VA BENEFITS

Improvements Needed 

to Ensure Claimants 

Receive Appropriate 

Representation

Report to Congressional Requesters

August 2013

GAO-13-643

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-643, a report to 

congressional requesters

August 2013

VA BENEFITS

Improvements Needed to Ensure Claimants Receive 

Appropriate Representation

Why GAO Did This Study

Representatives accredited by VA 

serve a critical role in helping veterans 

or their family members file claims for 

VA benefits. By law, accredited 

individuals must demonstrate good

moral character and program 

knowledge and VA’s OGC is tasked to 

ensure they do so by reviewing initial 

applications and monitoring ongoing 

requirements, such as training. 

GAO examined (1) the extent to which 

VA’s procedures adequately ensure 

representatives meet program 

requirements, and (2) any obstacles 

that may impede VA’s efforts to 

adequately implement its accreditation

process. GAO reviewed relevant 

federal laws, regulations and 

procedures, and interviewed VA 

officials and organizations of 

accredited representatives. GAO also

reviewed a representative sample of 

accreditation decisions made in 2012 

as well as complaints received by VA 

in 2012. GAO also conducted 

additional checks on a random but 

small and non-representative sample 

of accredited individuals. 

What GAO Recommends

To improve the integrity of 

accreditation, GAO recommends that 

VA explore options for strengthening 

knowledge requirements and 

addressing emerging threats, improve 

its outreach, and determine the 

resources needed to adequately carry 

out accreditation. VA concurred or 

concurred in principle with GAO’s 

recommendations and cautioned that 

imposing additional requirements to 

address concerns with representative 

knowledge or address emerging 

threats could have a chilling effect on 

representation. 

What GAO Found

The Department of Veterans Affairs’ (VA) Office of General Counsel (OGC) 

procedures do not sufficiently ensure that accredited representatives have good 

character and knowledge. While GAO’s analysis shows that VA follows its 

procedures for reviewing initial accreditation applications, VA relies on limited 

self-reported information to determine whether applicants have a criminal history 

or their character could be called into question, which in turn leaves VA 

vulnerable to accrediting individuals who may not provide responsible assistance. 

For example, when GAO conducted additional checks on a non-representative 

sample of accredited individuals, GAO found that some individuals had histories 

of bankruptcies or liens, information which could help develop a more complete 

picture of applicants’ character and prompt further inquiry by VA into their 

background. VA’s procedures also do not ensure that representatives have 

adequate program knowledge. For example, VA’s initial training requirements are 

minimal and VA does not consistently monitor whether representatives meet 

additional continuing education requirements. As a result, some accredited 

representatives may not have adequate program knowledge to effectively assist 

clients with their claims. After being briefed on GAO’s findings in May 2013, VA’s 

OGC announced plans to take additional steps toward conducting background 

checks on applicants and auditing ongoing character and training requirements. 

VA efforts to administer accreditation are hindered by an inadequate allocation of 

resources and unclear communication with claimants. For example, OGC has 

only four staff dedicated to overseeing thousands of accreditation applications 

each year, in addition to monitoring approximately 20,000 accredited 

representatives. As a result, OGC has not kept pace with pending accreditation 

applications, and has not consistently monitored continuing requirements. OGC’s 

reliance on manual data entry results in resource-intensive program 

administration. For instance, OGC lacks information technology systems and 

tools that would help it proactively and efficiently identify representatives who are 

not meeting ongoing training requirements. Moreover, VA does not clearly solicit

feedback from claimants about accredited representatives. For example, neither 

VA’s accreditation web page nor information VA sends to claimants clearly 

communicates their rights or how to report abuses. Absent such outreach, 

claimants may not be aware that some representatives may be engaging in 

prohibited practices. Lastly, VA’s current accreditation program does not address 

some emerging threats to claimants. For instance, VA has received complaints 

regarding unaccredited individuals inappropriately charging claimants to apply for 

benefits. By law, only accredited individuals can assist claimants. However, VA is 

not aware of the extent these unaccredited individuals operate, and is limited in 

the actions it can take to prevent them from assisting claimants.

View GAO-13-643. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov.
Page i GAO-13-643 VA Benefits

Letter 1 

Background 2

VA’s Procedures and Requirements Do Not Sufficiently Ensure 

That Representatives Are Qualified 6

Inadequate Resource Allocation and Unclear Communication with 

Claimants Hinder Efforts to Administer Accreditation 12

Conclusions 17

Recommendations for Executive Action 17

Agency Comments and Our Evaluation 18

Appendix I Objectives, Scope, and Methodology 22

Appendix II Comments from the Department of Veterans Affairs 24

Appendix III GAO Contact and Staff Acknowledgments 30

Tables

Table 1: Categories of Individuals Accredited by VA 3

Table 2: Specific Initial and Ongoing Accreditation Requirements 

by Type of Representative 5

Table 3: Organizations Interviewed by GAO 23

Figure

Figure 1: Number and Percentage of Open Claims by 

Representation Type 4

Contents 
Page ii GAO-13-643 VA Benefits

Abbreviations

CLE Continuing Legal Education

OGC Office of General Counsel

VA Department of Veterans Affairs

VBA Veterans Benefits Administration

VSO Veteran Service Organization

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-13-643 VA Benefits

441 G St. N.W.

Washington, DC 20548

August 1, 2013

Congressional Requesters

In 2012, veterans, their spouses, or survivors filed over a million claims 

for various benefits with the Department of Veterans Affairs (VA). In order 

to help these claimants navigate what can be a complex and lengthy 

process, VA accredits individuals—called representatives—to help ensure 

responsible and qualified representation is available to prepare, present, 

and prosecute claims on the behalf of veterans.1 Representatives who 

assist veterans and their families in applying for benefits must have good 

moral character and be capable of providing competent representation, 

and VA has responsibility for making such determinations through its 

accreditation process. However, we and others have found instances in 

which individuals that purport to help veterans may actually be harming 

them. For example, in prior work we identified instances where 

representatives charged excessive fees for filing claims or failed to 

properly file claims, costing veterans thousands of dollars in foregone 

benefits.2

At your request, we reviewed VA’s procedures for accrediting and 

monitoring representatives. Specifically, this report examines (1) the 

extent to which VA’s procedures adequately ensure representatives meet 

program requirements, and (2) any obstacles that may impede VA’s 

efforts to adequately implement its accreditation process. To identify 

requirements for the program, we reviewed applicable federal laws, 

regulations, and program guidance. To determine how VA carries out its 

responsibilities and the challenges it faces, we interviewed officials in 

VA’s Office of General Counsel—which administers VA’s accreditation 

function—as well as the Veterans Benefits Administration, which reviews 

disability benefits claims and awards benefits. We also visited a VA 

regional office to obtain an operational perspective. To gain further 

understanding of VA’s procedures for screening applicants and 

 

1 VA uses the term representative to refer only to individuals affiliated with recognized 

veteran service organizations, but for the purposes of this report, we use the term more 

broadly to include all individuals accredited by VA, unless it is specifically stated that we 

are referring only to representatives of veteran service organizations.

2 Veterans’ Pension Benefits: Improvements Needed to Ensure Only Qualified Veterans 

and Survivors Receive Benefits, GAO-12-540 (Washington, D.C.: May 15, 2012). 

 
 

Page 2 GAO-13-643 VA Benefits

addressing complaints, we reviewed a randomly selected and 

representative sample of 92 accreditation decisions made in 2012, and a 

judgmental sample of 24 complaints received by VA. Additionally, we 

judgmentally selected a sample of 21 individuals—individuals who had 

either received accreditation in 2012 or individuals for whom VA had 

received a complaint in 2012—for additional checks into their criminal and 

financial histories. To provide additional perspectives and further context 

to our review, we interviewed officials from four national organizations 

that represent veterans, as well as three organizations that represent 

accredited attorneys or agents.

We conducted this performance audit from September 2012 to August 

2013 in accordance with generally accepted government auditing 

standards. These standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We 

conducted our related investigative work in accordance with investigation 

standards prescribed by the Council of the Inspectors General on Integrity 

and Efficiency. Additional information on our scope and methodology is 

provided in Appendix I.

Although VA is required by law to assist claimants in obtaining the 

evidence necessary to substantiate a claim for benefits, accreditation 

helps ensure that claimants have access to qualified representation. By 

law, only individuals accredited by VA can represent claimants in the VA 

claims process.3 Table 1 below describes the three types of individuals 

that VA recognizes as accredited representatives.

 

3 VA allows for a one-time exemption so that claimants can designate non-accredited 

individuals as their representative, without compensation. VA officials told us that this 

exemption can be used by claimants who wish to designate a family member as their 

representative.

Background 
 

Page 3 GAO-13-643 VA Benefits

Table 1: Categories of Individuals Accredited by VA

Category Who is eligible to apply

Veteran Service Organization 

(VSO) representatives

Employees or members of recognized veterans service organizations. a

Attorneys

VSOs are 

organizations recognized by VA that serve the needs of veterans, such as providing 

information on benefits and assistance in applying for them. Recognized organizations may be 

private organizations, as well as state and local government entities.

Attorneys in good standing with a state bar. Any attorney may apply regardless of the area of 

law in which they specialize. 

Claim agents Any individual who is neither a service organization representative nor an attorney. There is no 

occupational or educational requirement, but examples include veteran’s advocates and 

financial planners.

Source: GAO analysis of VA regulations and VA.

a 

To implement accreditation, the law and VA regulations set forth a 

number of requirements representatives must meet.

VA regulations establish a process by which VSOs may be officially recognized by VA. Only 

recognized VSOs may seek accreditation for their staff or members who wish to provide 

representation.

4

• Be of good character: Although what constitutes good character is not 

specifically defined, VA regulations provide, with respect to agents 

and attorneys, that evidence showing a lack of good character and 

reputation may include such things as: conviction of a felony or other 

crimes related to fraud, theft, or deceit; or suspension or disbarment 

from a court, bar, or government agency on ethical grounds. In 

addition, all representatives are required to be truthful in their dealings 

with claimants and VA.

For example, 

representatives must:

• Provide competent representation: Representatives must provide 

competent representation, which includes the knowledge, skills, 

thoroughness, and preparation necessary for representation, as well 

as an understanding of the issues of fact and law relevant to the 

claim.

• Provide prompt representation: Representatives must act with 

reasonable diligence and promptness in representing claimants. This 

includes responding promptly to VA requests for information or 

assisting a claimant in responding promptly to VA requests for 

information.

 

4 See 38 U.S.C. §§ 5901 - 5905 and 38 C.F.R. §§ 14.626 – 14.637.
 

Page 4 GAO-13-643 VA Benefits

As of May 2013, VA had on its rolls approximately 20,000 individuals who 

are accredited to represent claimants. Specifically, VA had accredited 

8,207 VSO representatives, 11,568 attorneys, and 345 claim agents.

Available data demonstrate the growing role and importance of 

accreditation. Since current program rules were adopted in mid-2008, the 

number of applications VA received has grown from 2,696 in 2008 to over 

5,000 in each year since. Additionally, almost 80 percent of claims that 

were open as of November 2012 used the services of a representative, 

with VSOs accounting for the bulk of those claims (see fig. 1).

Figure 1: Number and Percentage of Open Claims by Representation Type

Note: Data provided by VA does not distinguish between attorneys and agents. None reflects 

claimants who chose to pursue benefits on their own, without the aid of any representative.

VA’s Office of General Counsel (OGC) oversees the accreditation 

program. To this end, OGC staff review accreditation applications and 

make approval decisions, monitor whether accredited representatives 

meet ongoing program requirements, and investigate issues and 

complaints that could lead to a representative having his or her 

accreditation cancelled or suspended. Table 2 describes the initial and 

ongoing requirements for these representatives. Additionally, OGC staff 

receive and review fee agreements—contracts between claimants and 

representatives outlining how claimants will be charged for services. 

Within VA, the Veterans Benefits Administration (VBA) also plays a 

limited role in enforcing accreditation rules—checking that individuals are 

accredited when claimants designate them as their representative. In 
 

Page 5 GAO-13-643 VA Benefits

cases where an individual is not accredited, VA policy is to inform the 

would-be representative of accreditation program rules and prohibit the 

individual from serving as the representative for that claim.

Table 2: Specific Initial and Ongoing Accreditation Requirements by Type of Representative

Good character requirements Knowledge requirements 

Initial Ongoing Initial Ongoing 

VSO VSOs recommending a 

prospective representative to 

VA must certify the individual is 

of good character.

Representatives’ good 

character must be 

recertified by their VSO 

every 5 years.

VSOs recommending a 

prospective representative 

to VA must certify the 

individual has demonstrated 

an ability to represent 

claimants before VA.

Representatives’ ability 

to represent claimants 

before VA must be 

recertified by their VSO 

every 5 years.

Attorney Presumed to meet character 

requirements based on state 

bar membership in good 

standing unless OGC receives 

credible information to the 

contrary; must also provide 

character references and 

background information, 

including information concerning 

criminal background, as part of 

the accreditation application.

Must annually submit to 

VA information about any 

court, bar, or federal or 

state agency to which they 

are admitted to practice or 

authorized to appear, 

along with a certification 

that they are in good 

standing. 

As a condition of initial 

accreditation, required to 

complete 3 hours of 

qualifying continuing legal 

education (CLE) within 12 

months.

Must complete an 

additional 3 hours of 

qualifying CLE within 3 

years of initial 

accreditation and every 2 

years thereafter.

Agent VA must make an affirmative 

determination of character 

before a prospective agent can 

be accredited. Must provide 

character references and 

provide background information 

in application to VA.

Same as ongoing attorney 

requirements above. 

Same as initial attorney 

requirements above. In 

addition, must pass a written 

examination by VA.

Same as ongoing 

attorney requirements 

above.

Source: VA regulations and VA. 

VA rules also govern the fees that each type of representative can charge 

claimants. VSO representatives are required to provide their services free 

of charge. Attorneys and claim agents may not charge claimants for 

services related to the initial preparation and filing of their claims, but can 

charge fees for any services rendered after VA makes an initial decision 

on a claim and the claimant initiates an appeal of VA’s decision.

5

 

5 For instance, if the claim is denied or claimant believes he or she is entitled to a higher 

level of disability compensation.

For 

services rendered after an initial decision is made and an appeal is 

initiated, VA rules generally allow attorneys and agents to charge a 
 

Page 6 GAO-13-643 VA Benefits

reasonable fee based on retroactive benefits that are awarded. Fees that 

do not exceed 20 percent of any retroactive benefits are presumed to be 

reasonable. 

VA’s OGC may cancel accreditation if the representative fails to meet any 

of the requirements for accreditation, knowingly presents a fraudulent or 

frivolous claim, or demands or accepts unlawful compensation. OGC may 

also suspend and reinstate the individual if he or she meets conditions for 

reinstatement. Additionally, a VSO can request that VA suspend or cancel 

accreditation for one of its representatives based on misconduct or lack of 

competence. OGC is required to inform representatives of the nature of 

their alleged violation and representatives may request a hearing on the 

matter. An OGC decision can be appealed to the Board of Veteran’s 

Appeals.

VA consistently follows its procedures when reviewing applications for 

accreditation; however, those procedures are not sufficient to ensure 

representatives have good character.6 Based on our analysis of a sample

of 92 accreditation decisions for attorneys and agents,7

 

6 VA officials told us they do not have any documented policy or guidance for reviewing 

applications for accreditation, beyond what is in regulations. In lieu of documented 

guidance, GAO considered officials’ statements made during interviews describing VA’s 

procedures for reviewing applications, and making accreditation decisions as criteria for 

our review.

we estimate that 

VA correctly followed its procedures in 95 percent of applications 

7 Because VA relies on VSOs to certify that their representatives meet requirements for 

representing veterans, VA’s review of accreditation applications and related decisions 

mostly pertains to attorneys and agents.

VA’s Procedures and 

Requirements Do Not 

Sufficiently Ensure 

That Representatives 

Are Qualified

VA Does Not Sufficiently 

Assess Whether 

Representatives Have 

Good Character
 

Page 7 GAO-13-643 VA Benefits

approved in 2012.8

Reliance on limited data: VA relies on attorneys and agents to self-report 

background information on their accreditation applications. For example, 

these applicants are expected to provide true and correct information 

about issues such as their criminal history, but VA does not independently 

verify this information to ensure that applicants were honest about their 

criminal history. Because they do not verify applicants’ information, OGC 

officials told us they could unknowingly accredit individuals who lack good 

character. Additionally, VA does not collect additional information, such 

as Social Security numbers or credit histories, which could be used to 

conduct a more thorough review of applicants’ backgrounds. For 

instance, when we conducted further inquiries into the backgrounds of 

accredited attorneys and agents, we found in 9 of 20 instances that 

individuals had histories of bankruptcies or liens.

Such procedures include ensuring that applicants 

have appropriate qualifications (such as bar membership for attorneys), 

and obtaining additional information when applicants state they had prior 

criminal activity or other incidents that could call their character into 

question. That said, we identified several limitations in VA’s accreditation 

procedures and requirements that call into question whether VA can 

adequately ensure the character of accredited representatives. These 

include:

9

 

8

 Based on our analysis using a 95 percent confidence interval, VA correctly followed its 

procedures for 88 to 98 percent of attorney and agent applications approved in 2012. In 

the remaining cases, there was no evidence in the application file that VA conducted 

needed follow-up or we were not able to make an assessment because of missing 

documentation. 

We also searched to 

see if these individuals had a criminal history that would warrant further 

follow-up from VA or had professional licenses suspended, but did not 

find any such instances. While VA does not currently consider 

bankruptcies or liens as grounds for barring or cancelling an individual 

from being accredited, soliciting and confirming such information may 

provide a more complete picture about an individual’s financial situation 

and management, and could prompt further inquiries that can inform the 

accreditation decision. The official that oversees accreditation 

9 For four of these individuals, VA received complaints alleging these same individuals 

charged non-allowable fees for filing claims. Of the 21 individuals we conducted 

background checks on, 10 of them had complaints against them on file with VA. The 

remaining 11 individuals were selected from our sample of 92 attorneys and agents 

accredited in 2012. We were able to obtain information on 20 of the 21 individuals in our 

sample.
 

Page 8 GAO-13-643 VA Benefits

acknowledged that additional background information, particularly on 

agents who are also financial planners, would be useful in informing VA’s 

judgment of their character. Subsequent to our May 2013 exit briefing 

with VA, OGC officials informed us that they recently gained access to 

VBA’s system to conduct background searches and are developing plans 

to conduct comprehensive background checks on all claim agent 

applicants and on attorney applicants as necessary. The official that 

oversees accreditation also stated that VA is considering requiring 

applicants to supply information on any professional certifications they 

hold and confirming this information with agencies like the Financial 

Industry Regulatory Authority, which regulates brokers’ activities.

Not consistently following up on references: VA may be missing 

opportunities to obtain additional information about applicants by not 

consistently following up on character references. While attorneys and 

agents are required to provide references in their accreditation 

applications, the official who oversees accreditation told us that VA 

contacts references only for agents, which we verified in our review of 

applications. Further, the value of reference letters VA receives is 

questionable as VA did not use a standard set of questions or guidance to 

obtain specific information that should be included in reference letters, 

such as requesting information on the agents’ criminal or employment 

history. Several reference letters we reviewed did not provide substantial 

information on applicants’ ability to assist veterans. In one instance, VA 

had to request additional reference letters for an applicant because two of 

the applicant’s reference letters were from members of the same church 

group and had identical language. Additionally, we found several 

instances where references listed in applications were family members or 

lived at the same address as the applicant, calling into question the 

impartiality of the information received. At our May 2013 exit briefing with 

VA, officials announced that VA has revised and will begin using a 

standardized letter to references to specifically request information on 

agents’ criminal and employment histories, as well as their interest in 

serving veterans.

Reliance on VSOs and state bars: OGC officials told us that they rely 

heavily on the judgment of VSOs when deciding whether to accredit their 

prospective representatives. OGC officials told us that they believe VSOs 

do a good job of screening their applicants and that it is in the best 

interests of VSOs to maintain a positive reputation regarding the quality of 

representation they provide as VSOs depend on contributions from 

veterans to fund their operations. That said, VA does not actively review 

VSO certification plans and therefore cannot know whether there is
 

Page 9 GAO-13-643 VA Benefits

variability in procedures and standards among organizations. Regarding 

attorneys, VA generally presumes good character and fitness to represent 

claimants if they have a state bar membership in good standing. 

However, our work shows that an attorney’s standing with a state bar may 

not always be a sufficient proxy for good character. In one example, an 

attorney was in good standing with his state bar, but he had several 

previous suspensions from the bar and multiple felonies in his criminal 

record involving theft or misappropriation of property or funds. In this 

instance, VA chose not to accredit the individual based on his selfreported criminal record, but it is not clear what the outcome would have 

been had VA relied on his bar membership status in the absence of such 

self-reported information.

Limited ongoing monitoring: Once representatives become accredited, VA 

does little to ensure that they retain good character. VA requires attorneys 

and agents to annually certify that they are in good standing with any 

court, bar, or federal or state agency to which they are admitted to 

practice or authorized to appear. VA also requires VSOs to recertify their 

representatives every 5 years. However, VA officials told us that they 

currently face a backlog in processing these annual certifications and 

therefore have not consistently monitored whether these re-certifications 

have occurred. For example, the official that oversees accreditation told 

us that in one instance, an attorney self-reported in a letter to VA that he 

was disbarred and that his accreditation should be cancelled. Since VA 

does not consistently monitor whether attorneys annually certify their 

standing with the bar, the agency would not have known that this 

individual was disbarred had he not voluntarily communicated this 

information. After our May 2013 exit briefing with VA, OGC informed us 

that they are developing plans to annually audit the certifications of good 

standing that attorneys and agents file.

VA’s initial knowledge requirements for attorneys and agents are limited 

and do not ensure that they are knowledgeable about VA benefits. To 

become accredited, agents must pass an exam comprised of 25 multiplechoice and true-false questions. However, organizations that represent or 

help train agents told us the exam covers a wide array of subjects 

concerning veterans’ benefits law and procedure without deeply 

broaching any particular topic. Further, they said that the exam alone is 

not sufficient to determine whether agents have enough knowledge to 

represent veterans. For attorneys, VA presumes that any attorney in good 

standing with the bar is qualified and knowledgeable enough to assist 

veterans. As such, attorneys are not required to take an initial exam to 

VA Requirements Do Not 

Ensure Representatives 

Are Knowledgeable
 

Page 10 GAO-13-643 VA Benefits

demonstrate their knowledge of veterans’ benefits law. However, officials 

from two organizations that provide training for accreditation told us that 

membership with the bar does not guarantee that an individual is 

knowledgeable about VA benefits law. One attorney noted that it can take 

years to understand VA benefits issues and provide knowledgeable 

assistance in this area. In fact, representatives from one VSO told us that 

attorneys and agents often contact VSOs with questions about 

representing their claimants.

In addition, VA’s initial and ongoing training requirements do not ensure 

accredited attorneys and agents are knowledgeable and VA does not 

consistently enforce existing requirements. In addition to requiring that 

attorneys and agents complete 3 hours of qualifying continuing legal 

education (CLE) within 12 months as an initial condition of accreditation, 

VA requires that accredited attorneys and agents complete 3 hours of 

training every 2 years, and that this training cover certain topics such as 

representation before VA, claims procedures, basic eligibility for benefits, 

and appeal rights. Officials from two organizations that provide training for 

accreditation told us that this amount of training is not sufficient to ensure 

that attorneys and agents are knowledgeable. Additionally, officials from 

these organizations told us that VA does not review, or provide guidance 

on course content. OGC officials told us that they rely on each state bar 

association to approve its own training, which can introduce variability 

across states. Moreover, VA does not consistently ensure that attorneys 

and agents complete required training. OGC officials told us that 

individuals who do not certify their training requirements could have their 

accreditation suspended. Despite this, OGC has fallen behind on its 

monitoring of this requirement, and it is likely that individuals who should 

not be accredited continue to assist claimants. After our May 2013 exit 

briefing with VA, OGC officials informed us that they are developing plans 

to annually audit the training certifications which attorneys and agents 

must file with OGC.

VA relies on VSOs to train their representatives and ensure that VSO 

representatives can provide knowledgeable assistance to veterans with 

relatively little oversight from VA. We spoke to three national VSOs who 

noted that they provide numerous training opportunities for their 

representatives, which may include on-the-job training, seminars, and 

regular conferences. Two VSOs we spoke with also said that they monitor 

whether their representatives are meeting knowledge requirements. 

However, the official who oversees accreditation said VA relies on VSOs 

to ensure their staff have appropriate training and that VA does not review 

VSO training programs. While VA did not express concerns about VSO 
 

Page 11 GAO-13-643 VA Benefits

representatives meeting knowledge requirements, GAO’s standards for 

internal controls state that information about a program’s operations 

should be communicated to management, in order to determine whether 

the agency is achieving compliance requirements under relevant laws 

and regulations.10

Representatives’ knowledge is critical to meeting another VA 

requirement—ensuring that they provide prompt representation. Officials 

at one regional office noted that some representatives are less 

knowledgeable than others and that they might forget or overlook certain 

items in a claim. At the same time, they stated that it is VA’s responsibility 

to review claims to make sure they are complete and to notify claimants 

when information is missing. However, officials from an organization 

representing attorneys and agents told us that VA does not consistently 

follow up with veterans to make sure that their paperwork is complete and 

there have been instances where mistakes on initial claims resulted in 

veterans losing the ability to claim benefits that they were entitled to 

receive. Similarly, the officials told us that a representative who is not 

knowledgeable enough to use the appropriate language for appealing a 

decision may result in VA not recognizing the communication as a formal 

disagreement with VA’s decision, in turn causing the veteran to miss the 

deadline for appealing their claims case.

Absent better oversight of VSO training, VA cannot 

ensure the knowledge of representatives who represent a majority of 

claimants.

 

10 The standards for internal control emphasize the need for agencies to have relevant 

and reliable information relating to external as well as internal events, in order to run and 

control operations. To support agencies’ efforts to obtain information, the internal controls 

specifically state that operational information should be provided to managers so that they 

may determine whether their programs comply with applicable laws and regulations. See 

GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington, 

D.C.: August 2001) and GAO, Standards for Internal Control in the Federal Government, 

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

Page 12 GAO-13-643 VA Benefits

VA has dedicated only a few staff to administer its accreditation program, 

which has resulted in limited monitoring efforts and workload backlogs. 

VA officials told us that approximately four staff positions in OGC are 

dedicated to accreditation. These staff are responsible for reviewing 

thousands of applications each year, and ensuring that the approximately 

20,000 individuals already accredited meet continuing requirements. 

Officials told us this level of staffing is insufficient to carry out all these 

responsibilities and that VA has chosen to prioritize screening initial 

accreditation applications over monitoring ongoing requirements. Even 

so, VA has a significant backlog of accreditation applications to review. 

VA estimates that it may take 60 to 120 days to review an application 

after it is received. Because by law only accredited individuals may 

represent claimants, this backlog may cause delays for claimants who 

need assistance with their claims.

VA currently has no plans to permanently increase the number of staff 

dedicated to accreditation. OGC officials told us that they have been 

seeking to increase the number of staff working on accreditation, but have 

been unsuccessful in obtaining additional permanent staff. An official 

noted that in the fall of 2012, several staff were assigned to accreditation 

on a temporary basis and, with their help, OGC was able to eliminate its 

backlog of attorney and VSO representative applications. However, OGC 

stated that a considerable backlog of agent applications remains and it is 

likely the backlog of attorney and VSO representative applications will 

return since this temporary initiative has ended. Moreover, as of May 

2013, one of the four positions was not filled because of a resignation. 

OGC is in the process of replacing staff lost to attrition as well as 

obtaining an additional temporary staff person. Still, OGC officials stated 

that they would need several additional staff beyond the four dedicated 

positions to function more effectively. It is questionable if this will happen 

Inadequate Resource 

Allocation and 

Unclear 

Communication with 

Claimants Hinder 

Efforts to Administer 

Accreditation 

Inadequate Staffing and 

Information Technology 

Leads to Backlogs and 

Limited Program 

Monitoring 
 

Page 13 GAO-13-643 VA Benefits

in the near future as VA’s proposed fiscal year 2014 budget calls for 

fewer staff in VA’s OGC. This may also affect OGC’s plans to increase its 

oversight of accredited representatives because those plans are 

contingent upon eliminating the backlog of initial applications.

VA’s implementation of its accreditation process is also hampered by 

limited information technology (IT) support. Officials told us that the 

database system used by OGC cannot automatically inform individuals 

that they are meeting program requirements and OGC staff must do this 

manually. Further, an official noted that a significant amount of data entry 

is required when applicants submit information for accreditation. Officials 

noted that other IT improvements, such as the ability for applicants to 

electronically submit applications, or for accredited representatives to 

submit certifications of good standing and training certifications would 

help OGC manage its responsibilities more efficiently. However, no steps 

have been taken to date toward developing these capabilities.

VA’s ability to identify and address abuses by representatives is limited 

because VA has missed opportunities to educate claimants about their 

rights and protections against potential abuses. In prior work, we reported 

that targeted communication with a specific message is a best practice for 

outreach to veterans.11 Individuals who do not yet have representation 

receive a letter from VA after submitting a claim containing some 

information on representation—such as explaining what VSOs are and 

that they provide assistance at no charge. However, the letter does not 

discuss attorneys and agents, nor does it note that a claimant should not 

have to pay for services associated with filing an initial claim. Similarly, 

the form that claimants use to designate an attorney or agent12

 

11 GAO, Social Security Disability: Additional Outreach and Collaboration on Sharing 

Medical Records Would Improve Wounded Warriors’ Access to Benefits, 

refers 

individuals to the section of the law governing fees, but does not explain 

that claimants should not pay for filing an initial claim. Beyond these 

forms, VBA officials told us that VA does not actively conduct outreach to 

claimants regarding representation, what to expect from their 

representative, or their right to not pay filing fees for initial claims. As a 

GAO-09-762 

(Washington, D.C.: Sept. 16, 2009). 

12 VA requires a signed declaration of representation designating the representative on 

VA Form 21-22 or 21-22a before an individual can represent a claimant. 

VA’s Oversight Is Limited 

by a Lack of Outreach to 

Claimants and an Unclear 

Complaint Process
 

Page 14 GAO-13-643 VA Benefits

result, several VSOs we interviewed stated that veterans are often 

unaware of their rights or what to expect during the claims process. One 

VSO service officer told us that nearly all veterans he encounters are 

unaware that they should not pay to file initial claims. He added that if a 

veteran is told that he or she must pay a fee, the veteran will usually just 

assume this is how business is done. Further, many of the complaints to 

VA we reviewed regarded improper fees.

VA’s ability to learn about and address potential abuses also may be 

hampered by a complaint process that is not well-communicated to 

claimants. GAO standards for internal controls state that effective 

communications—such as with external stakeholders—is critical for 

agencies to ensure they receive information that may significantly affect 

whether they achieve their objectives. While VA regulations establish a 

complaint process, VA may be missing opportunities to serve and protect 

claimants as it has not clearly communicated to claimants or others how 

to report concerns about representatives.13

Further, the process of responding to and addressing complaints—which 

can be difficult and lengthy—is understaffed, thereby limiting its 

effectiveness. VA officials told us they require clear and convincing 

evidence in order to cancel a representative’s accreditation. One official 

noted the process of monitoring representatives who received complaints 

is difficult given competing demands for resources. Additionally, collecting 

evidence can be difficult because claimants may be reluctant to reveal 

their identities when making complaints. They added that some 

cancellation actions may take years to resolve when representatives 

exercise their right to appeal decisions. An OGC official told us that 

For example, VA’s 

accreditation website does not explicitly state how to report concerns 

about representatives. While the website provides a link to an e-mail 

address used for general inquiries, an official noted that OGC receives a 

large volume of emails at this address—including complaints—and is 

behind in responding to inquiries. Additionally, the materials provided to 

individuals when filing a claim also do not clearly state how to report 

complaints. When we interviewed veterans at two VSOs in the D.C. area, 

we generally found that they were unfamiliar with program requirements 

and did not know where or how to file a complaint.

 

13 VA’s regulations clearly indicate that OGC will accept credible written information from 

any source indicating improper conduct or incompetence on the part of representatives of 

any kind.
 

Page 15 GAO-13-643 VA Benefits

allocated resources were currently inadequate to effectively monitor 

representatives about whom complaints had been submitted and that 

information about complaints is not shared with other parts of VA. For 

instance, OGC does not share information with VBA that could help 

identify or monitor the activities of representatives with complaints. OGC 

estimated that only two attorneys or agents had their accreditation 

cancelled over the last 5 years for violating the rules of the program and 

none were suspended.14

VA faces challenges with unaccredited individuals helping veterans file 

claims and charging claimants for assistance. While federal regulations 

require representatives to be accredited, we found a number of 

complaints about individuals who are not accredited filing claims for 

veterans. Of the 24 complaints filed against attorneys and agents in 2012, 

7 were regarding unaccredited individuals. Because VA is not aware of 

the extent to which these individuals interact with claimants, VA cannot 

take action or ensure they provide quality services. An OGC official told 

us that when it learns of these individuals, it is limited in the actions it can 

take beyond instructing the individual to stop. Additionally, he said he has 

written to state attorneys general offices regarding potential wrongful 

actions a few times in the last year, but does not know if the states took 

action. In our review, we found a few instances in which OGC sent letters 

concerning unaccredited individuals to state attorneys general only to 

continue to receive complaints about these individuals. An OGC official 

added that, beyond cancelling or suspending accreditation, there are no 

penalties for individuals who violate the requirements of accreditation and 

that cases generally are not referred to VA’s Inspector General.

Accreditation also does not address whether individuals should sell 

financial products to veterans. Our prior work has shown that some 

accredited individuals were selling financial products to veterans in order 

 

14 In this same time period, VA estimates that 17 VSO representatives lost their 

accreditation for breaking program rules and 3 were suspended. Officials told us that 

VSOs may request that VA cancel accreditation for their representatives based on their 

own information regarding the individual’s behavior. Many more individuals have their 

accreditation cancelled for reasons not related to conduct. VA estimates that 1,387 VSO 

representatives, 15 attorneys, and 1 agent had their accreditation cancelled for reasons 

not related to conduct in fiscal year 2012.

Accreditation Does Not 

Address Some Emerging 

Threats
 

Page 16 GAO-13-643 VA Benefits

to shelter assets and allow them to qualify for VA pension benefits.15

It is also difficult for VA to ensure that claimants are being charged 

appropriate fees. Attorneys and agents are not allowed to charge or 

receive a fee for the preparation or initial filing of a claim, but are allowed 

to charge a fee for services provided after VA has decided the claim and 

a notice of disagreement has been filed initiating an appeal of that 

decision. The allowable fee is often 20 percent of retroactive benefits 

awarded if the claim is granted. However, there is no restriction on fees 

charged for services before an individual files a claim. VA’s OGC issued a 

letter in 2004 noting that attorneys may charge claimants for services that 

are rendered before the individual begins the process of filing a claim, 

such as consulting with the individual about the range of VA and other 

federal benefits he or she may qualify for. Some VSOs and other experts 

expressed some concern regarding pre-filing consultation fees. The head 

of one VSO noted that these fees may serve as a mechanism to hide the 

fact that attorneys and agents are charging claimants for preparing 

Some of these cases involved vulnerable populations, such as veterans 

in assisted living facilities, or involved individuals selling products that 

resulted in veterans losing control of their assets without qualifying for VA 

benefits. VA and some VSO officials told us that financial planners 

continue to be an area of concern. VA officials told us that an increasing 

number of financial planners are applying for accreditation as agents. In 

fact, all six of the agents in our file review appeared to have a financial 

planning background. VA also told us that when an individual with a 

financial planning background applies for accreditation, it asks for 

additional information about their business plans, reviews any business 

websites, and reminds applicants that the purpose of accreditation is to 

provide assistance to veterans and that they should not use accreditation 

to promote financial products. That said, the official who oversees 

accreditation told us that they often lack a sufficient basis to deny 

accreditation to these individuals because being a financial planner in and 

of itself does not violate VA’s accreditation rules. He added that it might 

be helpful to collect additional information on these individuals, such as 

from financial regulators, when deciding whether to accredit them.

 

15 VA pension benefits are intended to provide economic benefits to low-income veterans 

who served during a time of war, and to qualify, veterans must have income and assets 

below a certain threshold. Our prior work found instances of companies advertising 

financial planning services to veterans that circumvented eligibility requirements such as 

by placing assets in trusts or transferring them to family members. See GAO-12-540. 
 

Page 17 GAO-13-643 VA Benefits

claims. Ambiguity regarding these fees makes it difficult for claimants and 

VA to know whether they are being charged allowable fees, and may 

result in attorneys inappropriately billing for work related to the claim as if 

it was for a general consultation. Because fees for pre-filing activities are 

outside the claims process, VA also has no way of knowing the extent to 

which they occur or are properly charged. More than half of the 

complaints against attorneys and agents (15 of 24) that we reviewed were 

related to fees.

Hundreds of thousands of veterans and their families rely on accredited 

representatives to guide them through the process of applying for VA 

benefits. However, current program implementation and requirements do 

not sufficiently ensure that veterans and their families are protected 

against potential abuses or that VA has the ability to identify and address 

situations where representatives are not acting in the best interests of 

clients. While recent plans to collect more information on applicants and 

increase oversight of existing representatives are promising, it is unclear 

how OGC will implement and sustain these improvements given the 

current level of resources VA has allocated to this program. Additionally, 

without providing better information to claimants about how to report 

issues or concerns about their representation, claimants may not know 

where to turn to report an abuse or not even recognize that their 

representative is engaged in prohibited practices. Lastly, claimants may 

be vulnerable to emerging threats—such as unaccredited 

representatives—in the absence of VA tools to provide protection. We 

recognize that in considering program enhancements, VA will need to 

balance the effort of instituting changes and the additional burdens they 

may place on program staff and representatives with ensuring that 

claimants continue to have ready access to representation. However, 

representatives with ill-intent or poor knowledge can cause real harm to 

claimants and a weak accreditation process will negatively affect VA’s 

ability to provide veterans the benefits to which they are entitled.

To improve VA’s ability to ensure that claimants are represented by 

qualified and responsible individuals, the Secretary of Veterans Affairs 

should explore options and take steps to:

1. Ensure an appropriate level of staff and IT resources are in place to 

implement the requirements of the accreditation program. This should 

include exploring options for utilizing other VA components and 

resources outside of OGC.

Conclusions 

Recommendations for 

Executive Action
 

Page 18 GAO-13-643 VA Benefits

2. Strengthen initial and continuing knowledge requirements for 

accreditation for all types of representatives.

3. Enhance communications with claimants, including how they can 

report complaints related to their representation. This could include 

exploring options for incorporating information about representation 

and veterans’ rights into existing communications and outreach 

efforts.

4. Address potentially abusive practices by representatives who lack 

accreditation, charge inappropriate fees, or sell financial products to 

claimants that are not in their best interest. If necessary, VA should 

consider seeking additional legislative authority to address such 

practices and enforce program rules.

We provided a draft of this report to the Secretary of Veterans Affairs for 

review and comment. In its comments (see app. II), VA generally agreed 

with our conclusions, and either concurred or concurred in principle or in 

part with our recommendations, as discussed more fully below.

VA concurred in principle with our first recommendation to ensure 

accreditation has appropriate staffing and IT resources, noting that efforts 

to increase staff and obtain IT resources must be considered within the 

existing OGC budget. We agree and fully support VA’s plans to identify 

available resources within and outside of OGC.

VA concurred in principle with our second recommendation that it explore 

strengthening initial and continuing knowledge requirements. VA stated 

that it believes that existing initial knowledge requirements for attorneys 

and agents adequately ensure that VA claimants have qualified 

representation. Additionally, VA expressed concerns that additional 

knowledge or testing requirements could have a chilling effect on attorney 

representation for claimants. Nevertheless, VA stated that it will consider 

ways in which it can equip newly accredited attorneys and agents with 

information regarding veterans benefits law and procedures. Additionally, 

VA stated it plans to revise and update examinations for prospective 

agents to ensure they have adequate knowledge of veterans law and 

procedures. Regarding VSO representatives, VA reiterated that it 

believes it is in each organization’s best interest to ensure their 

representatives are competent and qualified. Nevertheless, VA plans to 

request and review training curricula for up to about 10 percent of 

recognized organizations each year—an effort which we commend. We 

Agency Comments 

and Our Evaluation
 

Page 19 GAO-13-643 VA Benefits

support these efforts, but continue to believe VA should consider ways to 

better equip all accredited attorneys and agents with relevant information

and not limit efforts to just newly accredited attorneys and agents, for 

example, by improving the quality of required continuing legal education. 

Regarding our recommendation to enhance communications with 

claimants, VA concurred and plans to include information on how to 

report complaints on OGC’s accreditation Web site, and will work with 

VBA to identify potential outreach activities. We agree with VA’s stated

efforts to improve communication with claimants.

VA also concurred in principle with our recommendation to explore 

options for addressing potentially abusive practices by representatives 

and stated it would consider seeking additional legislative authority to 

address these practices and enforce program rules. VA noted that 

imposing penalties on unaccredited individuals, individuals who 

inappropriately charge claimants, or sell financial products to claimants 

could help curb inappropriate practices, but in some cases may have a 

chilling effect on the legitimate activities of others. We acknowledge that 

penalties may be an appropriate deterrent in some but not all 

circumstances and agree with VA’s desire to balance any changes with 

maintaining access for claimants to valuable assistance. We also urge VA 

to further explore other remedies that would not require legislative action, 

such as closer cooperation with state and local law enforcement 

regarding individuals who may commit unlawful acts.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of Veterans Affairs, 

and other interested parties. In addition, this document will be available at 

no charge on GAO’s Web site at http://www.gao.gov. 
 

Page 20 GAO-13-643 VA Benefits

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

me at (202) 512-7215 or at bertonid@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Staff members who made key contributions to 

this report are listed in Appendix III.

Daniel Bertoni

Director, Education, Workforce,

 and Income Security 
 

Page 21 GAO-13-643 VA Benefits

List of Requesters

The Honorable Patty Murray

Chairman

Committee on the Budget

United States Senate

The Honorable Bernie Sanders

Chairman

The Honorable Richard Burr

Ranking Member

Committee on Veterans’ Affairs

United States Senate

The Honorable Bill Nelson

Chairman

Special Committee on Aging

United States Senate
Appendix I: Objectives, Scope, and 

Methodology

Page 22 GAO-13-643 VA Benefits

In conducting our review of how the Department of Veterans Affairs (VA) 

accredits and oversees veterans’ representatives, our objectives were to 

examine (1) the extent to which VA’s procedures adequately ensure 

representatives meet program requirements, and (2) any obstacles that 

may impede VA’s effort to adequately implement its accreditation 

process. We conducted this performance audit from September 2012 to 

August 2013, in accordance with generally accepted government auditing 

standards. These standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. We conducted our related 

investigative work in accordance with investigation standards prescribed 

by the Council of the Inspectors General on Integrity and Efficiency.

To determine the extent to which VA’s procedures are adequate, we 

reviewed pertinent federal laws and regulations and interviewed officials 

in VA’s Office of General Counsel (OGC) and Veterans Benefits 

Administration. To assess the extent to which VA carries out its 

procedures, we reviewed a random, representative sample of 92 case 

files for attorneys and agents who were granted accreditation in 2012.1

We examined these files to determine whether individuals provided 

complete information on their personal histories, whether individuals had 

the appropriate qualifications, and to determine whether VA took steps to 

collect additional information when necessary. We determined whether 

the evidence in each file indicated that VA carried out the procedures that 

VA officials stated they follow when reviewing files.2

 

1 We decided to not review accreditation decisions for Veterans’ Service Organization 

representatives since VA officials told us that they generally rely on the recommendation 

of the organizations when approving these applications.

Additionally, we 

reviewed all 24 complaints that OGC received in 2012 regarding 

attorneys and claim agents in order to understand the actions that VA 

takes in response to concerns. Additionally, we selected a random, 

judgmental sample of 21 attorneys and agents to determine whether an 

independent background check would uncover issues that could call their 

character into question. These 21 individuals consisted of 5 attorneys and 

6 agents selected in our random sample of 2012 accreditation decisions, 

2 We found incomplete documentation or missing documents in 3 of the 92 files selected. 

In these cases, we were not able to determine whether VA carried out its procedures.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 23 GAO-13-643 VA Benefits

and 5 attorneys and 5 agents whose complaint files we reviewed.3

To provide further context on VA’s procedures and to determine obstacles 

that impede VA’s efforts to adequately implement accreditation, we 

interviewed a number of veterans service organizations (VSO)—which 

both assist veterans in filing claims and advocate for their interests—and

organizations that represent attorneys and claim agents (see table 3).

We 

used Accurint—a commercial database of public records—to determine 

whether these individuals had (1) a criminal history, (2) bankruptcies, (3) 

liens, or (4) professional licenses revoked. In the instances in which 

Accurint delivered a positive result, we confirmed the result by obtaining 

court records.

Table 3: Organizations Interviewed by GAO

Veterans service organizations Groups representing attorneys or agents

• American Legion

• Disabled American Veterans

• National Veterans Legal Services 

Program 

• Veterans of Foreign Wars

• Academy of VA Pension Planners

• National Care Planning Council

• National Organization of Veterans’ 

Advocates

Source: GAO.

Additionally, we conducted a site visit to the Philadelphia VA Regional 

Office where we interviewed regional managers, veterans service 

representatives, and staff who review fee agreements, as well as local 

VSO representatives. Finally, we informally met with groups of veterans 

who were present at two VSOs in the Washington, D.C. area on the days

of our visits, to obtain views on their experiences with representation.

 

3 Our search did not find results for 1 individual, so we reported on findings for the 

remaining 20 in our report.
Appendix II: Comments from the Department 

of Veterans Affairs

Page 24 GAO-13-643 VA Benefits

Appendix II: Comments from the Department 

of Veterans Affairs
Appendix II: Comments from the Department 

of Veterans Affairs

Page 25 GAO-13-643 VA Benefits
Appendix II: Comments from the Department 

of Veterans Affairs

Page 26 GAO-13-643 VA Benefits
Appendix II: Comments from the Department 

of Veterans Affairs

Page 27 GAO-13-643 VA Benefits
Appendix II: Comments from the Department 

of Veterans Affairs

Page 28 GAO-13-643 VA Benefits
Appendix II: Comments from the Department 

of Veterans Affairs

Page 29 GAO-13-643 VA Benefits
Appendix III: GAO Contact and 

Staff Acknowledgments

Page 30 GAO-13-643 VA Benefits

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

In addition to the contact named above, Michele Grgich and Lori 

Rectanus (Assistant Directors), Daniel Concepcion and Aimee Elivert 

made key contributions to this report. David Chrisinger, Paul Desaulniers, 

Sheila McCoy, Wayne McElrath, Dae Park, Almeta Spencer, Roger 

Thomas, and Walter Vance provided support.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(131207)
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