Review of the Fiduciary Program’s Misuse Allegation Process
Report Information
Summary
The VA Office of Inspector General (OIG) conducted this review to help protect vulnerable beneficiaries from fiduciaries’ misuse of their VA benefits payments. The OIG team examined whether fiduciary program staff in the Veterans Benefits Administration (VBA) took action that was consistent with governing guidance for about 1,600 misuse allegation cases completed from April 2024 through March 2025. Properly recording fiduciaries’ potential misuse of beneficiaries’ funds and investigating credible allegations against fiduciaries are vital to stopping financial abuse and reimbursing misused VA benefits to beneficiaries.
The OIG found that fiduciary program staff did not always accurately record the earliest date when misuse allegations were received and did not advance all allegations of potential misuse for investigation consistent with requirements. Contributing causes for these issues included staff’s confusion about applying unclear provisions from the VA Fiduciary Program Manual and incorrectly applying standards of evidence. The OIG team found there was no systematic national monitoring of misuse allegations to detect staff’s missteps. Without clearer guidance about how staff should record and investigate misuse allegations, the risk of financial abuse will continue undetected. In addition, comprehensive oversight of allegations about misuse of funds would provide greater assurance that staff are correctly managing misuse allegations.
The OIG made four recommendations to clarify and improve guidance so allegations about fiduciaries’ misuse of benefits are correctly recognized, recorded, processed, and advanced for investigation. The principal deputy under secretary for benefits concurred with all four recommendations. The OIG considers recommendation 4 closed and will close the remaining recommendations when VBA provides sufficient evidence that it has addressed the risks identified in the report.
Review and update applicable sections of the VA Fiduciary Program Manual to clarify how to properly evaluate an allegation, including detailing what constitutes a misuse allegation that must be documented and reviewed, and when an investigation is needed, in coordination with the VA Office of General Counsel if necessary.
Clarify in the VA Fiduciary Program Manual how potential misuses of beneficiary funds, such as red flag indicators, must be addressed and documented, and reinforce with training or resources as needed.
Clearly communicate the evidentiary standard staff should use in the allegation phase to help ensure application of different standards is accurate and easily understood and results in consistent compliance with how investigations are initiated, and consider consulting with the VA Office of General Counsel if necessary.
Develop a plan to implement or enhance the national quality review program to ensure compliance with procedural guidance for processing all phases of misuse allegations.