GAO-23-105730, Veterans Affairs: Projection, Use, and Oversight of COVID-19 Relief Funding

Issuer: Government Accountability Office
Document type: Report
Date: 2022-08-23

Source document: GAO-23-105730, Veterans Affairs: Projection, Use, and Oversight of COVID-19 Relief Funding of COVID-19 Relief Funding; document type: congressional-materials.

Full text

VETERANS AFFAIRS
Projection, Use, and
Oversight of COVID-
19 Relief Funding

Report to Congressional Committees
November 2022

GAO-23-105730

United States Government Accountability Office

Highlights of GAO-23-105730, a report to
congressional committees

November 2022
VETERANS AFFAIRS
Projection, Use, and Oversight of COVID-19 Relief
Funding
What GAO Found
The Department of Veterans Affairs (VA) received approximately $36.70 billion in
supplemental funding outside of its annual appropriation from three COVID-19
relief laws between 2020 and 2021: the CARES Act; the Families First
Coronavirus Response Act (FFCRA); and the American Rescue Plan Act of 2021
(ARPA). As of August 23, 2022, VA had obligated approximately 99 percent of its
funds from the CARES Act and FFCRA and 56.9 percent of funds from ARPA.
Department of Veterans Affairs’ (VA) COVID-19 Supplemental Funding and
Reported Obligations and Expenditures through August 2022

Note: An obligation is a definite commitment that creates a legal liability to pay and an expenditure is
the actual spending of money.

To determine the amount of COVID-19 supplemental funds to request from
Congress, VA relied on assumptions based on information from public health
sources and pre-pandemic data. As the pandemic progressed, VA transferred
CARES Act funds within the department to respond to changing circumstances
related to the pandemic. Further, it relied on data such as medical facilities’
caseloads during COVID-19 peaks to inform its request for ARPA funding.

VA used FFCRA and CARES Act funds to finance key areas such as community
care, information technology efforts, and education system modernization. It
continued to sustain these priorities with ARPA funds. VA is developing plans to
continue to finance key areas once the current funding sources are exhausted.

VA took actions to address challenges related to the projection, use, and
oversight of COVID-19 supplemental funds. For example:
•
VA requested and received congressional approval for greater flexibility in
the permitted use of funds to accommodate changing needs;
•
VA established a governance council to review proposed information
technology investments; and
•
to address confusion among VA staff, VA’s Office of Finance developed
guidance documents on the use of supplemental funds.
View GAO-23-105730. For more information,
contact Sharon M. Silas at (202) 512-7114 or
Silass@gao.gov.
Why GAO Did This Study
As of September 26, 2022, VA
reported 766,537 cumulative cases of
COVID-19 among veterans and 22,990
deaths. The CARES Act, FFCRA, and
ARPA included supplemental funds to
VA for COVID-19 relief, most of which
were for providing health care.
To provide oversight of VA’s spending
of this supplemental funding, Congress
passed, and the President signed into
law, the VA Transparency & Trust Act
of 2021. The Act included a provision
for GAO to review supplemental VA
funding for COVID-19. This report
describes 1) information used to
determine the amount of requested
COVID-19 supplemental funding; 2)
how VA used supplemental funds for
the pandemic; and 3) actions VA took
in response to challenges related to
the projection, use, and oversight of
COVID-19 supplemental funds.
GAO reviewed VA data on obligations,
expenditures, and spend plans for
COVID-19 supplemental funding, as
well as documentation on
supplemental funding processes, and
guidance on the use of these funds.
GAO interviewed VA officials including
officials from six Veterans Integrated
Services Networks to gain insights into
their roles in the projection, use, and
oversight of supplemental funding.
These six networks were selected
based on geographic diversity and a
range of funding levels.
VA reviewed a draft of this report and
provided technical comments, which
were incorporated as appropriate.

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
Letter
1
Background
6
VA Initially Determined COVID-19 Funding Needs Using Limited
Available Data, but Later Considered Additional Information
10
VA Used Supplemental Funds to Address Several Key Areas
15
VA Took Actions in Response to Projection, Use, and Oversight
Challenges
25
Agency Comments
28
Appendix I
VA COVID-19 Supplemental Funding from the CARES
Act and Families First Coronavirus Response Act (FFCRA)
30
Appendix II
VA COVID-19 Supplemental Funding from
the American Rescue Plan Act of 2021
33
Appendix III
GAO Contact and Staff Acknowledgments
36
Tables
Table 1: Department of Veterans Affairs (VA) Reported
Appropriations, Transfers, Net Appropriations,
Obligations, and Expenditures of Supplemental Funding
for CARES Act and FFCRA, as of August 23, 2022
31
Table 2. Department of Veterans Affairs (VA) Reported Net
Allocations, Obligations, and Expenditures of
Supplemental Funding Provided by the American Rescue
Plan Act as of August 23, 2022
33
Figures
Figure 1: Department of Veterans Affairs’ (VA) Process for
Requesting Supplemental Funds
6
Figure 2: Department of Veterans Affairs’ (VA) COVID-19
Supplemental Funding and Reported Obligations and
Expenditures through August 2022
7
Figure 3: Time Availability for CARES Act, FFCRA, and ARPA
Appropriations as of August, 2022
8
Contents

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
Figure 4: VA Allocations and Obligations by VA Component for
CARES Act Funding as of July 2022
16
Figure 5: VHA American Rescue Plan Act of 2021 Actual and
Planned Obligations by Areas Funded, Fiscal Years 2021
to 2023, as of July 2022
21
Figure 6: VBA American Rescue Plan Act of 2021 Actual and
Planned Obligations by Areas Funded, Fiscal Years 2021
to 2023, as of July 2022
24
Abbreviations
ARPA
American Rescue Plan Act of 2021
CFO
Chief Financial Officer
FFCRA
Families First Coronavirus Response Act
IT
information technology
OIT
Office of Information Technology
OMB
Office of Management and Budget
PPE
personal protective equipment
VA
Department of Veterans Affairs
VBA
Veterans Benefits Administration
VHA
Veterans Health Administration
VISN
Veterans Integrated Service Network
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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
441 G St. N.W.
Washington, DC 20548
November 29, 2022
The Honorable Jon Tester
Chairman
The Honorable Jerry Moran
Ranking Member
Committee on Veterans’ Affairs
United States Senate
The Honorable Mark Takano
Chairman
The Honorable Mike Bost
Ranking Member
Committee on Veterans’ Affairs
House of Representatives
The Department of Veterans Affairs (VA) operates one of the largest
health care systems in the United States. It is charged with providing
health care services to the nation’s eligible veterans and their
beneficiaries through the Veterans Health Administration (VHA). VHA, like
the U.S. health care system in general, has adapted its clinical operations
to respond to the COVID-19 pandemic. As of September 26, 2022, VA
reported 766,537 cumulative veteran cases of COVID-19 and 22,990
deaths from the disease.
In addition to health care services, VA provides other services and
benefits through its components.1 For example, the Veterans Benefits
Administration (VBA) provides compensation and pension, education, and
other benefits to veterans. Operations for some of these activities were
affected by COVID-19, such as medical exams required for certain benefit
programs. In addition, the Office of Information Technology (OIT)
provides information technology (IT) tools and services VA-wide. During
the pandemic, it assisted VA components with transitions to telehealth
and telework.

1For purposes of this report, we define a component to include both department-wide
offices, such as the Office of Information Technology (OIT), and the administrations that
implement benefit programs.
Letter

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
To respond to the COVID-19 pandemic, VA received COVID-19
supplemental funding—additional funding outside its annual
appropriations act—from three sources:
1. the CARES Act;
2. the Families First Coronavirus Response Act (FFCRA); and
3. the American Rescue Plan Act of 2021 (ARPA).2
In March 2020, VA received $19.62 billion in COVID-19 supplemental
funding from the CARES Act and FFCRA.3 In March of the following year,
VA received an additional $17.08 billion in supplemental funding from
ARPA. While the majority of these funds are to provide health care
services, these funds also support information technology systems,
administration of veterans’ benefits, general VA administration, and
oversight of VA’s response to COVID-19 by the VA Office of Inspector
General.
To provide oversight of VA’s spending of this supplemental funding from
the CARES Act, FFCRA, and ARPA, Congress passed, and the President
signed into law, the VA Transparency & Trust Act of 2021.4 In addition to

2CARES Act, Pub. L. No. 116-136, div. B, tit. X, 134 Stat. 281, 583 (2020); Families First
Coronavirus Response Act, Pub. L. No. 116-127, div. A, tit. VI, 134 Stat. 178, 183 (2020);
American Rescue Plan Act of 2021, Pub. L. No. 117-2, tit. VIII, 135 Stat. 4, 112-17 (2021).
An appropriation provides budget authority to incur obligations and to make payments for
specified purposes. Supplemental appropriations are provided in an act appropriating
funds in addition to those already enacted in an annual appropriation act. We will be
referring to the supplemental appropriations enacted in the CARES Act, FFCRA, and
ARPA as supplemental funding in this report. See GAO, A Glossary of Terms Used in the
Federal Budget Process, GAO-05-734SP (Washington, D.C.: Sept. 1, 2005).
3The FFCRA funds were available for COVID-19-related items and services, and the
CARES Act funds were available to prevent, prepare for, and respond to COVID-19.
4VA Transparency & Trust Act of 2021, Pub. L. No. 117-63, § 2(c), 135 Stat. 1484, 1485
(2021).

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
requirements for VA, this act included a provision for us to review
obligations and expenditures of the supplemental funds.5
In this report, we
1. describe information VA used to determine the amount of COVID-19
supplemental funding it requested from Congress;
2. describe how VA used COVID-19 supplemental funding; and
3. describe actions VA has taken in response to challenges related to
the projection, use, and oversight of COVID-19 supplemental funds.
To describe information VA used to determine the amount of COVID-19
supplemental funding it requested from Congress, we reviewed VA’s
financial policy that included information on supplemental funding
procedures.6 We also reviewed supplemental funding requests, including
documentation from VHA, VBA, and OIT describing estimates that
support supplemental funding requests for the CARES Act and ARPA.7
These documents provided insight into VA’s need for and planned use of
the CARES Act supplemental funding request and subsequent ARPA
supplemental funding request.
To describe how VA used supplemental funds, we reviewed spend plans
for CARES Act, FFCRA, and ARPA funds and VA bi-weekly reports on
allocations, obligations, expenditures, and transfers of CARES Act funds
between VA components. We reviewed VA data on monthly allocations,

5The act also includes requirements for VA to provide a detailed plan to congressional
committees outlining its intent for obligating and expending funds covered by the act,
including a justification for each type of obligation. Additionally, the act requires VA to
submit reports to congressional committees every 14 days (bi-weekly) detailing its
obligations, expenditures, and planned uses of the funds, as well as justification for any
deviation from the plan. An obligation is a definite commitment that creates a legal liability
of the government for the payment of goods and services ordered or received, or a legal
duty on the part of the United States that could mature into a legal liability by virtue of
actions on the part of the other party beyond the control of the United States whereas an
expenditure is the actual spending of money. See GAO-05-734SP.
6See Department of Veterans Affairs, Various Appropriations Law Related Topics. Volume
II. Chapter 7. (Washington, D.C.: Aug. 29, 2014). Supplemental funding procedures
reviewed in VA’s financial policy included emergencies that may affect the safety of
human life, the protection of property, or the immediate welfare of individuals, as
prescribed by law.
7According to VA officials, the $60 million in COVID-19 relief funding provided under the
FFCRA did not require a supplemental funding request.

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
obligations, and expenditures of CARES Act, FFCRA, and ARPA funds
through July 2022. We also reviewed VA data on the allocation of funds
to components within VA. To provide detailed information on VHA, VBA,
and OIT activities, we reviewed VA data on actual obligations for CARES
Act, FFCRA, and ARPA funds, as of July 2022 and planned obligations
through fiscal year 2023. Additionally, we reviewed information from the
federal spending database, www.usaspending.gov, on VA’s use of
COVID-19 supplemental funds.8 We assessed the reliability of VA data on
allocations, obligations, and expenditures by examining the data for
errors, outliers, and omissions and reviewing different VA data sources to
ensure data consistency. We also interviewed VA officials who are
knowledgeable about these data to identify any data limitations.9 As a
result of these steps, we determined that the data were sufficiently
reliable for the purpose of describing funding allocations, actual and
planned obligations, and expenditures.
To describe how VA addressed challenges related to the projection of
need for, use, and oversight of funds for the COVID-19 pandemic, we
reviewed VA documentation, including an OIT lessons-learned review,
VHA financial policies, and guidance developed by VHA’s Office of
Finance that provided answers to staff questions related to COVID-19
supplemental funds. We also interviewed officials from six of VHA’s 18
Veterans Integrated Service Networks (VISN), which are responsible for

8The publicly available website, www.usaspending.gov, is developed and operated by the
Department of the Treasury and includes detailed data on federal spending, including
obligations across the federal government.
9VA’s Financial Management System is VA’s primary mechanism to track and monitor the
use of all funds, including the COVID-19 supplemental funding, to help ensure that VA’s
obligations and expenditures stay within authorized budget limits. In VA’s Agency
Financial Report for fiscal year 2021, the auditors reported a material weakness in its
financial system and reporting because, among other things, the Financial Management
System, has limited functionality to meet VA’s current financial management and reporting
needs and VA continues to record a large number of journal entries in order to produce a
set of auditable financial statements. According to VA officials, VA has implemented
workarounds to ensure some expenditures are populated with object classification codes
and reviewed the data to identify outliers. See U.S. Department of Veterans Affairs,
Agency Financial Report, Fiscal Year 2021. (Washington, D.C.: Nov. 15, 2021).
In the course of our work, we spoke with VA officials within the VA Office of Budget to
understand Financial Management System limitations related to the allocation, obligation,
and expenditure data needed for our review. Officials noted that aggregate data from the
Financial Management System are reliable and that detailed data on activities funded
using supplemental funds may be subject to manual adjustments to ensure the data are
accurate. Officials reviewed the data and identified any outliers before providing us the
data.

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
overseeing VA medical facilities within their networks. To select the six
VISNs, we first identified the allocated amount of supplemental funding
that each VISN received from VHA as of September 2021. We then
selected three VISNs from among those with higher allocations, and three
from among those with lower allocations, while also ensuring geographic
diversity by considering the region of the country in which each VISN is
located.
For all objectives, we interviewed VA officials, including officials from the
VA Office of Budget, which manages the department’s budget, VHA,
VBA, and OIT. Within VHA, we interviewed officials from the Office of the
Chief Financial Officer, which is responsible for all VHA financial
management and accounting operations and the Office of Community
Care, which, at the time, oversaw health care services delivered by non-
VA providers to veterans and eligible beneficiaries.10 To examine how
VHA will continue to finance key areas, we interviewed VHA’s Office of
Enrollment and Forecasting—which is responsible for developing
projections from the Enrollee Health Care Projection Model and annually
updating the assumptions that affect those projections—about processes
to account for VHA’s COVID-19 response in VA’s budget justifications to
support the annual presidential budget requests.11
We conducted this performance audit from January 2022 to November
2022 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.

10In May 2022, the Office of Community Care merged with the Office of Veterans Access
to Care to create the Office of Integrated Veteran Access.
11The Enrollee Health Care Projection Model is an actuarial model VA uses to estimate
approximately 90 percent of its health care budget and is also used to separately estimate
the resources needed to purchase care veterans receive in the community. These
estimates inform the annual President’s budget request for VA health care services—a
request for appropriations for the following 2 fiscal years.

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Each year, VA submits a budget justification to Congress to support the
President’s budget request for annual appropriations. According to VA’s
financial policy, the department will consider requesting supplemental
funding under certain circumstances, such as to address public health
emergencies or natural disasters.12 To request these funds, VA’s Office of
Budget works with VA components and VA’s Chief Financial Officer to
submit a request to the Office of Management and Budget. (See fig. 1.)
Figure 1: Department of Veterans Affairs’ (VA) Process for Requesting Supplemental Funds

VA received approximately $36.70 billion in supplemental funding from
the CARES Act, FFCRA, and ARPA between 2020 and 2021 for COVID-
19-related relief. As of August 23, 2022, VA obligated almost all of its

12See Department of Veterans Affairs, Various Appropriations Law Related Topics.
Volume II. Chapter 7. (Washington, D.C.: Aug. 29, 2014). Emergencies include
circumstances that may affect the safety of human life, the protection of property, or the
immediate welfare of individuals, as prescribed by law. According to VA officials, in
response to the COVID-19 pandemic, the VA’s Office of Budget were involved in the
CARES Act supplemental funding request by initiating a data call for funding requirements
across VA. The Office of Budget used the initial estimates to coordinate funding needs.
Background

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
funds (98.9 percent) from the CARES Act and (99.9 percent) from FFCRA
and approximately 56.9 percent of funds from ARPA. (See fig. 2.)
Figure 2: Department of Veterans Affairs’ (VA) COVID-19 Supplemental Funding and Reported Obligations and Expenditures
through August 2022

Notes: Supplemental appropriations are provided in an act appropriating funds in addition to those
already enacted in an annual appropriation act. For this report, supplemental funding includes
supplemental appropriations enacted in the CARES Act, Families First Coronavirus Response Act
(FFCRA), and the American Rescue Plan Act of 2021 (ARPA). An obligation is a definite commitment
that creates a legal liability of the government for the payment of goods and services ordered or
received, whereas an expenditure is the actual spending of money.

The funds appropriated to VA and its components from the CARES Act,
FFCRA, and ARPA have different periods of availability. (See fig. 3.)

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
Figure 3: Time Availability for CARES Act, FFCRA, and ARPA Appropriations as of
August, 2022

Note: CARES Act supplemental funding refers to the initial amounts appropriated by Congress in
March of 2020 prior to account transfers. Subsequent transfers between VA accounts occurred
through August, 2021. These transfers reduced the total appropriation for the Veterans Health
Administration (VHA) to $16.69 billion and increased the Veterans Benefits Administration (VBA) to
$351.00 million and the Office of Information Technology (OIT) to $2.19 billion.
aThe Families First Coronavirus Response Act (FFCRA) supplemental funding to VA totaled
$60,000,000, and it was provided to VHA. This subset of funds is available through September 30,
2022.
bWhile most of the American Rescue Plan Act of 2021 (ARPA) funds are available until September
2023, different sections of ARPA have various periods of availability. For example, Section 8003
(Funding for Supply Chain Modernization), part of Section 8004 (Funding for State Homes), and
Section 8008 (Emergency Department of Veterans Affairs Employee Leave Fund) are available
through fiscal year 2022, while Section 8001 (Funding for Claims and Appeals Processing) and
Section 8002 (Funding Availability for Medical Care and Health Needs) are available through fiscal
year 2023. The funds in the remaining sections are available until expended.
cVA’s CARES Act supplemental funding also includes funds to the following accounts: State Home
Construction Grants ($150,000,000), General Administration ($6,000,000), and the Office of Inspector
General ($12,500,000). The funds for the Office of Inspector General are available until expended.
dVA’s $17.08 billion in ARPA funds includes the funds identified for VHA and VBA, as well as funds
for the following activities: supply chain modernization ($100,000,000), state homes ($750,000,000),

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
the Office of Inspector General ($10,000,000), COVID-19 Veteran Rapid Retraining Assistance
Program ($386,000,000), copayments and cost sharing for medical services, community care, and
care collection funds ($1,000,000,000), and Emergency Department of Veterans Affairs Employee
Leave Fund ($80,000,000).
eOf the $14.482 billion in supplemental funding appropriated for medical care and health needs, no
more than $4 billion is to be used for community care purposes under 38 U.S.C. §§ 1703(c)(1) and
1703(c)(5). In addition to medical needs, $1 billion in ARPA funds were provided to VA for
copayments and cost sharing as well as $750 million for funding of state homes. Depending on the
activity, COVID-19 supplemental funds from ARPA may be available to cover the impacts of delays in
care due to the COVID-19 pandemic; sustainment of CARES Act supported staffing, and service-level
expansions, including in the areas such as VA homelessness programs and telehealth; and medical
services to veterans, including medical facility improvements, research, and administrative expenses.
See H. Rep. No. 117-7, at 533-34 (2021).

The CARES Act provided authority for VHA to transfer funds among four
of its appropriation accounts through September 30, 2021.13 The
Continuing Appropriations Act, 2021, and Other Extensions Act, enacted
in October 2020 allowed VHA to transfer funds to VA components outside
of its accounts.14 In total, VHA transferred $6.44 billion initially
appropriated for VA medical care to other accounts within and outside of
VHA through September 30, 2021.15
See appendix I for more information about CARES Act and FFCRA
appropriations, transfers, obligations, and expenditures. See appendix II
for more information on ARPA allocations, obligations, and expenditures.

13Pub. L. No. 116-136, div. B, tit. X, § 20001, 134 Stat. 281, 585 (2020). Under the
CARES Act, VHA received the authority to transfer funds among four of its appropriation
accounts for amounts of 2 percent or less of the total amount appropriated under the
CARES Act and to request approval from Congress for transfers in excess of 2 percent of
the appropriations. VHA is funded through several appropriation accounts with the
following general purposes: Medical Services, which funds clinical operations in VA
medical centers; Medical Community Care, which funds claims for non-VA provided
medical care; Medical Support and Compliance, which generally funds medical facility
administration; and Medical Facilities, which generally funds facility-related costs including
maintenance, leases, and energy costs. The Veterans Medical Care and Health Fund was
created for the deposit and disbursement of funds for medical care and health care needs
provided under section 8002 of ARPA.
14Subsequent appropriations acts included additional authority to transfer certain CARES
Act funding outside of VHA. Continuing Appropriations Act, 2021 and Other Extensions
Act, Pub. L. No. 116-159, § 163, 134 Stat. 709, 722 (2020); Consolidated Appropriations
Act, 2021, Pub. L. No. 116-260, div. J, tit. V, §§ 514, 515, 134 Stat. 1182, 1689-1691
(2020).
15Of the $6.44 billion in transfers, $5.89 billion was transferred to different appropriation
accounts within VHA. VA accounts outside of VHA received the remaining transferred
funds, including VBA, OIT, Canteen Services, the National Cemetery Administration,
James A. Lovell Federal Health Care Center, and the Board of Veterans’ Appeal. For the
purposes of this report, we refer to these as VA components.

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In March 2020, VA determined the amount of COVID-19 supplemental
funding to request from Congress through the CARES Act based on (1)
the limited information about the pandemic available from public health
sources, and (2) existing data on VA medical care and IT services. As the
pandemic continued, VA used additional information to determine the
amount of COVID-19 supplemental funding that would be needed to
sustain these services once CARES Act funds were expended.
CARES Act. VA officials told us that at the start of the pandemic, VA
determined that additional funding would be needed for the pandemic
response. However, when determining the amount of funding to request
through the CARES Act, little information was known about the timeline
and the magnitude of the pandemic. According to VA officials, VA’s Office
of Budget worked with each component within VA to understand their
needs in responding to the pandemic. Such needs included the expected
number of COVID-19 patients and the amount of personal protective
equipment (PPE) for VA staff. To determine these needs, VA components
relied on assumptions based on available information from public health
sources, and existing data on medical care and IT services. VA officials
noted the following information and assumptions, by VA component:
•
VHA CARES Act funding request: To inform its initial estimate of
funding needs in March 2020, VHA relied on the limited information
available at the time from public health sources, such as reported
COVID-19 cases in China and the cruise industry’s early experiences
with COVID-19, according to officials.
After considering this information, VHA based its initial estimated
funding needs on the assumptions that over the course of 12 months
its level of emergency care would double, 20 percent of its patients
would be infected, and 12 percent of the infected patients would need
to be hospitalized for an average of 7 days. In addition, VHA
considered the need for security measures at its facilities, ventilators,
PPE, staff overtime, and the level of care at VA medical facilities and
in the community. For staffing considerations specifically, VHA
officials stated that VHA used its managerial cost accounting system.
This financial system generated cost estimates of (1) VA hospital
stays and health care encounters, and (2) additional staff and
overtime needed during the early stages of the pandemic.
•
VBA CARES Act funding request. Officials told us they determined
VBA’s request for CARES Act funds based on expenses associated
with transitioning employees not already teleworking into the telework
environment, including the purchase of supplies such as replacement
VA Initially
Determined COVID-
19 Funding Needs
Using Limited
Available Data, but
Later Considered
Additional Information

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monitors for existing employees. For employees that continued to
report to the office, the request included costs for a bulk acquisition of
PPE and for deep cleaning workspaces. According to VBA officials,
this request was based on an assumption that the pandemic response
would last 6 months.
•
OIT CARES Act funding request. According to officials, OIT put
together a team to review information from VA components, such as
VHA, VBA, and the Office of Emergency Management to determine
what was required for OIT to support these entities during the COVID-
19 pandemic. This team reviewed requirements such as tele-service
expansion, telecommunication, veteran-facing applications (e.g.,
VA.gov), and staffing. OIT discussed projections such as the number
of staff teleworking and the number of patients who would use
telehealth services to estimate IT services and hardware needed for
the transition, such as the number of devices and the amount of
bandwidth.
For example, OIT based initial funding estimates
•
for mobile applications used for veteran telehealth services, such
as VA Video Connect, on the assumption that for every 2 months
the use of telehealth care services would double and, as a result,
OIT system usage would also double.
•
to support telehealth applications, on its need to increase
bandwidth, and specifically based its funding estimates on the
assumption that VA would be adding roughly 30,000 telehealth
sessions a day based on an increase of 170,000 remote users for
a total of 210,000 remote users per day.
•
for staffing considerations to support VA, VBA, and VHA during
the pandemic, on the assumption that for the 12 months following
its estimate, OIT would spend $1 million per month for subject
matter experts to provide IT support, infrastructure buildouts, and
remote work efforts.
Transfer of CARES Act funds. VA officials told us that as the pandemic
continued, it was apparent VA would have to transfer funding
appropriated in the CARES Act between its appropriation accounts to
respond to changing circumstances related to COVID-19.16 Furthermore,
VA officials told us that during the pandemic there was a decrease in
services provided at VA medical facilities. For example, ventilators were

16The CARES Act provided authority for VHA to transfer funds among four of its
appropriation accounts through September 30, 2021.

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in high demand during the beginning of the pandemic, but as the
pandemic continued, demand for ventilators abated.
In addition, early in the pandemic VHA allocated funds to the production
of COVID-19 educational pamphlets and communication tools. However,
officials told us that as fewer veterans were accessing VA medical
facilities in person, VHA did not need to print as many of these materials.
Instead, VHA could deliver much of the necessary information through
less costly methods such as texting. In total, changing conditions
prompted VHA to transfer $6.44 billion from its account for medical
services to other appropriations accounts.
Over the same period of time, VHA observed an increase in the demand
for community care health services from non-VA providers, which are
primarily funded through the Medical Community Care appropriation
account. Of the $6.44 billion transferred from VHA’s account for medical
services, roughly 85 percent went to its Medical Community Care account
to fund services delivered by community providers, including emergency
room and urgent care. According to VHA officials, VHA had already been
experiencing an increase in community care, separate from the
pandemic, and continued to experience increases in community care
during the pandemic. According to VA officials, community care increased
for reasons such as providers in the community reopening during the
pandemic faster than VA medical facilities, and increased demand for
community care based on health care providers and veterans’ desire to
reduce COVID-19 transmission.17
VBA officials told us that in addition to the $13 million originally requested
through the CARES Act, it received a transfer of $338 million from VHA’s
Medical Services appropriation account to address unforeseen

17VHA officials told us it is challenging to determine if COVID-19, eligibility changes from
the VA MISSION Act of 2018 (VA MISSION Act), or both are responsible for increases in
community care inpatient services. VHA is continuing to examine this issue. The VA
MISSION Act established the VA’s Community Care program that was implemented in
June 2019. The Community Care program expanded certain veterans’ eligibility to receive
care from approved community providers and assigned responsibility to VA for ensuring
that veterans’ appointments are scheduled in a timely manner, among other things. VA
MISSION Act of 2018, Pub. L. No. 115-182, tit. I, § 101, 132 Stat. 1393, 1395-1404
(2018).

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circumstances.18 Specifically, the National Personnel Records Centers
and National Archives and Records Administration closed during the
pandemic, which disrupted VBA’s access to federal records that it needed
for evidence when adjudicating disability and compensation claims.19 To
compensate for this lack of access, VBA required additional funding to
pay staff overtime to retrieve records, as well as establish the capability to
scan paper records onsite and convert files to be uploaded into a
database. This database allowed VBA to access these records internally
in order to continue to process benefit claims. According to VBA officials,
the additional funding also helped support changes to VBA digital
education systems that were necessary due to of the COVID-19-driven
shift to distance learning.
ARPA. VA officials told us that in January 2021, it had a much clearer
understanding of needs based on months of experience with the
pandemic and data such as medical facilities’ caseloads during COVID-
19 peaks. Therefore, VA relied on this additional information to inform its
requests for additional funding—subsequently enacted through ARPA—to
cover COVID-19 related needs through September 2023. Specifically, VA
agencies determined their funding requests in the following ways:
•
VHA ARPA funding request. Officials explained that as the
pandemic continued, the focus shifted from responding to the
pandemic to planning for how to sustain needed programs and
making changes in health care services as a result of the pandemic.
VHA officials told us that they based the ARPA request on information
such as COVID-19 transmission levels and historical data on VA’s
response to COVID-19, indicating increases in telehealth and
community care services among veterans.
•
VBA ARPA funding request. Officials told us that they requested
ARPA funding for staff overtime to continue its efforts to reduce the
backlog of disability and compensation claims and to increase its
scanning of paper records into VBA’s database, due to the closure of

18VBA received a total of $338 million, transferred from VHA Medical Services, as
authorized by the Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. J, tit.
V, §§ 514, 515, 134 Stat. 1182, 1689-1690 (2020).
19The National Personnel Records Centers is an operation of the National Archives and
Records Administration that functions as a central repository of personnel-related records
for both the military and civil services of the United States government. The National
Personnel Records Centers located in St. Louis, Missouri stores medical treatment
records of retirees from all services, as well as records for dependent and other persons
treated at naval medical facilities.

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the National Personnel Records Centers and National Archives and
Records Administration federal records centers.
•
OIT ARPA funding request. Officials told us that when requesting
ARPA funding, VA’s enhanced understanding of changes to veteran
health care delivery allowed it to better determine VA’s IT funding
needs. OIT officials told us they extrapolated data on the activities
financed during the CARES Act to forecast the amount of funds
needed to sustain VHA IT services. For example, OIT used ARPA
funding to continue to provide critical program and technical support
(e.g., security, software quality assurance testing) for software
services that aid in the transfer of data between community care
network providers and VA. That critical program and technical support
included transferring data on COVID-19 vaccinations at community
providers to VA’s Electronic Health Record system.20
Future funding. VHA, VBA, and OIT officials told us they plan to develop
estimates for future budget requests based on how VA’s health care
services are changing as a result of the pandemic. Officials from VHA’s
Office of Enrollment and Forecasting told us that starting in the summer of
2020, VHA began developing estimates for future budget requests that
incorporated the impact of the COVID-19 pandemic on VHA services.
These estimates took into account COVID-19-specific assumptions such
as amounts of deferred and returning care, the economic recession in
2020, and rising health care costs. VA officials told us that they
incorporated some of these impacts from the pandemic into the fiscal
year 2022 President’s budget.
In addition, VHA used a modeling approach for the fiscal year 2023
President’s budget request that included both pre-pandemic and

20The Veterans Medical Care and Health Fund was created for the deposit and
disbursement of funds for medical care and health care needs provided under section
8002 of ARPA. OIT was reallocated $1.24 billion in ARPA section 8002 funds to provide
sustainment support for VHA IT projects that were initiated due to the COVID-19
pandemic and originally funded under the CARES Act. In July 2022, VHA reallocated an
additional $196.16 million for information technology needs, for a total of $1.43 billion.
VA’s COVID-19 response introduced new IT requirements and taxed pre-COVID
infrastructure capacity. According to VA, it now supports a capability level that its base
appropriation cannot fully sustain at a “new normal” operating level. These investments
comprise both direct support of medical care activities and enterprise-level investments
that benefit VHA as well as the rest of the Department, according to officials.

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pandemic workload data.21 VHA officials also told us that they are
examining how to incorporate changes in telehealth services, as a result
of the pandemic, in both its budget projections and resource allocation
model. We plan to assess these efforts as part of our ongoing work.22

VHA, VBA, and OIT received the majority (98.3 percent) of VA’s CARES
Act funds and used their funds for key areas including VHA community
care, VHA pay and benefits, VHA supplies and materials, and information
technology efforts.23 As of July 31, 2022, VA obligated 98.9 percent of its
CARES Act funds and expended 95.0 percent of the allocated funds.
(See fig. 4.)

21Actuaries from Milliman, the actuarial consultant that helps VA with the Enrollee Health
Care Projection Model, told us that the hybrid modeling approach included 2019, 2020,
and 2021 workload data in an attempt to remove short-term COVID impacts from long-
term projections. The model uses fiscal year 2019 as the base year, since it was the last
full pre-pandemic year, and uses high-level data from both fiscal year 2020 and fiscal year
2021. The Office of Enrollment and Forecasting’s primary analysis involved comparing
actual workload during the pandemic to pre-pandemic expectations of normal workload for
fiscal year 2020. The gap in expectations was attributed to the effects of COVID-19.
22The VA Transparency & Trust Act of 2021 includes a provision for us to issue a final
report pertaining to VA’s COVID-19 supplemental funds by September 30, 2024. Pub. L.
No. 117-63, § 2(c)(2), 135 Stat. 1484, 1485 (2021).
23In addition to VHA, VBA, and OIT, VA allocated CARES Act funds for Canteen Services
($140,000,000), the James A. Lovell Federal Health Care Center ($10,000,000), State
Home Construction Grants ($150,000,000), the National Cemetery Administration
($12,000,000), General Administration ($6,000,000), Board of Veterans’ Appeals
($1,000,000), and the Office of Inspector General ($12,500,000). In March 2020, the
FFCRA appropriated $60 million to VA to carry out health services consisting of COVID–
19 testing and related visits. Of this amount, $30 million was for VHA medical services and
$30 million was for community care services.
VA Used
Supplemental Funds
to Address Several
Key Areas
Key areas VA funded
through the CARES Act

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Figure 4: VA Allocations and Obligations by VA Component for CARES Act Funding as of July 2022

Note: Figure not to scale and totals may not add due to rounding. An obligation is a definite
commitment that creates a legal liability of the government for the payment of goods and services
ordered or received whereas an expenditure is the actual spending of money.
aOther Department of Veterans Affairs (VA) allocations’ includes allocations to the following
components: Canteen Services ($140,000,000), James A. Lovell Federal Health Care Center
($10,000,000), National Cemetery Administration ($12,000,000), State Home Construction Grants
($150,000,000), General Administration ($6,000,000), Board of Veterans’ Appeals ($1,000,000), and
the Office of Inspector General ($12,500,000).
bOther OIT obligations” includes development of new or expanded IT capabilities, such as the ability
to engage with VA through electronic outreach and communications.
cOther VHA obligations includes activities such as contracts for nursing services and medical
specialists, equipment such as ventilators, and grants and subsidies to support homeless veterans.

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VHA CARES Act obligations. VA data show that of VHA’s $16.69 billion
allocation from the CARES Act funding, VHA obligated $16.48 billion
(98.8 percent) as of July 31, 2022.24 VHA allocated this funding across its
medical facilities based on information such as bed capacity, workload
data, and the costs of facility updates related to COVID-19. VHA made
adjustments throughout the pandemic based on what areas needed
funding.25 According to VHA data, of the $16.48 billion obligated in total,
$13.21 billion (80.1 percent) was obligated to key areas including paying
claims for community care contracts, pay and benefits, and supplies and
materials.26
•
Community care contracts. VA data show that VHA obligated $7.48
billion (45.4 percent) to pay community care claims for veterans to
receive care at non-VA facilities throughout the country.27 VHA used

24The CARES Act appropriated $17.23 billion to VHA. VA subsequently transferred
$546.00 million within VHA to other VA accounts to respond to changing circumstances
related to COVID-19. VHA allocation with transfers was $16.69 billion.
25Most funding for VHA health care is allocated to the VISNs and local VA medical centers
for use. Each year, VHA allocates about two-thirds of funds for general patient care using
two main allocation models. The first model, Veterans Equitable Resource Allocation,
allocates general purpose funds to each VISN and a second model—the Medical Center
Allocation System—then allocates these funds to the medical centers that report to each
VISN. These models are based on patient workload—that is, the number and type of
veterans served and the complexity of care provided. VHA allocates its remaining one-
third of funds—known as specific purpose funds—to program offices that manage various,
specific programs, such as community care and prosthetics. Program offices, in turn,
allocate these funds directly to medical facilities using different methodologies, including a
workload-based model for community care. For more information on VHA’s process for
allocating funds, see GAO, Veterans Health Care: VA Needs to Improve Its Allocation and
Monitoring of Funding, GAO-19-670 (Washington, D.C.: Sept. 23, 2019).
26In addition to these key areas, VHA obligated $975.46 million (5.9 percent) for non-
community care contracts to obtain nurses or medical specialists or to provide additional
resources to VA medical facilities, $928.64 million (5.6 percent) to grants and subsides to
support homeless veterans, $897.26 million (5.4 percent) for ventilators and necessary
equipment, and $471.96 million (2.9 percent) was obligated to other needs, such as
printing, land and structures, State Veterans Homes, rent, travel, and transportation of
supplies.
27VA allocated $7.60 billion to the Medical Community Care appropriation account and of
that amount, $7.48 billion was obligated for Community Care Network contracts. The
Community Care Network is comprised of five regional networks that serve as the primary
contract vehicle for VA to provide care to veterans from community providers. The
Community Care Network covers all U.S. states and territories and relies on third party
administrators to develop and administer regional networks of high-performing licensed
health care providers to veterans.

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these funds to support an increased demand for emergency room and
urgent care during the pandemic.
•
Pay and benefits. VA data show that VHA obligated $3.02 billion
(18.4 percent) for pay and benefits for health care providers to help
VHA address staffing challenges during the COVID-19 pandemic.
Challenges included needing additional employees to support
underserved medical facilities and additional housekeepers,
administrative support, and facilities staff.
•
Supplies and materials. VA data show that VHA obligated $2.70
billion (16.4 percent) for drugs and other medicines; medical supplies
including hospital, surgical, laboratory, and morgue supplies; and
PPE. For example, one VISN official said that their VISN used the
funds for ventilators, PPE, and cleaning supplies, while an official from
another VISN said that they used the funds for beds and furniture.28
VBA CARES Act obligations. VA data show VA allocated $351.00
million from the CARES Act funding to VBA, of which VBA obligated
$346.72 million (98.8 percent), as of July 31, 2022.29 Almost the entire
amount allocated to VBA was obligated to key areas including:
•
Modernizing VBA’s education service systems. VA data show that
VBA’s largest obligation ($194.94 million or 56.2 percent) went to
support changes to the VBA’s digital education systems used by
veterans and beneficiaries, made necessary as a result of the COVID-
19 shift to distance learning.30
•
File conversion, mailing, and printing services. VA data show that
VBA obligated about $104.31 million (30.1 percent) for file conversion,
mailing, and printing services. According to VA’s data, these funds

28For more information on VA’s procurement of supplies and materials see GAO, VA
COVID-19 Procurements: Pandemic Underscores Urgent Need to Modernize Supply
Chain, GAO-21-280 (Washington, D.C.: June 15, 2021).
29The CARES Act appropriated $13.00 million to VBA. Pursuant to sections 514 and 515
of the Consolidated Appropriations Act, 2021, VA transferred $338.00 million from VHA’s
Medical Services account to VBA’s General Operating Expenses account for a total
allocation of $351.00 million. See Pub. L. No. 116-136, 134 Stat. 281, 582 (2020); Pub. L.
No. 116-260, div. J, tit. V, §§ 514, 515, 134 Stat. 1182, 1689-1690 (2020).
30The pandemic highlighted the shortcomings in the VBA education service systems.
CARES Act funding was obligated for the Digital GI Bill—an effort to improve education
benefits and customer service delivery to GI Bill beneficiaries and modernize claims
processing and customer service for external partners. VBA officials indicated that CARES
Act funding allowed VBA to start the Digital GI Bill modernization earlier than anticipated.

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helped start the implementation of VBA’s plan to proactively convert
files and scan more than 15 million personnel records at the National
Personnel Records Centers and National Archives and Records
Administration when these facilities shut down during the pandemic.
•
Staff overtime. VA data show that VBA obligated $47.46 million (13.7
percent) to staff overtime to process a backlog of disability and
compensation claims. According to VBA officials, COVID-19 disrupted
VBA’s access to the evidence required to adjudicate disability and
compensation claims causing the number of pending disability
examinations to increase. VBA officials told us the CARES Act
funding allowed VBA to reduce—from 264,000 in October 2021 to
less than 165,000 in August 2022—the number of claims pending by
more than 125 days.31
OIT CARES Act obligations. VA data show that it allocated OIT $2.19
billion from the CARES Act funding, nearly all of which was obligated as
of July 31, 2022.32 Of the amount allocated to OIT, $2.12 billion was
obligated to key areas including:
•
IT efforts. VA data show OIT obligated $1.84 billion (84.5 percent) to
sustain its information technology efforts. Some of these efforts
included provisioning laptops, cell phones, and other devices to
support expanded telework and telehealth during the pandemic. OIT
also strengthened its infrastructure and supporting systems to handle
increased demand and bandwidth requirements.
•
Hiring temporary staff. VA data show OIT obligated $273.51 million
(12.5 percent) to hire temporary staff to support COVID-19 efforts. For
example, these new staff configured and provisioned desktops,

31According to VBA officials, in addition to the closure of the National Personnel Records
Centers and National Archives and Records Administration facilities during the COVID-19
pandemic, several other factors contributed to the claims processing backlog, such as the
processing of new disability claims presumptively linked to Agent Orange and airborne
hazards. Prior to the pandemic, VBA’s number of claims pending by more than 125 days
was 70,814.
32Pursuant to section 515 of the Consolidated Appropriations Act, 2021 VA transferred
$45.00 million from VHA’s Medical Services account to VA’s Information Technology
Systems account for a total allocation of $2.19 billion CARES Act funding for OIT. Pub. L.
No. 116-260, div. J, tit. V, § 515, 134 Stat. 1182, 1690 (2020).

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laptops, and printers and provided technical support for on-site and
remote users.33
Our analysis of VA data shows that as of July 31, 2022, VA obligated
$8.63 billion (50.8 percent) and expended $6.45 billion (38.0 percent) of
the $17.08 billion in ARPA COVID-19 supplemental funds.
VHA ARPA obligations. Unlike the CARES Act funding, the
supplemental appropriations VHA received under ARPA were not limited
to the response to COVID-19 and, thus, were available for a broader
array of activities.34 This flexibility and ARPA’s multi-year period of
availability enabled VHA to prioritize using CARES Act funds—available
through September 30, 2021— and FFCRA funds – available through
September 30, 2022—as well as its annual fiscal year 2021 and 2022
appropriations, before using its ARPA funds.35 As a result, VHA did not
incur most ARPA obligations until January 2022. VHA intends to expend
all ARPA funds by September 30, 2023.
According to VA data, VA allocated $14.48 billion to VHA for medical care
and health needs, of which VHA obligated $7.37 billion (50.9 percent) as
of July 31, 2022.36 According to VHA officials, VHA has used or intends to
use its ARPA funds to finance similar areas as it did with the CARES Act
funds and to sustain existing VHA programs. The key areas VHA funded

33In addition to IT efforts and hiring temporary staff, OIT obligated $66.87 million to
development efforts such as supporting the ability for veterans to engage with VA through
electronic outreach and communications.
34Section 8002 of the American Rescue Plan Act of 2021 appropriated $14.48 billion for
allocation under chapters 17, 20, 73, and 81 of 38 U.S.C., and of that amount, VA can
spend up to $4.0 billion for health care through the Veterans Community Care program for
purposes under 38 U.S.C. §§ 1703(c)(1) and 1703(c)(5).
35A total of $1.89 billion in ARPA funds provided to VA under section 8004 (funding for
State Homes), Section 8005 (funding for the Office of Inspector General), section 8006
(Veteran Rapid Retraining Assistance Program), and section 8007 (prohibition on
Copayments and Cost Sharing) are available until expended. Further, when ARPA was
enacted in March 2021, VA FFCRA funds were available until September 2022 and
CARES Act funds available until September 2021.
36Section 8002 of ARPA appropriated $14.48 billion to VHA for medical care and health
care needs. Not included are VHA’s ARPA appropriations under section 8004 (State
Homes) and section 8007 (Copayments and Cost Sharing), totaling an additional $1.75
billion.
Key areas funded through
ARPA

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with its ARPA allocation include medical care, non-recurring
maintenance, equipment, and information technology.37 (See fig. 5.)
Figure 5: VHA American Rescue Plan Act of 2021 Actual and Planned Obligations by Areas Funded, Fiscal Years 2021 to 2023,
as of July 2022

37According to VA officials, OIT requested $1.70 billion in ARPA funds in the President’s
budget and the Office of Management and Budget did not approve this request. Instead,
VHA initially reallocated $1.24 billion of its $14.48 billion appropriation to information
technology needs related to the pandemic and in July 2022, VHA reallocated an additional
$196.16 million for information technology needs, for a total of $1.43 billion.

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Note: Figure not to scale and totals may not add due to rounding. An obligation is a definite
commitment that creates a legal liability of the government for the payment of goods and services
ordered or received, whereas an expenditure is the actual spending of money. The Veterans Medical
Care and Health Fund was created for the deposit and disbursement of funds for medical care and
health care needs provided under section 8002 of the American Rescue Plan Act of 2021.
aActual obligations are as of July 2022 and the remaining amounts are planned obligations through
fiscal year 2022.
bVHA initially reallocated $1.24 billion of its $14.48 billion appropriation to information technology
needs related to the pandemic. In July 2022, VHA reallocated an additional $196.16 million for
information technology needs, for a total of $1.43 billion.
cIncludes obligations to sustain homelessness programs, the new Regional Readiness Centers
initiative, a new suicide prevention grant program, and research projects to better understand and
respond to the pandemic.

•
Medical care. According to VA data, through fiscal year 2023 VHA
plans to obligate the largest share of its ARPA allocation, $9.54 billion
or 65.9 percent, for veteran medical care in both VA medical facilities
and in the community.38 VHA anticipates increased needs for care
due to COVID-19 related care deferrals and a greater reliance on VA
care due to economic impacts from the pandemic.
•
Non-recurring maintenance. According to VA data, through fiscal
year 2023, VHA plans to obligate $1.77 billion (12.2 percent) to facility
enhancements to better prepare VHA to deliver care in a pandemic or
post-pandemic environment. This includes upgrades to ventilation
systems and other projects to prevent pandemic contagion.
•
Equipment. According to VA data, through fiscal year 2023, VHA
plans to obligate $746.22 million (5.2 percent) for purchasing critical
high-cost medical equipment upgrades, such as Magnetic Resonance
Imaging, Computerized Tomography scanners, and Positron Emission
Tomography scanners.
•
Information technology. According to VA data, VHA reallocated
$1.43 billion (9.9 percent) from VHA to OIT, to support information
technology needs.39 According to OIT officials, these efforts include

38Medical care obligations are funded with VHA’s five appropriations accounts: Veterans
Medical Care and Health Fund, Medical Services, Medical Support and Compliance,
Medical Facilities, and Medical Community Care. The Veterans Medical Care and Health
Fund was created for the deposit and disbursement of funds for medical care and health
care needs provided under section 8002 of ARPA.
39VHA reallocated $1.43 billion of its appropriations under Section 8002 of ARPA for
information technology. In addition, VA allocated $23.89 million (with rescissions) in
appropriations under section 8003 to OIT to fund supply chain modernizations. As of July
31, 2022, $7.18 million of this allocation has been obligated.

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sustaining new systems created with CARES Act funding to support
VA’s COVID-19 response.
VBA ARPA obligations. According to VA data, VA allocated $262.00
million in ARPA funds to VBA, of which $59.29 million was obligated as of
July 31, 2022.40 VBA plans to obligate $251.00 million (95.8 percent) of its
ARPA funds for key areas including scanning and overtime to continue to
reduce the disability and compensation claims backlog.41 VBA intends to
obligate all of its ARPA funds by September 2023. (See fig. 6.)

40These funds were provided under section 8001 of ARPA. A total of $262.00 million was
allocated for VBA general operating expenses and $10.00 million is for the Board of
Veterans’ Appeals. Section 8006 of ARPA appropriated an additional $386.00 million to
VBA for their Veteran Rapid Retraining Assistance Program. This program is intended to
provide education assistance to veterans who are unemployed due to the covered public
health emergency and are not eligible for certain other veteran education programs. As of
July 31, 2022, $160.28 million of this allocation has been obligated. VBA intends to
obligate all of their ARPA funds by September 2023.
41VBA plans to obligate the remaining $10.99 million (4.2 percent) of its ARPA funds for
enhanced claims processing.

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Figure 6: VBA American Rescue Plan Act of 2021 Actual and Planned Obligations by Areas Funded, Fiscal Years 2021 to 2023,
as of July 2022

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
•
Scanning. According to VA data, VBA plans to obligate $151.00
million (57.6 percent) of its ARPA allocation for increased scanning
efforts at the National Personnel Records Centers and National
Archives and Records Administration facilities to continue to bring
personnel records into VBA.
•
Overtime. According to VA data, VBA plans to obligate $100.00
million (38.2 percent) of its ARPA allocation for additional overtime to
continue to address the disability and compensation claims backlog
that accrued during the COVID-19 pandemic due to the shutdown of
required in-person disability examinations and inability to access
records housed in the National Personnel Records Centers and
National Archives and Records Administration facilities.
VA officials from the VA Office of Budget, VHA, VBA, OIT, and six
selected VISNs described several actions to address challenges related
to the projection, use, and oversight of COVID-19 supplemental funds.
Specifically, these actions included the following:
Requested flexibility in the permitted use of funds. As described
previously in this report, VA was provided transfer authority and made
multiple transfers of CARES Act funds to accommodate changing needs.
These changing needs were the result of circumstances such as
increases in veteran use of community care, rather than using health care
services provided at VHA facilities. VHA officials told us that making
transfers was challenging due to the labor-intensive manual work required
to identify and perform adjustments in VA’s antiquated financial
systems.42
To allow for greater flexibility, VA made suggestions to provide flexibility
in the permitted use of ARPA funds as part of its technical assistance to
Congress. Additionally, VHA was more general in its identification of
needs when requesting ARPA funds, rather than specifying particular
needs as it did for its CARES Act funding request. According to VA
officials, this provided VHA with the flexibility to change which health care
needs it focused on as the circumstances of the pandemic shifted.

42VA is in the process of updating the financial systems throughout the agency. The VA
Office of Inspector General previously reported problems with VHA’s reliance on several
accounting subsystems for payroll and purchase card transactions that require VHA staff
to perform a significant amount of manual work to identify and perform adjustments so that
the COVID-19 obligations and expenditures are captured in VA’s reporting.
VA Took Actions in
Response to
Projection, Use, and
Oversight Challenges

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Gathered information to better inform supplemental funding
requests. VA officials told us that there was little information available at
the start of the pandemic to inform the CARES Act supplemental funding
request and that they gathered information on the impacts of the
pandemic to better inform subsequent supplemental funding requests.
For example, to inform VA’s request for ARPA funds, officials from VA’s
Office of Budget said that in the year between the CARES Act and ARPA
requests, the Office of Budget gathered information such as 1) caseload
data during COVID-19 peaks, 2) the pandemic-related needs of the
various VA components, and 3) the use of pandemic funds, such as for
increased telework and changes to the delivery of healthcare and
benefits.
Coordinated among offices. VA officials told us that adapting to the
effects of the pandemic reinforced the need for coordination, which was
important for supporting the department’s overall response throughout the
pandemic. For example, OIT coordinated with VHA to support veterans’
increased use of telehealth during the pandemic and coordinated with
VBA to help modernize education services. As another example, some
VISN officials we interviewed told us that their VISNs coordinated with VA
medical facilities to reallocate funds and resources among facilities based
on changing workload due to COVID-19 cases.
Reduced reliance on third-party organizations. The pandemic caused
the National Archives and Records Administration and other federal
records facilities to close, which contributed to a backlog in VBA’s
processing of disability and compensation claims. To address this
challenge, VBA made organizational changes to scan and convert files to
upload these records internally to its claims database. According to VBA
officials, the Office of Business Integration led efforts to employ a VA
contractor team at the National Archives and Records Administration’s
National Personnel Records Center in St. Louis, Missouri to extract, scan,
and upload records for all veterans. Additionally, VBA officials told us this
effort will save retrieval time and speed future processing for veterans
who have never filed VA claims for disability compensation. VBA officials
also told us that as a result of this organizational change, VBA has
become less reliant on third party organizations for the records it uses in
its claims processing.
Created financial guidance. In response to confusion concerning the
use of COVID-19 supplemental funds from VISN and VA medical facility
staff, VHA’s Office of Finance developed guidance documents that
provided staff answers from VHA’s Office of Finance on questions related

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GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
to COVID-19 supplemental funds. These questions covered topics such
as determining reasonable uses of these funds and how to input costs in
VA’s accounting system.
For example, VISN officials told us that during the early stages of the
pandemic, some administrative staff were moved to entrance gates to
screen employees and veterans for COVID-19. Since the accounting
system did not allow for their time to be recorded as both clinical and
administrative work, VHA’s financial guidance clarified that this COVID-19
screening should not be recorded as clinical work, and that VA medical
facilities could continue to record these employees’ salaries under the
administrative account. According to VISN officials, the VHA guidance
was helpful as it provided consistent information across VISNs and a
clear understanding of what was an appropriate use of COVID-19
supplemental funds. VISN officials also told us that the VISNs and VA
medical facilities relied heavily on these documents to inform purchasing
decisions.
Developed VA-wide oversight mechanisms. To help address
challenges related to the completeness and accuracy of reported COVID-
19 supplemental funding data, in May 2022, VA created a new chapter in
its financial policy with guidance on the oversight of supplemental funds.43
This chapter also addresses topics such as ensuring that reported
obligation and expenditure data related to any supplemental appropriation
is complete and accurate by maintaining regular, systematic oversight
over such funds. According to VA officials, this chapter highlights the
importance of coordination and oversight of supplemental funds and
outlines responsibilities of specific VA components. For example, the
chapter specifies that VA’s Office of Management is responsible for
establishing and coordinating national workgroups for overseeing the use

43See Department of Veterans Affairs Office of Inspector General, Veterans Health
Administration: Review of VHA’s Financial Oversight of COVID-19 Supplemental Funds,
VA OIG 20-02967-121, (Washington, D.C: June 10, 2021), which recommended that the
VA Deputy Undersecretary for Health coordinate with VA’s Office of Management to 1)
implement internal control procedures to ensure the completeness and accuracy of the
data in VA’s reports to the Office of Management and Budget and to Congress and 2)
execute data validation procedures to make certain that reports to the Office of
Management and Budget and to Congress can be traced back efficiently to the source
transactions. The Office of Inspector General report notes that the Acting Undersecretary
for Health concurred in principle with one recommendation and agreed with the second
without qualifier.

Page 28
GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
of supplemental appropriations and consolidating administration-level
spend plans for how to use supplemental funding.44
Established an information technology governance council. As part
of a lessons learned review, OIT identified challenges related to
predicting costs for information technology and recommended that OIT
establish a governance council to review proposed obligations of
supplemental funds related to information technology.45 OIT established
this governance council in March 2020, and officials told us that it allowed
flexibility in VA’s COVID-19 response while maintaining controls and
oversight over the obligation and expenditure of supplemental funds. For
example, once COVID-19 supplemental funds were allocated to OIT, its
governance council reviewed justifications for proposed obligations. After
this review, the governance council made a final decision on whether or
not to provide funding based on the justification provided. OIT officials
told us having a governance council was important because it provided
oversight of the cost projections and use of COVID-19 supplemental
funds. OIT officials said that in a future public health emergency, OIT is
likely to establish a governance council tasked with adapting to the
financial needs of the emergency response, and with providing oversight.
We provided a copy of this draft report to VA for review and comment. VA
provided us with technical comments, which we incorporated as
appropriate.

44See Department of Veterans Affairs, Appropriations, Funds and Related Information:
Supplemental Appropriations Oversight. Volume II. Chapter 11. (Washington, D.C.: May
11, 2022).
45OIT identified and documented lessons learned in a review of its response to the first 3
months (March 2020 through June 2020) of the COVID-19 pandemic. As of August 2022,
OIT is still in the process of implementing its remaining recommended actions such as
establishing a financial emergency preparedness plan, conducting planning exercises to
help mitigate VA and OIT resource shortages during emergencies, and memorializing the
process to develop a funding dashboard.
Agency Comments

Page 29
GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
We are sending copies of this report to the Secretary of Veterans Affairs
and appropriate congressional committees. The report is also available at
no charge on GAO’s website at http://www.gao.gov.
If you or your staff has any questions regarding this report, please contact
me at (202) 512-7114 or silass@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made key contributions to this report
are listed in appendix III.

Sharon M. Silas
Director, Health Care

Appendix I: VA COVID-19 Supplemental
Funding from the CARES Act and Families
First Coronavirus Response Act (FFCRA)

Page 30
GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
The Veterans Health Administration (VHA), the Office of Information
Technology (OIT), and the Veterans Benefits Administration (VBA)—the
three Department of Veterans Affairs’ (VA) components that received the
majority of VA’s supplemental funding under the CARES Act and
FFCRA—were responsible for 98.3 percent of the total $19.41 billion in
obligations of this funding. Together, all VA components expended over
96 percent of this obligated CARES and FFCRA funding as of August 23,
2022.1
VA has the authority to transfer funds between its appropriation accounts
under certain circumstances.2 In response to the changing program
needs during the COVID-19 pandemic, VHA transferred over $6.44 billion
from its Medical Services account to other VHA accounts, including
Medical Community Care, Medical Support and Compliance, and Medical
Facilities, as well as to the VBA and other VA components.3 See table 1
for more information about CARES Act and FFCRA appropriations,
transfers, net appropriations, obligations, expenditures, and the percent of
net appropriations expended.

1CARES Act, Pub. L. No. 116-136, div. B, tit. X, 134 Stat. 281, 583 (2020); Families First
Coronavirus Response Act, Pub. L. No. 116-127, div. A, tit. VI, 134 Stat. 178, 183 (2020).
An appropriation provides budget authority to incur obligations and to make payments for
specified purposes. Supplemental appropriations are funds enacted in an act
appropriating funds in addition to those already enacted in an annual appropriation act.
We will be referring to the supplemental appropriations enacted in the CARES Act,
FFCRA, and the American Rescue Plan Act of 2021 (ARPA) as supplemental funding in
this report. See GAO, A Glossary of Terms Used in the Federal Budget Process,
GAO-05-734SP (Washington, D.C.: Sept. 1, 2005).
2Under the CARES Act, VHA received the authority to transfer funds among its four
appropriation accounts for amounts of 2 percent or less of the amounts appropriated to
each account under the CARES Act and to request approval from Congress for transfers
in excess of 2 percent of the appropriations. Subsequent appropriations acts included
additional authority to transfer CARES Act funding outside of VHA. Continuing
Appropriations Act, 2021 and Other Extensions Act, Pub. L. No. 116-159, § 163, 134 Stat.
709, 722 (2020); Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. J, tit. V,
§§ 514, 515, 134 Stat. 1182, 1689-1691 (2020).
3VHA is funded through several appropriation accounts with the following general
purposes: Medical Services, which funds clinical operations in VA medical centers;
Medical Community Care, which funds claims for non-VA provided medical care; Medical
Support and Compliance, which generally funds medical facility administration; and
Medical Facilities, which generally funds facility-related costs including maintenance,
leases, and energy costs. A new appropriation account—Veterans Medical Care and
Health Fund—was created for the deposit and disbursement of funds for medical care and
health care needs provided under section 8002 of ARPA.
Appendix I: VA COVID-19 Supplemental
Funding from the CARES Act and Families
First Coronavirus Response Act (FFCRA)

Appendix I: VA COVID-19 Supplemental
Funding from the CARES Act and Families
First Coronavirus Response Act (FFCRA)

Page 31
GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
Table 1: Department of Veterans Affairs (VA) Reported Appropriations, Transfers, Net Appropriations, Obligations, and
Expenditures of Supplemental Funding for CARES Act and FFCRA, as of August 23, 2022
VA component or
account
Appropriation
amount ($ in
thousands)
Amount
transferred
($ in
thousands)a
Net
appropriations
($ in thousands)
Total
obligations ($
in thousands)
Total
expenditures ($
in thousands)
Percent of net
appropriations
expended
CARES Act Supplemental Fundingb

Medical Services
14,432,000
(6,441,000)
7,991,000
$ 7,826,546

7,590,240
95.0
Medical Community
Care
2,100,000
5,500,000
7,600,000
7,600,000
7,600,000
100.0
Medical Support
and Compliance
100,000
255,000
355,000
329,969
319,740

90.1
Medical Facilities
606,000
140,000
746,000
742,046

624,673

83.7
Total Veterans
Health
Administration
medical care
17,238,000
(546,000)
16,692,000
16,498,561

16,134,653

96.7
Canteen Service
Revolving Fund
0
140,000
140,000
140,000
140,000
100.0
James A. Lovell
Federal Health Care
Center
0
10,000
10,000
10,000
10,000
100.0
Information
Technology Service
2,150,000
45,000
2,195,000
2,188,671

2,070,720

94.3
Veterans Benefits
Administrationc
13,000
338,000
351,000
339,689

248,318

70.7
National Cemetery
Administration
0
12,000
12,000
11,413
8,844

73.7
State Home
Construction Grants
150,000
0
150,000
150,000

16,249

10.8
General
Administration
6,000
0
6,000
5,992

5,936

98.9
Board of Veterans’
Appeals
0
1,000
1,000
1,000
974

97.4
Office of Inspector
General
12,500
0
12,500
12,500
12,477

99.8

Appendix I: VA COVID-19 Supplemental
Funding from the CARES Act and Families
First Coronavirus Response Act (FFCRA)

Page 32
GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
VA component or
account
Appropriation
amount ($ in
thousands)
Amount
transferred
($ in
thousands)a
Net
appropriations
($ in thousands)
Total
obligations ($
in thousands)
Total
expenditures ($
in thousands)
Percent of net
appropriations
expended
VA Total CARES
Act Funds
19,569,500
0
19,569,500
19,357,826
18,648,172
95.3
Families First Coronavirus Response Act (FFCRA)d

Medical Services
30,000
0
30,000
30,000
30,000
100.0
Medical Community
Care
30,000
0
30,000
30,000
30,000
100.0
VA Total FFCRA
Act Funds
60,000
0
60,000
60,000
60,000
100.0
Total, VA FFCRA
and CARES Act
Supplemental
Funding
19,629,500
6441,000
19,629,500
19,417,826
18,708,172
95.3
Source: GAO analysis of VA data, CARES Act, Families First Coronavirus Response Act. | GAO-23-105730
aAs of August 23, 2022, VA has transferred $6.44 billion from the Medical Services account to other
VA accounts based on authority provided in the CARES Act, Pub. L. No. 116-136, div. B, tit. X, §
20001, 134 Stat. 281, 585 (2020), the Continuing Appropriations Act, 2021 and Other Extensions Act,
Pub. L. No. 116-159, § 163, 134 Stat. 709, 722 (2020), or the Consolidated Appropriations Act, 2021,
Pub. L. No. 116-260, div. J, tit. V, §§ 514-515, 134 Stat. at 1689-91.
bCARES Act, Pub. L. No. 116-136, div. B, tit. X, 134 Stat. 281, 583 (2020).
cThe Veterans Benefits Administration (VBA) received supplemental funding in its General Operating
Expenses appropriation account.
dFamilies First Coronavirus Response Act, Pub. L. No. 116-127, div. A, tit. VI, 134 Stat. 178, 183
(2020).

Appendix II: VA COVID-19 Supplemental
Funding from the American Rescue Plan Act of
2021

Page 33
GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
The Department of Veterans Affairs (VA) received additional COVID-19
supplemental funds totaling $17.08 billion from the American Rescue
Plan Act of 2021 (ARPA).1 As with CARES Act and Families First
Coronavirus Response Act (FFCRA) supplemental funds, VA allocated
most of the funds to the Veterans Health Administration (VHA) in the
amount of $14.48 billion.2 Depending on the appropriation, VA can
obligate ARPA supplemental funds through 2023.3 Together, VA
components obligated 57.2 percent and expended 44.0 percent of funds
as of August 23, 2022. See table 2 for the net allocations (including
rescissions), obligations, expenditures, and percent of net allocations
expended for ARPA as of August 23, 2022.
Table 2. Department of Veterans Affairs (VA) Reported Net Allocations, Obligations, and Expenditures of Supplemental
Funding Provided by the American Rescue Plan Act as of August 23, 2022
American Rescue Plan Act section
and appropriation account
Net allocations
($ in thousands)a
Total
obligations
($ in thousands)
Total
expenditures
($ in thousands)
Percent of net
allocations
expended
Section 8001: Funding for Claims and Appeals Processing
Veterans Benefits Administration (VBA) - General Operating Expenses and Board of Veterans’ Appeals,
Departmental Administration
VBA
262,000
79,468

56,986
21.8
Board of Veterans’ Appeals
10,000
4,645
4,541
45.4
Total ARPA funds section 8001
272,000
84,113
61,528
22.6
Section 8002: Funding Availability for Medical Care and Health Needs

1American Rescue Plan Act of 2021, Pub. L. No. 117-2, tit. VIII, 135 Stat. 4, 112-17
(2021). The Consolidated Appropriations Act, 2022 rescinded $76.1 million of funds made
available by section 8003 of the American Rescue Plan Act of 2021, which was provided
to VA for supply chain modernization initiative, resulting in net allocation to of $17.00
billion in supplemental funds to VA. Pub. L. No. 117-103, § 256, 136 Stat. 49, 561 (2022).
2Of the $14.82 billion in supplemental funding appropriated for medical care and health
needs, no more than $4 billion may be used for community care purposes under 38
U.S.C. §§ 1703(c)(1) and 1703(c)(5). In addition to medical needs, $1 billion in ARPA
funds were provided to VA for copayments and cost sharing as well as $750 million for
funding of state homes. COVID-19 supplemental funds from ARPA may be available to
cover the impacts of delays in care due to the COVID-19 pandemic; sustainment of
CARES supported staffing and service-level expansions, including in the areas such as
VA homelessness programs and telehealth; and medical services to veterans, including
medical facility improvements, research, and administrative expenses. See H. Rep. No.
117-7, at 533-34 (2021).
3ARPA funding has various periods of availability. Depending upon the appropriation
involved, the funds’ availability range from no fiscal limitations or availability through
September 2022 or September 2023.
Appendix II: VA COVID-19 Supplemental
Funding from the American Rescue Plan Act
of 2021

Appendix II: VA COVID-19 Supplemental
Funding from the American Rescue Plan Act of
2021

Page 34
GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
American Rescue Plan Act section
and appropriation account
Net allocations
($ in thousands)a
Total
obligations
($ in thousands)
Total
expenditures
($ in thousands)
Percent of net
allocations
expended
Veterans Medical Care and Health Fund
Medical Services
5,680,191
4,244,547
3,742,885
65.9
Medical Community Care
4,000,000
1,675,387
1,675,387
41.9
Medical Support and Compliance
978,433
435,564
289,020
29.5
Medical Facilities
2,572,958
1,206,323
432,523
16.8
Medical and Prosthetic Research
9,000
8,816
7,798
86.6
Information Technology Systems (Office of
Information Technology (OIT))
1,241,418
496,913
251,201
20.2
Total ARPA funds section 8002
14,482,000
8,067,550
6,398,815
44.2
Section 8003: Funding for Supply Chain Modernizationa
Information Technology Systems
Information Technology Systems (OIT)
23,895
7,188
0
0.0
Total ARPA funds section 8003
23,895
7,188
0
0.0
Section 8004: Funding for State Homes
Medical Community Care and Grants for Construction of State Extended Care Facilities
Medical Community Care
250,000
249,999
249,999
100.0
Grants for Construction of State Extended
Care Facilities
500,000
495,442
3,171
0.6
Total ARPA funds section 8004
750,000
745,440
253,169
33.8
Section 8005: Funding for Office of the Inspector General
Office of the Inspector General
Office of Inspector General
10,000
6,796
6,368
63.7
Total ARPA funds section 8005
10,000
6,796
6,368
63.7
Section 8006: Veteran Rapid Retraining Assistance Program
Readjustment Benefits
Readjustment Benefits – Veteran Rapid
Retraining Assistance Program
386,000
173,604
119,035
30.8
Total ARPA funds section 8006
386,000
173,604
119,035
30.8
Section 8007: Copayments and Cost Sharing
Medical Services, Medical Community Care, and Medical Care Collections Fund
Medical Services
627,900
340,414
340,414
54.2
Medical Community Care
72,100
29,276
29,276
40.6
Medical Care Collections Funds
300,000
248,347
248,347
82.8
Total ARPA funds section 8007
1,000,000
618,036
618,036
61.8

Appendix II: VA COVID-19 Supplemental
Funding from the American Rescue Plan Act of
2021

Page 35
GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
American Rescue Plan Act section
and appropriation account

Net allocations
($ in thousands)a
Total
obligations
($ in thousands)
Total
expenditures
($ in thousands)
Percent of net
allocations
expended
Section 8008: Emergency Department of Veterans Affairs Employee Leave Fund

Emergency Department of Veterans Affairs Employee Leave Fund
Emergency Department of Veterans Affairs
Employee Leave Fund
80,000
25,954
25,954
32.4
Total ARPA funds section 8008
80,000
25,954
25,954
32.4
Total ARPA Funds for Sections 8001 through 8008
17,003,895
9,728,681
7,482,904
44.0
Source: GAO analysis of VA data and the American rescue Plan Act. | GAO-23-105730
aThe Consolidated Appropriations Act, 2022 rescinded $76.10 million of funds made available by
section 8003 of the American Rescue Plan Act of 2021 which was provided to VA for supply chain
modernization initiative. Pub. L. Np. 117-103, § 256, 136 Stat. 49, 561 (2022).

Appendix III: GAO Contact and Staff
Acknowledgments

Page 36
GAO-23-105730 Veterans Affairs COVID-19 Relief Funding
Sharon Silas, (202) 512-7114 or Silass@gao.gov.

In addition to the contact named above, Michael Zose (Assistant
Director), Courtney Liesener (Analyst-in-Charge), Emily Loriso, and Nira
Marte made key contributions to this report. Also contributing were Jennie
Apter, Cori Cafaro, Jacquelyn Hamilton, and Ethiene Salgado-Rodriguez.

Appendix III: GAO Contact and Staff
Acknowledgments
Contact
Staff
Acknowledgments
(105730)

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