Veterans' Benefits: Improved Management Would Enhance VA's Pension Program
Published: 2008-02-14T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 2006, the Department of Veterans Affairs (VA) paid about $3.5 billion in means-tested pension benefits to over 500,000 veterans and survivors. GAO was asked to review the management of VA pension program. This report assesses (1) the characteristics and trends in size of the current pensioner population, (2) the policies and procedures VA has in place to ensure that initial pension eligibility decisions are well managed, and (3) the procedures VA has in place to ensure that pensioners continue to receive the proper benefit payments on an ongoing basis. Our study included reviews of agency policies, procedures, and internal controls; site visits to 4 of VA's 57 regional offices and all three of its pension maintenance centers; and a selected file review of new claims at three locations.
section_title: What GAO Found
paragraphs: In 2006, most of the over 500,000 VA pensioners had nonpension incomes well below the federal poverty level, were beyond retirement age, and had multiple impairments, and the population has been decreasing in number. The average annual reported income of these pensioners, excluding their VA pensions, was less than $5,000. The average age of VA pensioners was 70. More than 80 percent had no spouse or dependent children. Three-fourths of veteran pensioners had multiple impairments. After reaching a peak of almost 2 million in 1978, the overall size of the pensioner population has gradually decreased, although the number of pensioners from more recent service periods has been increasing. VA policies and procedures are not sufficient to ensure sound decisions on new pension claims. Unlike other federal agencies with similar income-based programs, VA largely does not independently verify the accuracy of financial information provided by claimants to support initial pension program eligibility. In addition, the guidance used by staff to make pension eligibility decisions is not always current or clear. Further, VA's quality assurance review process for initial claims does not select a sufficient number of pension cases to ensure the accuracy of pension claims decisions. Finally, VA does not adequately evaluate training for pension staff. VA procedures for assessing whether pensioners continue to receive the proper benefits have significant limitations. Although the agency requires pensioners to report changes that might affect their pensions, VA does not require documentation such as bank or asset statements when pensioners report financial changes. Also, a key data match operation with the Internal Revenue Service is not conducted in a timely or efficient manner. Finally, despite millions of dollars in improper pension payments made each year, VA lacks a system to monitor and analyze their causes.

section_title: Letter
paragraphs: The Department of Veterans Affairs (VA) pension program is intended to  The Department of Veterans Affairs (VA) pension program is intended to  provide a minimum level of economic security for veterans with financial  provide a minimum level of economic security for veterans with financial  need. It is available to those low-income veterans who are at least 65 years  need. It is available to those low-income veterans who are at least 65 years  old or have disabilities unrelated to their military service, as well as to  old or have disabilities unrelated to their military service, as well as to  their surviving spouses and dependent children. In fiscal year 2006, the  their surviving spouses and dependent children. In fiscal year 2006, the  program paid about $3.5 billion in benefits to over 500,000 pensioners. In  program paid about $3.5 billion in benefits to over 500,000 pensioners. In  administering the program, VA is required to assess the continued  administering the program, VA is required to assess the continued  eligibility of pensioners to determine if changes in family income and  eligibility of pensioners to determine if changes in family income and  assets, or number of dependents, might warrant payment adjustment or  assets, or number of dependents, might warrant payment adjustment or  termination of the pension. Although the VA Pension Benefit program is a  termination of the pension. Although the VA Pension Benefit program is a  relatively small program, it has a critical role in supporting disabled and  relatively small program, it has a critical role in supporting disabled and  aging veterans and their survivors who depend on the program to provide  aging veterans and their survivors who depend on the program to provide  a minimum level of economic security. Providing this benefit honors their  a minimum level of economic security. Providing this benefit honors their  service to their country and provides some financial assurance to those in  service to their country and provides some financial assurance to those in  need.  need.
The Senate Veterans’ Affairs Committee asked GAO to (1) determine the  The Senate Veterans’ Affairs Committee asked GAO to (1) determine the  characteristics and trends in size of the pensioner population, (2) assess  characteristics and trends in size of the pensioner population, (2) assess  the policies and procedures VA has in place to ensure that initial pension  the policies and procedures VA has in place to ensure that initial pension  eligibility decisions are well managed, and (3) assess the procedures VA  eligibility decisions are well managed, and (3) assess the procedures VA  has in place to ensure that pensioners continue to receive the proper  has in place to ensure that pensioners continue to receive the proper  benefit payments.  benefit payments.
Pensions are one of the many benefits available to qualified veterans  Pensions are one of the many benefits available to qualified veterans  through VA. Other VA benefits include medical care, educational  through VA. Other VA benefits include medical care, educational  resources, and compensation for disabilities sustained or worsened as a  resources, and compensation for disabilities sustained or worsened as a  result of active duty military service. VA actually administers three  result of active duty military service. VA actually administers three  pension programs, and we included pensioners from all three programs  when analyzing trends in population size, as this allowed for a more  thorough understanding of changes within different war cohorts over time.  The remainder of the report, however, focuses on the Improved Pension  program, which is the largest and the only one still open to new members.  To determine the characteristics and size of the pensioner population, we  analyzed data from VA’s Benefit Delivery Network (BDN), VA budget  reports, and other reports through fiscal year 2006. To address our  remaining objectives, we reviewed relevant laws, guidance, procedures,  and internal controls that VA uses to ensure the soundness of pension  benefit decisions. We also analyzed VA’s internal control policies and  performance reports. We visited 4 of VA’s 57 regional offices, located in  Boston, Milwaukee, Providence, and St. Paul. We selected these sites  based on variations in size and geographic locations. We also visited VA’s  three pension maintenance centers (PMC), located in Philadelphia,  Milwaukee, and St. Paul, and the Debt Management Center in St. Paul. We  interviewed VA officials and staff at these sites as well as officials at VA  Central Office in Washington, D.C. We also conducted case file reviews in  three locations—Milwaukee, Providence, and St. Paul—to verify the  adequacy of documentation in support of initial pension decisions. For  more details on our scope and methodology, see app. I. We conducted our  review from November 2006 to February 2008, in accordance with  generally accepted government auditing standards. Those standards  require that we plan and perform the audit to obtain sufficient, appropriate  evidence to provide a reasonable basis for our findings and conclusions  based on our audit objectives. We believe that the evidence obtained  provides a reasonable basis for our findings and conclusions based on our  audit objectives.
subsections: section_title: Background
paragraphs: VA’s pension program is means-tested and provides a minimum level of  economic security for veterans with financial need. It is one of two cash  benefits programs administered by VA. The other is disability  compensation, which pays benefits to veterans who have disabilities  related to their military service—often referred to as “service-connected”  disabilities.  The pension program, on the other hand, which is the subject  of this report, pays benefits to low-income veterans who either are elderly  or have disabilities unrelated to their military service. Each program also  provides benefits to eligible survivors. A veteran who applies for and  meets requirements for both disability compensation and pension benefits  will receive benefits through whichever program provides higher benefits.
In 2006, VA paid over $34 billion in compensation and pension benefits to  about 3.5 million veterans and survivors. Of this amount, $30.9 billion was  paid in compensation benefits to 3,014,282 veterans and their survivors.  The remaining $3.5 billion was paid in means-tested pension benefits to  535,380 veterans and their survivors.
The amount of financial assistance provided by the pension program is  relatively modest and intended to raise pensioners’ incomes to a level set  out in statute. Pensioners are awarded an amount equal to the difference  between their countable income, as determined by VA, and the maximum  pension amounts as updated annually by statute. The maximum pension  amount varies according to the pensioner’s current income and number of  dependents. In 2006, veterans with no income and no dependents could  receive as much as $10,579 annually, while survivors with no income and  no dependents could receive a maximum of $7,094 per year. Pensioners  are required to report any changes in income, dependency, or other  relevant circumstances to VA so that benefit levels can be adjusted  accordingly. Generally, for each dollar of income received from other  sources, the VA pension is reduced by the same amount.
subsections: section_title: Eligibility Determinations for VA’s Improved Pension Program
paragraphs: To determine a veteran’s initial eligibility for the pension program, VA’s  regional office staff employ several criteria, including the veteran’s  military status, age or disability, and income. (App. II provides a summary  of this process.) Eligibility for pension benefits is restricted to veterans  who are at least 65 or have total and permanent disabilities unrelated to  their military service. Also, VA considers the income of all family  members, including spouses and children, but excludes the income of  other individuals residing in the household. Various sources of income are  considered when determining income eligibility, including employment,  interest and dividends, retirement, annuities, workers’ compensation,  Social Security retirement and Disability Insurance benefits.  Unreimbursed medical expenses that exceed 5 percent of the maximum  pension amount may be deducted from income in determining eligibility.  Eligibility for the surviving spouses and children of such veterans is based  on similar factors. Once pensioners have been awarded benefits, VA  makes ongoing eligibility determinations and adjusts benefit levels as  needed. Pensioners are required to inform VA of any changes in their  circumstances—such as hospitalization or incarceration, as well as  changes in income and assets—that could affect their eligibility or benefit  levels. To further assess ongoing eligibility and benefit levels, VA also  requires pensioners who have any income other than Social Security to file  an annual report with VA. Then, VA evaluates the information in this  report to determine if pensioners continue to meet eligibility requirements.
section_title: The VA Pension Population Is Characterized by Low Income, Older Ages, Multiple Impairments, and Decreasing Numbers
paragraphs: In 2006, most VA pensioners had nonpension incomes well below the  federal poverty level, were beyond retirement age, and had multiple  impairments, and the population had been decreasing in number. In  addition to low incomes, the majority of VA pensioners had few assets and  limited education. Since 1978, the total pension population has been  decreasing, although there have been increases in numbers of pensioners  from more recent service periods, including the Vietnam era and the Gulf  War.
subsections: section_title: VA Pensioners Generally Have Nonpension Incomes Well Below the Poverty Level, Few Assets, and Low Levels of Education
paragraphs: Most pensioners have very low annual incomes outside of their pension  benefits. According to our analysis of VA data, veteran pensioners’ average  annual nonpension income was $4,573 in 2006. This was well below the  2006 federal poverty level of $9,800 for a single adult. Survivors had a  lower average annual nonpension income of $3,046. Both veterans and  survivors under 65 had lower average annual nonpension incomes than  those 65 and older. Social Security benefits and non-Social Security  retirement income accounted for much of the difference, as shown in table  1. When VA pension benefits are included, most veterans had annual  incomes above the federal poverty level. This is not true of survivors, who  receive smaller pension awards than veterans. Pension benefits in 2006  averaged $8,232 per year for veterans and $4,260 per year for survivors, for  an average total income, respectively, of $12,805 and $7,306.
In a 2002 VA study, pensioners reported having few assets and low levels  of education. Less than half of pensioners reported owning their own  homes, with ownership rates for spouses being lower than those for  veterans. Even fewer pensioners owned vehicles. About one-third of  veterans reported owning a car, and only about one-fifth of spouses  reported owning a car. Moreover, pensioners generally reported low levels  of education, with those over age 65 reporting less education than those  under age 65. More than half of veterans and spouses over age 65 reported  not having a high school diploma, compared with 22 percent of veterans  under age 65 and 44 percent of spouses under age 65. Over a third of  pensioners under age 65 reported having a high school diploma, and less  than 7 percent reported completion of a bachelor’s or higher degree.
section_title: The Average VA Pensioner Is 70 Years of Age and Has No Spouse or Dependents
paragraphs: The average age of VA pensioners is approximately 70, with approximately  60 percent over age 65 and less than 20 percent age 55 or younger.  Significant numbers are over age 75, as shown in figure 1. The average age  is highest for surviving spouses of deceased veterans, who constitute  approximately one-third of all pensioners. In 2006, their average age was  72, while that of veterans was 69. About three-quarters of all surviving  spouses are over age 65, compared to just over half of all veterans. Less  than 2 percent of all pensioners are younger than age 45.
Most VA pensioners have no spouse or dependent children, according to  information the pensioners provided to VA in 2006. As shown in figure 2,  about 82 percent of pensioners receive benefits for themselves alone, and  most of the remaining 18 percent are veterans living with dependents.  Proportionately few pensioners have dependent children eligible for  pension benefits: About 22,000 of the half-million pensioners receive VA  payments for support of their children, in most cases for one or two  children.
section_title: The Majority of Veteran Pensioners Have Multiple Impairments, and About One-Third of All Pensioners Require Assistance to Perform Daily Activities
paragraphs: Most veteran pensioners have multiple disabling conditions, with  approximately 95 percent reporting at least one impairment and nearly 75  percent reporting two or more impairments. As shown in figure 3,  excluding those impairments classified as “other,” musculoskeletal  conditions were the most common type of impairment among veteran  pensioners. For veterans under age 65, the next most common type of  impairment was mental, while for veterans age 65 and older it was  cardiovascular.
Many pensioners require aid and attendance in their activities of daily  living, such as dressing and feeding themselves. According to VA, slightly  less than one-third of pensioners are housebound or in need of aid and  attendance, and most of these pensioners are age 65 and older. While  more than 40 percent of pensioners age 65 and over require aid and  attendance, less than 15 percent of younger pensioners do. Only a small  number of pensioners reside in a nursing home—less than one-half of 1  percent of pensioners under age 65 and 3 percent of pensioners age 65 and  over.
In a 2002 VA study, about 95 percent of veterans and 87 percent of  surviving spouses reported having some form of health insurance.  Medicare was a source of coverage for 50 percent of veterans and 69  percent of surviving spouses. Over half of veterans also reported health  care coverage through VA or military hospitals. Less than 15 percent of  veterans relied on Medicaid for their health insurance and less than 15  percent of veterans had private health insurance. By contrast, 47 percent  of surviving spouses relied on Medicaid, making it the second most  common source of coverage after Medicare, while 18 percent reported  having private insurance.
section_title: The Size of the Pensioner Population Has Decreased
paragraphs: As shown in table 2, the total number of pensioners has been decreasing in  recent years, although the number of pensioners from more recent service  periods has been increasing. In 2006, the three pension programs served  about 535,000 veterans and survivors, a 75 percent decrease from 1978,  when participation peaked at almost 2 million. VA attributes the overall  reduction in numbers largely to the death of World War II era pensioners  and the greater availability of Social Security retirement benefits, which  often raise veterans’ incomes above the VA pension program’s eligibility  levels.
While total program enrollment has declined, the Vietnam era and Gulf  War cohorts of pensioners have increased in number in recent years, as  shown in table 3. VA expects the Vietnam era cohort to continue to  increase in number as more Vietnam era veterans meet the 65-year age  requirement for pension eligibility. An estimated 5.2 million of these  veterans will be age 65 or older in the year 2015. However, VA has no  estimate of how many also will have qualifying wartime service, meet  income requirements, and submit pension claims. Further, the number of  Gulf War veterans receiving pensions increased by nearly 300 percent  between 2000 and 2006, although they are still less than 5,400 in number.  Even with increases in these two cohorts, VA estimates that the total  pensioner population will continue to decline in size through at least 2017.
The main reason for caseload termination is death, followed by increased  income, as shown in figure 4. In January 2007, about 70 percent of veteran  pension cases and 50 percent of surviving spouse cases were terminated  as a result of the death of the pensioner. Increased income was the reason  for termination in about a fifth of veteran cases and in about two-fifths of  surviving spouse cases. For surviving children, however, about two-thirds  of the cases were terminated due to the child’s age, and one in five was  because of a death.
section_title: For Initial Pension Claims, VA Policies and Procedures Do Not Always Ensure Well-Supported Decisions
paragraphs: VA policies and procedures are not sufficient to ensure sound decisions on  new pension claims. Unlike other federal agencies with similar income- based programs, VA largely does not independently verify the accuracy of  financial information provided by claimants to support initial pension  program eligibility, a fact that makes the pension program vulnerable to  improper payments. In addition, the guidance used by staff to make  pension eligibility decisions, which is under revision and dispersed across  several sources, is not always current or clear. Further, VA’s quality  assurance review process for initial claims does not select a sufficient  number of pension cases to examine to ensure the accuracy of pension  decisions. Finally, VA does not adequately evaluate pension training. For  example, VA does not systematically collect feedback from participants at  the end of a training course.
subsections: section_title: VA Does Not Verify All Financial Information Provided by Applicants
paragraphs: VA does not require new pension applicants to submit documents that  would support their declarations of income and assets. While the agency  does corroborate their reported Social Security income with SSA records,  it does not require claimants to submit evidence for other financial  resources, such as by asking for copies of bank statements or tax returns.  Furthermore, until recently, there was no legislative authority for VA to  arrange for the cross-checking of claimants’ statements of non-Social  Security income against the Department of Health and Human Service’s  (HHS) National Directory of New Hires (NDNH). The NDNH includes  quarterly wage data for up to eight quarters, which can be compiled into  annual data for matching purposes.  HHS conducts matches using the  NDNH for other agencies—such as SSA, IRS, and the Department of  Housing and Urban Development to assist them in improving their  enforcement efforts.  The Dr. James Allen Veteran Vision Equity Act of  2007, which became effective December 26, 2007, requires VA to provide  applicant information to HHS and requires HHS to match it against the  NDNH and disclose to VA information for verifying applicant employment  and income.
Furthermore, while VA allows income deductions for certain  unreimbursed medical expenses, the agency does not always require  documentation for these expenses. For example, VA requires  documentation for the costs of nursing home care, but not for the cost of  prescription drugs. In contrast, VA does require applicants to verify some  nonfinancial information, such as by submitting an official notice of  military separation or marriage and divorce records.
section_title: Guidance Used by Staff Is Poorly Organized and Not Necessarily Current or Clear
paragraphs: We found that staff in the regional offices we visited used guidance that  was not compiled in a single source; not always current; and, according to  those we spoke with, unclear. This may be, in part, because VA has been in  the process, since 2001, of revising various sections of its compensation  and pension manual to help clarify complex regulations. However, staff  told us that while the revisions are taking place, they must check a variety  of sources for updates, including e-mails and posted memos, to be certain  they have the most current version for a specific procedure. Staff also said  the piecemeal and dispersed nature of the guidance can lead to different  interpretations for pension eligibility decisions. VA expects to have most  of the revisions implemented by 2009. Finally, staff also expressed a  concern over the clarity of some pension guidance, which they said both  leaves too much room for interpretation and can result in inconsistent  decisions on eligibility. For example, some said they must interpret  ambiguous guidance when determining how to treat claimants in assisted  living centers versus nursing homes, and that it is possible for staff to  reach different conclusions about a claimant’s eligibility or proper benefit.  They told us that when faced with unclear guidance, staff are expected to  use their own discretion in interpreting the guidance, along with the  advice of supervisory staff, which they believe can vary.
section_title: VA Has a Limited Approach to Evaluating the Quality of Initial Pension Decisions
paragraphs: The internal controls VA employs to evaluate the quality of initial pension  decisions are insufficient because VA reviews only a very small random  sample of initial claims that are selected from compensation and pension  cases. Since pension claims constitute only about 11 percent of the  combined compensation and pension caseload, few are likely to be  included in the quality assurance review sample. Although VA reported  about a 12 percent error rate for compensation and pension claims  combined, a recent VA Inspector General (IG) study found a higher  incidence of errors in some cases that subsequently required pension  payment adjustments. Specifically, the IG reported that VA procedures did  not ensure that the benefits of veterans hospitalized for more than 90 days  were appropriately adjusted.
section_title: VA Does Not Adequately Evaluate the Training for Pension Staff
paragraphs: VA’s training program does not include a comprehensive evaluation to  ensure its effectiveness. Although we have found that evaluation is  essential to performance, VA does not systematically collect feedback  from participants at the end of a training course. For example, new staff  receiving training at VA’s training center in Baltimore are required to  submit their evaluation of the training. By comparison, staff receiving  training in the use of an electronic Web tool are not required to evaluate  the training.
When we discussed VA’s limited evaluation of training with headquarters  officials, they noted that the agency has made assessments of new training  materials before they are put into place. However, VA has not consistently  evaluated all training courses offered at the regional offices. Many staffers  told us that some of their training is repetitive or does not include updates  and revisions in procedures.
section_title: For Ongoing Pension Cases, VA Procedures and Controls Do Not Adequately Ensure That Benefits Are Proper
paragraphs: VA procedures for assessing whether pensioners continue to receive the  proper benefits have significant limitations because VA does not require  pensioners to submit financial documentation, conducts untimely and  inefficient verification of pensioners’ incomes and assets, and lacks a  system for identifying and reducing improper pension benefits. Although  the agency requires all pensioners to submit documentation for  nonfinancial changes, such as for marriages or deaths, it does not require  documentation such as bank or asset statements when pensioners report  financial changes. Also, while the agency does verify certain pensioner  information by comparing it with data from other federal agencies, we  found that a key procedure using SSA and IRS data is not conducted in a  timely or efficient manner. Finally, despite millions of dollars in improper  payments made each year, VA does not collect sufficient data on causes of  improper payments that could be used to help it better manage the  pension program.
subsections: section_title: VA Has a Limited Approach to Verifying Financial Information Reported by Pensioners
paragraphs: Although VA requires all pensioners to report changes that might affect  their payments or eligibility, it does not require them to submit  documentation to corroborate changes in financial circumstances.  Whereas VA does require pensioners to submit documents for such  changes in circumstances as marriage or spousal deaths, it does not do so  for reported changes in income or assets. This leaves the agency heavily  dependent on the pensioner for self-reporting financial updates. The  exception is Social Security income, which VA staff verify using a direct  computer link to SSA benefit data. Pensioner reports of other financial  changes, however, need not be accompanied by such documents as pay  stubs, bank statements, or tax returns. This is in contrast to other income- based federal programs that typically ask for verification of key financial  information. For example, SSA requires Supplemental Security Insurance  (SSI) recipients to document their earnings on a regular basis.
Similarly, VA does not ask pensioners for financial documentation when  completing the annual Eligibility Verification Report (EVR), the requested  update that the agency sends out annually to those who have previously  reported having income and assets other than their pensions and Social  Security benefits. VA uses information collected from the EVR responses  to adjust or, if necessary, terminate VA pension benefits. (See table 4 for  an overview of the EVR steps.) VA has indicated that the pension program  is prone to overpayments caused by pensioners failing to report income  changes as they occur. One agency official responsible for the  management of the EVR process told us that the EVR process provides the  agency an opportunity to adjust the pension benefits as pensioner status  changes, thus preventing higher overpayments.
In addition to VA not asking respondents to submit financial  documentation, we found a number of other deficiencies in the EVR  process that may likely limit VA’s ability to make timely and accurate  adjustments to benefits. First, the EVR process only queries pensioners  who have previously reported income to VA, so the agency fails to reach  pensioners who may acquire new sources of income, such as earnings  from new employment. Second, during the annual review of EVRs, VA  does not attempt to corroborate via independent third-party sources any  information that pensioners report on the EVR beyond SSA benefits.  Third, the EVR asks pensioners to estimate their income for the year, and  the agency adjusts their pensions based on these estimates. Yet pensioner  estimates could prove to be incorrect. For example, income estimates for  the coming year could change due to the death of a spouse. Fourth, the  narrow seasonal window within which pension maintenance center (PMC)  staff attempt to review and process the EVRs—the first 3 months of the  year—postpones other pension-related activities, including data  comparisons with other federal agencies that could provide third-party  verification. This limited approach to verification of pensioner-provided  updates puts the program at risk of issuing improper payments based on  pensioners’ reports.
section_title: VA’s Key Data Match Procedure Is Not Timely or Efficient in Detecting Improper Payments
paragraphs: In addition to deficiencies in the EVR process, VA’s ability to detect  improper payments is hindered by untimely processing of a key data  match. Through formal agreements, VA compares its electronic data on  pensioners’ reported income, and other eligibility information, to similar  information from a number of federal agencies, as shown in table 5. VA  identifies discrepancies and, after due process, uses this information to  adjust or terminate pension benefits. VA projects that its data-matching  activities save the pension program millions of dollars annually.
Nevertheless, VA’s key data match, the Income Verification Match  program (IVM), which uses SSA and IRS data to detect pensioners who  have failed to report earned or unearned income, is running far behind  schedule. This match is scheduled to occur on an annual basis. However,  since 2006, VA has attempted to become current by conducting 2 years’  worth of IVM data matches simultaneously. Yet combining data match  records for multiple years has added to the complexity and the length of  case evaluations, according to officials we interviewed.
VA estimates that the IVM data match has the potential of saving the  program over $10 million each year, which suggests that a delay of 2 years  could delay saving as much as $25 million dollars in payment errors. Such  errors include both underpayments, which require VA staff to make  retroactive payments or benefit adjustments, and overpayments, which  can be burdensome for VA to recover from such a low-income population  of pensioners and which threaten the financial stability of pensioners.  While VA officials told us they plan to have all IVM data match cases  entered into their system by the end of 2007, they could not provide  assurance that these cases will be completed in the same year.
The effectiveness of the IVM is also undermined by the fact that the data  used are not current. VA uses income data that are about 2 years old,  despite the fact that the SSA data are available earlier and that more  recent earned income data are available from another federal database,  the NDNH. Moreover, while VA could make use of SSA earned income  data as early as September following the end of the tax year, it postpones  the match of pension benefits and waits for unearned income from IRS so  that it can simultaneously evaluate eligibility for pension and Individual  Unemployability (IU) benefits. We determined that the combination of  old earned income data, along with the delays noted above, means that  individuals with unreported earned income could continue to receive  benefits for at least 2 years before VA can determine that their pension  benefits should be adjusted or terminated.
We also found that VA’s handling of the IVM data match results is  inefficient because the dollar threshold used to select pensioners for  review of ongoing pension eligibility has not kept pace over nearly two  decades with wages necessary for a person to sustain a living. Specifically,  the IVM data match threshold in use until December 2006—which VA told  us was meant to represent wages for marginal employment—was set in  1988 (when VA’s maximum annual pension rate for a veteran with no  dependents was $6,463). Yet between 1988 and 2006, the U.S. Census  Bureau’s poverty threshold had increased over 70 percent. As a result of  VA’s continued reliance upon the 1988 threshold, PMC staff told us that  they manually reviewed many more cases than necessary in order to find  and delete those cases that did not warrant a review. In fact, staff typically  eliminated about one-third of the initial matches because their combined  countable income and pension did not exceed their maximum allowable  pension benefit. VA increased the $6,000 threshold to $9,383 in December  2006, but has not decided whether it would make such changes to update  the threshold on a regular basis in the future.
The timeliness of the IVM process is also hampered by the fact that VA’s  match records are paper based and lack the organizing and transmission  efficiencies of an electronic database. Therefore, VA’s follow-up work is  slowed by the need to ship boxes of uncollated paper records— worksheets, correspondence with pensioners and employers, and related  documents—from the Hines center to the PMCs for manual assembly and  analysis. Although software exists to transfer the confidential information  electronically, VA officials said the need to comply with IRS’s specific  security measures for income-related data has precluded VA’s use of it.  However, we have noted in prior work that electronic software exists to  transfer confidential information securely.
section_title: VA Conducts No Analysis of the Causes of Improper Pension Payments
paragraphs: Many millions of dollars in improper payments accrue each year before  they are discovered and corrected, but VA has not taken steps to identify  the causes of these improper payments. According to VA estimates, about  8.4 to 11 percent of pension program payments were made in error each  year between 2003 and 2006, with most of these being overpayments, as  shown in table 6. Specifically, VA estimated a total of almost $1.2 billion in  overpayments and about $44 million in underpayments during this period.  Such payment errors, particularly underpayments, can have a negative  impact on pensioners living on very low incomes. By contrast, the agency  has estimated that only about 1 percent of disability compensation  program payments were made in error, with about $730 million in  overpayments and $375 million in underpayments for the same period.
Furthermore, according to VA officials, less than 30 percent of the  overpayments for compensation and pension are recovered.  We found  that VA has not been successful in collecting overpayments. In fact, a  significant portion of overpayments are written off because of pensioners’  death or bankruptcy, or because the overpayment is considered  uncollectible. For example, in cases where VA’s Committee on Waivers  concludes that repayment of the overpayment debt would cause undue  financial hardship for the pensioner, the debt may be waived. Most of the  remaining overpayments remain on VA’s financial account for up to 10  years, at which time VA discontinues its collection efforts.
Despite VA’s estimates of relatively high amounts in improper payments  for the pension program, the agency lacks a process for determining the  nature and actual extent of payment errors. For example, VA currently  does not have the ability to identify the dollar amount of overpayments  generated because of a failure to report income, gambling winnings, or  death of a spouse. Likewise, VA cannot identify the amount of improper  payments caused by administrative factors, such as those associated with  VA delays in conducting the IVM data matches. Although the agency has  identified several causes for improper payments, such as inaccurate  reporting of Social Security benefits, remarriage of surviving spouse, or  change in dependents, it has not developed a system to assess the degree  to which they occur, and therefore cannot develop strategies to target  problems and take steps to correct them.
section_title: Conclusions
paragraphs: VA’s pension eligibility operations currently provide a limited return on  investment when it comes to making appropriate payments. The agency’s  financial verification processes are heavily weighted toward detection of  payment errors late in the process rather than up-front prevention of  errors. By not requiring supporting financial documentation from  individuals at the time of application, and relying much later in the process  on untimely data matching for this information, VA increases the  likelihood of making improper payments. Additionally, VA concentrates  staff resources in the first 3 months of each year on a process for updating  eligibility that is time-consuming and still lacks for financial  documentation or independent verifications. Meanwhile, the data- matching operations that do offer third-party verifications on financial  status are delayed until after the EVR process is completed. A key data  match procedure, the IVM, has been delayed in the past, and the agency  continues to be at risk of making improper payments as it tries to rectify  the situation. Even when the IVM data match becomes current, VA’s ability  to use it in a timely way will be limited if processing of the information  remains grounded in a manual handling of paper documents. Moreover, if  VA does not regularly update its IVM data match threshold in its incoming  financial information system, the agency will continue to have an  inefficient procedure for selecting cases for IVM review.
In view of the fact that the program incurs a proportionately high level of  improper payments—about 8.4 to 11 percent of annual program benefits— VA’s investment in the prevention of errors seems too modest. VA could  readily justify increasing its investment in the error prevention process.  The agency does not have a quality assurance process robust enough to  ensure with a high degree of confidence the accuracy of decisions made in  initial pension cases, it has not developed a consistently rigorous approach  to the evaluation of training, and it does little to identify and analyze the  causes of improper payments.
Taken together, VA forfeits the opportunity to address administrative  weaknesses and prevent payment errors. Unless these weaknesses are  addressed, VA pension benefit payments will remain vulnerable to a  relatively high rate of errors. Reconciling improper payments draws  resources from the agency that could be better utilized elsewhere, and to  the extent overpayments are never collected, they undermine the agency’s  financial stewardship over public funds. Moreover, underpayments can  lead to hardships among this low-income segment of the veteran  population. Certainly, the program is not too small to ensure that  appropriate levels of assistance are provided to a vulnerable and deserving  population. This can and should be done with a level of efficiency that  minimally burdens all concerned.
section_title: Recommendations for Executive Action
paragraphs: In order to enhance VA’s management of the pension eligibility process,  we recommend that the Secretary of Veterans Affairs direct the Under  Secretary for Benefits take the following actions.  1.  Take steps to make more accurate and timely decisions about  initial and ongoing pension eligibility and payment levels. Such  actions might include requiring pensioners to submit supporting  documentation of their income and assets, conducting a more  robust independent verification with third parties, or maximizing  process automation.  2.  Take steps to improve its quality assurance review of initial claims,  which could include reviewing a larger sample of pension claims.  3.  Incorporate evaluative feedback more consistently into the  planning, design, and implementation of its training efforts.  4.  Evaluate options for improving the effectiveness of its annual  eligibility verification review. This effort could involve  reformulating the EVR process by (a) surveying every pensioner  rather than a selected subset; (b) performing reviews on a rolling  basis, such as on an individual’s anniversary date, rather than  diverting staff for this activity for a 3-month period; (c) reviewing  pensioners’ eligibility once every few years rather than every year;  or (d) focusing on verifying pensioners’ income and assets.  5.  Update the IVM data match threshold level to be in line with the  U.S. Census Bureau poverty threshold or a comparable measure.  6.  Evaluate the causes of improper payments and use the results to  develop and implement an action plan to prevent them from  occurring.
section_title: Agency Comments and GAO Response
paragraphs: We provided a draft of this report to the Secretary of Veterans Affairs for  review and comment.  In its written comments on a draft of this report  (see app. III), VA agreed in part or fully with our recommendations.   Although VA raised concern with some of the options we present to help  implement several of the recommendations, the agency’s comments  indicate it will take steps to implement these recommendations.
Regarding our recommendation that VA should take steps to make more  accurate and timely pension eligibility and payment decisions, the agency  agreed in part but took exception with several of the actions we suggested.   VA noted that requiring pensioners to provide documentation of income  and net worth could be onerous to individuals and possibly diminish the  timeliness of initial pension eligibility decisions.  However, VA also stated  elsewhere in its comments that pensioners use the end-of-year tax  statements (Form 1099) to accurately report income from all sources.   This indicates that it may not be an added burden to pensioners to include  a Form 1099 in their initial claim.  But to the extent that burden is added to  preparing the initial application, the possible gains in accuracy and  avoidance of corrective actions later taken to address improper payments  need to be considered. Additionally, VA cited its data-matching process  with SSA as an existing mechanism to independently verify income.   However, as we point out in this report, other federal agencies with similar  income-based programs independently verify self-reported information to  support initial eligibility decisions.  By verifying claims up front, rather  than years after the claim is established, the agency can effectively save  the program millions of dollars that it might never recover otherwise.   Moreover, VA does not always require documentation of unreimbursed  medical expenses, which can be deducted from income for pension  eligibility. It is important for VA to gather supporting documentation in  this area as well. The agency may consider piloting the feasibility of  requiring additional documentation of key financial information.
Regarding our recommendation that VA take steps to improve its quality  assurance review of initial claims, which could include reviewing a larger  sample of pension claims, the agency agreed with this recommendation  and indicated it will double the entire rating sample size in 2008.  While we  commend VA’s effort to increase the overall number of claims reviewed in  its quality assurance review of rating-related decisions, we remain  concerned that this approach will not ensure that enough initial pension  claims are reviewed for quality assurance. As we point out in this report,  VA samples 10 claims from most regional offices’ caseload of  compensation and initial pension claims. Given that initial pension claims  constitute about 11 percent of the caseload, a regional office, on average,  would likely have only 1 pension claim selected for review. Doubling the  sample size would increase the expected number of claims to 2, which we  believe is too few. Alternatively, VA might consider increasing the number  of pension claims in the overall sample, such as weighing the sample size  to include more pension claims or conducting stand-alone reviews of  pension claims.
The agency agreed with our recommendation to incorporate evaluative  feedback more consistently into the planning, design, and implementation  of its training efforts.
The agency agreed with our recommendation that VA evaluate options for  improving the effectiveness of its annual eligibility verification review.   The agency stated there are inconsistencies between the possibilities we  present, though it did not elaborate.  Our intent in presenting these options  is to stimulate actions that VA may take to improve the effectiveness of the  EVR process. The agency discussed issues—such as veterans’ ease in  providing corroborating information—that need to be considered as it  moves forward.
The agency agreed with our recommendation that it update the IVM data  match threshold level to be in line with the U. S. Census Bureau poverty  threshold or a comparable measure.
The agency agreed with our recommendation that it evaluate the causes of  improper payments and use the results to develop and implement an  action plan to prevent them from occurring.
In the version of the draft report sent to VA for review, we recommended  that VA seek legislative authority to use the NDNH in its enforcement  efforts.  However, we have withdrawn this draft recommendation because  VA has been mandated to use this database effective December 2007.  In  its comments on this draft recommendation, VA indicated that it has  initiated the process necessary to gain access to the NDNH earnings  database. Given this development, we encourage VA to act swiftly to  position itself to fully utilize the NDNH in a timely manner.
We will send copies of this report to the Secretary of Veterans Affairs,  appropriate congressional committees, and other interested parties. The  report will also be available at no charge on GAO’s Web site at  http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-7215 or bertonid@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Other contacts and staff acknowledgments are listed in  appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The Senate Veterans’ Affairs Committee asked GAO to (1) determine the  characteristics and trends in size of the pensioner population, (2) assess  the policies and procedures the Department of Veterans Affairs (VA) has  in place to ensure that initial pension eligibility decisions are well  managed, and (3) assess the procedures VA has in place to ensure that  pensioners continue to receive the proper benefit payments.
To determine the characteristics and size of the pensioner population, we  analyzed data from VA’s Benefit Delivery Network (BDN), VA budget  reports, and other reports through fiscal year 2006. To address our  remaining objectives, we reviewed relevant laws, guidance, procedures,  and internal controls that VA uses to ensure the soundness of pension  benefit decisions. We also analyzed VA’s internal control policies and  performance reports. We visited 4 of VA’s 57 regional offices, located in  Boston, Milwaukee, Providence, and St. Paul. We selected these sites  based on variations in size and geographic locations. We also visited VA’s  three pension maintenance centers (PMC), located in Philadelphia,  Milwaukee, and St. Paul, and the Debt Management Center in St. Paul. We  interviewed VA officials and staff at these sites as well as officials at VA  Central Office in Washington, D.C. We also conducted case file reviews in  three locations—Milwaukee, Providence, and St. Paul—to verify the  adequacy of documentation in support of initial pension decisions. We  conducted our review from November 2006 to February 2008, in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
subsections: section_title: Analysis of Pensioners’ Characteristics
paragraphs: To analyze the characteristics of pensioners, we extracted data on basic  characteristics and enrollment trends from VA’s Benefit Delivery Network  and routine annual VA budget submissions. We supplemented our analysis  with additional data from a study contracted by VA and conducted by ORC  Macro.
VA maintains data on pensioners in its Benefits Delivery Network at the  Hines Information Technology Center in Illinois. Hines issues routine  reports to various units in VA, including budget and policy, for use in  program management. Most of these reports provide characteristics for  two or three factors, for example, for veterans by age grouping and by  state of residence. We based our analysis on year-end reports through  fiscal year 2006.
To obtain data not available from published VA reports, we analyzed  additional BDN data as of September 2006. VA regularly provides GAO  with two sources of BDN data. The first provides data on a few  characteristics of the entire universe of pensioners. The other provides  data on a broader range of characteristics for a random sample of 5  percent of all pensioners. We used data from the entire universe of cases  when they were available and supplemented our analysis with additional  data from the random sample. When reporting data from the 5 percent  sample, we report confidence intervals around point estimates.
subsections: section_title: Budget Data
paragraphs: We also analyzed data extracted from tables in the fiscal year 2002 through  2008 budget submissions.
section_title: ORC Macro Study Data
paragraphs: In 2002, VA contracted with ORC Macro to survey a sample of pensioners  that included veterans and surviving spouses. For more detailed data not  available from VA’s BDN, we used data reported in the ORC Macro report.  However, data are not generalizable to current pensioners because of the  time frame when the survey was conducted. The ORC Macro study was a  telephone-administered survey. The survey sample generally mirrored the  pensioner population at the time. However, for the sample of veterans,  nursing home residents were underrepresented. In addition, the spouse  sample and spouse recently enrolling sample underrepresented spouses  receiving aid or attendance services. In all three cases, ORC Macro  conducted a sensitivity analysis to find out whether these  underrepresented groups would have changed key question response  frequencies if they were correctly represented. In each of the three cases,  ORC found they would not significantly change response frequencies.
GAO’s applied research and methods group evaluated the BDN and ORC  Macro survey data and found the information to be sufficiently reliable for  our purposes.
section_title: Case File Review
paragraphs: To verify the adequacy of documentation in support of initial pension  decisions, we reviewed case files on a random sample of Improved  Pension claims and Death Pension claims that had been completed by  three VA regional offices, in Milwaukee, St. Paul, and Providence. We  chose Milwaukee and St. Paul because they were associated with a PMC.
Because the Milwaukee site processes new claims in both the regional  office and the PMC, we included files that originated at both locations in  our review. Additionally, because the St. Paul office completed pension  cases that had been transferred from another regional office, we included  those cases in our review. We chose the Providence regional office  because it was not associated with a PMC and because of its geographic  location.
At the three sites we reviewed a total of 72 case files for completed initial  pension claims. In order to select case files to review, VA provided a list of  all initial (or original) claims for Improved Pension (for veterans) and  Death Pension (for survivors) considered and determined between  February 1, 2007, and February 28, 2007. To select from this list, which  included both approved and denied cases, we used random number  assignment procedures to help ensure a broad range of these types of  cases were included in our sample. Specifically, at St. Paul, we used a  randomized ordering process to select and review 32 case files. On  subsequent site visits, we randomized all EP 180 and EP 190 claims and  reviewed the first available 14 EP 180 and 6 EP 190 case files. In some  instances, case files we selected were unavailable because they were being  reviewed at the regional office or were categorized as pension claims but  over the course of VA developing the claim no longer met our selection  criteria of initial pension claims. We attempted to review a 2-to-1 ratio of  EP 180 to EP 190 cases, which is approximately the ratio that exists in the  pension claims population. The number of case files we reviewed at each  site is given in table 7.
To ensure consistency, we used a standardized checklist to examine case  files at each location, and the same individuals conducted the reviews at  all three sites. The checklist, which was developed by examining the  procedural guidance and case files at a regional office, included  information about each of the major eligibility criteria: military service,  disability, net worth, and income. In addition, we reviewed demographic  information about the claimants. We also looked for evidence that VA had  followed guidance on procedures, for example, whether letters were sent  to the claimant appropriately. At each of the sites we communicated with  VA office management when questions about the files we were reviewing  arose. In some cases these conversations helped us better understand why  a case had been handled in a particular way, while in other cases  management acknowledged that errors had been made.
The results of visits to the sample of regional offices are not generalizable  to all 57 regional offices; similarly, results of case file reviews are not  generalizable to all pension files. The testimonial evidence, such as that  gathered during interviews with staff, also is not generalizable.
section_title: Appendix II: Pension Eligibility Determination
subsections: section_title: Administrative Structure
paragraphs: VA’s Compensation and Pensions (C&P) Service administers the pension  program and oversees the operation of 57 regional offices and three  pension maintenance centers (PMC). The C&P central office has  responsibility for managing policy and procedures, guidance, quality  assurance, and general operations. The regional offices process initial  pension applications and determine eligibility. The offices have  jurisdiction in the geographic area where a veteran or survivor lives. At  least one regional office is located in every state except Wyoming, as well  as the District of Columbia, Puerto Rico, and the Philippines.
The PMCs are responsible for conducting annual reviews of eligibility and  adjusting benefit levels when a pensioner’s circumstances change. As part  of the annual review, staff at the PMCs examine annual reports from  pensioners, which contain information on, for example, income and  medical expenses. Staff also examine the results of a variety of  computerized data matches with other government agencies to determine  whether adjustments are warranted. Additionally, VA’s Hines Information  Technology Center handles all computer transactions that affect benefit  payment levels, and VA’s Debt Management Center is responsible for  collecting overpayments that occur.
section_title: Initial Eligibility Determinations for VA’s Improved Pension Program
paragraphs: To determine a veteran’s initial eligibility for the pension program, VA’s  regional office staff review several eligibility criteria, including the  veteran’s military status, age or disability, and income. For the surviving  spouses and children of such veterans, VA uses similar factors to  determine eligibility, as shown in figure 5. All survivors are subject to  income and asset limits, but only surviving children must meet disability or  age requirements.
To qualify for the pension program, veterans must meet one of four  military service criteria set out in statute, but in practice they have been  collapsed into a single requirement. The VA characterizes these criteria as  generally requiring that veterans have served on active duty in the military,  naval, or air forces for 90 days or more, with at least one of those days  being during a period of war, and been discharged under conditions other  than dishonorable. In addition, veterans who enlisted after September 7,  1980, generally must have served at least 24 months or the full period for  which called or ordered to active duty to qualify.
subsections: section_title: Disability or Age Requirement
paragraphs: Eligibility for pension benefits is restricted to veterans who are either  totally and permanently disabled due to circumstances unrelated to their  military service or to willful misconduct, or who are at least age 65.  Veterans under age 65 must be considered totally and permanently  disabled, which means that the veteran is unable to pursue substantially  gainful employment due to a disabling condition and that the condition is  reasonably certain to continue throughout the veteran’s life. Veterans who  receive Social Security disability benefits or long-term care in nursing  homes are presumed to be totally and permanently disabled.
section_title: Income and Asset Limits
paragraphs: In determining eligibility, VA considers the income of all family members,  including spouses and children, but excludes other individuals residing in  the household. Pensioners meet income eligibility requirements if their  family incomes are less than the maximum annual pension amounts  established annually by Congress. Various sources of income are  considered when determining eligibility, including employment, interest  and dividends, retirement, annuities, workers’ compensation, and Social  Security Disability Insurance benefits. Income from other federal or state  means-tested programs—such as Temporary Assistance to Needy  Families, food stamps, housing assistance, or Supplemental Security  Income—is not counted toward family income. Pensioners may deduct  unreimbursed medical expenses that exceed 5 percent of the maximum  annual pension amount from their income for the purposes of determining  eligibility.
VA does not apply specific limits on the net worth of assets when determining  eligibility for pensions. However, veterans will not be awarded a pension if VA  determines that they have sufficient assets to live on for a reasonable period  of time. To make this determination, VA guidance calls for net worth in  excess of $80,000 to be reviewed during the initial eligibility determination  process, taking into consideration such factors as the veteran’s life  expectancy and the convertibility of the assets into cash.
Net worth includes all personal property and real estate owned by  veterans and their families, excluding the value of their home and the land  on which their homes are located.
section_title: Survivor Eligibility
paragraphs: When a veteran with qualifying wartime service dies, his survivors may be  entitled to a pension. The veteran does not have to be receiving a pension  at the time of his death in order for his survivors to be eligible for benefits.  Survivors are not required to have a disability in order to qualify, but they  must meet income and asset requirements. For spouses, there is no age  requirement, but they lose eligibility if they remarry. Generally children  under age 18 are eligible, as are those under 23 who are in school. Older  unmarried children may also be eligible, but only if they are incapable of  self-support and if this incapacity occurred prior to their reaching age 18.
section_title: Ongoing Eligibility Determinations for VA’s Improved Pension Program
paragraphs: Once pensioners have been awarded benefits, VA makes ongoing eligibility  determinations and adjusts benefit levels as needed. Pensioners are  required to inform VA of any changes in entitlement factors that could  affect their eligibility or benefit levels as soon as they occur.  Hospitalization or incarceration, as well as changes in income, assets, or  marital status, can affect the continued eligibility of pensioners or result in  adjustments to the amount of payments that they receive. Any changes in  circumstances must be reported to VA in writing as soon as they occur,  and VA is required to make any necessary adjustments. To further assess  ongoing eligibility and benefit levels, VA also requires pensioners who  have any income other than Social Security to file an annual report with  VA. Then, VA evaluates the information in this report to determine if  pensioners continue to meet income eligibility requirements.
section_title: Appendix III: Comments from the Department of Veterans Affairs
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: The following individuals made important contributions to the report:  Brett Fallavollita, Assistant Director; Anna Kelley; Scott Purdy; Shannon  Diamant; as well as Susan Bernstein; Pat Elston; Lara Laufer; Wayne  Turowski; Walter Vance; Joan Vogel; and Craig Winslow.
section_title: Related GAO Products
paragraphs: Veterans Affairs: Continued Focus on Critical Success Factors Is  Essential to Achieving Information Technology Realignment.   GAO-07-844. Washington, D.C.: June 15, 2007.
Veterans Benefits Administration: Progress Made in Long-Term Effort  to Replace Benefits Payment System, but Challenges Persist. GAO-07-614.  Washington, D.C.: April 27, 2007.
Veterans’ Disability Benefits: Processing of Claims Continues to Present  Challenges. GAO-07-562T. Washington, D.C.: March 13, 2007.
Veterans’ Disability Benefits: VA Can Improve Its Procedures for  Obtaining Military Service Records. GAO-07-98. Washington, D.C.:  December 12, 2006.
Veterans’ Disability Benefits: VA Should Improve Its Management of  Individual Unemployability Benefits by Strengthening Criteria,  Guidance, and Procedures. GAO-06-309. Washington, D.C.: May 30, 2006.
Veterans’ Benefits: Further Changes in VBA’s Field Office Structure  Could Help Improve Disability Claims Processing. GAO-06-149.  Washington, D.C.: December 9, 2005.
Veterans’ Benefits: VA Needs Plan for Assessing Consistency of  Decisions. GAO-05-99. Washington, D.C.: November 19, 2004.
Veterans’ Benefits: More Transparency Needed to Improve Oversight of  VBA’s Compensation and Pension Staffing Levels. GAO-05-47.  Washington, D.C.: November 15, 2004.
Veterans’ Benefits: Improvements Needed in the Reporting and Use of  Data on the Accuracy of Disability Claims Decisions. GAO-03-1045.  Washington, D.C.: September 30, 2003.
Veterans Benefits Administration: Process for Preventing Improper  Payments to Deceased Veterans Can Be Improved. GAO-03-906.  Washington, D.C.: July 24, 2003.
Major Management Challenges and Program Risks: Department of  Veterans Affairs. GAO-03-110. Washington, D.C.: January 1, 2003.
Veterans’ Benefits: Claims Processing Timeliness Performance Measures  Could Be Improved. GAO-03-282. Washington, D.C.: December 19, 2002.
Veterans’ Benefits: Quality Assurance for Disability Claims and Appeals  Processing Can Be Further Improved. GAO-02-806. Washington, D.C.:  August 16, 2002.
Veterans’ Benefits: Despite Recent Improvements, Meeting Claims  Processing Goals Will Be Challenging. GAO-02-645T. Washington, D.C.:  April 26, 2002.