide evidence to 

support eligibility. VA uses EVRs for this purpose. An EVR is a form that is used to 

request income, net worth, dependency status, and any other information necessary to 

determine or verify entitlement to pension.7

 

Table 4 on the following page shows that EVR processing errors exceeded VBA’s 13 

percent target error rate for total pension claims processing at the St. Paul and 

Philadelphia PMCs; the St. Paul PMC error rate exceeded the target for the Improved 

Death Pension program. PDIC program error rates exceeded standards at all three PMCs. 

 

7 VBA Manual 21-1, Part IV, Authorization Issues, Chapter 29, “Eligibility Verification Reports,” dated 

December 19, 2005. 

VA Office of Inspector General 7 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

 Table 4. EVR’s Needing Improvement by PMC and Pension Program 

PMC and Pension Program 

(Target goal 13%) 

Number of 

EVRs with 

Errors 

Number of 

EVRs 

Audited 

EVR 

Processing 

Error Rate 

St. Paul 

 Improved Disability Pension 15 48 31% 

 Improved Death Pension 11 30 37% 

 PDIC 17 30 57% 

 Subtotal 43 108 40% 

Philadelphia PMC 

 Improved Disability Pension 11 64 17% 

 Improved Death Pension 2 30 7% 

 PDIC 12 30 40% 

 Subtotal 25 124 20% 

Milwaukee PMC 

 Improved Disability Pension 3 53 6% 

 Improved Death Pension 0 30 0% 

 PDIC 10 30 33% 

 Subtotal 13 113 12% 

Totals 81 345 23%8

Our analysis disclosed that incomplete EVRs and incorrect calculation of income and 

expenses accounted for 57 (70 percent) of the 81 incorrectly processed EVRs. Table 5 

that follows summarizes the errors by category. 

 Table 5. EVRs Needing Improvement by Category

PMC

EVR Error Category Total

St. 

Paul Philadelphia Milwaukee 

Incomplete EVR Processed 26 16 8 2 

Income Incorrectly Calculated 16 11 3 2 

Expenses Incorrectly Calculated 15 5 7 3 

Dependency Improperly Developed 13 5 6 2 

Incorrect Effective Date Used 3 2 1 

Incorrect Signature on EVR 3 2 1 

Policies Regarding Special Monthly 

 Pension Incorrectly Applied 

 

2 

 

1 1 

Incorrect End Product Code Used 1 1 

Missing Signature on Award 1 1 

Incorrect Net Worth Code 1 1 

Totals 81 43 25 13 

St. Paul PMC. Our audit revealed that improved accuracy was needed for 43 (40 percent) 

of 108 audited EVRs processed. Of theses 43 EVRs, 24 (56 percent) of the 43 errors 

could have been mitigated by strengthening monitoring. For example, our review of 

documents that could have been used by PMC managers to monitor employee accuracy 

 

8

 The error rate is not weighted; therefore, it does not reflect the size of the pension programs. 

VA Office of Inspector General 8 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

disclosed these errors could have been identified and corrected if the PMC managers had 

reviewed these documents. 

The remaining 19 errors were attributed to conflicting procedures. VBA policy specifies 

which EVR blocks can be left blank. 9

 In January 2002, C&P Service issued an e-mail 

allowing EVRs to be processed without all required information. As a result of this email, awards were granted when amounts related to net worth, retirement income, interest 

income, and other Government benefits were not listed on the EVR. In December 2005, 

C&P Service reminded all employees that unless procedures are published in VBA 

Manual 21-1, the policies or procedures are not considered official. 

Philadelphia PMC. We determined that improved accuracy was needed for 25 (20 

percent) of 124 audited EVRs processed. We attributed 15 (60 percent) of the 25 EVR 

errors to the lack of a comprehensive training program. Twelve (80 percent) of the 15 

errors were related to the PDIC program. Three (25 percent) of the errors arose from the 

incorrect calculation of Medicare premiums. The Philadelphia PMC had not provided 

any training related to either subjects during FYs 2004 or 2005. 

We attributed 5 (19 percent) of the 26 EVR errors to processing EVRs with incomplete 

information. We identified 5 EVRs without income information. Also, 2 of those 5 

EVRs did not have a report of net worth. We associated these errors with the conflicting 

procedures issued in January 2002 by C&P Service. We did not identify a systemic cause 

for the remaining five errors. 

Milwaukee PMC. Of the 113 EVRs we reviewed, we determined 13 (12 percent) were 

incorrectly processed. We attributed 10 (77 percent) of the 13 errors to the infrequent 

processing of PDIC claims. We did not identify a systemic reason for the remaining 

three errors. 

As a result of the 81 EVR errors, we estimated inaccurate awards totaling $6.7 million. 

Of the $6.7 million, we determined beneficiaries received $6.3 million in overpayments 

and $400,000 in underpayments. (See Appendix A, pages 15–17, for a detailed analysis 

of errors resulting in overpayments and underpayments.) 

C&P System Messages Need to be Processed Timely. PMC managers need to improve 

the timely processing of C&P system messages. C&P system messages, or writeouts, are 

an important internal control that can help ensure the accuracy of benefit payments. 

When a change occurs to the C&P master record, an automatic audit is initiated by the 

system. If an error is identified, a writeout is generated, notifying the appropriate PMC 

that a “possible overpayment” or “possible underpayment” may exist. When a writeout is 

generated but not reviewed and cleared from the C&P master record, the audit error 

continues to regenerate until action is taken. Until system messages errors and the 

 

9 VBA Manual 21-1, Part IV, Authorization Issues, Chapter 29, “Blocks on EVR Blank,” dated December 14, 1995. 

VA Office of Inspector General 9 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

underlying overpayments and possible underpayments are addressed, these errors could 

continue to place an undue financial hardship on the claimant. 

We audited 5,250 writeouts generated from July 1, 2005, to December 23, 2005, with 

message codes 809 (underpayments) and 810 (overpayments). (We determined the 809 

and 810 codes represented the highest risks to pension claims.) Of the 5,250 writeouts, 

2,754 (52 percent) were regenerated after 30 days. These writeouts had an average 

outstanding time of 86 days. 

We believe timeliness was an issue for the PMCs because they had no specific 

performance standards or procedures for processing writeouts. Table 6 that follows 

illustrates the number of average days outstanding by message code and PMC. 

 Table 6. Average Days Outstanding by PMC 

PMC and Writeout Category 

Total 

Reviewed 

Average 

Days 

Outstanding 

Minimum 

Days 

Outstanding 

Maximum 

Days 

Outstanding 

Median 

Days 

Outstanding 

St. Paul 

 Overpayment 115 88 33 135 84 

 Underpayment 581 87 31 135 84 

Philadelphia 

 Overpayment 172 89 31 135 84 

 Underpayment 1,376 90 31 149 92 

Milwaukee 

 Overpayment 67 75 31 135 69 

 Underpayment 443 84 31 135 84 

Totals 2,754 86 31 149 86 

We have initiated a separate audit to expand our coverage to determine whether VBA’s 

C&P system messages are an effective internal control that ensures the accuracy of 

benefit payments. 

Controls over Scanning and Filing Documents into VVA Need Strengthening. Our 

audit of 1,666 veterans’ e-folders disclosed 263 (16 percent) of the e-folders were 

missing required documents. Specifically, we audited 603 e-folders at the St. Paul PMC, 

572 at the Philadelphia PMC, and 491 at the Milwaukee PMC. VVA serves to replace 

the paper-based folders by imaging paper documents into e-folders. VBA policy 

specifies the documents and forms—generated or received as a result of VBA’s eligibility 

verification process or in connection with income adjustments—are to be imaged into 

VVA.10 VVA is used in support of pension maintenance activities at all three PMCs. 

Examples of missing documents include EVRs, C&P award actions, and notification 

letters. We attributed this to the lack of a reliable methodology to ensure necessary 

 

10 VBA Manual 21-1MR, Part V, Subpart iv, Chapter 1, “Imaging Documents for Virtual VA,” dated 

March 22, 2004. 

VA Office of Inspector General 10 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

documents were imaged into VVA. Future award actions that require adjustments based 

on historical data and appellate actions cannot take place when documents are missing. 

We also identified five instances, two at the St. Paul PMC and three at the Philadelphia 

PMC, where documents containing veterans’ personal information—names, Social 

Security numbers, and addresses—were imaged into five other veterans’ e-folders. As a 

result, five veterans’ personal data are at risk of inappropriate disclosure. Under the 

Privacy Act, VA is responsible for establishing appropriate administrative, technical, and 

physical safeguards to ensure the security and confidentiality of records and to protect 

against any anticipated threats or hazards to their security or integrity which could result 

in substantial harm, embarrassment, inconvenience, or unfairness to any individual on 

whom information is maintained.11 

Observation: Consistency of Debt Waiver Decisions Needs Improvement. In some 

instances, Committee on Waivers and Compromises (COWC) members were making 

inconsistent decisions when dealing with similar facts. VA has the authority to waive 

recovery of erroneous pension payments. A single standard of equity and good 

conscience is used to determine whether collection of a debt should be waived.12 Each 

PMC established a COWC for this purpose. 

At one site, a COWC member determined the veteran was at fault for failure to report 

Social Security income. Pension debt of $56,129 was waived because the veteran’s 

expenses exceeded his income. In a comparable case (a veteran failed to report Social 

Security income and the veteran’s expenses exceeded his income), another COWC 

member did not waive the $31,772 debt because he believed it would be unjust 

enrichment for the veteran to retain the benefit. We also identified instances where the 

same COWC member made inconsistent decisions when faced with similar facts. 

We identified 257 (58 percent) of 446 instances where similar facts were present and 

inconsistent decisions were made. The VA OIG previously reported this condition in 

February 1997.13

 

11 5 U.S.C. Section 552a. 

12 38 U.S.C. Section 5302. 

13 This issue is discussed in Review of Waiver Decisions for C&P Debts (Report No. 7R1-B01-047, dated 

February 21, 1997). 

VA Office of Inspector General 11 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Table 7 that follows illustrates inconsistencies in waiver decisions by PMC. 

 Table 7. Inconsistent Waiver Decisions by PMC 

PMC 

Waivers 

Granted with 

Similar Facts 

Waivers 

Denied with 

Similar Facts 

Total Waivers 

Reviewed 

St. Paul 33 29 98 

Philadelphia 73 25 171 

Milwaukee 39 58 177 

Totals 145 112 446

Because decisions were made in accordance with the “equity and good conscience” 

standard, we made no recommendation. 14 However, PMC managers should be aware of 

the waiver decision inconsistencies. 

Conclusion 

We concluded that VBA needs to strengthen key controls over pension claims processing 

at the three PMCs. We determined controls over processing income adjustments and 

eligibility verifications at two of the three PMCs needs strengthening due to the need to 

standardize procedures, improve monitoring, provide sufficient training, and the 

infrequent processing of specialized awards. Using a 95 percent confidence level, we 

estimated 7,570 (5.2 percent) of 146,463 beneficiaries received inaccurate awards 

totaling $13.4 million. Of the $13.4 million, beneficiaries received $9.4 million in 

overpayments and $4.0 million in underpayments. 

We also determined that improvement in accuracy and timeliness was needed for 

processing C&P system messages, scanning and filing required documents into VVA. 

Recommendations. To address the issues pertaining to the accuracy and timely 

processing of pension claims, we recommended the Under Secretary for Benefits: 

1. Ensure PMCs use standardized procedures among the PMCs for processing income 

adjustments and EVRs. 

2. Develop and implement standardized monitoring procedures among the PMCs to 

ensure pension processing accuracy rates reflect actual processing performance. 

3. Ensure standardized training among the three centers is provided to all PMC 

employees responsible for processing pension claims. For income adjustments, 

emphasis should be placed on the calculation of unreimbursed medical expenses, 

prospective medical expenses, and income calculation. For EVRs, emphasis should 

be placed on income and expense calculation, dependency development, and required 

EVR elements. 

 

14 38 C.F.R. Section 1.965. 

VA Office of Inspector General 12 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

4. Develop procedures to reduce errors associated with the infrequent processing of 

specialized awards. 

5. Develop and implement procedures to more timely process C&P system messages 

associated with pension maintenance activities. 

6. Develop procedures to ensure veterans’ e-folders contain the required documents and 

ensure e-folders contain veteran-specific documents. 

The Under Secretary for Benefits agreed with the recommendations. The Under 

Secretary reported VBA is standardizing training, designating quality review coordinators 

to be responsible for quality improvement oversight, developing a refresher training 

curriculum to help reduce errors associated with infrequent processing of specialized 

awards, conducting tests of an electronic application that stores and sorts write-outs by 

frequency, claim number, terminal digit, and improving controls over e-folder 

documentation. The Under Secretary also reported that all improvement actions would 

be completed by September 2007. The improvement actions are acceptable, and we will 

follow up on the completion of planned actions. 

While agreeing with our recommendations, the Under Secretary qualified that a 

distinction should be made between errors resulting in an inaccurate monetary benefit 

amount compared with errors not affecting monetary benefit amounts. We agree with the 

Under Secretary’s comment that a distinction should be made between the two types of 

errors, and we have made this distinction throughout the report. (This distinction is first 

made on page 4.) Our audit of 563 pension claims where beneficiaries reported either 

changes in income, medical expenses, the number of dependents, or other miscellaneous 

changes concluded that PMC employees made income adjustment or processing errors in 

106 (19 percent) of the audited pension claims. 

The report points out that 60 of the 106 income adjustment or processing errors resulted 

in either overpayments or underpayments. This represents 11 percent of the pension 

claims audited and does not clearly represent the extent of the control weakness. The 

remaining 46 processing errors did not result in a change of monetary benefits. (See 

Appendix A, pages 15–17, for a detailed analysis of errors resulting in overpayments and 

underpayments.) 

He also reported VBA does not have specific accuracy targets for income adjustments or 

EVRs. While we do not comment on management’s decision to set accuracy targets, our 

audit revealed that improved accuracy was needed. For example, at the St. Paul PMC our 

audit showed that improved accuracy was needed for 55 (32 percent) of 172 audited 

income adjustments and improvement was needed for 43 (40 percent) of 108 audited 

EVRs processed. Standardizing procedures among the PMCs for processing income 

VA Office of Inspector General 13 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

adjustments, EVRs, and monitoring employee accuracy rates would serve to improve the 

accuracy and timeliness of processing pension claims. 

VA Office of Inspector General 14 
Audit of VBA's Pension Maintenance Program Administered by the Pension Maintenance Centers

Appendix A 

Sampling Methodology and Estimates 

Sampling Methodology 

To determine whether PMCs processed income adjustments and EVRs accurately and 

timely, we used VBA’s C&P Work-In-Progress and Master Record databases to identify 

the population and sample. VBA provided the OIG a weekly copy of the Work-InProgress database and a quarterly copy of the C&P Master Record database. 

Population 

The population consisted of 220,358 claims submitted by 146,463 beneficiaries processed 

by the 3 PMCs from January 1, 2004, to June 30, 2005. The 220,358 excludes claims 

with monthly payments less than $200 for income adjustments, claims processed under a 

closed pension program, and original pension claims processed by Regional Offices, 

Sampling Design

We used a random sampling design that included nine strata. The stratum was based on 

the Improved Disability Pension, Improved Death Pension, and PDIC at the three PMCs. 

Table 8 that follows illustrates the stratified sample size. 

 Table 8. Sample Size by Stratification 

PMC Strata Number of Claims Claim Sample Size 

Philadelphia Improved Disability Pension 57,055 194 

Improved Death Pension 32,017 60 

PDIC 1,254 60 

 Subtotal 90,326 314 

Milwaukee Improved Disability Pension 47,695 192 

Improved Death Pension 24,792 62 

PDIC 867 60 

 Subtotal 73,354 314 

St. Paul Improved Disability Pension 38,980 160 

Improved Death Pension 16,960 60 

PDIC 738 60 

 Subtotal 56,678 280 

Totals 220,358 908 

VA Office of Inspector General 15 
Audit of VBA's Pension Maintenance Program Administered by the Pension Maintenance Centers

Appendix A 

Table 9 that follows illustrates the sample size and population size by sample unit. 

Table 9. Sample Size by Type of Claim 

Type of Claim 

End Product Work 

Codes 

Number of 

Beneficiaries 

Number of 

Claims 

Claim 

Sample Size 

Income Adjustments-Income Change 150 and 157 58,589 78,821 563 

Eligibility Verification Reports 050 and 155 98,271 141,537 345 

Adjustment to Eliminate 

Beneficiaries with More Than One 

Claim 

 

 (10,397) 

Totals 146,463 220,358 908 

Estimation Methodology 

We used the Department of Health and Human Services (HHS) OIG’s RAT-STATS 

computer software to perform our statistical analysis.15

Our estimation of $13.4 million resulted from adding the estimates for overpayments and 

underpayments for income adjustments and EVR errors. Our estimation of 7,570 

beneficiaries resulted from adding the estimated number of beneficiaries processed with 

income adjustment and processing errors and the estimated number of beneficiaries 

processed with EVR errors (4,784 beneficiaries with income adjustment errors plus 2,786 

beneficiaries with EVR errors). Table 10 that follows illustrates the total estimate. 

 Table 10. Calculation of Inaccurate Awards 

Category 

Estimated 

Overpayments 

and 

Underpayments Totals 

Overpayments-Income Adjustments $3,136,212 

Overpayments-EVRs 6,302,496 

Total Estimate of Overpayments $ 9,438,708 

Underpayments-Income Adjustments 3,657,120 

Underpayments-EVRs 356,844 

Total Estimate of Underpayments 4,013,964

Total Estimate of Inaccurate Awards $13,452,672 

Income Adjustment Estimate. We identified 106 income adjustment or processing errors, 

of which 60 resulted in either overpayments or underpayments. As a result, we estimated 

annual overpayments of $3.1 million and annual underpayments of $3.7 million. The 

sub-population for income adjustments was 78,821 claims. The total sample size for the 

 

15 RAT-STATS is a package of statistical software tools designed to assist the user in selecting random samples and 

evaluating the audit results. It has been used by the HHS OIG since the early 1970s. 

VA Office of Inspector General 16 
Audit of VBA's Pension Maintenance Program Administered by the Pension Maintenance Centers

Appendix A 

audit of income adjustments was 563. For monetary estimates we used a 95 percent 

confidence level. Table 11 that follows reflects the income adjustment estimates. 

 Table 11. Income Adjustment Estimates 

Precision (95% Confidence) 

Category 

Number of 

Beneficiaries 

Projections 

(Annual Point 

Estimates) 

Lower Limit Upper Limit 

Underpayments 1,485 $3.7 million $ 0 $7.7 million 

Overpayments 3,299 $3.1 million $0.7 million $5.6 million 

Totals 4,784 $6.8 million 

 

EVR Estimate. We identified 81 EVR errors, 11 of them resulted in either overpayments 

or underpayments. As a result, we estimated annual overpayments totaling $6.3 million 

and annual underpayments totaling $.4 million. The sub-population for EVRs consisted 

of 141,537 claims. The total sample size for the audit of EVRs was 345. For monetary 

estimates we used a 95 percent confidence level. Table 12 that follows reflects the EVR 

estimates. 

 Table 12. EVR Estimates 

Precision (95% Confidence) 

Category 

Number of 

Beneficiaries 

Projections 

(Annual Point 

Estimates) 

Lower Limit Upper Limit 

Underpayments 763 $0.4 million $ 0 $ 0.8 million 

Overpayments 2,023 $6.3 million $ 0 $18.2 million 

Totals 2,786 $6.7 million 

VA Office of Inspector General 17 
Audit of VBA's Pension Maintenance Program Administered by the Pension Maintenance Centers 

Appendix B 

Monetary Benefits in Accordance with 

IG Act Amendments 

Recommendation Explanation of Benefit(s) Questioned Costs

1a Estimated $9.4 million in 

overpayments less $4.0 million in 

underpayments resulting from 

incorrect processing of income 

adjustments and EVRs at three 

PMCs. 

$5.4 million 

VA Office of Inspector General 18 
Audit of VBA's Pension Maintenance Program Administered by the Pension Maintenance Centers 

Appendix C 

Under Secretary for Benefits Comments 

Department of 

Veterans Affairs Memorandum

Date: December 22, 2006 

From: Under Secretary for Benefits (20) 

Subject: Audit of Veterans Benefits Administration's Pension 

Program Administered by the Pension Maintenance 

Centers 

To: Assistant Inspector General for Auditing (52) 

1. This is in response to your request for VBA’s review of OIG Revised Draft Report: 

Audit of Veterans Benefits Administration’s Pension Maintenance Program 

Administered by the Pension Maintenance Centers. Attached are VBA’s comments 

addressing the OIG findings. 

2. VBA concurs with the recommendations in the revised draft report. 

3. Questions may be referred to Dee Fielding, VBA’s OIG Liaison, at 273-7018. 

 (original signed by:)

 Daniel L. Cooper 

Attachment 

VA Office of Inspector General 19 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Appendix C 

Attachment 

VBA COMMENTS TO OIG DRAFT REPORT 

Audit of Veterans Benefits Administration’s Pension Maintenance Program 

Administered by the Pension Maintenance Centers 

The Veterans Benefits Administration has implemented process changes and enhanced 

training programs at the Pension Maintenance Centers subsequent to the period covered 

by the audit that have significantly improved performance. For example, accuracy of 

claims processed by the PMCs increased from 80.7 percent for the period January 1, 2004 

through June 30, 2005 to 90.5 percent for the period January 1 through May 31, 2006. In 

particular, processing of income adjustments improved from 84 percent to 91.8 percent (4 

errors in 49 reviewed) and the processing of Eligibility Verification Reports (EVRs) 

improved from 76.4 percent to 90.7 percent (6 errors in 65 reviewed). This response 

details the improvement steps implemented by VBA subsequent to the period covered by 

the audit, including those most recently instituted in response to the OIG audit findings. 

All improvement efforts are being tracked and monitored for completeness and positive 

results. 

We offer the following comments on specific statements in the draft report: 

Page 4, under Beneficiary Income Adjustments Need to Be Made in Accordance with 

VBA Policies: “...concluded that PMC employees incorrectly adjusted income for 106 

(19 percent) of the audited pension claims.” 

This statement leads the reader to incorrectly conclude that all 106 errors 

affected the amount of benefits received by the beneficiaries. However, 

according to the appendix, page 15, from the 107 [sic] identified income 

adjustment errors, only 60 resulted in either overpayments or underpayments. 

The processing errors in the other 47 transactions did not result in a change of 

monetary benefits. Therefore, out of the sample of 563, only 11 percent of the 

audited claims resulted in incorrect payments to beneficiaries. We believe this is 

an important distinction that needs to be made clear in this section. 

Pages 4 & 5, under Beneficiary Income Adjustments Need to Be Made in Accordance 

with VBA Policies: “Regional Office Directors’ performance appraisal plans established 

a target error rate of 13 percent in FY 2004 and a target error rate of 12 percent in FY 

2005 for pension claims processing. While we do not comment on management’s 

decision to set these targets, the table that follows illustrates that errors exceeded 

VBA’s 13 percent target error rate for the Improved Disability Pension program...” 

There are no specific accuracy targets for income adjustments or EVRs. VBA’s 

pension processing accuracy target also includes other types of pension 

VA Office of Inspector General 20 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Appendix C 

processing transactions not covered in the OIG’s review. The overall pension 

processing accuracy target for FY 2004 was 87 percent, which increased to 88 

percent in FY 2005. The current overall pension processing accuracy target is 

90 percent. 

Page 6, under St. Paul PMC: “Our review of the quality assessments used by 

supervisors to monitor employee performance showed a disparity between local quality 

reviews and data maintained in the Benefits Delivery Network (BDN).” 

VBA disagrees with using award authorization data from the Benefits Delivery 

Network (BDN) to measure local accuracy. An authorizer may return a case for a 

number of reasons besides processing errors. Cases can be returned at the 

request of an employee, because of processing cycle issues, to add a COLA line, 

etc. For this reason, VBA has never viewed authorization data from BDN as a 

gauge of an individual’s work. 

Page 7, under Improved Accuracy Needed for EVR Processing: “Our audit showed 

improved accuracy was needed for the processing of 81 (23 percent) of 345 audited 

EVRs.” 

Here again the report fails to distinguish between payment errors and errors that 

are clerical or technical in nature. According to the OIG appendix, page 16, from 

the 84 [sic] identified EVR errors, only 12 resulted in either overpayments or 

underpayments. The other 72 transactions that OIG considered erroneous did 

not affect payments. Therefore, out of a sample size of 345, we believe the 

report should emphasize that only 3 percent resulted in inaccurate payments to 

beneficiaries. 

VA Office of Inspector General 21 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Appendix C 

VBA Comments on Recommended Improvement Actions 

Recommendation 1: Ensure PMCs use standardized procedures among the PMCs for 

processing income adjustments and EVRs. 

VBA concurs. Standardized training has been implemented. The manual re-write of the 

pension chapters is underway, with C&P Service soliciting input to the drafts from PMC 

staff. This re-write will further clarify processing procedures and reduce ambiguity, 

thereby minimizing areas needing additional local guidance. C&P Service released Part 

V, Subpart iii, Chapter 7, Eligibility Verification Reports, on October 31, 2006. M21-1 

Part IV, Chapter 16 on income and net worth will be completed and released by 

December 31, 2006. 

Recommendation 2: Develop and implement standardized monitoring procedures among 

the PMCs to ensure pension processing accuracy rates reflect actual processing 

performance. 

VBA concurs. Each PMC has designated quality review coordinators responsible for 

quality improvement oversight. These coordinators monitor all quality issues, such as 

training, mentoring, overseeing the 31-case stratified sample review, coordinating the 

monthly quality reviews for performance evaluations, and monitoring local and national 

Systematic Technical Accuracy Review (STAR) findings. These individuals also work 

closely with the other two PMC quality coordinators, as well as the C&P STAR staff, and 

keep station management apprised of all efforts. The PMCs implemented this position in 

March 2006. There are three levels of quality checks performed at each PMC; local 

employee quality, local station quality, and national STAR quality review. VBA requests 

closure of this recommendation, which was implemented in March 2006.

Recommendation 3: Ensure standardized training among the three centers is provided to 

all three PMC employees responsible for processing pension claims. For income 

adjustments, emphasis should be place on the calculation of unreimbursed medical 

expenses, prospective medical expenses, and income calculation. For EVRs, emphasis 

should be placed on income and expense calculation, dependency development, and 

required EVR elements. 

VBA concurs. A national standardized training program for new PMC employees was 

released to the field in March 2006. A refresher training curriculum was developed by 

the C&P Service and became available via the C&P training website on September 29, 

2006. Topics include income adjustments based on claims for unreimbursed medical 

expenses, write-out procedures, and parent’s DIC procedures. The Philadelphia 

Insurance Center conducted public contact team training at the Milwaukee and St. Paul 

PMCs in April and May 2006. VBA requests closure of this recommendation, which was 

implemented by September 2006. 

VA Office of Inspector General 22 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Appendix C 

Recommendation 4: Develop procedures to reduce errors associated with the infrequent 

processing of specialized awards. 

VBA concurs. A refresher training curriculum was developed by the C&P Service and 

became available via the C&P training website on September 29, 2006. Topics include 

income adjustments based on claims for un-reimbursed medical expenses, write-out 

procedures, and parent’s DIC procedures. 

The C&P Service Procedures Staff, in collaboration with the PMCs, developed eight new 

job aids and posted them on the C&P Service training website. These job aids cover 

topics such as dependency, Income Verification Match (IVM) for pension, IVM for 

individual unemployability, apportionments, Section 306 and Old Law Pension, 

hospitalization, incarceration, and incompetency. VBA requests closure of this 

recommendation, which was implemented in September 2006. 

Recommendation 5: Develop and implement procedures to more timely process C&P 

system messages associated with pension maintenance activities. 

VBA concurs. Technical staffs from the C&P Service and the Philadelphia Insurance 

Center are testing an electronic application that stores and sorts write-outs by frequency, 

claim number, terminal digit, etc. This application is being developed in Philadelphia, 

and we expect rollout to all PMCs by September 2007. Future enhancements to the 

application will allow all regional offices to manage write-outs in an electronic 

environment. 

Recommendation 6: Develop procedures to ensure veterans’ e-folders contain the 

required documents and ensure e-folders contain veteran-specific documents. 

VBA concurs. We have implemented the following measures to ensure accurate 

electronic filing: 

• In May 2006, standard operating procedures were implemented based on industry best 

practices for the Capture (i.e. scanning) Units. 

• Automatic imports (uploads) to Virtual-VA (VVA) were increased. Automatic 

uploads include BDN letter inserts, certain QTC documents, and PCGL bar-coded 

letters. Bar-coded letters can be scanned and then stored directly in VVA. Reports of 

contact can be created and automatically stored in VVA, as well as SHARE SSA 

screens. 

• A new enhancement to VVA was introduced to facilitate scanning and indexing. 

VA Office of Inspector General 23 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Appendix C 

• PMCs now review three prepping batches and ten indexing documents per employee 

per month. Completed cases are reviewed to ensure all actions were forwarded to the 

Capture Unit and properly indexed. 

• National production standards for scanners and indexers were established in 

July 2005. 

Based on the above actions, VBA requests closure of this recommendation, which was 

implemented in July 2006. 

VA Office of Inspector General 24 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers 

Appendix D 

OIG Contact and Staff Acknowledgments 

OIG Contact Michael A. Raponi (727) 395-2422 

Acknowledgments Brent E. Arronte 

Karen C. Chambers 

Christina J. Surber 

VA Office of Inspector General 25 
Audit of VBA’s Pension Maintenance Program Administered by the Pension Maintenance Centers

Appendix E 

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 Committee on Appropriations, Subcommittee on Military Construction, Veterans 

Affairs, and Related Agencies 

House Committee on Oversight and Government Reform 

Senate Committee on Veterans’ Affairs 

Senate Committee on Appropriations, Subcommittee on Military Construction, Veterans 

Affairs, and Related Agencies 

Senate Committee on Homeland Security and Governmental Affairs 

National Veterans Service Organizations 

Government Accountability Office 

Office of Management and Budget 

This report will be available in the near future on the OIG’s Web site at 

http://www.va.gov/oig/publications/. This report will remain on the OIG Web site for 

at least 2 fiscal years after it is issued. 

VA Office of Inspector General 26