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Veterans Affairs: Use of Additional Funding for COVID-19 Relief

Summary

GAO report GAO-21-379 to congressional committees, Veterans Affairs: Use of Additional Funding for COVID-19 Relief, dated May 2021. It states that the Department of Veterans Affairs (VA) received $19.6 billion in supplemental funding in March 2020 under the CARES Act and the Families First Coronavirus Response Act to respond to the COVID-19 pandemic. GAO's analysis of VA data shows that through March 2021 VA had obligated $9.9 billion and expended $8.1 billion of that funding, and that the Consolidated Appropriations Act, 2021 gave VA added flexibility to transfer the funds across the department. The report notes that as of April 14, 2021 VA reported 224,538 cumulative veteran COVID-19 cases and 11,366 deaths.

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             United States Government Accountability Office
             Report to Congressional Committees




             VETERANS AFFAIRS
May 2021




             Use of Additional
             Funding for COVID-19
             Relief




GAO-21-379
                                               May 2021

                                               VETERANS AFFAIRS
                                               Use of Additional Funding for COVID-19 Relief

Highlights of GAO-21-379, a report to
congressional committees




Why GAO Did This Study                         What GAO Found
As of April 14, 2021, VA reported              The Department of Veterans Affairs (VA) received $19.6 billion in supplemental
224,538 cumulative veteran cases of            funding—additional funding above the annual appropriation—in March 2020 to
COVID-19, and 11,366 deaths. The               respond to the COVID-19 pandemic. GAO’s analysis of VA data shows that
CARES Act and Families First                   through March 2021, VA had obligated $9.9 billion and expended $8.1 billion of
Coronavirus Response Act included              the supplemental funding.
supplemental funding for COVID-19
relief, and the Consolidated                   Department of Veterans Affairs (VA) Reported Obligations and Expenditures of CARES Act
Appropriations Act, 2021, permitted VA         and Families First Coronavirus Response Act Funding through March 2021
additional flexibility to transfer these
funds across the department.
The CARES Act also included a
provision for GAO to report on its
ongoing monitoring and oversight
efforts related to the COVID-19
pandemic.
This report examines 1) VA’s
obligations and expenditures of
COVID-19 supplemental funding, as
well as its plans to obligate remaining
funds, and 2) how VA oversees the
use of COVID-19 supplemental funds.
GAO reviewed VA data on obligations,
expenditures, and spend plans for
COVID-19 supplemental funding, as
well as contracting documentation and
documentation on the processes and             Note: An obligation is a definite commitment that creates a legal liability to pay, and an expenditure is
                                               the actual spending of money.
guidance VA developed to oversee the
use of funds. GAO interviewed VA               The majority of the obligated supplemental funding ($8.3 billion) was obligated by
officials responsible for oversight of the     VA’s Veterans Health Administration (VHA) for care provided to veterans by non-
supplemental funding, including                VA providers, the additional costs of salaries (such as for overtime) and related
officials from five regional networks,         expenses of VHA staff, supplies and materials, and support for homeless
selected based on funding levels and           veterans, due to COVID-19 response. The remaining obligations included costs
geography, to gather information about         of VA’s transition to telehealth and telework during the COVID-19 pandemic,
their roles in overseeing the use of and       primarily through the Office of Information Technology (OIT). According to spend
accounting for supplemental funding.           plan documents and department officials, VA plans to obligate its remaining $9.7
VA reviewed a draft of this report and         billion in funding on activities including COVID-19 testing, purchasing supplies
provided a technical comment, which            and equipment, and distributing COVID-19 vaccines.
was incorporated as appropriate.               VA mainly relies on its standard financial management processes to oversee the
                                               use of supplemental funds, including establishing new versions of standard
                                               financial codes to account for and report on use of funds through VA’s financial
                                               system. VA also collected details about the use of supplemental funding, such as
                                               descriptions of the activities for which funds were obligated, that were not
                                               available in its financial system. In addition, the VA components that received the
                                               majority of the supplemental funding—VHA and OIT—set up additional
View GAO-21-379. For more information,
contact Sharon M. Silas at (202) 512-7114 or   processes and issued guidance specific to the use of supplemental funding, such
silass@gao.gov.                                as establishing councils to review funding requests.

                                                                                                  United States Government Accountability Office
Contents


Letter                                                                                           1
                       Background                                                               5
                       VA’s COVID-19 Supplemental Funding Obligations and
                         Expenditures through March 2021                                        9
                       VA Mainly Relies on Its Standard Processes to Oversee the Use
                         of Supplemental Funds, and VHA and OIT Have Established
                         Additional Oversight Processes and Issued Guidance                    17
                       Agency Comments                                                         25

Appendix I             Department of Veterans Affairs’ (VA) Supplemental Funding for
                       COVID-19 Response Appropriations, Transfers, and Net
                       Appropriations                                                          29



Appendix II            Obligations and Expenditures of Department of Veterans Affairs’ (VA)
                       Supplemental Funding for COVID-19 Response                           32



Appendix III           Veterans Health Administration’s (VHA) Allocation of Supplemental
                       Funding for COVID-19 Response                                           34



Appendix IV            Department of Veterans Affairs’ (VA) Financial and Contracting Codes
                       for COVID-19 Obligations and Expenditures                            36



Appendix V             Comments from the Department of Veterans Affairs                        40



Appendix VI            GAO Contact and Staff Acknowledgments                                   41



Related GAO Products                                                                           42




                       Page i                                           GAO-21-379 Veterans Affairs
Tables
          Table 1: Supplemental Funding Appropriated to the Department of
                  Veterans Affairs (VA) by the CARES Act and the Families
                  First Coronavirus Response Acta                                  7
          Table 2: Department of Veterans Affairs’ (VA) Reported
                  Appropriations, Transfers, and Net Appropriations of
                  Supplemental Funding for COVID-19 Response, as of
                  March 2021                                                      30
          Table 3: Department of Veterans Affairs’ (VA) Supplemental
                  Funding for COVID-19 Response, Net Appropriations,
                  and Reported Obligations and Expenditures of as of
                  March 2021                                                      32
          Table 4: Veterans Health Administration’s (VHA) Allocation of
                  Supplemental Funds for COVID-19 from the CARES Act
                  and the Families First Coronavirus Response Act
                  (FFCRA) as of March 2021a                                       34

Figures
          Figure 1: Amount of Department of Veterans Affairs’ (VA) COVID-
                   19 Supplemental Funding Obligated and Expended as of
                   March 2021 (in billions)                                       10
          Figure 2: Department of Veterans Affairs’ (VA) COVID-19
                   Supplemental Funding and Reported Obligations and
                   Expenditures through March 2021                                12
          Figure 3: Veterans Health Administration’s (VHA) Obligations of
                   COVID-19 Supplemental Funding through February 2021
                   (in millions)                                                  14
          Figure 4: Department of Veterans Affairs, Office of Information
                   Technology (OIT) Obligations of COVID-19 Supplemental
                   Funding through February 2021 (in millions)                    16
          Figure 5: Contract Documentation for a Contract Partially Funded
                   by COVID-19 Supplemental Funds                                 37
          Figure 6: Screenshots of VA’s Contracting System for a Contract
                   Partially Funded by COVID-19 Supplemental Funds                38
          Figure 7: Screenshot of Federal Procurement Data System-Next
                   Generation (FPDS-NG) for a Contract Partially Funded
                   by COVID-19 Supplemental Funds                                 39




          Page ii                                          GAO-21-379 Veterans Affairs
Abbreviations

COVID-19          Coronavirus Disease 2019
FFCRA             Families First Coronavirus Response Act
FMS               Financial Management System
FPDS-NG           Federal Procurement Data System-Next Generation
OIG               Office of Inspector General
OIT               Office of Information Technology
VA                Department of Veterans Affairs
VBA               Veterans Benefits Administration
VERA              Veterans Equitable Resource Allocation
VHA               Veterans Health Administration
VISN              Veterans Integrated Service Network




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Page iii                                                       GAO-21-379 Veterans Affairs
                       Letter




441 G St. N.W.
Washington, DC 20548




                       May 5, 2021

                       Congressional Committees

                       The Department of Veterans Affairs (VA) operates one of the largest
                       health care systems in the United States and is charged with providing
                       health care services to the nation’s eligible veterans and beneficiaries
                       through the Veterans Health Administration (VHA). VHA, like the U.S.
                       health care system in general, has been stressed and has adapted its
                       clinical operations to respond to the Coronavirus Disease 2019 (COVID-
                       19), including shifting some care to telehealth. As of April 14, 2021, VA
                       reported 224,538 cumulative veteran cases of COVID-19, including 4,458
                       active cases, and 11,366 deaths. We have previously reported on VA’s
                       efforts to increase its capacity to deliver COVID-19 care for veterans,
                       through efforts such as hiring staff for VA medical centers and increasing
                       telehealth services. 1

                       In addition to health care services, VA provides other services and
                       benefits through its components. 2 The Veterans Benefits Administration
                       (VBA) provides compensation and pension, education, and other benefits
                       to veterans, and operations for some of these activities have also been
                       affected by COVID-19, such as medical exams required for certain benefit
                       programs.

                       In March 2020, the Families First Coronavirus Response Act (FFCRA)
                       and the CARES Act collectively appropriated about $19.6 billion to VA in
                       supplemental funding—that is, additional funding above VA’s annual




                       1GAO, COVID-19: Federal Efforts Could Be Strengthened by Timely and Concerted
                       Actions, GAO-20-701 (Washington, D.C.: Sept. 21, 2020). GAO, COVID-19: Critical
                       Vaccine Distribution, Supply Chain, Program Integrity, and Other Challenges Require
                       Focused Federal Attention, GAO-21-265 (Washington, D.C.: Jan. 28, 2021).
                       2For 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.




                       Page 1                                                         GAO-21-379 Veterans Affairs
appropriation—for COVID-19 relief. 3 While the majority of the funding was
to support the provision of health care services, this funding also supports
information technology systems, administration of veterans’ benefits,
general administration, and oversight of VA’s response to COVID-19 by
the Office of Inspector General (OIG). The CARES Act requires VA to
submit monthly reports to Congress detailing the obligations,
expenditures, and planned activities related to the use of supplemental
funding. 4

The CARES Act also includes a provision for GAO to conduct monitoring
and oversight of the federal government’s efforts to prepare for, respond
to, and recover from the COVID-19 pandemic, including reporting on the
use of funds made available under the CARES Act or any other law for
these purposes. 5

In this report, we

1. describe VA’s obligations and expenditures of COVID-19
   supplemental funding, as well as plans for obligating remaining funds,
   and


3The CARES Act, Pub. L. No. 116-136, div. B, tit. X, 134 Stat. 281, 583 (2020), and the
Families First Coronavirus Response Act, Pub. L. No. 116-127, div. A, tit. VI, 134 Stat.
178, 183 (2020). In March 2021, the American Rescue Plan Act of 2021 appropriated an
additional $17 billion to VA for COVID-19 relief, including $14.48 billion for medical care
and health needs. Pub. L. No. 117-2, tit. VIII, 135 Stat. 4, 112-117 (2021). Due to the
timing of enactment of the American Rescue Plan Act of 2021, review of this funding is
outside the scope of this performance audit. 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 FFCRA and the CARES Act 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).
4An 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. GAO-05-734SP
5Pub. L. No. 116-136, § 19010, 134 Stat. at 579-81. We regularly issue government-wide
reports on the federal response to COVID-19. For the latest report, see GAO, COVID-19:
Sustained Federal Action Is Crucial as Pandemic Enters Its Second Year, GAO-21-387
(Washington, D.C.: Mar. 31, 2021). Our next government-wide report will be issued in July
2021 and will be available on GAO’s website at https://www.gao.gov/coronavirus.




Page 2                                                            GAO-21-379 Veterans Affairs
2. assess how VA oversees the use of COVID-19 supplemental funds.

To describe VA’s obligations and expenditures of COVID-19
supplemental funding, as well as plans for obligating remaining funds, we
collected and reviewed data from VA’s Financial Management System
(FMS) provided by the VA Office of Management that included total
obligations and expenditures as of March 31, 2021. 6 We also reviewed
data as of February 28, 2021, from VHA, the Office of Information
Technology (OIT), VBA, and OIG on their obligations of COVID-19
supplemental funding by programmatic activity, and VHA’s allocations of
its supplemental funding. According to VA officials, obligation data
provided by these components may vary from the obligations reported by
the VA Office of Management, as component obligation data do not
reflect high-level adjustments made at the department level. Finally, we
reviewed spend plans from the above named offices indicating future
planned obligations by activity. We assessed the reliability of the VA data
on obligations, expenditures, and allocations by reviewing related
documentation, checking for missing values and outliers, and interviewing
officials knowledgeable of the data. As a result of these steps, we
determined that the data were sufficiently reliable for the purpose of
reporting on actual and future planned obligations, allocations, and actual
expenditures.

To assess how VA oversees the use of COVID-19 supplemental funds,
we reviewed documents describing financial codes used to record
transactions in FMS, contracting codes for VA’s contracting system, and
standard reporting requirements for VA components that received
COVID-19 supplemental funding. We reviewed guidance VA developed to
communicate the activities for which supplemental funding may be used
and the appropriate codes to record financial transactions related to
supplemental funding. We also reviewed documentation of oversight
processes such as council meetings, dashboard displays used to monitor
use and availability of funding, and memos and emails requesting the use
of supplemental funds.

We reviewed 12 VA contracts including 10 national contracts and two
regional contracts. We selected 10 national contracts that had the highest
total obligations between March and August 2020 with the COVID-19

6FMS is used to track obligations and prevent offices from obligating amounts that are
greater than the funds they have available. FMS is VA’s primary mechanism to track and
monitor the use of all funds, including the COVID-19 supplemental funding.




Page 3                                                        GAO-21-379 Veterans Affairs
National Interest Action code in the Federal Procurement Data System-
Next Generation (FPDS-NG). 7 We sought variation based on the
contracting office associated with the contract by selecting no more than
two contracts for each contracting office code. To obtain perspectives
from regional staff, we also reviewed two regional contracts that were
selected by a related GAO engagement. 8 For each selected contract, we
reviewed contract documentation and interviewed contracting officers and
relevant VA officials who were knowledgeable about the financial codes
for the selected contracts. We also reviewed FMS financial codes
provided by VA for the 10 national contracts. This selection is not
intended to be representative of all VA contracts related to COVID-19, nor
did we review whether the appropriate appropriation was used to fund the
contracts. We selected the contracts to provide illustrative examples
about how VA coded the selected COVID-19 contracts.

For our assessment of how VA oversees the use of COVID-19
supplemental funds we relied on federal internal control standards. 9 We
determined that the monitoring and information and communication
components were significant to our objective, including the underlying
principles that management should (1) establish and operate monitoring
activities to monitor the internal control system and evaluate results, and
(2) internally communicate the necessary quality information to achieve
the agency’s objectives. To assess VA’s monitoring activities, we
reviewed documentation on processes VA developed specifically to
oversee the supplemental funding to determine whether they would allow
for separate accounting of and reporting on the use of supplemental
funding, and provide VA with information including the amount of
supplemental funding it has obligated to date, the amount remaining, and
the purposes for which supplemental funding has been used. To assess
VA’s internal communication of quality information, we assessed the

7The FPDS-NG is a publicly facing data system that provides information on federal
contracts at or above the micro purchase threshold (generally $10,000, although it is
increased to $20,000 to support response to emergencies or major disasters inside the
United States). National Interest Action codes track federal procurements for specific
disasters, emergencies, or contingency events, such as the COVID-19 pandemic.
8We selected two contracts that had been awarded by Network Contracting Offices with
the COVID-19 National Interest Action code in FPDS-NG. The related engagement
describes VA’s procurement response for COVID-19. We plan to issue the report in spring
2021.
9Internal control is a process effected by an entity’s oversight body, management, and
other personnel that provides reasonable assurance that the objectives of an entity will be
achieved. GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: September 2014).




Page 4                                                         GAO-21-379 Veterans Affairs
             means by which VA communicated guidance to its various components.
             We focused on assessing the processes and guidance VA developed to
             conduct oversight of the use of COVID-19 supplemental funding, and did
             not evaluate the extent to which offices and facilities adhered to them.

             For both objectives, we interviewed agency officials, including officials
             from the VHA Office of Finance, which is responsible for all VHA financial
             management and accounting operations, the Office of Community Care,
             which oversees health care services delivered by non-VA providers to
             veterans and eligible beneficiaries, and five of VHA’s 18 Veterans
             Integrated Service Networks (VISN), which are responsible for managing
             and overseeing VA medical centers within their networks. We identified
             the nine VISNs that had received the highest allocations of supplemental
             funding from VHA as of August 2020, based on ordering the VISNs from
             highest to lowest allocations. We then selected five VISNs of the nine,
             considering the region of the country in which each VISN is located to
             ensure geographic diversity. While not generalizable to all VISNs, these
             five selected VISNs accounted for 37 percent of funding allocated to
             VISNs as of that time.

             We interviewed officials within the VA Office of Management, which
             oversees the budget and financial management on behalf of the entire
             department, including officials from the Financial Services Center within
             the Office of Management, who are responsible for accounting services
             and financial reports. We interviewed officials from the Office of
             Information Technology, which oversees information technology
             development and infrastructure on behalf of the department. 10

             We conducted this performance audit from August 2020 to May 2021 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.

             Each year, VA submits a budget justification to Congress to support the
Background   President’s budget request. Following enactment of its annual
             appropriations by Congress, VA allocates funding to the various


             10We did not interview VBA or OIG staff for this engagement since those offices received
             a relatively small amount of supplemental funding.




             Page 5                                                       GAO-21-379 Veterans Affairs
components responsible for carrying out its mission to support veterans,
such as VHA. VHA then allocates funding to the VISNs and VA medical
centers that provide care to veterans. Staff in VISN and VA medical
center finance offices are then responsible for managing the funding,
including recording obligations, in VA’s financial management system—
FMS.

Use of FMS by VA program and finance officials is one aspect of the
department’s financial management, and helps ensure that VA’s
obligations and expenditures stay within authorized budget limits.
According to VA officials, FMS prevents VA components from entering
obligations into the system in amounts greater than the funds they have
available. VA’s financial management processes also generally require
funds be expended solely for the purposes for which they were
appropriated. VA’s policies related to funding oversight further note that
VA will maintain Treasury-approved appropriation accounts for
accounting and reporting on program activities; VA establishes specific
codes in FMS to enable this accounting and reporting. These general
processes apply to the agency’s annual appropriations as well as the
supplemental funding VA received to respond to COVID-19.

In fiscal year 2020, VA’s annual budget exceeded $200 billion, most of
which supported health care administered by VHA and benefits
administered by VBA. In addition, the CARES Act and FFCRA, both
enacted in March 2020, appropriated a total of $19.6 billion to a number
of existing VA appropriation accounts to prevent, prepare for, and
respond to COVID-19, and to support COVID-19 testing. For instance, the
CARES Act and FFCRA appropriated funding to existing VHA
appropriation accounts through which VHA funds care to veterans:

•   The Medical Services appropriation account funds clinical operations
    of VA medical centers, including staff salaries, pharmacy, and medical
    equipment.
•   The Medical Community Care appropriation account funds claims for
    care by non-VA providers, also called community care.
•   The Medical Support and Compliance appropriation account generally
    funds administration of VA medical centers.
•   The Medical Facilities appropriation account funds facility-related
    costs including maintenance, leases, and energy costs.

The CARES Act also provided funding to existing VA appropriation
accounts for construction grants to states for extended care facilities,


Page 6                                               GAO-21-379 Veterans Affairs
                                              OIT’s development and operations of information technology systems,
                                              OIG’s oversight of VA’s COVID-19 response, and general operations of
                                              VBA and the department as a whole (see table 1). Most of the funding
                                              appropriated to VA in the CARES Act is available through September 30,
                                              2021, though the CARES Act funding for the OIG and funds appropriated
                                              in FFCRA are available through September 30, 2022.

Table 1: Supplemental Funding Appropriated to the Department of Veterans Affairs (VA) by the CARES Act and the Families
First Coronavirus Response Acta

                                                                                                                   Percentage of total
                                                                                          Appropriation amount          supplemental
                                                                                                 ($ in millions)       appropriations
CARES Act
Veterans Health Administration (VHA)b                                                                  17,388.0                   88.6
     Medical Community Carec                                                                             2,100.0                  10.7
     •   Supports an increased demand for care in the community, including
         emergency room and urgent care.
     Medical Support and Compliancec                                                                      100.0                    0.5
     •  Supports VHA’s 24-hour emergency management coordination, including
        overtime, travel, transportation of materials, and training.
     Medical Servicesc                                                                                 14,432.0                   73.5
     •  Supports increased demand for health care services, including telehealth,
        purchase of medical equipment and supplies—including personal
        protective equipment—and to provide additional support to vulnerable
        veterans, such as those experiencing or at-risk of homelessness.
     Medical Facilitiesc                                                                                  606.0                    3.1
     •  Supports development of alternative sites of care, improvements in
        security, and reconfiguration of existing spaces to support care.
     Grants for Construction of State Extended Care Facilitiesc                                           150.0                    0.8
     •   Supports modification or alteration of existing facilities to prevent, prepare
         for, and respond to COVID-19.
Office of Information Technologyd                                                                        2,150.0                  11.0
•   Supports increased telework, telehealth, and call center capabilities, including
    purchase of devices and system bandwidth.
Veterans Benefits Administrationd                                                                          13.0                    0.1
•   Supports increased telework and enhanced cleaning contracts.
Office of Inspector General                                                                                12.5                    0.1
•   Supports oversight of VA’s efforts to prevent, prepare for, and respond to
    COVID-19.
General Administration                                                                                       6.0                  <0.1
•  Expands and maintains 24-hour operations of crisis response and continuity of
   operation plan, as well as expands cleaning and sanitation services.
CARES Act total                                                                                        19,569.5                   99.7




                                              Page 7                                                        GAO-21-379 Veterans Affairs
                                                                                                                                                Percentage of total
                                                                                                                       Appropriation amount          supplemental
                                                                                                                              ($ in millions)       appropriations
Families First Coronavirus Response Act
Medical Services                                                                                                                        30.0                    0.2
•  Provides $30 million to VHA’s Medical Services account to fund costs related to
   COVID-19 testing in VA medical centers.
Medical Community Care                                                                                                                  30.0                    0.2
•  Provides $30 million to VHA’s Medical Community Care account for costs
   related to COVID-19 testing through non-VA providers, called community care.
Families First Coronavirus Response Act total                                                                                           60.0                    0.3
Total, VA COVID-19 supplemental funding                                                                                             19,629.5                   100
Source: CARES Act, FFRCA, and Senate Appropriations Committee summary of COVID-19 supplemental funding. | GAO-21-379

                                                            Note: Amounts may not total due to rounding.
                                                            a
                                                             The CARES Act, Pub. L. No. 116-136, div. B, tit. X, 134 Stat. 281, 583 (2020), and the Families First
                                                            Coronavirus Response Act, Pub. L. No. 116-127, div. A, tit. VI, 134 Stat. 178, 183 (2020). Senate
                                                            Appropriations Committee, $340 Billion Surge in Emergency Funding to Combat Coronavirus
                                                            Outbreak, accessed February 24, 2021,
                                                            https://www.appropriations.senate.gov/download/coronavirus-emergency-supplemental-
                                                            appropriations-summary.
                                                            b
                                                             VHA is funded through several appropriation accounts with the following 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. VHA also administers an annual appropriation for
                                                            construction grants to states for extended care facilities.
                                                            c
                                                              These amounts are subtotals of the total CARES Act funding appropriated to VHA, and are already
                                                            reflected in the VHA total of $17.388 billion.
                                                            d
                                                             The Veterans Benefits Administration received supplemental funding in its General Operating
                                                            Expenses appropriation account, and the Office of Information Technology received supplemental
                                                            funding through the Information Technology Systems appropriation account.


                                                            VHA has some flexibility to transfer funding appropriated in the CARES
                                                            Act to respond to changing circumstances related to COVID-19 and
                                                            veterans’ needs for health care during the pandemic. For example, VHA
                                                            may transfer funding from appropriation accounts for clinical care to those
                                                            for administrative purposes or from appropriation accounts for care
                                                            provided in VA medical centers to the appropriation account for
                                                            community care within certain parameters. Under the CARES Act, VHA
                                                            received the authority to transfer funds among four of its appropriation
                                                            accounts—Medical Services, Medical Community Care, Medical Support
                                                            and Compliance, and Medical Facilities—for amounts of 2 percent or less
                                                            of the appropriated amounts 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. Specifically,




                                                            Page 8                                                                       GAO-21-379 Veterans Affairs
                      •   the Continuing Appropriations Act, 2021 and Other Extensions Act,
                          enacted in October 2020, permitted $140 million of VHA’s Medical
                          Services appropriation provided in the CARES Act to be transferred to
                          the Canteen Services Revolving Fund due to revenue losses
                          experienced during COVID-19, 11 and
                      •   the Consolidated Appropriations Act, 2021, enacted in December
                          2020, further allowed for $410 million of VHA’s CARES Act
                          appropriation to be transferred to VBA, OIT, the National Cemetery
                          Administration, and the Board of Veterans Appeals. 12
                      See appendix I for more information on transfers of CARES Act funding.

                      Total VA obligations and expenditures. Our analysis of VA data shows
VA’s COVID-19         that as of March 31, 2021, VA obligated $9.9 billion and expended $8.1
Supplemental          billion of the $19.6 billion appropriated to the department in COVID-19
                      supplemental funding. 13 Approximately $9.7 billion remained available for
Funding Obligations   obligation. (See fig. 1.) According to VA’s spend plans, it intends to
and Expenditures      obligate nearly all remaining funds in fiscal year 2021. 14
through March 2021



                      11Pub. L. No. 116-159, § 163, 134 Stat. 709, 722 (2020).

                      12The Consolidated Appropriations Act, 2021, enacted in December of 2020, permits VA
                      to transfer $338 million from VHA to VBA, $26 million from VHA to the National Cemetery
                      Administration, $45 million from VHA to OIT, and $1 million from VHA to the Board of
                      Veterans Appeals. The Act also authorizes VHA to transfer $100 million from its Medical
                      Services account, which is used to fund care in VA medical centers, to its Medical
                      Community Care account, which is used to fund community care, to support payments to
                      state extended care facilities for veterans. Pub. L. No. 116-260, div. J, tit. V, §§ 514, 515,
                      517, 134 Stat. 1182, 1689-1691 (2020).
                      13COVID-19 supplemental funding refers both to funding appropriated in the CARES Act
                      as well as the FFCRA. 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. We plan to issue a
                      report on our review of VA’s procurement response for COVID-19, including the amount of
                      funding obligated for COVID-19 related contracts, in spring 2021.
                      14While most supplemental funding is available for obligation through fiscal year 2021,
                      CARES Act funding for OIG and funds appropriated in FFCRA are available through
                      September 30, 2022.




                      Page 9                                                           GAO-21-379 Veterans Affairs
Figure 1: Amount of Department of Veterans Affairs’ (VA) COVID-19 Supplemental
Funding Obligated and Expended as of March 2021 (in billions)




Note: 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.


VA was slower to obligate funding in the initial months following receipt of
supplemental funds than later in fiscal year 2020. Before VA could
obligate supplemental funding, it needed to set up new accounting codes
specific to the supplemental funding and allocate the funding. VA initially
coded some COVID-19 related expenses as obligations of annual
appropriations, and later recoded those expenses as obligations of
supplemental funding when the funds became available. 15 Further, OIT
experienced delays related to the hiring process for additional personnel,
which also contributed to the initial slow growth in the obligations and
expenditures of these funds.

According to officials, obligations and expenditures of supplemental
COVID-19 funding increased significantly in August through September
2020 for two primary reasons. First, VA’s Office of General Counsel
provided updated guidance in August 2020 clarifying that supplemental
funds for VHA’s community care program could be obligated for a wider


15VA officials referred to the process of recoding obligations as a cost transfer. We did not
review whether the cost transfers were legally appropriate.




Page 10                                                                GAO-21-379 Veterans Affairs
range of services than permitted under the original guidance. 16 Second,
part of the increase reflected a recoding of VHA obligations for COVID-19
related purposes that had been charged to the annual appropriations prior
to August 2020. According to VA officials, VHA was able to recode these
obligations and instead charge them to the supplemental funding as part
of the agency’s fiscal year 2020 end-of-year close out activities,
contributing to the increase in obligations of supplemental funding in
August and September. 17

Obligations and expenditures of COVID-19 supplemental funding leveled
off from October to December. VHA officials explained that as of early
December, they had not yet allocated funding from all supplemental
funding appropriation accounts to VISNs, and were waiting to make
transfer decisions until they knew VHA’s final annual appropriation for
fiscal year 2021. 18 Officials expected obligations to increase through the
remainder of fiscal year 2021 due to continued hiring and facility
improvements. (See fig. 2.) See appendix II for an overview of obligations
and expenditures of VA’s supplemental funding.




16VHA originally obligated supplemental funding for Medical Community Care only when
claims contained procedure or diagnostic codes related to testing, laboratory costs,
pharmaceuticals, and health care costs related to COVID-19. In August 2020, VHA
received guidance from its Office of General Counsel that this funding could be used more
broadly because providers and veterans were more often choosing community care to
reduce potential COVID-19 exposure and travel for veterans who otherwise would receive
care in VA medical centers.
17In addition to recoding that occurred as part of end-of-year close out, VHA regularly
recodes obligations from annual appropriations to supplemental funding for salaries and
awards related to COVID-19 response. These transactions generally occur every two
weeks when supplemental funding is available, according to VHA officials.
18VA’s appropriation for fiscal year 2021 was enacted as part of the Consolidated
Appropriations Act, 2021 on December 27, 2020. Pub. L. No. 116-260, div. J, tit. II, 134
Stat, 1182, 1665 (2020).




Page 11                                                        GAO-21-379 Veterans Affairs
Figure 2: Department of Veterans Affairs’ (VA) COVID-19 Supplemental Funding and Reported Obligations and Expenditures
through March 2021




                                        Note: 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.
                                        a
                                         In some instances, VA initially obligated annual appropriations for COVID-19 related activities, and
                                        later recoded the obligations as supplemental funding.




                                        Page 12                                                                GAO-21-379 Veterans Affairs
VHA obligations and expenditures. VA data show that VHA obligated
$8.3 billion (49 percent) and expended $6.9 billion (41 percent) of its
$17.0 billion net appropriations for COVID-19 supplemental funding as of
March 31, 2021. 19 This includes both amounts that were allocated to
VISNs and medical centers and amounts obligated for national level
activities. For more information about VHA’s allocation of COVID-19
supplemental funding, see appendix III.

VHA’s own data show that as of February 28, 2021—the most recent
VHA data available at the time of our analysis—the largest source of VHA
obligations were for community care. 20 The majority of other obligations
were for the additional costs of salaries and related expenses, supplies
and materials, and support for homeless veterans due to responding to
the pandemic. (See fig. 3.) According to VHA guidance, supplemental
funding obligations for salary costs should only reflect additional costs
due to the pandemic response, such as for overtime or for staff
reassigned to another position, and not regular duties that may involve
caring for veterans with COVID-19. Officials we spoke with from two
VISNs used a similar approach to determine whether to use supplemental
funding for COVID-19 related activities and to assess whether needs
were beyond what would typically be purchased under normal
circumstances.




19VHA was originally appropriated $17.4 billion under the CARES Act and FFCRA. We are
reporting obligations and expenditures based on the amounts remaining after VHA
transferred $408 million to other VA components, as permitted by the Continuing
Appropriations Act, 2021 and Other Extensions Act, and the Consolidated Appropriations
Act, 2021.
20Obligations for specific VHA activities as of March 31, 2021, were not yet available at
the time of our analysis.




Page 13                                                         GAO-21-379 Veterans Affairs
Figure 3: Veterans Health Administration’s (VHA) Obligations of COVID-19
Supplemental Funding through February 2021 (in millions)




Notes: Figure 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, 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.
a
 The “Other” category reflects obligations for activities including emergency management, travel and
transportation, facilities, communication, rent, and utilities.


Plans for remaining VHA funds: According to VHA’s supplemental
funding spend plan and VHA Office of Finance officials, VHA intends to
use the remaining CARES Act supplemental funding for COVID-19
related activities in fiscal year 2021, including for vaccine distribution,
personal protective equipment, and COVID-19 testing. For example, from
March 2021 through the end of fiscal year 2021, VHA intends to obligate
$110 million for personal protective equipment. At the time of our review,




Page 14                                                                   GAO-21-379 Veterans Affairs
VHA Office of Finance officials did not have a spend plan estimate for
vaccine distribution or COVID-19 testing. 21

Office of Information Technology obligations and expenditures. Our
review of VA data shows that as of March 31, 2021, OIT obligated $1.4
billion (65 percent) and expended $1.0 billion (47 percent) of the over
$2.1 billion in supplemental funding it received from the CARES Act. 22
The CARES Act required VA to provide a spend plan detailing how much
of the supplemental funds appropriated for information technology it
intended to use for information technology systems development,
operations and maintenance of systems, and pay and associated costs.
OIT-specific data show that as of February 28, 2021—the most recent
OIT data available at the time of our analysis—OIT obligated over $1.1
billion of its CARES Act funding for operations and maintenance activities
related to COVID-19, such as enabling expanded telehealth and telework
throughout VA. 23 (See fig. 4.)




21Our latest government-wide report on the federal response to COVID-19 includes an
enclosure on VA’s vaccination efforts. See GAO-21-387, 109.
22The CARES Act appropriated $2.15 billion in supplemental funding for VA’s information
technology systems. Pub. L. No. 116-136, div. B, tit. X, 134 Stat. at 584 (2020). VHA
subsequently transferred an additional $45 million in CARES Act funding to OIT based on
authority in the Consolidated Appropriations Act, 2021.
23We requested OIT obligations for specific activities as of February 28, 2021, consistent
with availability of obligation data from VHA. For more information on VA’s use of
telehealth during the pandemic, see GAO-21-265, 124.




Page 15                                                        GAO-21-379 Veterans Affairs
Figure 4: Department of Veterans Affairs, Office of Information Technology (OIT)
Obligations of COVID-19 Supplemental Funding through February 2021 (in millions)




Note: An obligation is a definite commitment that creates a legal liability of the government for the
payment of goods and services ordered or received.


Plans for remaining OIT funds: According to the agency’s spend plan
for its supplemental funding, as of February 2021, OIT intends to obligate
the remaining supplemental funding in fiscal year 2021. Key activities
include additional equipment ($283 million), network capacity ($257
million), and software licenses ($52 million) necessary to support
increased staffing and telework. OIT officials explained that the spend
plan reflects estimated spending and may change as the pandemic
evolves.

Other VA obligations and expenditures. VBA, OIG, and the Office of
Human Resources and Administration/Office of Operations, Security, and
Preparedness—funded by general administration funds—obligated $105




Page 16                                                                  GAO-21-379 Veterans Affairs
                       million in supplemental funding through March 31, 2021. 24 Funds were
                       primarily used for additional staff or staff overtime, cleaning and hygiene
                       costs, and equipment related to increased telework related to COVID-19.
                       Through March 2021

                       •   OIG obligated $12.5 million (100 percent) and expended over $11
                           million (90 percent) of its supplemental funding.
                       •   VBA obligated nearly $90 million (40 percent) and expended $36
                           million (16 percent), of its supplemental funding.
                       •   The Office of Human Resources and Administration/ Office of
                           Operations, Security, and Preparedness obligated $2.3 million (39
                           percent) and expended $1.7 million (29 percent) of its supplemental
                           funding.
                       VA mainly relies on its standard financial management processes to
VA Mainly Relies on    oversee the use of COVID-19 supplemental funds—such as establishing
Its Standard           specific financial codes in FMS to enable accounting and reporting of
                       program activities within appropriation accounts. In addition, the VA
Processes to           components that received the majority of the supplemental funding—VHA
Oversee the Use of     and OIT—set up processes and issued guidance specifically to oversee
                       the use of these funds.
Supplemental Funds,
and VHA and OIT
Have Established
Additional Oversight
Processes and
Issued Guidance

                       24The CARES Act appropriated $13 million in supplemental funding for VBA, $12.5 million
                       for OIG, and $6 million for general administration, which funds the Office of Human
                       Resources and Administration/ Office of Operations, Security, and Preparedness. Pub. L.
                       No. 116-136, div. B, tit. X, 134 Stat. at 582-584 (2020). The Consolidated Appropriations
                       Act, 2021 authorized an additional $338 million in supplemental funding to be transferred
                       to VBA from VHA’s CARES Act appropriation for Medical Services, and $210 million of
                       that amount has been transferred as of March 31, 2021. Pub. L. No. 116-260, div. J, tit. V,
                       §§ 514-515, 134 Stat. at 1689-90. According to VA officials, VBA intends to obligate the
                       transferred funding to continue veterans’ education benefits during COVID-19 and reduce
                       backlogs in processing veterans’ disability claims. For more information on VBA disability
                       claims backlog, see GAO-21-265, 205. Since 2003, improving VA’s disability programs
                       has been on GAO’s High Risk list. While VA has made progress in reducing the disability
                       claims backlog, the pandemic has contributed to the recent increase in backlogged claims.




                       Page 17                                                       GAO-21-379 Veterans Affairs
VA Mainly Oversees the   Based on our review of VA documentation and interviews with VA
Use of Supplemental      officials, we found that VA mainly oversees the use of COVID-19
                         supplemental funds through its standard financial management
Funding through Its
                         processes. These processes include using its financial management
Standard Financial       system—FMS—to record obligations and expenditures of supplemental
Management Processes     funding and report on the use of this funding. We reviewed these
                         processes in the context of federal standards for internal control related to
                         monitoring and communication. 25 Specifically:

                         •   According to federal internal control standards, management should
                             establish and operate activities to monitor the internal control system
                             and evaluate the results. We found that VA established specific codes
                             in FMS to account for and report on its COVID-19 related obligations
                             and expenditures and developed a process to track data not available
                             through FMS. This process allowed VA to monitor transaction-level
                             details of the use of supplemental funding and develop summary
                             reports for departmental leadership, the Office of Management and
                             Budget, and Congress.
                         •   Federal internal control standards also state that management should
                             internally communicate the necessary quality information to achieve
                             the entity’s objectives. We found that the VA Office of Management
                             communicated guidance to financial officers of its components—such
                             as VHA and OIT—about how they should record financial information
                             for COVID-19 related obligations and expenditures through VA-wide
                             guidance documents, consistent with its standard practices.

                         Although we did not evaluate the extent to which VA’s components
                         adhered to the processes developed to oversee supplemental funding,
                         we did not observe non-adherence to these processes based on our
                         review of nongeneralizable samples of five VISNs and the financial
                         coding of 10 national contracts. While we did not identify examples of
                         non-adherence to VA’s financial management processes, we note that
                         VA’s annual financial statement audit for fiscal year 2020 identified five
                         material weaknesses in internal control, including one related to financial
                         systems and reporting resulting from an outdated legacy financial




                         25GAO-14-704G




                         Page 18                                              GAO-21-379 Veterans Affairs
                               system. 26 Additionally, VA’s OIG has reported that VHA’s financial
                               management practices did not include financial controls necessary to
                               promote the efficient use of financial resources at its VISNs and medical
                               centers. 27

VA Oversight of Supplemental   VA mainly uses FMS to oversee the use of COVID-19 supplemental
Funding through Financial      funding, as it does for all appropriations, by recording obligations and
Systems                        expenditures against the various appropriation accounts. 28 According to
                               VA officials, data from FMS are used to generate reports reviewed by
                               senior VA leadership, as well as for weekly reports to Congress to track
                               the use of supplemental funding. 29

                               In addition to using FMS, VA also set up a process to collect certain
                               transaction-level data not available through FMS as part of its oversight
                               specific to the supplemental funding. Components that received
                               supplemental funding submit data, such as the description of the activity
                               or purchase and the obligation amount, to a central repository on a
                               weekly or bi-weekly basis. VA officials explained that this process is
                               necessary in part because many details at the transaction level cannot be
                               captured by FMS when obligations originally charged to annual
                               appropriations are recoded and charged to the COVID-19 supplemental


                               26This material weakness was related to FMS in general, and was not specific to
                               supplemental funding. VA’s annual financial statement audit includes findings from an
                               independent auditor regarding VA’s financial statements, compliance with internal controls
                               over financial reporting, and compliance with applicable laws and regulations. Department
                               of Veterans Affairs, Agency Financial Report, Fiscal Year 2020. (Washington, D.C.: Nov.
                               24, 2020).
                               27Department of Veterans Affairs, Office of Inspector General, Veterans Health
                               Administration: Financial Management Practices Can Be Improved to Promote the
                               Efficient Use of Financial Resources. (Sept. 2, 2020).
                               28FMS was implemented in 1992. According to VA’s financial statement audit for fiscal
                               year 2020, FMS has limited functionality to meet certain financial management and
                               reporting needs and producing auditable financial statements requires significant manual
                               interventions. Although VA is in the process of updating its financial system through the
                               Financial Management Business Transformation initiative, full implementation of the
                               system across all of VA is not expected until 2027.
                               29VA is also subject to oversight of its funds through its annual financial statement audit.
                               The fiscal year 2020 annual financial statement audit included review of COVID-19
                               supplemental funds that had been obligated in that year. VA’s OIG evaluates the
                               department’s financial management practices to reduce the risk of fraud, waste, and
                               abuse, and according to OIG officials, review of VHA’s use of COVID-19 supplemental
                               funding will be included in a forthcoming report.




                               Page 19                                                          GAO-21-379 Veterans Affairs
funding. 30 VA uses the data captured through the separate process for
oversight purposes, including reports to the Office of Management and
Budget on the use of supplemental funding, and according to officials will
retain the information to support national level inquiries on issues that
may be raised in the future.

New FMS codes. VA uses financial codes to track funds in FMS as part
of its oversight processes. VA primarily relied on two types of financial
codes to track COVID-19 related obligations for purposes of oversight:
those used to track the purpose for which the funding is being used
(accounting classification codes) and those used to denote the
appropriation account from which funds are obligated (FMS appropriation
fund codes). 31 VA established new versions of these codes in a manner
consistent with oversight of other VA funds. 32

In the beginning of the pandemic, VA used available funding in its annual
appropriation accounts to fund its response to COVID-19. VA set up
COVID-19 accounting classification codes to identify annual
appropriations used for this purpose and communicated these codes in
VA-wide guidance on March 13, 2020. Each of VA’s components, such as
VHA and OIT, was assigned a specific code. (See appendix IV for
accounting classification codes for VA components.) Officials from the
Financial Services Center said that all VA components were to use the


30According to VA, due to limitations in FMS, obligations for certain activities, such as
salaries and certain purchases related to COVID-19, cannot be obligated directly to the
supplemental funding. They are obligated to the annual appropriation and then recoded
and charged to the COVID-19 supplemental funding, freeing up the annual appropriation
for other operating costs. Other COVID-19 related obligations were similarly charged to
annual appropriations prior to the allocation of supplemental funding and later recoded
and charged to supplemental funding.
31VA’s accounting classification codes identify programs, projects, or activities, and are
used in FMS. For example, there is an accounting classification code for the Office of
Electronic Health Record Modernization. VA also maintains Treasury-approved
appropriation fund codes to account for the use of appropriated funds in each
appropriation account. Appropriation accounts encompass a number of activities or
projects and may be subject to restrictions or conditions applicable to only the account or
the appropriations act.
32Further, VA established Disaster Emergency Fund Codes for tracking COVID-19
supplemental funding, as required by the Office of Management and Budget. See Office of
Management and Budget, Implementation Guidance for Supplemental Funding Provided
in Response to the Coronavirus Disease 2019 (COVID-19), OMB M-20-21 (April 10,
2020).




Page 20                                                         GAO-21-379 Veterans Affairs
                          accounting classification codes for COVID-19 obligations and
                          expenditures immediately.

                          Once Congress appropriated supplemental funding to VA for COVID-19,
                          VA began using a different type of financial code, starting in April 2020, to
                          identify its obligations of supplemental funding, according to VA officials.
                          Specifically, VA’s Financial Services Center modified VA’s existing FMS
                          appropriation fund codes to identify obligations funded by the CARES Act
                          or FFCRA. (See appendix IV for details). Some components, such as
                          VHA, continue to use the COVID-19 accounting classification codes when
                          obligating annual appropriations for COVID-19 related purposes. For
                          example, in the event that a VA medical center had not yet received its
                          supplemental appropriation allocation, it may obligate funds from annual
                          appropriations and recode the obligations once it received its allocation,
                          according to VA officials. 33 Officials from the Financial Services Center
                          said they include transactions with the COVID-19 related accounting
                          classification codes and FMS appropriation fund codes when reporting
                          FMS data for internal and external stakeholders, including the Congress.

VA Processes for Coding   In addition to using financial codes to oversee the use of COVID-19
Contracts for Oversight   supplemental funding, VA used contracting codes in its contracting
                          system and the publicly available Federal Procurement Data System-Next
                          Generation (FPDS-NG) to oversee COVID-19-related contract
                          obligations.

                          •   VA’s contracting system. VA used existing processes to identify
                              contracts related to its COVID-19 response in its contracting system.
                              VA issued VA-wide guidance on coding all existing and planned
                              contracts related to COVID-19 in VA’s contracting system on March
                              19, 2020. Contracts supporting COVID-19 are also identified in VA’s
                              contracting system by coding them with a special management code,
                              which is used internally to track specific contracts of interest, such as
                              those funded with COVID-19 supplemental funding.
                          •   FPDS-NG. OMB guidance requires agencies to assign the COVID-19
                              National Interest Action code to all procurement actions reported into
                              FPDS-NG that are issued in response to the pandemic. This includes
                              new awards for supplies and services as well as modifications that are
                              issued to address COVID-19, irrespective of whether the contract

                          33Officials explained that similar recoding occurs on a normal basis, and is not specific to
                          the supplemental funding.




                          Page 21                                                         GAO-21-379 Veterans Affairs
                              being modified was originally awarded to address COVID-19. 34
                              Contracting codes within VA’s contracting system feeds data to the
                              publicly available FPDS-NG.

                          There are instances where contracts are partly funded by COVID-19
                          supplemental funds. Within VA’s contracting system, these contracts are
                          also coded with the internal special management code used for all
                          COVID-19 contracts. Additionally, contracting officers said they use
                          another data field to document the amount obligated from COVID-19
                          supplemental funds, ensuring that line items using non-COVID-19 funds
                          are not tracked as part of COVID-19 supplemental fund obligations. 35
                          (See appendix IV for more details).

VHA and OIT Established   The VA components that received the majority of the supplemental
Additional Oversight      funding—VHA and OIT—set up additional oversight processes and
                          issued guidance specific to the use of COVID-19 supplemental funds.
Processes and Issued
                          This is consistent with VA’s general approach to establish department-
Guidance on the Use of    wide processes and issue guidance for financial management, but to rely
COVID-19 Supplemental     on the components that were appropriated the funding to implement the
Funding                   processes.

                          VHA. VHA provided guidance to its VISNs and VA medical centers to
                          oversee the use of COVID-19 supplemental funding. 36 Guidance included
                          information on the appropriate use of supplemental funding and
                          instructions on how to apply accounting classification codes and
                          appropriation fund codes. For example, the guidance states the following:

                          •   It is appropriate for VISNs to use supplemental funding to procure
                              lodging for employees providing direct care to COVID-19 patients.




                          34Office of Management and Budget, Implementation Guidance for Supplemental Funding
                          Provided in Response to the Coronavirus Disease 2019 (COVID-19), OMB M-20-21 (April
                          10, 2020).
                          35Within FPDS-NG, the National Interest Action code is applied to contracts that are
                          related to COVID-19 regardless of the source of funds. FPDS-NG data may include
                          contract obligations for goods and services that are not COVID-19 related if a contract is
                          partially funded by COVID-19 supplemental funds. The General Services Administration
                          manages FPDS-NG. OMB issues guidance on the use of the National Interest Action code
                          in FPDS-NG.
                          36VHA Office of Finance COVID-19 Questions and Answers, September 14, 2020 Update.




                          Page 22                                                       GAO-21-379 Veterans Affairs
•   VA medical centers should use the COVID-19 accounting
    classification code when obligating annual appropriations for activities
    related to COVID-19 response. 37
•   Staff salaries should be funded by their original appropriation account
    even if the staff are reassigned to a different department to assist with
    COVID-19 response activities.

Officials we interviewed from the five selected VISNs pointed to this
guidance as their primary source of information for overseeing the use of
supplemental funds. Some VISN officials explained that the guidance
provided by VHA’s Office of Finance is updated with responses to
questions that VISN officials may bring up during regular calls with VHA
or through email inquiries.

As noted above, VHA’s Office of Finance provided guidance on the
appropriate use of supplemental funding but primarily relies on VISNs to
determine how to apply that guidance to oversee the use of the funds,
consistent with standard practice. Officials from four of the selected
VISNs we interviewed told us they monitor obligation trends across their
medical centers using standard reports. VISNs also discussed the
processes they set up to oversee the appropriate use of supplemental
funding such as leadership council reviews of requests for funding. Some
examples include:

•   Officials we interviewed from the five VISNs told us that they oversee
    the use of COVID-19 supplemental funding using a template
    containing transaction-level details of COVID-19 obligations for each
    VA medical center, which is reviewed weekly. For example, according
    to officials from one VISN, if a description of an item related to an
    obligation was not clearly COVID-19 related, the officials would gather
    further details from the VA medical center.




37VA used both its annual and supplemental appropriations for COVID-19 related
activities. In the event that a VA medical center had not yet received its supplemental
appropriation allocation, VHA’s Deputy Chief Financial Officer said that VA medical center
may obligate funds from annual appropriations and recode the obligation after it receives
its allocation.




Page 23                                                       GAO-21-379 Veterans Affairs
Veterans Integrated Service Network                       •   According to officials from one of the selected VISNs, the VISN
(VISN) Council to Approve Use of COVID-                       requires COVID-19 supplemental funding requests exceeding a
19 Supplemental Funds                                         certain dollar threshold to be reviewed by its Chief Logistics Officer,
The Chief Financial Officer from one of our                   the Chief Medical Officer, and the Deputy Network Director to ensure
selected VISNs provided an example of how
its VISN leadership council considered a                      that the requests are COVID-19 related. (See sidebar.)
medical center’s request for supplemental
funding. The request for funding to convert               •   According to officials from another VISN, the VISN also had its
existing hospital rooms for use by COVID-19                   Financial Quality Assurance Manager conduct an audit of its COVID-
patients included costs for a previously
identified repair that was unrelated to the
                                                              19 related obligations and rectified issues found through that audit,
COVID-19 response. In this case, the cost                     such as the hours related to COVID-19 salaries not being provided
related to the previously identified repair was               along with the salary dollar amounts.
funded through annual appropriations and the
remaining renovation costs were funded
through supplemental funds.                               VHA’s Deputy Chief Financial Officer explained that the use of
Source: GAO interview with VISN officials. | GAO-21-379   supplemental funding obligated at the headquarters level, such as for
                                                          national contracts, requires approval by the Deputy’s office. VHA
                                                          guidance states that requests to use supplemental funds are to be
                                                          submitted to a specific email group for review and approval. VHA’s
                                                          Deputy Chief Financial Officer said that there was not specific guidance
                                                          about what information should be included in the requests but said VHA
                                                          staff are asked to explain what the supplemental funds would be used for,
                                                          the time frame, and the amount needed.

                                                          Oversight processes for the supplemental funding in the Medical
                                                          Community Care appropriation account are handled differently than the
                                                          processes described above. The VHA Office of Community Care uses
                                                          national claim payment data to identify claims for services that can be
                                                          appropriately recorded to the COVID-19 supplemental funding, and VA’s
                                                          Financial Services Center recodes the related expenditures from annual
                                                          appropriations to COVID-19 supplemental funding. 38 According to VA, the
                                                          Office of Community Care identifies claims with COVID-19-related
                                                          procedure and diagnostic codes, as well as claims that meet the criteria
                                                          identified in revised guidance provided by VA’s Office of General
                                                          Counsel, which states that COVID-19 supplemental funds can be used for
                                                          a wider range of services than permitted under previous guidance. The
                                                          Office of Community Care’s COVID-19 guidance has detailed information
                                                          on the services that can be appropriately charged to COVID-19
                                                          supplemental funding.


                                                          38The Office of Community Care uses this process for supplemental Medical Community
                                                          Care funds it received under both the CARES Act and FFCRA. The VHA Office of Finance
                                                          uses a similar process to obligate funding through national-level transactions that recode
                                                          obligations or expenditures charged to the Medical Services account from annual
                                                          appropriations to supplemental funding provided by FFCRA.




                                                          Page 24                                                       GAO-21-379 Veterans Affairs
                  Officials explained that the national process was designed to ensure
                  consistency and timely processing while minimizing the burden on VISNs
                  and VA medical centers. VISNs and VA medical centers continue to have
                  a role in overseeing the supplemental funding, including through
                  monitoring account balances to ensure they have sufficient funds to cover
                  the obligations made at the national level by the Office of Community
                  Care; according to Office of Community Care guidance, FMS will reject
                  the obligations if accounts have insufficient funding.

                  OIT. OIT developed a new approval process and provided related
                  guidance to oversee the use of supplemental funds, including for
                  contracts. According to OIT guidance, in May 2020, OIT set up a COVID-
                  19 Information Technology Council with a committee focused on funding
                  to ensure supplemental funds are being used for appropriate purposes.
                  The council consists of senior management, including the Chief
                  Technology Officer, Deputy Chief Information Officers, and the Chief of
                  Staff. 39 OIT guidance explains that staff are to request approval from the
                  Chief Information Officer to use supplemental funds by documenting their
                  business case in a memo template.

                  OIT officials said that they communicated information about financial
                  codes to oversee the use of supplemental funds during standard calls and
                  meetings, including bi-weekly calls with relevant OIT staff. OIT also uses
                  dashboards to track the status of COVID-19 supplemental funding
                  obligations, and according to OIT officials, these are tracked on a daily
                  basis. One such dashboard displays key performance indicators, such as
                  planned and actual obligations for certain projects, which are used by OIT
                  leadership in its oversight of funds, according to OIT officials. Officials
                  said that another tool tracks OIT’s use of COVID-19 supplemental funding
                  by spend plan category, and serves as a repository for documentation
                  related to supplemental funding approval to support audits and other
                  oversight.

                  In a written response, reprinted in appendix V, VA stated that it had a
Agency Comments   technical comment on the draft report, which we incorporated as
                  appropriate.




                  39OIT officials said that they have also sometimes consulted their Office of General
                  Counsel on requests to use supplemental funding that were not clearly discussed in the
                  COVID-19 guidance.




                  Page 25                                                        GAO-21-379 Veterans Affairs
We are sending copies of this report to the appropriate congressional
committees, the Secretary of Veterans Affairs, and other interested
parties. In addition, the report is available at no charge on GAO’s website
at http://www.gao.gov/.

If you or your staff have any questions about this report, please contact
me at (202) 512-7114 or silass@gao.gov. Contact points for our Office of
Congressional Relations and Office of Public Affairs can be found on the
last page of this report. Other major contributors to this report are listed in
appendix VI.




Sharon M. Silas
Director, Health Care




Page 26                                               GAO-21-379 Veterans Affairs
Congressional Committees

The Honorable Patrick Leahy
Chairman
The Honorable Richard Shelby
Vice Chairman
Committee on Appropriations
United States Senate

The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate

The Honorable Patty Murray
Chair
The Honorable Richard Burr
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Gary C. Peters
Chairman
The Honorable Rob Portman
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Jon Tester
Chairman
The Honorable Jerry Moran
Ranking Member
Committee on Veterans’ Affairs
United States Senate

The Honorable Rosa L. DeLauro
Chairwoman
The Honorable Kay Granger
Ranking Member
Committee on Appropriations
House of Representatives


Page 27                                        GAO-21-379 Veterans Affairs
The Honorable Frank Pallone, Jr.
Chairman
The Honorable Cathy McMorris Rodgers
Republican Leader
Committee on Energy and Commerce
House of Representatives

The Honorable Bennie G. Thompson
Chairman
The Honorable John Katko
Ranking Member
Committee on Homeland Security
House of Representatives

The Honorable Carolyn B. Maloney
Chairwoman
The Honorable James R. Comer
Ranking Member
Committee on Oversight and Reform
House of Representatives

The Honorable Mark Takano
Chairman
The Honorable Mike Bost
Ranking Member
Committee on Veterans’ Affairs
House of Representatives

The Honorable Richard Neal
Chair
The Honorable Kevin Brady
Republican Leader
Committee on Ways and Means
House of Representatives

The Honorable Julia Brownley
Chairwoman
Subcommittee on Health
Committee on Veterans’ Affairs
House of Representatives




Page 28                                GAO-21-379 Veterans Affairs
Appendix I: Department of Veterans Affairs’
               Appendix I: Department of Veterans Affairs’
               (VA) Supplemental Funding for COVID-19

(VA) Supplemental Funding for COVID-19
               Response: Appropriations, Transfers, and Net
               Appropriations


Response: Appropriations, Transfers, and
Net Appropriations
               The CARES Act provided authority for the Veterans Health Administration
               (VHA) to transfer funds among four of its appropriation accounts to
               prevent, prepare for, and respond to COVID-19. 1 VHA has used this
               authority to transfer $3.7 billion from its Medical Services account to its
               Medical Community Care ($3.4 billion), Medical Facilities ($100 million),
               and Medical Support and Compliance ($225 million) accounts through
               March 31, 2021.

               Subsequent legislation, specifically, the Continuing Appropriations Act,
               2021, and Other Extensions Act, enacted in October 2020, permitted up
               to $140 million to be transferred from VHA’s Medical Services
               appropriation to the Canteen Services Revolving Fund. 2 Funds
               transferred to the Canteen Services Revolving Fund were to account for
               revenue lost during the COVID-19 pandemic. The Consolidated
               Appropriations Act, 2021, enacted in December 2020, further allowed for
               $410 million appropriated by the CARES Act to be transferred from VHA
               to other VA components. 3 As of March 31, 2021, VHA had transferred
               funding to the Veterans Benefits Administration ($210 million), Office of
               Information Technology ($45 million), the National Cemetery
               Administration ($12 million), and the Board of Veterans Appeals ($1
               million). VHA also transferred $100 million from its CARES Act
               appropriation for Medical Services to its appropriation for Medical
               Community Care based on the authority in the Consolidated
               Appropriations Act, 2021. See table 2 for the initial supplemental
               appropriation amount and transfers to other accounts.




               1Pub. L. No. 116-136, div. B, tit. X, § 20001, 134 Stat. 281, 585 (2020).

               2Pub. L. No. 116-159, § 163, 134 Stat. 709, 722 (2020).

               3The Consolidated Appropriations Act, 2021, enacted in December of 2020, permits VA to
               transfer $338 million from VHA to Veterans Benefits Administration, $26 million from VHA
               to the National Cemetery Administration, $45 million from VHA to Office of Information
               Technology, and $1 million from VHA to the Board of Veterans Appeals. The Act also
               authorizes VHA to transfer $100 million from VHA’s Medical Services account, which is
               used to fund care in VA medical centers, to VHA’s Medical Community Care account,
               which is used to fund community care, to support payments to state extended care
               facilities for veterans. Pub. L. No. 116-260, div. J, tit. V, §§ 514, 515, 517, 134 Stat. 1182,
               1689-1691 (2020).




               Page 29                                                           GAO-21-379 Veterans Affairs
                                                               Appendix I: Department of Veterans Affairs’
                                                               (VA) Supplemental Funding for COVID-19
                                                               Response: Appropriations, Transfers, and Net
                                                               Appropriations




Table 2: Department of Veterans Affairs’ (VA) Reported Appropriations, Transfers, and Net Appropriations of Supplemental
Funding for COVID-19 Response, as of March 2021

                                                                                                                Transfers to Other Accounts
                                                                        Appropriations                              Amount                      Net appropriations
 VA component, or account                                                 ($ in millions)                    ($ in millions)a                        ($ in millions)
 CARES Actb
 Veterans Health Administration (total)                                          17,388.0                              -408.0                              16,980.0
 Medical Community Carec                                                           2,100.0                            3,500.0                               5,600.0
 Medical Support and Compliancec                                                      100.0                             225.0                                 325.0
 Medical Servicesc                                                               14,432.0                            -4,233.0                              10,199.0
 Medical Facilitiesc                                                                  606.0                             100.0                                 706.0
 Extended Care Grantsc                                                                150.0                                   -                               150.0
 Office of Information Technologyd                                                 2,150.0                               45.0                               2,195.0
 Canteen Services Revolving Fund                                                            -                           140.0                                 140.0
 Veterans Benefits Administratione                                                     13.0                             210.0                                 223.0
 Office of Inspector General                                                           12.5                                   -                                12.5
 National Cemetery Administration                                                           -                            12.0                                  12.0
 General Administration                                                                  6.0                                  -                                  6.0
 Board of Veterans Appeals                                                                  -                              1.0                                   1.0
 CARES Act total                                                                 19,569.5                                    -                             19,569.5
 Families First Coronavirus Response Actf
 Medical Services                                                                      30.0                                   -                                30.0
 Medical Community Care                                                                30.0                                   -                                30.0
 Families First Coronavirus                                                            60.0                                   -                                60.0
 Response Act total
 Total, VA supplemental funding                                                  19,629.5                                     -                            19,629.5
Source: GAO analysis of VA data, CARES Act, Families First Coronavirus Response Act. | GAO-21-379

                                                               Note: In March 2021, the American Rescue Plan Act of 2021 appropriated an additional $17 billion to
                                                               VA for COVID-19 relief, including $14.48 billion for medical care and health needs. Pub. L. No. 117-2,
                                                               tit. VIII, 135 Stat. 4, 112-117 (2021). Due to the timing of enactment of the American Rescue Plan
                                                               Act of 2021, review of this funding is outside the scope of this performance audit.
                                                               a
                                                                As of March 31, 2021, VA has transferred $4.2 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), and the Consolidated Appropriations Act, 2021, Pub.
                                                               L. No. 116-260, div. J, tit. V, §§ 514-515, 134 Stat. at 1689-90.
                                                               b
                                                                   CARES Act, Pub. L. No. 116-136, div. B, tit. X, 134 Stat. 281, 583 (2020).
                                                               c
                                                                These amounts are subtotals of the total CARES Act funding appropriated to VHA, and are already
                                                               reflected in the VHA total of $17.388 billion.
                                                               d
                                                                The Office of Information Technology received supplemental funding in its Information Technology
                                                               Systems appropriation account.
                                                               e
                                                                The Veterans Benefits Administration received supplemental funding in its General Operating
                                                               Expenses appropriation account.




                                                               Page 30                                                                   GAO-21-379 Veterans Affairs
Appendix I: Department of Veterans Affairs’
(VA) Supplemental Funding for COVID-19
Response: Appropriations, Transfers, and Net
Appropriations




f
 Families First Coronavirus Response Act, Pub. L. No. 116-127, div. A, tit. VI, 134 Stat. 178, 183
(2020).




Page 31                                                                GAO-21-379 Veterans Affairs
Appendix II: Obligations and Expenditures of
                                         Appendix II: Obligations and Expenditures of
                                         Department of Veterans Affairs’ (VA)

Department of Veterans Affairs’ (VA)
                                         Supplemental Funding for COVID-19 Response




Supplemental Funding for COVID-19
Response
                                         The Veterans Health Administration and the Office of Information
                                         Technology—the two VA components that received the majority of VA’s
                                         supplemental funding under the CARES Act and Families First
                                         Coronavirus Response Act—were responsible for more than 98 percent
                                         of VA’s $9.9 billion in obligations of this funding through March 2021. The
                                         Veterans Benefits Administration, Canteen Services Revolving Fund,
                                         Office of Inspector General, and the Office of Human Resources and
                                         Administration/Office of Operations, Security, and Preparedness—funded
                                         by general administration funds— accounted for the remaining $181
                                         million in obligations of supplemental funding. 1 See table 3 below for
                                         obligations and expenditures for VA’s COVID-19 supplemental funding.

Table 3: Department of Veterans Affairs’ (VA) Supplemental Funding for COVID-19 Response, Net Appropriations, and
Reported Obligations and Expenditures of as of March 2021

                                                                  Obligations                             Expenditures
                                                                               Percentage                               Percentage
                                                Net                                  of net                                  of net
                                    appropriations                          appropriations                           appropriations
VA component or account             ($ in millions)a      ($ in millions)        obligated         ($ in millions)       expended
CARES Act Supplemental Fundsb
Veterans Health Administration
(total)                                    16,980.0              8,245.3                48.6              6,870.7               40.5
 Medical Community Carec,d                  5,600.0              2,099.0                37.5              2,040.7               36.4
Medical Support and
Complianced                                   325.0                159.3                49.0                121.4               37.3
 Medical Servicesd                         10,199.0              5,551.9                54.4              4,394.6               43.1
 Medical Facilitiesd                          706.0                435.1                61.6                314.0               44.5
 Extended Care Grantsd,e                      150.0                     -                   -                    -                  -
Office of Information Technologyf           2,195.0              1,430.9                65.2              1,037.9               47.3
Canteen Services Revolving
Fund                                          140.0                 76.0                54.3                 76.0               54.3
Veterans Benefits Administrationg             223.0                 89.8                40.3                 35.5               15.9

                                         1The CARES Act appropriated $13 million in supplemental funding for VBA, $12.5 million
                                          for OIG, and $6 million for general administration, which funds the Office of Human
                                          Resources and Administration/Office of Operations, Security, and Preparedness. Pub. L.
                                          No. 116-136, div. B, tit. X, 134 Stat. at 582-584 (2020). The Continuing Appropriations Act,
                                          2021, and Other Extensions Act, enacted in October 2020, permitted up to $140 million to
                                          be transferred from VHA’s Medical Services appropriation to the Canteen Services
                                          Revolving Fund. Pub. L. No. 116-159, § 163, 134 Stat. 709, 722 (2020). The Consolidated
                                          Appropriations Act, 2021 authorized an additional $338 million in supplemental funding to
                                          be transferred to VBA from VHA’s CARES Act appropriation for Medical Services, and
                                          $210 million of that amount has been transferred as of March 31, 2021. Pub. L. No. 116-
                                          260, div. J, tit. V, §§ 514-515, 134 Stat. at 1689-90.




                                         Page 32                                                         GAO-21-379 Veterans Affairs
                                                               Appendix II: Obligations and Expenditures of
                                                               Department of Veterans Affairs’ (VA)
                                                               Supplemental Funding for COVID-19 Response




                                                                                                    Obligations                           Expenditures
                                                                                                               Percentage                                 Percentage
                                                                   Net                                               of net                                    of net
                                                       appropriations                                       appropriations                             appropriations
 VA component or account                               ($ in millions)a              ($ in millions)             obligated       ($ in millions)           expended
 Office of Inspector General                                            12.5                         12.5            100.0                      11.3              90.4
 National Cemetery Administration                                       12.0                            -                 -                        -                    -
 General Administration                                                  6.0                          2.3             38.7                       1.7              29.1
 Board of Veterans Appeals                                               1.0                            -                 -                        -                    -
 CARES Act total                                                   19,569.5                    9,856.9                50.4               8,033.1                  41.0
 Families First Coronavirus Response Act Supplemental Fundsh
 Medical Services                                                       30.0                         30.0            100.0                      29.0             96.7
 Medical Community Care                                                 30.0                         12.4             41.3                      12.4             41.3
 Families First Coronavirus
 Response Act total                                                     60.0                         42.4             70.7                      41.4              69.0
 Total, VA Supplemental
 Funding                                                           19,629.5                    9,899.3                50.4               8,074.6                  41.1
Source: GAO analysis of VA data, CARES Act, Families First Coronavirus Response Act. | GAO-21-379

                                                               Note: According to VA officials, VA obligation data reported by the VA Office of Management may
                                                               differ from obligation data provided by components, such as the Veterans Health Administration and
                                                               the Office of Information Technology, as VA data may reflect high-level adjustments made at the
                                                               department level. In March 2021, the American Rescue Plan Act of 2021 appropriated an additional
                                                               $17 billion to VA for COVID-19 relief, including $14.48 billion for medical care and health needs. Pub.
                                                               L. No. 117-2, tit. VIII, 135 Stat. 4, 112-117 (2021). Due to the timing of enactment of the American
                                                               Rescue Plan Act of 2021, review of this funding is outside the scope of this performance audit.
                                                               a
                                                                The net appropriation reflects VA’s transfer of $4.2 billion out of the Medical Services account. Of
                                                               that amount, VA transferred $3.5 billion to Medical Community Care, $100 million to Medical
                                                               Facilities, $225 million to Medical Support and Compliance, $210 million to the Veterans Benefits
                                                               Administration, $45 million to the Office of Information Technology, $12 million to the National
                                                               Cemetery Administration, and $1 million to the Board of Veterans Appeals.
                                                               b
                                                                   CARES Act, Pub. L. No. 116-136, div. B, tit. X, 134 Stat. 281, 583 (2020).
                                                               c
                                                                Obligations for Medical Community Care funding are nearly equal to expenditures as obligations and
                                                               expenditures for claims payments are recorded at the same time.
                                                               d
                                                                These amounts are subtotals of the total CARES Act funding appropriated to VHA, and are already
                                                               reflected in the VHA net appropriation total of $16.98 billion.
                                                               e
                                                                   Extended Care Grants are expected to be awarded in fiscal year 2021.
                                                               The Office of Information Technology received supplemental funding in its Information Technology
                                                               f

                                                               Systems appropriation account.
                                                               g
                                                                The Veterans Benefits Administration received supplemental funding in its General Operating
                                                               Expenses appropriation account.
                                                               h
                                                                Families First Coronavirus Response Act, Pub. L. No. 116-127, div. A, tit. VI, 134 Stat. 178, 183
                                                               (2020).




                                                               Page 33                                                                   GAO-21-379 Veterans Affairs
Appendix III: Veterans Health                    Appendix III: Veterans Health Administration’s
                                                 (VHA) Allocation of Supplemental Funding for

Administration’s (VHA) Allocation of
                                                 COVID-19 Response




Supplemental Funding for COVID-19
Response
                                                 Through March 31, 2021, VHA allocated $11.8 billion of the $17.0 billion
                                                 in net appropriations provided under the CARES Act and Families First
                                                 Coronavirus Response Act to its Veterans Integrated Service Networks
                                                 (VISN) and medical centers. The allocations were made in these four
                                                 VHA appropriation accounts—Medical Community Care, Medical Support
                                                 and Compliance, Medical Services, and Medical Facilities. For a
                                                 description of the methods VHA used to allocate supplemental funding,
                                                 see table 4.

Table 4: Veterans Health Administration’s (VHA) Allocation of Supplemental Funds for COVID-19 from the CARES Act and the
Families First Coronavirus Response Act (FFCRA) as of March 2021a

                                                                                                                                         Allocation
CARES Act supplemental funds                                                                                                         ($ in millions)
VHA Medical Community Care                                                                                                                   2,100.0
•  Funds allocated based on claims submitted for care in the community related to COVID-19 or due
   to increased demand for community care based on desire to reduce COVID-19 transmission.
VHA Medical Support and Compliance                                                                                                             211.1
•  Funds allocated based on Veterans Equitable Resource Allocation (VERA) and the contracts
   approved for supporting COVID-19 related activities.
VHA Medical Services                                                                                                                         8,874.5
•  Allocated $5.3 billion to the 18 VISNs based on hospital bed capacity in VA medical centers’
   intensive care and medical/surgical units in addition to the VERA methodology; $1.7 billion was
   retained for national-level activities.b Additional allocations to VISNs were based on need.
VHA Medical Facilities                                                                                                                         548.0
•  Funds allocated based on VERA and costs associated with facility updates to support COVID-19
   related activities.
CARES Act total                                                                                                                            11,733.6
FFCRA supplemental funds                                                                                                                        60.0
•  $30 million in Medical Services used at a national level to fund costs related to COVID-19 testing
   in VA medical centers.
•  $30 million in Medical Community Care used for claims related to COVID-19 testing through non-
   VA providers.
Total, VHA COVID-19 supplemental funding allocations                                                                                       11,793.6
Source: GAO analysis of VHA data. | GAO-21-379
                                                 a
                                                  Amounts include allocations for national-level activities as well as amounts allocated to Veterans
                                                 Integrated Service Networks (VISN) and VA medical centers. Allocations are from the $17.0 billion in
                                                 net appropriations to VHA from the CARES Act and FFCRA.
                                                 b
                                                  Most funding for VHA health care is allocated to the VISNs and local 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, VERA, 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 centers using different methodologies, including a workload-based model for community




                                                 Page 34                                                              GAO-21-379 Veterans Affairs
Appendix III: Veterans Health Administration’s
(VHA) Allocation of Supplemental Funding for
COVID-19 Response




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).


VHA permitted VISNs discretion to determine how to allocate Medical
Services, Medical Support and Compliance, and Medical Facilities funds
to the VA medical centers they manage. 1 According to officials from the
five VISNs we interviewed, their VISNs allocated the funds

•   using the standard Medical Center Allocation System model used to
    allocate VHA’s annually appropriated funds, 2
•   mirroring the national CARES Act allocation formula that accounted
    for both patient workload and bed capacity,
•   by allocating a set amount to each VA medical center and
    replenishing funds as needed, or
•   through hybrids of the above-described approaches.




1Funds for Medical Community Care were allocated through a national-level process
based on claims for payment submitted for care in the community related to COVID-19 or
due to increased demand for community care based on desire to reduce COVID-19
transmission.
2The Medical Center Allocation System model allocates each VISN’s general purpose
funds—as determined by VERA—to the medical centers within each of the 18 VISNs. For
more information on how the Medical Center Allocation System is used to allocate 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).




Page 35                                                            GAO-21-379 Veterans Affairs
Appendix IV: Department of Veterans Affairs’
                    Appendix IV: Department of Veterans Affairs’
                    (VA) Financial and Contracting Codes for


(VA) Financial and Contracting Codes for
                    COVID-19 Obligations and Expenditures




COVID-19 Obligations and Expenditures
Financial Codes     Accounting Classification Codes. VA established COVID-19
                    accounting classification codes to identify obligations and expenditures
                    against annual appropriations. There were specific codes for VA
                    components, such as:

                    •   ND02D2001 for the Veterans Health Administration
                    •   ND02D2002 for the Veterans Benefits Administration
                    •   ND02D2005 for the Office of Information Technology.
                    FMS Appropriation Fund codes. VA used appropriation fund codes to
                    track COVID-19 obligations and expenditures against supplemental
                    funding. The first four digits of the six-digit code identify the appropriation
                    account, such as for Medical Community Care or Medical Services. VA
                    officials said that they modified the last two digits of the appropriation fund
                    account to identify the use of supplemental funds. For example,

                    •   0160A1 is the FMS appropriation account for Medical Services funds
                        from VA’s annual appropriation.
                    •   0160C2 is the same account, except that it is for supplemental
                        appropriations provided by the CARES Act. VA officials said that the
                        number two indicates that the funding is available for 2 fiscal years.
                    •   0160C3 is the same account, except that it is for supplemental
                        appropriations provided by the Families First Coronavirus Response
                        Act. VA officials said that the number three indicates that the funding
                        is available for 3 fiscal years.
                    Example of financial codes applied to specific contracts: VA used
                    contract A to purchase management consulting services for VA’s
                    response to COVID-19, such as estimating the expected disease burden
                    of COVID-19 and surveillance of the healthcare landscape. This contract
                    was signed in mid-March 2020 and is therefore coded with the COVID-19
                    accounting classification code (ND02D2001) and the appropriation fund
                    code for the annual appropriations to the Medical Support and
                    Compliance account (0152A1). In contrast, VA used contract B to
                    purchase isolation gowns in August 2020 and did not use the COVID-19
                    accounting classification code. The appropriation fund code for this
                    contract corresponds to the COVID-19 supplemental funds in the Medical
                    Services account (0160C2).

Contracting Codes   VA’s contracting system can also be used to identify COVID-19-related
                    obligations internally and publicly. In VA’s contracting system, VA staff
                    can code COVID-19 contracts with the “COVID-19” special management



                    Page 36                                               GAO-21-379 Veterans Affairs
                                       Appendix IV: Department of Veterans Affairs’
                                       (VA) Financial and Contracting Codes for
                                       COVID-19 Obligations and Expenditures




                                       code. VA’s contracting system can also track multiple line items for
                                       contracts that are partially funded with supplemental funds. In the publicly
                                       available Federal Procurement Data System-Next Generation, COVID-19
                                       related contract actions should have the “COVID-19 2020” National
                                       Interest Action code.

                                       Example of contracts partially funded by COVID-19 supplemental
                                       funds: Three of the contracts we reviewed were partially funded by
                                       COVID-19 supplemental funds (see Figure 5 for an example).

Figure 5: Contract Documentation for a Contract Partially Funded by COVID-19 Supplemental Funds




                                       Within VA’s contracting system, VA can track contracts that are partially
                                       funded with COVID-19 supplemental funds as being related to COVID-19
                                       through the use of the special management code. VA’s contracting
                                       system is also able to track that there are two sources of funding for this
                                       contract and the specific obligation amounts for each funding source (see
                                       Figure 6).




                                       Page 37                                                    GAO-21-379 Veterans Affairs
                                        Appendix IV: Department of Veterans Affairs’
                                        (VA) Financial and Contracting Codes for
                                        COVID-19 Obligations and Expenditures




Figure 6: Screenshots of VA’s Contracting System for a Contract Partially Funded by COVID-19 Supplemental Funds




                                        Page 38                                                GAO-21-379 Veterans Affairs
                                        Appendix IV: Department of Veterans Affairs’
                                        (VA) Financial and Contracting Codes for
                                        COVID-19 Obligations and Expenditures




                                        In FPDS-NG, this contract is coded with the “COVID-19 2020” National
                                        Interest Action code, consistent with VA’s contracting system. 1 Figure 7
                                        shows how this contract is coded in FPDS-NG.

Figure 7: Screenshot of Federal Procurement Data System-Next Generation (FPDS-NG) for a Contract Partially Funded by
COVID-19 Supplemental Funds




                                        1We previously reported that the USASpending.gov website discloses that not all
                                        contracts with the COVID-19 National Interest Action code are tied to COVID-19
                                        supplemental funding. GAO-20-701.




                                        Page 39                                                      GAO-21-379 Veterans Affairs
Appendix V: Comments from the Department
             Appendix V: Comments from the Department
             of Veterans Affairs


of Veterans Affairs




             Page 40                                    GAO-21-379 Veterans Affairs
Appendix VI: GAO Contact and Staff
                  Appendix VI: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  Sharon M. Silas, (202) 512-7114 or silass@gao.gov
GAO Contact
                  In addition to the contact named above, Michael Zose, Assistant Director;
Staff             Heather Tompkins, Analyst-in-Charge; Britt Carlson; Joy Kim; Emily
Acknowledgments   Loriso; Teague Lyons; and Jocelyn Yin made key contributions to this
                  report. Also contributing were Jennie F. Apter, Jacquelyn Hamilton,
                  Caroline Johnson, Shelby S. Oakley, and Vikki Porter.




                  Page 41                                           GAO-21-379 Veterans Affairs
Related GAO Products
             Related GAO Products




             COVID-19: Sustained Federal Action is Crucial as Pandemic Enters Its
             Second Year, GAO-21-387. Washington, D.C.: March 31, 2021.

             COVID-19: Critical Vaccine Distribution, Supply Chain, Program Integrity,
             and Other Challenges Require Focused Federal Attention, GAO-21-265.
             Washington, D.C.: January 28, 2021.

             COVID-19: Federal Efforts Could Be Strengthened by Timely and
             Concerted Actions, GAO-20-701. Washington, D.C.: September 21, 2020.

             VA Health Care: Additional Steps Could Help Improve Community Care
             Budget Estimates. GAO-20-669. Washington, D.C.: September 30, 2020.

             Veterans Health Care: VA Needs to Improve Its Allocation and Monitoring
             of Funding. GAO-19-670. Washington, D.C.: September 23, 2019.

             VA Health Care: Estimating Resources Needed to Provide Community
             Care. GAO-19-478. Washington, D.C.: June 12, 2019.

             VA’s Health Care Budget: In Response to a Projected Funding Gap in
             Fiscal Year 2015, VA Has Made Efforts to Better Manage Future
             Budgets. GAO-16-584. Washington, D.C.: June 3, 2016.

             Veterans’ Health Care Budget: Improvements Made, but Additional
             Actions Needed to Address Problems Related to Estimates Supporting
             President’s Request. GAO-13-715. Washington, D.C.: August 8, 2013.

             Veterans’ Health Care: Improvements Needed to Ensure That Budget
             Estimates Are Reliable and That Spending for Facility Maintenance Is
             Consistent with Priorities. GAO-13-220. Washington, D.C.: February 22,
             2013.

             Veterans’ Health Care Budget: Better Labeling of Services and More
             Detailed Information Could Improve the Congressional Budget
             Justification. GAO-12-908. Washington, D.C.: September 18, 2012.

             Veterans’ Health Care Budget: Transparency and Reliability of Some
             Estimates Supporting President’s Request Could Be Improved.
             GAO-12-689. Washington, D.C.: June 11, 2012.

             VA Health Care: Estimates of Available Budget Resources Compared
             with Actual Amounts. GAO-12-383R. Washington, D.C.: March 30, 2012.



             Page 42                                           GAO-21-379 Veterans Affairs
           Related GAO Products




           VA Health Care: Methodology for Estimating and Process for Tracking
           Savings Need Improvement. GAO-12-305. Washington, D.C.: February
           27, 2012.

           Veterans’ Health Care Budget Estimate: Changes Were Made in
           Developing the President’s Budget Request for Fiscal Years 2012 and
           2013. GAO-11-622. Washington, D.C.: June 14, 2011.

           VA Health Care: Need for More Transparency in New Resource
           Allocation Process and for Written Policies on Monitoring Resources.
           GAO-11-426. Washington, D.C.: April 29, 2011.

           Veterans’ Health Care: VA Uses a Projection Model to Develop Most of
           Its Health Care Budget Estimate to Inform the President’s Budget
           Request. GAO-11-205. Washington, D.C.: January 31, 2011.

           VA Health Care: Challenges in Budget Formulation and Issues
           Surrounding the Proposal for Advance Appropriations. GAO-09-664T.
           Washington, D.C.: April 29, 2009.

           VA Health Care: Challenges in Budget Formulation and Execution.
           GAO-09-459T. Washington, D.C.: March 12, 2009.

           VA Health Care: Long-Term Care Strategic Planning and Budgeting Need
           Improvement. GAO-09-145. Washington, D.C.: January 23, 2009.




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           Page 43                                           GAO-21-379 Veterans Affairs
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