COVID-19 Minimally Affected the Jobs for Veterans State Grants Program Amid Weaknesses in Eligibility Validation Practices January 22, 2026
Summary
U.S. Department of Labor Office of Inspector General report no. 06-26-001-02-203 to the Veterans' Employment and Training Service (VETS), issued January 22, 2026, on the Jobs for Veterans State Grants (JVSG) program, which funds 54 state workforce agencies. It finds that the COVID-19 pandemic minimally affected the program, which reportedly met or exceeded its employment rate goals, but says this apparent success may be misleading because of weaknesses in eligibility validation. VETS' April 2014 policy lets individuals self-attest eligibility for DVOP services without later validation, and VETS did not update it to match ETA guidance issued in June 2020 and October 2022. A review of 180 participant case files found 54, or 30 percent, incomplete.
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Full text
REPORT TO THE VETERANS’
EMPLOYMENT AND TRAINING
SERVICE
COVID-19 MINIMALLY AFFECTED THE
JOBS FOR VETERANS STATE GRANTS
PROGRAM AMID WEAKNESSES IN
ELIGIBILITY VALIDATION PRACTICES
DATE ISSUED: JANUARY 22, 2026
REPORT NUMBER: 06-26-001-02-203
What We Found
We found the COVID-19 pandemic minimally affected the overall
operations and effectiveness of the JVSG program in providing
training and employment services to eligible veterans and spouses
with SBE, as well as other eligible persons, as evidenced by the
program reportedly meeting or exceeding its employment rate goals.
However, this apparent success may be misleading due to
BRIEFLY… weaknesses identified in the program’s eligibility validation practices.
Specifically, while VETS’ policy, developed in collaboration with ETA
and issued in April 2014, allows individuals to self-attest their SBE
COVID-19 Minimally Affected the eligibility without documentation to receive DVOP services, it does
Jobs for Veterans State Grants not include procedures for subsequent validation, calling into
Program Amid Weaknesses in question the accuracy of the reported outcomes.
Eligibility Validation Practices
In June 2020 and October 2022, ETA issued guidance specifying
Why We Did the Audit documentation needed to validate eligibility, such as signed forms or
electronic signatures for self-attestation. However, VETS did not
The Jobs for Veterans State Grants update its policy to align with ETA’s guidance, resulting in conflicting
(JVSG) program allocates federal funds requirements that may have hindered validation efforts. Our review
to 54 state workforce agencies (states) of case files for 180 JVSG program participants who received DVOP
to support various positions, including services from Program Year (PY) 2020 to PY 2022, covering periods
Disabled Veterans’ Outreach Program before, during, and after the pandemic, across 45 states, found the
(DVOP) specialists, who provide career files for 54 participants, or 30 percent, were incomplete, meaning
and training services to eligible veterans they lacked documentation or contained inadequate documentation
and spouses with significant barriers to to validate their eligibility. These findings raise questions about the
employment (SBE). These services are eligibility of those served and the accuracy of reported program
also offered to other eligible persons, outcomes for assessing program performance during the pandemic.
such as transitioning service members
and caregivers of eligible veterans. Additionally, among the reviewed case files for 12 participants from
one state, files for 11 individuals indicated they did not meet the
To evaluate program effectiveness, the participant eligibility criteria for DVOP services. VETS’ program staff
Employment and Training later clarified that errors in the state’s management information
Administration (ETA) establishes system had incorrectly recorded these individuals as participants.
performance metrics to assess program Because VETS’ policy limits DVOP services to eligible veterans and
outcomes and overall success. The spouses with SBE, as well as other eligible persons, these system
Veterans’ Employment and Training errors raise questions about the eligibility of all participants who
Service (VETS) provides states with received DVOP services in this state from PY 2020 to PY 2022.
technical assistance and oversight to Consequently, up to $8.4 million in JVSG funds spent by the state to
support effective program support DVOP specialists during that period may represent
implementation. unsupported costs, indicating a potential waste of federal funds.
In March 2020, the COVID-19 pandemic What We Recommended
was declared a national emergency. To
assess the pandemic’s impact, we We made three recommendations to VETS to revise its current
conducted a performance audit to program policies to strengthen eligibility validation procedures and
answer the following question: conduct a comprehensive assessment to determine the full extent of
unsupported costs caused by ineligible individuals recorded as
How did the COVID-19 pandemic program participants. VETS did not agree with two
affect the JVSG program’s operations recommendations and partially agreed with one recommendation.
and effectiveness in providing
training and employment services to Read the Full Report
eligible veterans and spouses with For more information, go to:
significant barriers to employment, as https://www.oig.dol.gov/public/reports/oa/2026/06-26-001-02-
well as other eligible persons? 203.pdf.
U.S. Department of Labor – Office of Inspector General
TABLE OF CONTENTS
INSPECTOR GENERAL’S REPORT .................................................................... 1
RESULTS ............................................................................................................. 4
Participant Eligibility Validation Concerns May Have Impacted
Reported Outcomes ................................................................................... 6
Ineligible Recipients of DVOP Services ................................................... 11
OIG’S RECOMMENDATIONS ............................................................................ 12
Analysis of Agency’s Comments .............................................................. 13
EXHIBIT 1: STATE-REPORTED EMPLOYMENT OUTCOMES AND GOALS ... 16
EXHIBIT 2: STATE EXPENDITURES AND UNSUPPORTED COSTS .............. 19
APPENDIX A: SCOPE AND METHODOLOGY .................................................. 21
APPENDIX B: AGENCY’S RESPONSE TO THE REPORT ............................... 25
-i-
U.S. Department of Labor Office of Inspector General
Washington, DC 20210
INSPECTOR GENERAL’S REPORT
Jessie Jane Duff
Deputy Assistant Secretary for Policy
for Veterans’ Employment and Training Services
U.S. Department of Labor
200 Constitution Avenue NW
Washington, DC 20210
This report presents the results of the U.S. Department of Labor (DOL) Office of
Inspector General’s (OIG) audit of the COVID-19 pandemic’s effect on the
Veterans’ Employment and Training Service’s (VETS) Jobs for Veterans State
Grants (JVSG) program.
The JVSG program allocates federal funds through a formula grant to 54 state
workforce agencies 1 (states) to support Disabled Veterans’ Outreach Program
(DVOP) specialists, Local Veteran’s Employment Representatives (LVER), and
Consolidated DVOP/LVER staff. DVOP specialists provide individualized career
and training services to eligible veterans2 and eligible spouses 3 who face
significant barriers to employment (SBE). These services are also offered to
other eligible persons, including transitioning service members 4 and caregivers of
eligible veterans 5 (hereinafter collectively referred to as “other eligible persons”6).
LVERs conduct outreach to employers to advocate for the hiring of veterans, and
1 The 54 state workforce agencies, referred to in the report as “states,” are labor agencies that
provide workforce development services in each of the 50 states, the District of Columbia, the
Commonwealth of Puerto Rico, Guam, and U.S. Virgin Islands.
2 Eligible veteran, as defined by 38 U.S.C. § 4211(4) and further detailed in VPL No. 03-14, Jobs
for Veterans’ State Grants (JVSG) Program Reforms and Roles and Responsibilities of American
Job Center Staff Serving Veterans (April 10, 2014)
3 Eligible spouse, as defined by 38 U.S.C. § 4101(5) and further detailed in VPL No. 03-14, Jobs
for Veterans’ State Grants (JVSG) Program Reforms and Roles and Responsibilities of American
Job Center Staff Serving Veterans (April 10, 2014)
4 Transitioning Service Member, as specified in VPL No. 03-19, Designation of Additional
Populations Eligible for Services from Disabled Veterans’ Outreach Program Specialist
(February 7, 2019)
5 Caregiver, as defined by 38 U.S.C. § 1720G(d) and further detailed in VPL No. 03-19,
Designation of Additional Populations Eligible for Services from Disabled Veterans’ Outreach
Program Specialist (February 7, 2019)
6 Other eligible persons, as specified in VPL No. 03-19, Designation of Additional Populations
Eligible for Services from Disabled Veterans Outreach Program Specialists (February 7, 2019)
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U.S. Department of Labor – Office of Inspector General
Consolidated DVOP/LVER staff perform the combined duties of both a DVOP
specialist and LVER.
Program effectiveness is assessed through performance metrics established by
the Employment and Training Administration (ETA), with the employment
outcomes of participants serving as a key indicator of program success. In
conjunction with these efforts, VETS provides oversight and technical assistance
to states to support program implementation.
In March 2020, the COVID-19 pandemic was declared a national emergency,
prompting nationwide health and safety measures. To assess the pandemic’s
impact, we conducted a performance audit to answer the following question:
How did the COVID-19 pandemic affect the JVSG program’s operations
and effectiveness in providing training and employment services to eligible
veterans and spouses with significant barriers to employment, as well as
other eligible persons?
To answer our objective, we interviewed VETS officials at both the national and
regional levels as well as JVSG program staff. We distributed follow-up
questionnaires to regional offices, and responses were analyzed. We also
reviewed relevant laws, regulations, and program policies and guidance,
including Training and Employment Guidance Letters (TEGL) issued by ETA,
Veterans’ Program Letters (VPL) issued by VETS, and prior DOL OIG audit
reports that pertain to the JVSG program.
Furthermore, we analyzed state-reported performance data for Program Year
(PY) 2018 to PY 2022 (July 1, 2018, to June 30, 2023), covering periods before,
during, and after the pandemic. 7 We also reviewed federal financial reports
detailing program expenses for Fiscal Year (FY) 2020 through FY 2023
(October 1, 2019, to September 30, 2023).
Lastly, we reviewed case files for a randomly selected sample of 180 participants
who received DVOP services from PY 2020 to PY 2022 (July 1, 2020, to
June 30, 2023), covering the pandemic period and beyond. This sample of
participants received DVOP services across all of VETS’ six regions,
representing a total of 45 states. 8
7 The COVID-19 pandemic was declared a national emergency starting on March 1, 2020, and
this declaration ended on May 11, 2023.
8 VETS is divided into six regions: Atlanta, Boston, Chicago, Dallas, Philadelphia, and San
Francisco. Each region includes various states, totaling 54 states and territories across all regions
(see Footnote 1). However, our sample selection consists of individuals who received DVOP
services across 45 of the 54 states and territories. Each region serves as a hub for VETS,
providing services and support for veterans in their respective locations.
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JVSG Program Funding and Participants
VETS administers employment and training services designed to meet the needs
of veterans and other eligible individuals consistent with 38 U.S.C § 4102A. The
JVSG program provides federal funding to states through a formula grant to hire
DVOPs, LVERs, and Consolidated DVOP/LVER staff. Funding allocations are
based on several factors that include the ratio of veterans seeking employment in
each state compared to the total number of veterans seeking employment across
all states. 9 Grant funds also cover reasonable expenses for training, travel,
supplies, and other business expenses. 10
TEGL No. 14-18 defines a JVSG program participant as an individual who
receives a JVSG-funded service under the Workforce Innovation and Opportunity
Act (WIOA) 11 from a DVOP specialist after satisfying all applicable programmatic
requirements for the provision of services, including eligibility determination. 12
VPL No. 03-14 13 directs DVOP specialists to limit services to eligible veterans14
or eligible spouses 15 who meet at least one of the following SBE categories:
• special disabled or disabled, 16
• homeless, 17
• recently separate service member, 18
• an offender, 19
• educationally disadvantaged (lack a high school diploma or equivalent
certificate), or
• low income. 20
VPL No. 03-14 further states that DVOP specialists may serve additional
members of the veteran population as authorized by 38 U.S.C. § 4103A(a)(1)(C)
9 38 U.S.C. § 4102A(c)(2)(B)(i)
10 38 U.S.C. § 4102A(b)(5)(C)
11 JVSG-funded services to eligible veterans and other eligible persons include individualized
career- and training-related services, primarily defined in WIOA Section 134(c)(2)(A)(xii) and its
implementing regulations, specifically 20 C.F.R. § 680.170(b).
12 TEGL No. 14-18, Operating Guidance for the Workforce Innovation and Opportunity Act
(referred to as WIOA), (March 25, 2019)
13 VPL No. 03-14, Jobs for Veterans’ State Grants (JVSG) Program Reforms and Roles and
Responsibilities of American Job Center Staff Serving Veterans (April 10, 2014)
14 Eligible veteran, as defined by 38 U.S.C. § 4211(4)
15 Eligible spouse, as defined by 38 U.S.C. § 4101(5)
16 Special disabled and disabled, as defined by 38 U.S.C. § 4211 (1) and (3)
17 Homeless, as defined by 42 U.S.C. § 11302(a) and (b)
18 Recently separate service member, as defined by 38 U.S.C. § 4211(6)
19 Offender, as defined by Workforce Innovation and Opportunity Act, Section 3(38)
20 Low income, as defined by Workforce Innovation and Opportunity Act, Section 3(36)
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U.S. Department of Labor – Office of Inspector General
and specified in VPL No. 03-19. 21 This VPL identifies the additional populations
eligible to be served by a DVOP specialist, which include:
• veterans aged 18–24 with limited civilian history;
• Vietnam-era veterans; 22 and
• eligible transitioning service members, spouses, and caregivers. 23
RESULTS
We found the COVID-19 pandemic minimally affected the overall operations and
effectiveness of the JVSG program in providing training and employment services
to eligible veterans and spouses with SBE, as well as other eligible persons. While
there were operational disruptions, such as staff reassignments and a shift to
online service delivery, the program continued to meet or exceed its employment
rate goals, which serve as primary indicators of performance. However, this
apparent success may be misleading because weaknesses identified in the
program’s eligibility validation practices call into question the eligibility of those
served and the accuracy of state-reported performance data for assessing program
performance during the pandemic.
In April 2014, VETS, in collaboration with ETA, established policy allowing
individuals to self-attest to SBE eligibility based solely on self-identification.
Interviews with VETS officials and program staff confirmed that individuals may
self-attest without supporting documentation, whether through an intake form or a
written questionnaire, and if these are not used, this information must be made
clear orally. This lack of documentation was previously reported 24 by the OIG and
continues to raise concerns about the eligibility of those served and the accuracy of
the state-reported performance data.
To support the need for valid and reliable performance data, while VETS’ 2014
policy was still in effect, ETA issued guidance in June 2020 directing JVSG
recipients (the states) to develop procedures for validating eligibility. The guidance
21 VPL No. 03-19, Designation of Additional Populations Eligible for Services from Disabled
Veterans’ Outreach Program Specialist (February 7, 2019)
22 Vietnam-era Veteran, as defined by 38 U.S.C. § 101(29)
23 As defined in VPL No. 03-19: (a) Transitioning Members of the Armed Forces who have been
identified as in need of Individualized Career Services; (b) members of the Armed Forces who are
wounded, ill, or injured and receiving treatment in the military treatment facilities or warrior
transition units; and (c) the spouses or other family caregivers of such wounded, ill or injured
members
24 VETS’ Oversight of Florida’s Jobs for Veterans State Grants Program Needs to be
Strengthened, Report No. 06-14-001-02-001 (March 27, 2014), available at:
https://www.oig.dol.gov/public/reports/oa/2014/06-14-001-02-001.pdf
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U.S. Department of Labor – Office of Inspector General
identifies acceptable forms of source documentation to validate eligibility, including
case notes, crossmatches, electronic records, and a signed form (paper or
electronic) to support self-attestation. The guidance also states that JVSG grant
recipients were strongly encouraged but not required to implement the specified
data validation framework. ETA revised this guidance in October 2022 to further
clarify documentation requirements for validating self-attestation.
VETS provided its Data Validation Desk Reference, which adopts portions of ETA’s
guidance applicable to the JVSG program. This reference emphasizes that
although documentation to verify eligibility is not required initially, individuals who
self-attest their eligibility should be presumed to be accurate to avoid
inappropriately delaying or denying services. It further states that the source
documentation requirements specified in ETA’s guidance are not optional unless
otherwise noted. This documentation is necessary to verify the accuracy of
performance reporting and is fundamental to ensuring performance accountability.
Despite these clarifications, VETS did not update its policy to align with ETA’s
documentation requirements. Interviews with VETS officials and program staff
indicated self-attestation without documentation continues to occur. The conflicting
requirements undermine efforts to ensure valid and reliable state-reported
performance data.
To assess compliance with ETA’s source documentation requirements, we
reviewed case files for 180 randomly selected participants who received DVOP
services from PY 2020 to PY 2022. We found the files for 54 participants, or
30 percent, were incomplete, meaning they lacked source documentation 25 or
contained inadequate documentation 26 to validate eligibility. These findings raise
concerns about the eligibility of those served and the accuracy of the program
performance outcome that suggested the pandemic had minimal impact on the
JVSG program.
Of the 12 participant case files reviewed from one state, 11 files indicated that
participants did not meet the participant eligibility criteria for DVOP services,
resulting in a 92 percent exception rate. Specifically, the files indicated these
individuals were not eligible veterans or other eligible persons, and therefore,
should not have received DVOP services. VETS’ program staff later clarified that
25 For this audit, the term “lacked documentation” refers to a case file that did not include any
critical components to validate state-reported performance data entries and/or did not contain any
documentation to comply with self-attestation documentation requirements. For each participant,
the relevant documentation requirement is the one in effect on the program entry date.
26 For this audit, the term “inadequate documentation” refers to a case file missing critical
components to validate state-reported performance data entries and/or comply with
self-attestation documentation requirements. For each participant, the relevant documentation
requirement is the one in effect on the program entry date.
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errors in the state’s management information system incorrectly recorded these
individuals as participants. These errors raise concerns about the eligibility of all
participants served in that state from PY 2020 to PY 2022. As a result, $8.4 million
in JVSG funds used to support DVOP specialists may represent unsupported
costs. This high exception rate indicates a potentially wasteful use of federal funds,
as defined by Government Auditing Standards. 27
In summary, although reported outcomes during the pandemic-era indicate the
JVSG program met its employment rate goals, weaknesses in eligibility validation
practices call into question the validity and reliability of state-reported performance
data used to calculate these outcomes. Misclassification of individuals as
participants may compromise the integrity of program reporting and raise concerns
about the appropriate use of JVSG funds.
Participant Eligibility Validation Concerns
May Have Impacted Reported Outcomes
Our analysis of state-reported performance data, 28 as documented in the
program’s Participant Individual Record Layout (PIRL), 29 examined the
employment outcomes of all participants who exited the JVSG program between
PY 2018 and PY 2022, covering periods before, during, and after the pandemic.
The analysis indicated that VETS met or exceeded its employment rate goals,
with only slight fluctuations noted during the pandemic (see Exhibit 1). However,
the program’s actual success may be misleading due to weaknesses identified in
its eligibility validation practices.
Our review of case files for 180 participants who received DVOP services from
PY 2020 to PY 2022, covering the pandemic period and beyond, could not
determine the eligibility for 54 participants, or 30 percent, because the files were
incomplete. 30 Specifically, these files either lacked documentation, such as an
intake form, written questionnaire, or case note identifying the SBE, or contained
27 Per 2018 Government Auditing Standards, “[w]aste is the act of using or expending resources
carelessly, extravagantly, or to no purpose. Importantly, waste can include activities that do not
include abuse and does not necessarily involve a violation of law. Rather, waste relates primarily
to mismanagement, inappropriate actions, and inadequate oversight.”
28 Individual data was retrieved from the program’s Participant Individual Record Layout, which is
used to document direct services provided to all participants and to track post-exit employment
outcomes.
29 Individual data was retrieved from the program’s Participant Individual Record Layout, which is
used to document direct services provided to all participants and to track post-exit employment
outcomes.
30 We received the state case files on various dates between August 17, 2024, and
September 24, 2024.
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inadequate documentation, such as a paper or electronic intake form missing a
signature or digital declaration, as specified in TEGL No. 23-19, Change 1, 31 and
TEGL No. 23-19, Change 2. 32 These issues could affect the reported program
outcomes, particularly when including performance data from unvalidated
participants in such reporting, potentially misrepresenting the program’s success
and compromising its integrity.
Issues with Documentation to Validate Participant
Eligibility
The audit could not determine eligibility for DVOP services for both exited and
non-exited JVSG program participants due to their incomplete case files, which
either lacked necessary documentation or contained inadequate documentation.
Incomplete Case Files: Lacking and Inadequate Documentation
Under 38 U.S.C. § 4103A(a), DVOP specialists are responsible for providing
services to meet the employment needs of eligible veterans with SBE or other
eligible persons determined by the Secretary, as outlined in VPL No. 03-14 and
TEGL No. 03-19. However, VPL No. 03-14 and TEGL No. 19-13, 33 both
implemented in 2014, allowed for self-attestation without requiring documentation
to validate an SBE. Furthermore, TEGL No. 23-19, 34 implemented in 2020,
permitted self-attestation when determining eligibility without requiring
documentation.
This changed with the implementation of both TEGL No. 23-19, Change 1, and
TEGL No. 23-19, Change 2, which noted:
[S]elf-attestation means a written, or electronic/digital declaration of
information for a particular data element, signed and dated by the
participant. Electronic signatures or submission from the participant
such as an email, text, or unique online survey response are
considered an electronic signature or verification; it must be
participant generated and traceable to the participant. Grantees
must retain documentation of the self-attestation.
31 TEGL No. 23-19, Change 1, Guidance for Validating Required Performance Data Submitted by
Grant Recipients of U.S. Department of Labor Workforce Programs (October 25, 2022)
32 TEGL No. 23-19, Change 2, Guidance for Validating Required Performance Data Submitted by
Grant Recipients of U.S. Department of Labor Workforce Programs (May 12, 2023)
33 TEGL No. 19-13, Jobs for Veterans’ State Grants (JVSG) Program Reforms and Roles and
Responsibilities of American Job Center (AJC) Staff Serving Veterans (April 10, 2014)
34 TEGL No. 23-19, Guidance for Validating Required Performance Data Submitted by Grant
Recipients of U.S. Department of Labor Workforce Programs (June 18, 2020)
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During our review of the case files for the 180 randomly selected participants, 35
we identified issues related to the accuracy of the state reported performance
data reported for establishing eligibility and the validity of that data. Case files
missing critical components to validate PIRL entries and/or comply with
self-attestation documentation requirements were classified as containing
inadequate documentation. Case files that did not include any critical
components to validate PIRL entries and/or did not contain any documentation to
comply with self-attestation documentation requirements were considered to be
lacking necessary documentation.
Eligibility Validation of Exited Participants
The program’s effectiveness is evaluated based on performance metrics and
employment outcomes of eligible participants who received DVOP services and
subsequently exited the program. From our sample of 180 participants,
124 exited between PY 2020 and PY 2022, covering the pandemic-era and
beyond. However, we could not determine the eligibility for 41 of these
124 participants because their case files were incomplete, with 8 case files
lacking necessary source documentation and 33 case files containing inadequate
documentation (see Table 1).
Table 1: Case File Review of Exited Participants
Number of Case Percent of Total
Documentation Status
Files Case Files
Validated Documentation 83 67%
Incomplete Documentation 41 33%
Total Case Files Reviewed 124 100%
Source: As of May 6, 2024, the state case files of participants who exited the program between
July 1, 2020, and June 23, 2023, per the PIRL.
The inclusion of unvalidated participants in the performance metrics raises
concerns about the accuracy of reported outcomes, potentially distorting
perceptions of the program’s success, which otherwise suggests the pandemic had
minimal impact on the JVSG program.
35 The random selection of 180 participants includes the following numbers: 124 exited
participants, 45 non-exited participants, and 11 ineligible participants. Table 1 does not include
the 11 ineligible participants; these participants are discussed in the section titled “Ineligible
Recipients of DVOP Services.”
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Eligibility Validation of Non-Exited Participants
In the random selection of 180 participants, we found the state-reported
performance data did not include exit dates for 45 individuals from 24 states
across all of VETS’ six regions. This indicates that participants had not exited the
program by the time we received the data. Among the case files for these
individuals, 13 (29 percent) were incomplete, with 3 case files lacking necessary
documentation and 10 containing inadequate documentation to validate eligibility.
This further raised concerns about the performance metrics and employment
outcomes used to assess the program’s success once these participants do exit
(see Table 2).
Table 2: Case File Review of Non-Exited Participants
Number of Case Percent of Total
Documentation Status
Files Case Files
Validated Documentation 32 71%
Incomplete Documentation 13 29%
Total Case Files Reviewed 45 100%
Source: As of May 6, 2024, the state case files of participants who did not exit the program based
on the blank exit dates recorded on the PIRL.
Historical Context and Ongoing Weaknesses
In 2014, a DOL OIG audit of the Florida JVSG program found 135 out of
179 case files reviewed (75 percent) for individuals who exited the program
between April 1, 2010, and March 31, 2011, lacked documentation to support an
SBE. 36 As a result of this finding, the OIG recommended that VETS develop
guidance to identify and document SBEs.
In response to the recommendation, VETS issued VPL No. 03-14 in April 2014,
directed at JVSG program staff. The guidance allowed for an eligible veteran or
eligible spouse to attest to an SBE. Additionally, it specified that the
determination of disability under SBE definitions must be made solely based on
self-identification. This information can be obtained via a written questionnaire;
however, if no written questionnaire is used, this information must be made clear
orally. This guidance remained applicable in subsequent revisions to
36 VETS’ Oversight of Florida’s Jobs for Veterans State Grants Program Needs to be
Strengthened, Report No. 06-14-001-02-001 (March 27, 2014), available at:
https://www.oig.dol.gov/public/reports/oa/2014/06-14-001-02-001.pdf
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VPL No. 03-14 made in February 37 and October 38 2015.
In April 2024, during the course of our audit, VETS established VPL No. 05-24, 39
which incorporated the acceptance of a verbal confirmation of an individual’s
eligibility status and experiences as sufficient evidence for referral to a DVOP
specialist. However, it also directs the program to adhere to TEGL No. 23-19,
Change 2, issued in 2023, for source documentation and self-attestation
guidance. This conflicting approach raises concerns as it undermines efforts to
ensure accurate data and program integrity (see Figure 1).
Figure 1: Timeline of VETS and ETA Guidance for Self-Attestation
Source: Guidance issued by VETS and ETA
37 VPL No. 03-14, Change 1, Expansion and Clarification of Definition of Significant Barriers to
Employment for Determining Eligibility for the Disabled Veterans’ Outreach Program
(February 11, 2015)
38 VPL No. 03-14, Change 2, Expansion and Clarification of Homeless Definition as a Significant
Barrier to Employment (October 14, 2015)
39 VPL No. 05-24, Jobs for Veterans State Grants Staff Roles and Responsibilities and
Coordination with Workforce Innovation and Opportunity Act Services to Veterans (April 25, 2024)
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Eligibility Validation Issues May Have Impacted
Reported Program Success
The program’s effectiveness relies on valid and reliable performance metrics and
post-exit employment outcomes of eligible participants. This requires case files to
be completed and in compliance with ETA’s self-attestation documentation
requirements. Including performance and employment data of unvalidated
participants in the JVSG program’s performance metrics may have
misrepresented the program’s apparent success in meeting or exceeding its
employment rate goals during the pandemic, thereby compromising the
program’s integrity.
If these challenges remain unaddressed, there is a risk that stakeholder
confidence, including that of Congress, could diminish, potentially jeopardizing
future funding. Such a loss can impede the program’s ability to effectively serve
eligible veterans and spouses facing SBE and other eligible persons.
Ineligible Recipients of DVOP Services
The random selection of 180 participants included 12 participants from one state
within one of VETS’ six regions reported as receiving DVOP services. In
response to our request for case files for these participants, the state submitted
documentation indicating 11 of the participants were not eligible veterans or
eligible persons. It was also noted that these individuals received services under
the Wagner-Peyser program, 40 which includes activities such as job searches,
workshops, counseling, and resume assistance. Our review of the state-reported
performance data regarding these 11 non-veterans determined the following:
• 10 individuals were incorrectly classified as eligible veterans with SBEs
who entered the program between March 2021 and March 2023. The
remaining individual had no reported entry or exit date and was not a
veteran with an SBE.
• 9 individuals exited the program between April 2021 and May 2023. The
report did not include an exit date for one individual, suggesting that they
were still in the program at the time of the review.
After our review of the documentation, we interviewed VETS program staff for
further clarification regarding the ineligible individuals reported as receiving
40 Wayner-Peyser program is a separate employment service program that operates through
American Job Centers, where the JVSG program also offers services.
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DVOP services. The staff confirmed that these individuals were not participants
in the JVSG program. They clarified that the discrepancies in performance data
stemmed from activities conducted through self-service options in the state’s
management information system, which allowed individuals to self-register
without proper validation. The Wagner-Peyser program staff, rather than DVOP
specialists, provide these services. Moreover, errors within the state’s
management information system may have contributed to the misclassification of
individuals as JVSG program participants, even if they had declined services.
The state spent $15.8 million in JVSG funds to support the efforts of DVOP
specialists and LVERs to provide services to 14,260 individuals, and for other
expenses such as training and travel. Of that amount, the state spent $9.2 million
on DVOP specialists. Given that this sample shows an exception rate of
approximately 92 percent, it potentially leads to unsupported costs amounting to
$8.4 million for services provided by DVOP specialists (see Exhibit 2). This
situation highlights significant issues regarding the accuracy of program
performance data and expenditure reporting that could affect the overall integrity
of the JVSG program.
OIG’S RECOMMENDATIONS
We recommend the Deputy Assistant Secretary for Policy for the Veterans’
Employment and Training Service:
1. Strengthen Veterans’ Program Letter No. 05-24 (dated April 25, 2024) to
detail the eligibility validation procedures for veterans and eligible persons,
including the source documentation required for eligibility validation
outlined in the Employment and Training Administration’s Training and
Employment Guidance Letter No. 23-19, Change 2, Attachment II (dated
May 18, 2023).
2. Work with the one state and conduct a comprehensive assessment to
determine the full extent of ineligible individuals being recorded as
program participants.
3. Remedy the $8.4 million in potentially unsupported costs from providing
Disabled Veterans’ Outreach Program services between Program Years
2020 and 2022 to ineligible individuals.
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Analysis of Agency’s Comments
In response to a draft of this report, VETS addressed the three recommendations
and provided additional observations. The agency did not concur with two
recommendations and partially agreed with one. We reviewed VETS’ response
and made some clarifying edits to the Final Report. The agency’s response did
not result in any material changes to our reported results or conclusions.
Synopses of VETS’ comments and our corresponding responses are detailed as
follows:
• VETS did not concur with Recommendation 1 and stated JVSG operates
under statutory authority in 38 U.S.C., which permits self-attestation and
does not require DD-214 forms or TEGL documentation. VETS stated
TEGLs are ETA guidance and are not legally binding on JVSG.
o The OIG disagrees with VETS’ position on Recommendation 1.
While the 38.U.S.C. does not explicitly require a DD-214 for
eligibility determination, it also does not prohibit collecting proper
documentation to validate eligibility—documentation that can
initially be determined through self-attestations, as permissible
under VETS’s policy. Further, VETS notes in their Data Validation
Desk Reference that TEGL No. 23-19 is DOL’s guidance for
validating required performance data submitted by grant recipients
of DOL workforce programs, which includes the JVSG program.
During our fieldwork, all six regions concurred that they adhere to
the policies within TEGL No. 23-19. Additionally, ETA’s data
validation framework specifies that all core and non-core programs
must collect source documentation in compliance with Attachment
2 of TEGL No. 23-19 for the following categories: Case Notes,
Cross-Match, Electronic Records, and Self-Attestation.
Self-attestation means a written or electronic/digital declaration of
information for a particular data element, signed and dated by the
participant. Lastly, VPL No. 05-24 specifies that states must follow
ETA’s guidance regarding documentation, including Attachment 2,
for source documentation and self-attestation guidance.
• VETS partially concurred with Recommendation 2 and stated it is willing to
provide additional training and improve communication with ETA and state
partners to strengthen reporting practices. However, VETS states it cannot
take corrective action because the OIG did not identify the state where the
issue occurred. VETS views the issue as an isolated reporting error at the
state-level rather than a systemic weakness within the JVSG program.
Additionally, VETS states it is misleading to treat this incident as a
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systemic issue, given that the affected cases represent only 0.1 percent of
the total participants.
o The OIG disagrees with VETS’ position on Recommendation 2. We
disclosed relevant details to VETS about the state on
November 13, 2024, and during a follow-up meeting with VETS
program staff on February 12, 2025—before the draft report was
issued on September 10, 2025. Moreover, the OIG’s finding that
92 percent of the reviewed sample in the affected state were
misclassified as DVOP participants is not a minor coding error and
it raises concerns about data integrity and eligibility. This
92 percent misclassification (exception) rate suggests issues with
controls and oversight, impacting the accuracy of participant
classifications, performance reporting, and the appropriate use of
JVSG funds.
• VETS did not concur with Recommendation 3, explaining that the
identified $8.4 million represents an extrapolated estimate from one state
rather than an audited financial finding. VETS pointed out that this figure
stems from a reporting issue in one state and was calculated using
SF-425 Federal Financial Report (record). Agency officials also take issue
with the term “remedy,” arguing that it suggests a repayment or misuse of
funds, which was not supported by the record.
o The OIG disagrees with VETS’ position on Recommendation 3. As
mentioned above, we communicated to and provided VETS the
specific state before the issuance of the Draft Report. This advance
notice provided VETS with sufficient information to evaluate the
scope of the eligibility issue at hand. The $8.4 million reflects the
92 percent exception rate of the total JVSG funding that we
estimated the one state spent on DVOP services from PY 2020 to
PY 2022. This high rate of misclassification raises concerns about
the eligibility of all reported participants, which in turn puts the
allowability of the costs charged to the grant into question.
According to Government Auditing Standards, costs that lack
adequate documentation must be considered unsupported. The
purpose of the recommended remedy is not to presume repayment;
rather, it is to ensure that the state can demonstrate that JVSG
funds were used to provide program services to eligible participants
as required. Repayment would be warranted only if participants
were confirmed ineligible.
• In addition to addressing the recommendations, VETS shared “additional
observations” to clarify its stance on the draft report. VETS asserts that
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the draft report extends beyond the stated audit scope, which was to
assess the impact of COVID-19 on the JVSG program. Also, VETS
pointed out that the OIG based its findings on PIRL data, which are
quarterly files intended for performance reporting, not eligibility validation
or case file documentation. VETS explained that states maintain complete
case files in their management information systems, often supported by
scanned or paper records. VETS also maintained that the JVSG program
operated appropriately within statutory authority throughout the pandemic,
including the use of self-attestation.
o We disagree with VETS’ position that the report exceeds the
intended scope of the audit or relies on inadequate data sources.
Eligibility validation practices are crucial, as they directly affect the
accuracy of the performance outcomes used to assess the JVSG
program’s effectiveness during the pandemic. Therefore, it was
central to answering the audit objective. It is important to clarify that
the OIG did not consider PIRL data as case files; rather, PIRL
extracts were used to identify participants for sample selection. The
actual case files reviewed were those maintained and provided by
the states, including electronic, scanned, and paper documentation.
The weaknesses identified in eligibility validation practices stem
from the states’ own files, not from PIRL data. Additionally, while
VETS’ policy permits program applicants to self-attest their
eligibility for DVOP services, ETA’s guidance—which VETS’ own
policies require states to follow—makes clear that documentation
must still be retained to validate eligibility and ensure reliable
performance reporting.
The agency’s response to the draft report is included in its entirety in Appendix B.
We appreciate the cooperation and courtesies VETS extended to us during this
audit, and we will work with VETS toward the implementation of corrective
actions that meet the intent of these recommendations.
Laura B. Nicolosi
Assistant Inspector General for Audit
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EXHIBIT 1: STATE-REPORTED EMPLOYMENT OUTCOMES
AND GOALS
Our analysis of state-reported performance reports from PY 2018 to PY 2022—
covering periods before, during, and after the pandemic—indicated only slight
fluctuations in national employment outcomes. The following outlines the three
performance indicators for assessing the effectiveness of DVOP services
provided from PY 2018 to PY 2022, with PY 2020 to PY 2022 representing the
pandemic-era, along with the results from our analysis for each:
1. Employment Rate – 2nd Quarter After Exit: Percentage of program
participants who are in unsubsidized employment during the second
quarter after exit from the program (see Figure 2).
Figure 2: National Average Employment Goals and Outcomes
(2nd Quarter After Exit)
Source: Goal employment rates obtained from VETS’ published National Outcomes Data for
PY 2018 to PY 2022; outcome employment rates based on OIG’s analysis of VETS’ PIRL
dataset.
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2. Employment Rate – 4th Quarter After Exit: Percentage of participants who
are in unsubsidized employment during the fourth quarter after exit from
the program (see below Figure 3).
Figure 3: National Average Employment Goals and Outcomes
(4th Quarter After Exit)
Source: Goal employment rates obtained from VETS’ published National Outcomes Data for
PY 2018 to PY 2022; outcome employment rates based on OIG’s analysis of VETS’ PIRL
dataset.
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U.S. Department of Labor – Office of Inspector General
3. Median Earnings – 2nd Quarter After Exit: Median earnings of program
participants who are in unsubsidized employment during the second
quarter after exit from the program, as established through direct UI wage
record match, Federal or military employment records, or supplemental
wage information (see below Figure 4).
Figure 4: National Average Median Earning Goals and Outcomes
(Second Quarter After Exit)
Source: Goal Employment Median Earnings obtained from VETS’ published National Outcomes
Data for PY 2018 to PY 2022; outcome employment rates based on OIG’s analysis of VETS’
PIRL dataset.
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EXHIBIT 2: STATE EXPENDITURES AND UNSUPPORTED COSTS
Table 3 depicts the total JVSG funds spent by a state to support DVOP
specialists, LVERs, and Consolidated DVOP/LVER staff from July 1, 2020, to
June 30, 2023, covering PY 2020 to PY 2022. These costs were reported in the
expenditure reports across four fiscal years, from October 1, 2019, to
September 30, 2023. The state submits expenditure reports to VETS in
alignment with the fiscal year, which runs from October 1 through September 30.
Since the program operates on program year, which runs in a cycle from July to
June, expenditures are allocated to the corresponding program years based on
the DVOP service date.
Table 3: JVSG State Expenditures
Expenditure Dates DVOP Services Participant
Amount
Reported Expense Incurred Count
FY 2020 July 1, 2020 – September 30, 2020 4,734 $3,931,755.00
FY 2021 October 1, 2020 – September 30, 2021 2,844 $4,010,388.00
FY 2022 October 1, 2021 – September 30, 2022 3,208 $3,956,439.00
FY 2023 October 1, 2022 – June 30, 2023 3,474 $3,983,699.00
- Total 14,260 $15,882,281.00
- Exception Rate - 92%
- Total Potential Unsupported Cost - $8,436,366.15
Source: SF-425 – Final Federal Financial Reports for FY 2020 to FY 2023
Between FY 2020 and FY 2023 (from October 1, 2019, to June 30, 2023), the
state spent a total of $15,882,281 to support the efforts of DVOP specialists and
LVERs to provide services to 14,260 individuals, and for other expenses such as
training and travel. Of that amount, the state spent $9,203,309 for DVOP
specialists. 41 Our review of the case files for the sample of 12 individuals who
received DVOP services during this period, along with information gathered from
interviews with program staff, found that 11 of these individuals were neither
program participants nor veterans. This resulted in an exception rate of
approximately 92 percent. 42 By applying this rate to the total amount spent on
41 The state JVSG expenditure reports do not breakdown LVER and DVOPs costs. For our
calculation, VETS provided us with position breakdown of JVSG staff, and we determined the
percentage of DVOP staff working in the state (about 57.95% of staff). We used that percentage
and multiplied it by the state’s total expenditures.
42 The actual calculated percentage of 91.6666667% was rounded for reporting purposes.
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U.S. Department of Labor – Office of Inspector General
DVOP specialists, we identified unsupported costs of $8,436,366.15, indicating
that up to this amount may have been misallocated to support DVOP specialists
servicing ineligible individuals. This situation raises concerns about the potential
waste of federal funds.
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U.S. Department of Labor – Office of Inspector General
APPENDIX A: SCOPE AND METHODOLOGY
Scope
The audit covered VETS’ operations for the Jobs for Veterans State Grants
program from July 1, 2018, to June 30, 2023. This represents PY 2018 to PY 2022
and encompasses pre-pandemic, pandemic, and post-pandemic timeframes.
Methodology
We conducted this performance audit 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 objective.
We believe that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objective.
To answer our audit objective, we:
• Reviewed relevant laws, regulations, and program guidance and
procedures to gain an understanding of VETS’ process for determining
eligibility for the JVSG program.
• Interviewed selected VETS officials from the National Office and Regional
Offices, as well as JVSG program staff to determine what oversight
activities occur and what tools are used to retain proper documentation.
We also distributed follow-up questionnaires via email to regional offices
and analyzed the responses received.
• Reviewed prior DOL OIG audit reports to identify prior program
weaknesses.
• Reviewed the Federal Financial Reports and Technical Performance
Analysis Reports for FY 2020 to FY 2023 (October 1, 2019, to
September 30, 2023) to identify program expenditures from awarded
states.
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• Examined the employment outcomes for participants who exited the
program from July 1, 2018, to June 30, 2023 (PY 2018 to PY 2022). This
analysis covered pre-pandemic, pandemic, and post-pandemic
timeframes, focusing on participants who secured unsubsidized
employment during the second and fourth quarters following their exit. We
also examined the median earnings of participants employed in the
second quarter after exiting the program.
• Obtained a universe of JVSG program participants that received DVOP
services from July 1, 2020, to June 30, 2023 (PY 2020 to PY 2022). This
universe encompassed 54 states and covered the pandemic and
post-pandemic timeframes. We stratified the data to ensure that our
sample selection would include an unbiased selection of participants from
all six VETS regions (Atlanta, Boston, Chicago, Dallas, Philadelphia, and
San Francisco) and all three program years (PY 2020 to PY 2022). We
then randomly selected a sample of 10 participants from each project
year, totaling 30 for each region and 180 for the entire sample. Our final
selection included participants from 45 out of the 54 states. To validate
eligibility, we reviewed the participants’ case files to ensure they included
the required documentation supporting their eligibility based on the criteria
in effect during the period of enrollment.
Internal Controls
In planning and performing our audit, we assessed VETS’ internal controls
relevant to our audit objective by obtaining an understanding of those controls
through interviews and reviews of program policies and procedures. We
assessed the following internal control areas relevant to the audit objective: the
control environment, agency risk assessment, control activities, information and
communication, and monitoring. The objective of our audit was not to provide
assurance on internal controls; therefore, we did not express an opinion on
VETS’ internal controls. However, our assessment of internal controls for
administering the accountability of the program may not necessarily disclose all
matters that could be significant deficiencies. Due to the inherent limitations on
internal controls, misstatements or noncompliance may occur and remain
undetected.
Data Reliability
We assessed the reliability of VETS JVSG program performance data reported
online by performing completeness, consistency and accuracy tests. Through our
testing we found inaccuracies that we considered immaterial. Despite these
issues, we determined the data was sufficiently reliable to answer the audit
objective. Additionally, we assessed the reliability of VETS’ JVSG PIRL datasets
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by performing multiple tests including but not limited to: checking missing values,
identifying missing dates, reviewing date ranges, and running frequencies on
PIRL elements. Although we identified missing PIRL elements, we determined
the data was sufficiently reliable to answer the audit objective.
Criteria
• 20 C.F.R. - Part 1001 (Services for Veterans)
• 20 C.F.R. - Part 677 (Performance Accountability Under Title I of the
Workforce Innovation and Opportunity Act)
• 38 U.S.C. Chapter 41 (Job Counseling, Training, and Placement Service
for Veterans)
• 38 U.S.C. Chapter 42 (Employment and Training of Veterans)
• 42 U.S.C. § 11302 (General Definitions of Homeless Individual)
• Jobs for Veterans Act (November 7, 2022)
• Workforce Innovation and Opportunity Act (July 22, 2014)
• TEGL No. 19-13 (April 10, 2014) - Jobs for Veterans’ State Grants (JVSG)
Program Reforms and Roles and Responsibilities of American Job Center
(AJC) Staff Serving Veterans
• TEGL No. 14-18 (March 25, 2019) - Aligning Performance Accountability
Reporting, Definitions, and Policies Across Workforce Employment and
Training Programs Administered by the U.S. Department of Labor
• TEGL No. 23-19 (June 18, 2020) - Guidance for Validating Required
Performance Data Submitted by Grant Recipients of U.S. Department of
Labor Workforce Programs
• TEGL No. 23-19, Change 1, (October 25, 2022) - Guidance for Validating
Required Performance Data Submitted by Grant Recipients of U.S.
Department of Labor Workforce Programs
• TEGL No. 23-19, Change 2, (May 12, 2023) - Guidance for Validating
Required Performance Data Submitted by Grant Recipients of U.S.
Department of Labor Workforce Programs
• Workforce Innovation and Opportunity Act, Data Validation Desk
Reference (provided on August 1, 2024)
• VPL No. 03-14 (April 10, 2014) - Jobs for Veterans’ State Grants (JVSG)
Program Reforms and Roles and Responsibilities of American Job Center
Staff Serving Veterans
• VPL No. 03-14, Change 1, (February 11, 2015) - Expansion and
Clarification of Definition of Significant Barriers to Employment for
Determining Eligibility for the Disabled Veterans’ Outreach Program
• VPL No. 03-14, Change 2, (October 14, 2015) - Expansion and
Clarification of Homeless Definition as a Significant Barrier to Employment
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• VPL No. 03-15 (March 18, 2015) - Applying the Uniform National
Threshold Entered Employment Rate to States' Program Year (PY)
Veterans' Entered Employment Rates to Determine Compliance and
Identify Need for Remedial Actions
• VPL No. 03-19 (February 7, 2019) - Designation of Additional Populations
Eligible for Services from Disabled Veterans’ Outreach Program Specialist
• VPL No. 05-24 (April 25, 2024) - Jobs for Veterans State Grants Staff
Roles and Responsibilities and Coordination with Workforce Innovation
and Opportunity Act Services to Veterans
Prior Relevant Coverage
During the last 14 years, the OIG has issued 2 reports of significant relevance to
the subject of this report, as follows:
1. Kansas’ Controls Over Jobs for Veteran State Grant Contract Reporting
and Monitoring Need To be Strengthened, Report No. 04-11-002-02-201
(March 31, 2011), available at:
https://www.oig.dol.gov/public/reports/oa/2011/04-11-002-02-201.pdf; and
2. VETS’ Oversight of Florida’s Jobs for Veterans State Grants Program
Needs to be Strengthened, Report No. 06-14-001-02-001
(March 27, 2014), available at:
https://www.oig.dol.gov/public/reports/oa/2014/06-14-001-02-001.pdf.
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APPENDIX B: AGENCY’S RESPONSE TO THE REPORT
The agency’s response to our draft report follows.
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U.S. Department of Labor Office of the Assistant Secretary for
Veterans’ Employment and Training
Washington, D.C. 20210
November 14, 2025
MEMORANDUM FOR: Laura B. Nicolosi
Assistant Inspector General for Audit
Office of the Inspector General
FROM: Jessie Jane Duff
Deputy Assistant Secretary for Policy
Veterans’ Employment and Training Service
SUBJECT: Response to the Office of Inspector General (OIG) Draft Audit
Report No. XX-XX-XXX-XX-XXX titled, COVID-19 Minimally Affected
the Jobs for Veterans State Grants Program Amid Weaknesses in
Eligibility Validation Practices
The OIG Draft Audit Report includes three recommendations for the Veterans’ Employment and
Training Service (VETS) consideration. VETS does not concur with two of the
recommendations and partially agrees with the second one. VETS’ response is below.
Recommendation 1 – Strengthen Veterans’ Program Letter No. 05-24 (dated April 25,
2024) to detail the eligibility validation procedures for veterans and eligible persons,
including the source documentation required for eligibility validation outlined in the
Employment and Training Administration’s Training and Employment Guidance
Letter No. 23-19, Change 2, Attachment II (dated May 18, 2023).
VETS does not concur. JVSG operates under statutory authority in 38 U.S.C., which permits
self-attestation and does not require DD-214s or Training and Employment Guidance Letter
(TEGL) documentation. TEGLs are ETA guidance and are not legally binding on JVSG.
Accordingly, requiring Veterans Program Letters (VPLs) to align with TEGLs would impose
standards outside the program’s statutory authority. It is important to note that during the
pandemic, states appropriately relied on self-attestation when access to official records was
restricted due to National Archives closures. Applying TEGL standards to JVSG therefore
mischaracterizes both statutory requirements and the realities of pandemic operations.
Recommendation 2 – Work with the one state and conduct a comprehensive assessment to
determine the full extent of ineligible individuals being recorded as program participants.
1
VETS partially concurs. VETS supports enhanced training and communication with ETA and
state partners to strengthen reporting practices. However, the OIG report does not identify the
state in question. Without disclosure, VETS cannot verify the information or engage with the
state to take corrective action. The issue identified is best understood as a state reporting
anomaly, not a systemic JVSG program weakness.
This conclusion is reinforced by the fact that 12 cases were reviewed in one state, and 11 were
incorrectly coded due to system errors. These individuals were not JVSG participants but instead
received Wagner-Peyser services, which are basic employment services provided to all job
seekers under ETA funding. Treating this undisclosed anomaly—which represents only 0.1
percent of the 9,737 total participants—as a systemic weakness inflates the findings and
mischaracterizes the program. Moreover, the draft inconsistently describes these individuals as
both “not eligible” and “not participants.” If they were not participants, JVSG funds were not
misused. Without disclosure of the state, VETS cannot engage in corrective action, which
undermines the practicality of this recommendation.
Recommendation 3 – Remedy the $8.4 million in unsupported costs from providing
Disabled Veterans’ Outreach Program services between Program Years 2020 and 2022 for
the 11 ineligible individuals and determine the extent of any additional ineligible
individuals the state identifies as having received services during the same period.
VETS does not concur. The $8.4 million is not an audited finding but an extrapolated estimate
derived from the single-state anomaly described above. The calculation relies on SF-425
financial reports, which do not contain participant counts or DVOP-specific
expenditures and therefore cannot substantiate the figure. Furthermore, the sample is statistically
insignificant and cannot be generalized across the program.
The use of the term “remedy” is inappropriate, as it implies repayment or misuse of funds.
Neither condition is supported by the record. The estimate should instead be understood as an
observation about state reporting accuracy, not a quantified financial finding against JVSG.
Characterizing this as a financial liability misrepresents the nature of the data and undermines
confidence in the report’s conclusions.
Additional Observations
Beyond the recommendations, VETS notes that the draft report extends beyond its stated scope.
While the audit was intended to assess COVID-19 impacts, many findings focus on eligibility
validation practices instead. The evidence relied upon was taken from Participant Individual
Record Layout (PIRL) extracts, which are quarterly CSV files intended for performance
reporting. PIRL data were never designed for eligibility validation or to capture full case files.
2
States maintain complete case files in their management information systems, often supported by
scanned or paper records. Treating PIRL extracts as case files is a methodological flaw that
produces incomplete and potentially misleading conclusions.
Finally, VETS emphasizes that the JVSG program operated appropriately during the pandemic
within its statutory authority. States followed federal guidance, including the use of self-
attestation when official documents were unavailable due to National Archives closures. The
central findings of this draft report rest on an anomaly from an unidentified state that VETS
cannot address, and the $8.4 million estimate is not auditable, not representative, and does not
reflect program misuse.
VETS appreciates the opportunity to provide comments on the draft report and looks forward to
continued collaboration with OIG, ETA, and state partners to ensure program integrity and
strengthen reporting practices.
Should you have any questions, please contact Tamim Anwar from my staff at (571) 349-6232.
3
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