VA's Fiduciary Program: VA Plans to Improve Program Compliance and Policies, but Sustained Management Attention is Needed
Published: 2010-04-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Department of Veterans Affairs (VA) pays billions of dollars in compensation and pension benefits to disabled veterans and their dependents. For those beneficiaries who are unable to manage their own affairs, VA appoints a third party, called a fiduciary, to manage their VA funds. Congress, VA's Office of Inspector General (OIG) and GAO have noted that VA does not always have, or adhere to, effective policies for selecting and monitoring fiduciaries and therefore, does not fully safeguard the assets of beneficiaries in the Fiduciary Program. GAO was asked to discuss the Fiduciary Program and possible ways that it could be improved to better serve veterans, their families, and survivors. This statement is based on GAO's February 2010 report (GAO-10-241), which examined (1) VA policies and procedures for monitoring fiduciaries and safeguarding beneficiary assets and (2) challenges VA faces in improving program performance and oversight. To conduct that work, GAO reviewed program policies and relevant federal laws and regulations, analyzed a nationally representative random sample of case files, interviewed Central Office managers and staff, and conducted three site visits to Fiduciary Program offices, which accounted for 25 percent of program beneficiaries.
section_title: What GAO Found
paragraphs: Inconsistent staff compliance with some Fiduciary Program policies and weaknesses in others hinder VA's ability to effectively safeguard beneficiary assets; however, per GAO's recommendations, VA plans to take steps to improve the program. GAO found that VA did not always take required actions to monitor fiduciaries within established time frames or document in the beneficiary's case file that these actions were taken. Inconsistent staff compliance occurred in four areas: (1) initial visits to beneficiaries and fiduciaries, (2) follow-up visits to beneficiaries and fiduciaries, (3) follow up to obtain annual financial reports, and (4) oversight of surety bonds. For example, in about 18 percent of the cases GAO reviewed, VA was late in conducting required follow-up visits to monitor fiduciaries or did not provide sufficient documentation to show whether these visits were conducted. Similarly, while GAO estimated that about 39 percent of fiduciaries did not submit required annual financial reports on time, VA staff did not consistently follow-up with fiduciaries or failed to document actions that were taken. In addition to compliance issues, VA's policies for conducting on-site reviews of professional fiduciaries who manage funds for multiple beneficiaries do not ensure that these fiduciaries are effectively identified and monitored. For example, the agency's case management system uses the fiduciary's name - which may be entered inconsistently - to match them to beneficiaries, rather than requiring a unique identifier, such as a Social Security number. As a result, VA cannot always identify the fiduciaries that need to be reviewed. Moreover, VA does not have a nationwide quality review process to ensure that on-site reviews are conducted properly and consistently. Per GAO's February 2010 report recommendations, VA agreed to revise its Fiduciary program policies in an effort to enhance its oversight role, increase staff understanding and staff compliance, and better safeguard beneficiary assets. Two key challenges hinder VA's ability to improve Fiduciary Program performance and oversight, but VA has plans to address these challenges. First, managers and staff said that limitations with VA's electronic fiduciary case management system hinder their ability to capture key information. Per GAO's recommendation, VA has established a work group to evaluate alternative system modifications to meet the program's case management needs. Second, managers and staff indicated that training may not be sufficient to ensure that they have the expertise to properly carry out program responsibilities, as many of them had less than 2 years of program experience. In its response to GAO's recommendations, VA stated that it would begin providing additional standardized training for managers and staff this year. VA is also piloting a consolidated Fiduciary Program unit covering 14 VA regional offices to improve program performance and oversight. VA encountered a number of challenges during the pilot's implementation and has not yet evaluated it, but per our recommendation, plans to do so by September of this year.

section_title: Letter
paragraphs: I am pleased to have the opportunity to comment on how the Department  of Veterans Affairs (VA) Fiduciary Program can better protect vulnerable  veterans and their families. Each year, the VA pays billions of dollars in  compensation and pension benefits to disabled veterans and their  dependents. For those who are unable to manage their own affairs, VA  appoints a third party, called a fiduciary, to help manage and protect the  beneficiary’s funds. A fiduciary can be a spouse or other family member,  or an entity such as a law firm, hospital, or nursing home. In fiscal year  2008, fiduciaries provided services for more than 103,000 beneficiaries,  and managed nearly 4 percent of the $38.6 billion in compensation and  pension benefits VA paid out in that year. Moreover, the average annual  benefit amount for beneficiaries in this program was approximately  $14,400 in fiscal year 2008, which is about $4,200 more per year than the  average for all VA compensation and pension beneficiaries.
Over the years, both Congress and VA’s Office of Inspector General (OIG)  have expressed concern that VA’s Fiduciary Program is not fully  safeguarding beneficiaries’ assets. Areas of concern included delays in  conducting visits to select fiduciaries and insufficient monitoring of VA  fund usage by fiduciaries on behalf of beneficiaries. You asked us to  discuss such issues and possible ways that the Fiduciary Program could be  improved to better serve veterans, their families, and survivors. My  statement draws on our recent report which examined (1) VA policies and  procedures for monitoring fiduciaries and safeguarding beneficiary assets  and (2) challenges VA faces in improving program performance and  oversight.
Our work included reviewing program policies and relevant federal laws  and regulations, analyzing a nationally representative random sample of  205 case files and visiting three Fiduciary Program units located in VA  regional offices—St. Petersburg, Florida; Cleveland, Ohio; and Salt Lake  City, Utah—where we interviewed managers and staff about program  policies, procedures, and internal controls. These units accounted for 25  percent of the program’s beneficiaries. During these visits, we also  conducted file reviews of cases where either VA suspected that fiduciaries  were inappropriately using beneficiary funds or fiduciaries were seriously  late in submitting annual financial reports documenting how beneficiary  funds were spent. We also reviewed 12 VA on-site reviews which are  examinations of financial records of fiduciaries who oversee multiple  beneficiaries, whom we refer to as professional fiduciaries. Finally, we  interviewed Central Office officials and staff as well as Veterans’ Service  Organizations about the performance of the program. We conducted this  performance audit from December 2008 to February 2010, 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: Many individuals receiving monthly compensation and pension benefits  from the VA have mental impairments that can prevent them from  managing their finances. These conditions may result from injury, disease,  or infirmities of age. The VA Fiduciary Program matches beneficiaries who  are unable to manage their financial affairs with a fiduciary, giving  preference to spouses. If VA is unable to locate a qualified spouse who is  willing to serve in this capacity, an individual or other entity, such as a  lawyer or nursing home, will be appointed. VA appointed fiduciaries who  are not dependents or close family members can collect a fee for their  services (generally up to 4 percent of a beneficiary’s annual benefit  amount) and can oversee multiple beneficiaries. Whether a fiduciary is a  family member or a professional, the responsibilities are generally the  same and may include receiving the beneficiary’s VA benefits, paying the  beneficiary’s expenses, maintaining the beneficiary’s budget, and generally  seeing to the financial well-being—and, in some cases, the physical well- being—of the beneficiary. Finally, if a court has determined that a  beneficiary is unable to handle his or her own affairs and appoints its own  fiduciary, VA must assess the performance of that fiduciary to determine if  he or she is suitable for managing VA benefits given the needs and welfare  of the beneficiary. If VA decides to use the court-appointed fiduciary, the  agency generally defers to certain rules set by the court, such as those  pertaining to the fee amount that the fiduciary can charge for his or her  services.
Fiduciary Program policies and procedures are developed by Fiduciary  Program Central Office staff under the Office of Policy and Program  Management within the Veterans Benefits Administration (VBA).  Individual Fiduciary Program units are generally colocated in VA regional  offices that also oversee other VBA programs. One major exception to this  is the Western Area Fiduciary Hub, where Fiduciary Program units and  files from 14 western VA regional offices were merged into a single unit  colocated in the VA regional office in Salt Lake City, Utah, beginning in  January 2008.
section_title: Inconsistent Compliance with Some Policies and Weaknesses in Others Hinder VA’s Ability to Safeguard Beneficiary Assets
paragraphs: Our February 2010 report noted that VA Fiduciary Program staff did not  always take required actions within established time frames or document  in the case files that the required actions were taken. Below are four areas  where program staff did not always comply with program policies and, per  our recommendations, how VA plans to address them.
Initial Visits to Beneficiaries and Fiduciaries. VA policy states that  initial visits to appoint fiduciaries are to be conducted within 45 days of a  request for a fiduciary, and VA’s performance goal is to conduct at least 90  percent of these visits on time. Conducting timely initial visits is important  because beneficiaries cannot begin receiving VA benefits until they are  completed.
We sampled and reviewed 67 case files in which initial visits were  supposed to be conducted between July 1, 2006, and June 9, 2009, and  found that 37 visits were conducted within the 45-day time frame, and 10  were from 3 to 39 days late. For one case, the file lacked documentation  that an initial visit was made at all. Managers and staff in some offices we  visited said compliance with the timeliness policy for initial visits was  improving, but was still a concern. They attributed some compliance  issues to a continued lack of staff and resources.
Follow-Up Visits to Beneficiaries and Fiduciaries. Once the fiduciary  is selected, staff conduct periodic follow-up visits to re-evaluate the  beneficiary’s condition and to determine if funds have been properly used  and protected. The first routine follow-up visit generally takes place 1 year  after a fiduciary is selected, and subsequent visits typically take place  every 1 to 3 years thereafter. According to VA managers, it is VA’s policy  that follow-up visits to fiduciaries are to be conducted within 120 days of  the scheduled date, and the on-time goal for these visits is also 90 percent.  Timely follow-up visits are important to determine the continued  suitability of the fiduciary and to protect beneficiaries from potential  misuse of their funds.
Based on a nationwide sample of VA beneficiaries that had been assigned  a fiduciary, we estimated that approximately 61,000 adult beneficiaries  were supposed to have had at least one follow-up visit between July 1,  2006, and June 9, 2009. We estimated that 76 percent of these visits  occurred within the 120-day time frame. In about 18 percent of the cases,  however, VA did not conduct these required follow-up visits on time or  provided insufficient documentation to show whether these visits were  conducted at all. For the cases that were untimely (12 percent), they were  between 1 to 216 days late. In the most extreme example among the cases  with insufficient documentation to show whether visits were conducted (6  percent), the follow-up visit was overdue by 16 months. Similar to initial  visits, program managers and staff noted that compliance with the 120-day  time frame for follow-up visits can be challenging due in part to a lack of  staff and time. Program managers said that conducting visits in a timely  manner may be especially challenging in regional offices with only one or  two Fiduciary Program staff who may also have responsibilities outside of  the Fiduciary Program. In addition, managers and staff noted that  conducting timely visits can be challenging in areas where staff must drive  long distances to see beneficiaries and fiduciaries.
Annual Financial Reports. VA policy generally requires staff to obtain  yearly financial reports and bank statements from some fiduciaries to  determine how beneficiary funds were used. When fiduciaries do not  submit their financial reports on time, staff are required to follow-up with  them and document such actions in the beneficiaries’ files. Staff can  follow-up with letters, telephone calls, or face-to-face contacts. VA policy  requires staff to conduct the first of such follow-up actions when fiduciary  financial reports are 35 to 65 days late and again when they are 90 days  late. At that time, they may inform the fiduciary of the possible  repercussions of a failure to comply, which may include legal actions, a  referral to the OIG, or other actions. After 120 days, the financial reports  are considered “seriously delinquent,” and appropriate action is to be  taken. Failure to take aggressive action to secure timely financial reports  may result in a finding of negligence, which will require VA to re-issue any  misused benefits.
Based on our nationwide sample, we estimate that fiduciaries for about  33,000 beneficiaries were required to submit such reports between July 1,  2006, and June 9, 2009. Of these, 39 percent were submitted between 1   and 140 days late and 47 percent were submitted on time. In addition  our sample and site visit file reviews showed that follow-up contact was  frequently not done or not documented by program staff. Of the 30 case  files in our sample where financial reports were submitted more than 65  days late, 19 case files either lacked documentation of any follow-up  actions or showed that such actions were not taken within required time  frames.
Moreover, we found additional instances of inadequate staff follow-up on  seriously delinquent financial reports during file reviews conducted at the  three regional offices we visited. We reviewed 20 such cases, and found  only 1 where the initial follow-up contact was taken within the required 65  days. For the other 19 cases, contact was either between 3 days and 11  months late or there was not adequate documentation to determine if or  when such contact had occurred. In one case, a fiduciary’s financial report  was submitted more than 2 years later than the original due date, and only  after VA initiated action to suspend payment. In another case, a financial  report due in June 2006 was not submitted until nearly 2 years later. The  file did not indicate that any follow-up actions had occurred, although the  case is now being investigated for possible misuse of funds. Staff in all  regional offices we visited said that they sometimes did not take follow-up  actions or failed to document actions they did take, in part, because they  lacked the time or believed that some actions did not warrant  documentation.
Surety Bonds. VA generally requires staff to obtain a surety bond from  fiduciaries overseeing estates with a value of $20,000 or more that is  attributable to VA funds. A bond ensures that the beneficiary’s estate will  be reimbursed in the event of fiduciary mismanagement or abuse of  beneficiary funds. Our nationwide sample showed that program staff  sometimes failed to obtain proof that a fiduciary purchased a bond, when  required, or did not adequately document in the beneficiary case files that  the bond requirement was waived. Of the 52 case files in our sample for  which fiduciaries were required to purchase a bond, 8 case files lacked  adequate documentation to indicate whether a bond was purchased or  that the bond requirement was waived because the fiduciary met  conditions for an exception. Some of the 8 cases involved substantial  benefit amounts. For example, 2 cases which contained no documentation  that bonds were purchased had VA estate values of approximately $82,000  and $62,000—leaving these beneficiaries and VA vulnerable to a  substantial loss if funds were misused. Some staff in regional offices we  visited said that they were often uncertain about what types of bonds are  required for certain types of fiduciaries, and this was confirmed by our site  visit file reviews. For example, in one case, a Fiduciary Program staff  member was told by a fiduciary who was an attorney that an individual  bond was unnecessary because the fiduciary had a “blanket” bond that  covered all VA responsibilities. Although this staff member documented in  the case file that he was unsure if this was correct, he took the fiduciary’s  word that an additional bond was not required. However, we were told by  managers and staff that a blanket bond was most likely not acceptable in  this case, and the staff person should have required the fiduciary to obtain  an individual bond.
In regard to the above findings, we recommended that VA ensure that staff  understand and carry out policies regarding file documentation, follow-up  with fiduciaries for late financial reports, and bond acquisition. VA  concurred and, in its comments to our report, outlined several planned  actions. For example, VA stated that it would roll out additional training  for staff in March of this year and expects to hold a manager’s training  conference later in the year. The agency also intends to revise the  program’s policy manual this year to clarify existing guidance, establish  new policies and procedures, and enhance oversight of fiduciary activities.
In addition to compliance issues, we identified weaknesses in VA’s policy  for conducting periodic on-site reviews of professional fiduciaries who  manage funds for multiple beneficiaries. Cumulatively, such benefits can  be a substantial amount of money. On-site reviews examine the financial  records across all beneficiaries that a professional fiduciary manages to  detect discrepancies among accounts, which may not be detected by  examining annual financial reports for a single beneficiary. We found two  weaknesses associated with the on-site review policy VA developed.  First, while VA is required to conduct periodic on-site reviews for  professional fiduciaries who oversee more than 20 beneficiaries with  combined benefits totaling $50,000 or more, the agency can not ensure  that all fiduciaries who need these reviews are identified. To generate a list  of fiduciaries meeting these criteria, each Fiduciary Program unit uses  VA’s electronic case management system to link or match a fiduciary to all  of their beneficiaries. This computer match is based on a fiduciary’s name,  rather than a unique identifier, such as the fiduciary’s Social Security  number (SSN) or tax identification number (TIN). However, if fiduciary  names are entered inconsistently into the system, a fiduciary for which an  on-site review is required may not be identified. While VA’s case  management system includes a field for unique fiduciary identifiers, VA  policy does not require this information for all fiduciaries. Central Office  staff acknowledged that requiring a unique identifier would decrease VA’s  chances of making mistakes in identifying fiduciaries with multiple  beneficiaries who require reviews. In response to our recommendation, VA  plans to begin requiring that all fiduciaries supply unique identifiers (such  as SSNs or TINs) to better track fiduciaries who manage multiple  beneficiaries.
We also found that VA lacks a nationwide quality review process to ensure  that on-site reviews are conducted properly and consistently. While VA has  quality review processes to ensure that actions—such as conducting initial  visits and obtaining financial reports and bonds—are carried out in  accordance with VA policies, Central Office managers acknowledged that  VA lacks a similar process for on-site reviews.  Having such a process is  not only a key internal control, but it is also important for ensuring that  on-site reviews are conducted properly and consistently across all  Fiduciary Program units nationwide. Our examination of 12 files from the  three regional offices we visited revealed deficiencies in these exams  which could be detected through a national quality review process. Four  of the files we examined lacked key case selection information, preventing  managers from determining whether they were selected according to VA  policy—which states that cases associated with beneficiary complaints or  a history of late or questionable financial reports should receive priority.  In addition, although VA policy requires that at least 25 percent of a  fiduciary’s beneficiary case files (or up to 25 case files) be examined  during the on-site reviews, we found that this threshold was not met in  four instances. At the time of our review, Central Office staff tracked  whether on-site reviews were completed; but, not whether they were  conducted in accordance with policy. In response to our recommendation,  VA noted that they recently began reviewing all completed on-site reviews  to ensure that they conform to program policy and procedures.
section_title: System Limitations and Insufficient Training Hamper Program Performance and Oversight; However, VA Is Taking Steps That May Help
paragraphs: We identified two key challenges that limit VA’s ability to improve  Fiduciary Program performance and oversight. First, VA’s electronic  fiduciary case management system does not provide sufficient information  to managers and staff about their cases, and it is cumbersome to use.  Second, some managers and staff may not have received sufficient training  to ensure that they have the necessary expertise to effectively monitor  individual fiduciaries and oversee the program. VA is taking steps to build  expertise about the case management system and the program itself by  developing additional standardized training and piloting a consolidated  Fiduciary Program unit covering 14 western VA regional offices.
VA’s Electronic Fiduciary Case Management System. The Fiduciary  Beneficiary System (FBS), VA’s electronic fiduciary case management  system, does not provide sufficient data to effectively manage the  Fiduciary Program. Although it does provide some useful information on  individual case files, pending workloads, and program performance,  several system limitations hamper its ability to maintain accurate and  timely data and provide management with quality information about the  program.
FBS data fields are configured to track a fixed number of pending  activities, which can limit the accuracy and completeness of information  in the system. Staff and managers in the three regional offices we visited  said they often need to track more upcoming actions than FBS permits.  For example, staff noted that FBS accepts only one due date for upcoming  financial reports, even though multiple financial reports may be due  simultaneously if one or more is late. In such cases, the due date for the  most recent overdue report overrides the older due date, even if the older  financial report has not yet been submitted. To compensate for this FBS  limitation, staff may track pending actions manually outside of the system  or keep personal notes as reminder.
In addition, some managers find that FBS management reports are not  always easy to generate or helpful in overseeing the program. For  example, one manager told us that monitoring staff performance was  difficult because the system does not generate a single report that shows  all upcoming work that staff need to conduct over a certain period of time.  Instead, several reports need to be generated and cross-referenced, which  can be cumbersome. In addition, FBS does not store historical information  beyond 30 days which would allow managers to examine past issues with  fiduciaries or staff performance. For example, managers in two regional  offices said that in order to look at historical information on seriously  delinquent financial reports, they would have to manually examine  monthly paper printouts generated in prior months by FBS, which can be  time consuming. A 2007 internal VA report also stated that FBS requires  extensive knowledge to use, which inhibits effective oversight and  management at all levels of the program. Central Office managers  acknowledged the shortcomings of FBS and in response to our  recommendations said that they would create a work group to determine  the feasibility of enhancing FBS or developing a new case management  system.
VA’s Fiduciary Program Training. Managers and staff in all three  regional offices we visited said the Fiduciary Program is complex and  requires a great deal of specialized knowledge to effectively monitor  fiduciaries and provide program oversight. Although the Fiduciary  Program has a policy manual to guide staff in carrying out their  responsibilities, managers and staff said there are many nuances and  exceptions that take time to master, particularly since each fiduciary and  beneficiary situation may be different. In addition to these program  complexities, managers in all of the regional offices we visited said that  high staff turnover has contributed to a large number of inexperienced  managers and staff in their Fiduciary Program units who need training.
For example, in two of the three regional offices we visited, only about  one-third of staff (15 out of 47) had more than 2 years of experience in the  program. During our site visits we were told that limited training for  managers and staff may have contributed to various program problems,  including failures to properly monitor fiduciaries or document certain  actions in beneficiary case files.
VA has provided some training to ensure that Fiduciary Program managers  and staff are proficient in carrying out their responsibilities, and some  regional offices have developed their own training. VA provides a  standardized computer-based training program for new staff who conduct  visits to beneficiaries and fiduciaries and for those needing a refresher.  Central Office managers and staff also said that they hold monthly  teleconferences and conduct periodic visits to individual Fiduciary  Program units to discuss selected topics. In addition, managers and staff in  all three regional offices we visited said that they conduct their own  weekly or biweekly training sessions on selected topics, such as how to  determine whether bonds are required, and what kinds of situations  constitute misuse. However, they noted that individual training occurs  primarily on the job, and the effectiveness and consistency of such  training depends on the expertise of staff conducting the training. Central  Office managers acknowledged that standardized training would be  beneficial and stated that they are increasing training for managers and  staff beginning this year.
VA’s Consolidation of Western Fiduciary Program Units. From  January to September 2008, VA consolidated Fiduciary Program unit  managers, staff, and files from 14 western VA regional offices into a single  location in Salt Lake City, Utah—referred to as the Western Area Fiduciary  Hub—to improve program performance and oversight. VA officials expect  the hub to result in increased staff expertise, more consistent training,  better leveraging of staff resources, and increased program efficiencies.  For example, the hub created specific management positions for the  Fiduciary Program and divided staff into teams to focus on specific  actions and responsibilities in an effort to build program expertise,  including expertise with FBS. In addition, the hub provides opportunities  to train more staff at once, which could help to further build staff  expertise and potentially increase the consistency of training. The hub also  eliminated jurisdictional boundaries that prevented staff from conducting  visits that were geographically close, but outside of their assigned area of  responsibility, which VA expects will help balance workloads among staff  and reduce travel time. Additionally, the hub moved from a paper based to  an electronic case file system, called Virtual VA, in an attempt to more  efficiently transfer information between Salt Lake City hub staff and the  staff conducting visits in other offices.
While some VA managers and staff in the hub believe consolidation can  help improve Fiduciary Program performance, they described some  challenges that have impeded effective implementation of the pilot project.  The hub’s managers explained that there had been multiple changes in  management and that implementation began before appropriate planning  and resources were in place. For these reasons, hub managers did not  consider the hub to be fully functional until January 2009, which was  approximately 1 year after it opened. During our July 2009 visit to the hub,  managers and staff mentioned such unforeseen difficulties as: (1)  inconsistent access was granted into Virtual VA; (2) paper documents  were being scanned into the wrong electronic beneficiary case file and (3)  substantial amounts of time were being spent updating old cases that had  been improperly maintained by the previous Fiduciary Program units. For  some improperly maintained cases, staff had not taken required actions to  address seriously delinquent financial reporting and potential misuse of  funds had gone unidentified for significant periods of time. This required  hub staff to perform necessary follow-up actions, in addition to completing  incoming new work. Managers and staff noted that they have gained  valuable insight and knowledge in implementing the hub that could help  inform future office consolidations.
At the time of our review, the hub was still undergoing multiple changes  and had not yet been evaluated, thus it was unclear whether consolidation  of Fiduciary Program units has improved program performance and  oversight. In response to our recommendation that the Central Office  evaluate the performance of the hub, VA responded that it anticipates  completing such an evaluation by September 2010.
section_title: Conclusions
paragraphs: One of VA’s most vulnerable populations—beneficiaries who are unable to  manage their own financial affairs—rely on VA’s Fiduciary Program to  ensure that their benefits are safeguarded. To better serve beneficiaries  and protect their benefits, VA has taken or plans to take a number of  actions intended to increase staff understanding and compliance with  polices as well as enhance program oversight. Revising program policies  and procedures, increasing training, evaluating alternatives to the  program’s case management system, and evaluating the Western Area  Fiduciary Hub are important steps. However, in order for these actions to  successfully address the longstanding shortcomings we and others have  identified, VA management must pay sufficient attention to this program,  including exercising adequate oversight of its staff. Absent sustained  management guidance and staff compliance, beneficiaries may remain  vulnerable to the consequences of fiduciaries misusing their funds.
Mr. Chairman, this concludes my prepared statement. I would be pleased  to answer any questions that you or other Members of the Subcommittee  may have.
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