Veterans' Pension Benefits: Improvements Needed to Ensure Only Qualified Veterans Receive Benefits

Published by the Government Accountability Office on 2012-06-06.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                            United States Government Accountability Office

GAO                         Testimony
                            Before the Special Committee on Aging,
                            U.S. Senate

                            VETERANS’ PENSION
For Release on Delivery
Expected at 2:00 p.m. EDT
Wednesday, June 6, 2012

                            Improvements Needed to
                            Ensure Only Qualified
                            Veterans Receive Benefits
                            Statement of Daniel Bertoni, Director
                            Education, Workforce, and Income Security Issues

Chairman Kohl, Ranking Member Corker and Members of the Committee:

I am pleased to be here to discuss the Department of Veterans Affairs’
(VA) pension program, which provides economic benefits to wartime
veterans age 65 and older or who have disabilities that are unrelated to
their military service, as well as to their surviving spouses and dependent
children. To qualify for VA pension benefits, a claimant must have limited
income and assets. Recently, concerns have been raised that some
organizations are marketing financial products and other services to help
individuals whose assets exceed the program’s financial eligibility
thresholds qualify for these benefits. These organizations may charge
substantial fees for products and services that may not always be in
claimants’ best long-term interests.

In our report released today on VA’s pension program, we identified
vulnerabilities in VA’s procedures for assessing financial eligibility. We
also found that there is no prohibition on claimants transferring assets
prior to applying for benefits, and some claimants do so. 1 Other means-
tested programs, such as Medicaid, conduct a look-back review to
determine if an individual has transferred assets for less than fair market
value, and if so, may deny eligibility for benefits for a period of time. This
control helps ensure that only those in financial need receive benefits.

My testimony is based on our report and focuses on what is known about
organizations that are marketing financial products and services to
veterans and survivors to enable them to qualify for VA pension benefits.
To conduct this work, we reviewed relevant federal laws and regulations,
and VA policies and procedures. We interviewed officials from VA
headquarters, as well as staff at VA’s three Pension Management
Centers (PMC). 2 We also conducted Internet research and interviews with
veterans’ advocacy groups, VA officials, and state and local officials to
identify organizations that market financial and estate planning services to
help claimants qualify for VA pension benefits. We contacted some of
these organizations to learn about the types of products and services
provided. Moreover, our investigative staff posed as the son of an 86-

 GAO, Veterans’ Pension Benefits: Improvements Needed to Ensure Only Qualified
Veterans and Survivors Receive Benefits, GAO-12-540 (Washington, D.C.:
May 15, 2012).
VA’s three PMC’s are located in Milwaukee, WI; Philadelphia, PA; and Saint Paul, MN.

Page 1                                                                    GAO-12-784T
year-old veteran and contacted 25 judgmentally selected organizations
which included both financial planners and attorneys. We had discussions
with representatives of 19 of these organizations. A more detailed
explanation of our methodology is available in our full report. Our audit
work was conducted in accordance with generally accepted government
auditing standards. Our investigative work was conducted in accordance
with Quality Standards for Inspection and Evaluation published by the
Council of the Inspectors General on Integrity and Efficiency.

In summary, we identified over 200 organizations that market financial
and estate planning services to help pension claimants with excess
assets qualify for pension benefits. These organizations consist primarily
of financial planners and attorneys who offer products such as annuities
and trusts. All 19 organizations our investigative staff contacted said a
claimant can qualify for pension benefits by transferring assets before
applying, which is permitted under the program. Two organization
representatives said they helped pension claimants with substantial
assets, including millionaires, obtain VA’s approval for benefits. Some
products and services provided, such as deferred annuities, may not be
suitable for the elderly because they may not have access to their funds
within their expected lifetime without facing high withdrawal fees. Also,
such asset transfers may result in ineligibility for Medicaid coverage for
long-term care for a period of time. The majority of the 19 organizations
contacted charged fees, ranging from a few hundred dollars for benefits
counseling to $10,000 for establishment of a trust. In our report we asked
Congress to consider establishing a look-back and penalty period for
pension claimants who transfer assets prior to applying for pension
benefits, similar to other federally supported means-tested programs,
such as Medicaid. We also recommended that VA obtain timely
information on asset transfers, strengthen income and asset verification
processes, and provide clearer guidance to claims processors. VA
concurred with our recommendations and agreed that a look back and
penalty period for asset transfers was needed.

Page 2                                                          GAO-12-784T
             In fiscal year 2011, VA provided about $ 4.3 billion in pension benefits for
Background   about 517,000 recipients. These benefits are available to low-income
             wartime veterans who are 65 and older, or who are under age 65 but are
             permanently and totally disabled due to conditions unrelated to their
             military service. 3 Surviving spouses and dependent children may also
             qualify for these benefits. Average annual payments in fiscal year 2011
             were $9,669 for veterans and $6,209 for survivors.

             VA provides pension benefits through its Veterans Benefits Administration
             (VBA), and claims processors assess claims at VBA’s three PMCs. VA
             also accredits representatives of veterans service organizations,
             attorneys, and claims agents to assist claimants with the preparation and
             submission of VA claims at no charge. 4 To become accredited, an
             individual must meet certain requirements set forth in federal law. 5

             To qualify for pension benefits, claimants’ countable income must not
             exceed annual pension limits that are set by statute. 6 These income limits
             are also the maximum annual pension payment that a beneficiary may
             receive and may vary based on whether claimants are veterans or
             survivors, their family composition, as well as whether they need enhanced

              VA currently administers three pension programs, commonly referred to as Improved Law
             Pensions (Pub. L. No. 95-588, 92 Stat. 2497), Prior Law Pensions (Pub. L. No. 86-211, 73
             Stat. 432), and Old Law Pensions (Pub. L. No. 73-2, 48 Stat. 8). About 95 percent of all
             pension recipients are under the Improved Pension program, and new beneficiaries can
             only accede to this program. We focus on the Improved Pension program in this
             testimony. For veterans with service-connected disabilities, VA provides cash benefits
             through its disability compensation program.
             See 38 U.S.C. §§ 5901-5904.
             See 38 U.S.C. §§ 1521, 1541, and 1542

             Page 3                                                                     GAO-12-784T
benefits, such as aid and attendance or housebound benefits. 7 For
example, to qualify for pension benefits in 2012 a veteran with no
dependents and who is in need of aid and attendance benefits cannot have
income that exceeds $20,447. In determining if a claimant’s income is
below program thresholds, VA includes recurring sources of income such
as Social Security retirement and disability benefits, but not income from
public assistance programs such as Supplemental Security Income (SSI).

VA’s policy manual specifically states that the VA pension program is not
intended to protect substantial assets or preserve an estate for a
beneficiary’s heirs. In assessing financial eligibility, VA also considers net
worth or the total value of claimants’ assets, such as bank accounts,
stocks, bonds, mutual funds, and any property other than the claimant’s
dwelling, a reasonable lot area, a vehicle, and personal belongings. 8, 9
According to VA’s policy manual, claims processors are generally
required to formally determine if claimants with assets worth over $80,000
have financial resources that will last a reasonable period of time to pay
for their basic expenses. In making this determination, claims processors
consider net worth, income, expenses, age, and life expectancy to

 As part of the pension program, VA provides enhanced pension benefit amounts to
veterans and surviving family members who demonstrate the need for aid and attendance,
or who are considered permanently housebound. Veterans may be eligible for Aid and
Attendance benefits if they demonstrate an inability to perform everyday personal
functions such as bathing, dressing, eating, adjusting prosthetic devices, and protecting
themselves from hazards or dangers in their daily environment. They may also be eligible
for these benefits if they are a patient in a nursing home, bedridden, or are blind or nearly
blind. Veterans may be eligible for Housebound benefits if they have a disability rated at
100 percent and, as a result, are permanently or substantially confined to their homes, or
have a disability rated at 100 percent and at least one other disability rated at 60 percent
or more (although these individuals are legally classified as Housebound, they may be
capable of leaving their homes). See GAO, VA Enhanced Monthly Benefits: Recipient
Population Is Changing, and Awareness Could Be Improved, GAO-12-153 (Washington,
D.C.: Dec. 14, 2011).
 See 38 C.F.R. § 3.275. For claimants who are veterans, VA also assesses the net worth
of the veteran’s spouse to determine financial eligibility.
 There are no thresholds on the value of a claimant’s assets that are defined in statute.
The relevant statute states that a veteran’s pension shall be denied “when the corpus of
the estate of the veteran or, if the veteran has a spouse, the corpus of the estates of the
veteran and of the veteran’s spouse is such that under all the circumstances, including
consideration of the annual income of the veteran, the veteran’s spouse, and the veteran’s
children, it is reasonable that some part of the corpus of such estates be consumed for the
veteran’s maintenance.” 38 U.S.C. § 1522(a).

Page 4                                                                          GAO-12-784T
                        determine if claimants’ financial resources are sufficient to pay for their
                        expenses without assistance from VA.

                        VA pension claimants may also be eligible for other means-tested
                        programs, such as Medicaid, a joint federal-state health care financing
                        program that provides coverage for long-term care services for certain
                        individuals who meet specific income and resource thresholds. Each state
                        administers its Medicaid program and establishes specific income and
                        resource eligibility requirements that must fall within federal standards. 10
                        Similarly, the SSI program provides cash benefits to individuals who are
                        65 or older, blind, or disabled who have limited income and whose
                        resources are $2,000 or less. 11

                        We identified over 200 organizations located throughout the country that
Organizations Help      market their services to help veterans and their surviving spouses qualify
Veterans Transfer       for VA pension benefits by transferring or preserving excess assets.
                        These organizations consist primarily of financial planners and attorneys
Assets to Qualify for   offering products and services such as annuities and the establishment of
Pension Benefits        trusts, to enable potential VA pension claimants with excess assets to
                        meet financial eligibility criteria for VA pension benefits. For example, one
                        organization’s website advertised that it develops financial plans which
                        include various insurance products, and that its specific area of expertise
                        is to help VA pension claimants with hundreds of thousands of dollars in
                        assets obtain approval for these benefits. Under current federal law and
                        regulations, VA pension claimants are allowed to transfer assets and
                        reduce their net worth prior to applying for benefits, so services being
                        marketed and provided by these organizations to qualify for VA pension
                        benefits are legally permissible under program rules. In contrast, for
                        Medicaid—another means tested program—federal law explicitly restricts
                        eligibility for coverage for long term care for certain individuals who

                          We reported in 2007 that in most states, an individual must have $2,000 or less in
                        countable financial resources to be eligible for Medicaid ($3,000 for a married couple).
                        See GAO, Medicaid Long-Term Care: Few Transferred Assets before Applying for
                        Nursing Home Coverage; Impact of Deficit Reduction Act on Eligibility Is Uncertain,
                        GAO-07-280 (Washington, D.C.: Mar. 26, 2007).
                          Financial resources must be less than $3,000 if the individual lives with their spouse.
                        Also, individuals in some states who require long-term care services can become eligible
                        for Medicaid benefits through participation in the SSI program.

                        Page 5                                                                         GAO-12-784T
transfer assets for less than fair market value prior to applying. 12, 13 As a
result, when an individual applies for Medicaid coverage for long-term
care, states conduct a look-back—a review to determine if the applicant
transferred assets for less than fair market value prior to applying.
Individuals who have transferred assets for less than fair market value
during the 60 months prior to applying may be denied eligibility for long-
term care coverage for a period of time, known as the penalty period. 14
For example, gifting assets would generally be considered a transfer of
assets for less than fair market value and result in a penalty period. Also,
under the SSI program, claimants who transfer assets for less than fair
market value prior to applying may become ineligible for these benefits for
up to 36 months. 15

During our investigative calls, all 19 organizations correctly noted that
pension claimants can legally transfer assets prior to applying. They
indicated it is possible to qualify for VA pension benefits despite having
excess assets, and almost all provided information on how to transfer
these assets. (See figure 1 for transcript excerpts of calls with
organizations on services they provide to qualify for VA pension benefits.)

 42 U.S.C. § 1396p(c).
  An asset transfer for less than fair market value would occur when the claimant gifts or
sells an asset and gets in return an amount that is less than the value of the asset on the
open market at the time of the transfer.
  The penalty period is calculated by dividing the uncompensated dollar value of the
assets transferred by the average monthly cost of private nursing home care in the state
(or in the community, at the option of the state). The penalty period generally begins on
the later of (1) the first day of the month during or after which the individual transferred
assets at less than fair market value, or (2) the date on which the individual would have
been eligible for Medicaid coverage for long-term care if it were not for these asset
transfers. Certain asset transfers are exempt from Medicaid penalty provisions such as
assets transferred to an individual’s spouse or disabled child. Asset transfers would also
not be penalized if the individual can demonstrate that the transfer was carried out
exclusively for purposes other than qualifying for Medicaid, or when the state determines
that the penalty would result in undue hardship. 42 U.S.C. § 1396p(c).
 42 U.S.C. § 1382b(c)(1)(A).

Page 6                                                                          GAO-12-784T
Figure 1: Transcript Excerpts of Calls with Organizations Providing Products and Services to Help Claimants Qualify for
VA Pension Benefits

                                         Note: For a complete transcript of all three calls, see GAO-12-540.

                                         A number of different strategies may be used to transfer pension
                                         claimants’ excess assets so that they meet financial eligibility thresholds.
                                         Among the 19 organizations our investigative staff contacted, about half
                                         advised transferring excess assets into an irrevocable trust with a family
                                         member as the trustee to direct funds to pay for the veteran’s expenses.
                                         A similar number also advised placing excess assets into some type of
                                         annuity. Among these, several advised placing excess assets into an
                                         immediate annuity that generates income for the client. In employing this
                                         strategy, assets that VA would count when determining financial eligibility
                                         for pension benefits are converted into monthly income. This monthly
                                         income would fall below program thresholds and enable the claimant to
                                         still qualify for the benefits. About one-third of the organizations
                                         recommended strategies that included the use of both annuities and
                                         trusts. For example, one organization we contacted advised repositioning
                                         some excess assets into an irrevocable trust, with the son as the trustee,

                                         Page 7                                                                  GAO-12-784T
and placing remaining excess assets into a deferred annuity that would
not be completely accessible, since most of the funds could not be
withdrawn without a penalty. In addition, several organization
representatives we interviewed also told us they may advise using
caretaker agreements to enable a client to qualify for VA pension
benefits. Organizations told us this strategy generally involves the
pension claimant transferring assets to family members as part of a
contract, in exchange for caretaker services to be provided by these
family members for the remainder of the claimant’s lifetime.

Some organization representatives we interviewed told us that
transferring assets to qualify for VA pension benefits is advantageous for
elderly pension claimants because it enables them to have more income
to pay for care expenses and remain out of a nursing home for a longer
period of time. For example, representatives from one organization said
the use of immediate income annuities allows pension claimants to
increase their monthly income that, combined with the VA pension, could
help pay for assisted living or in-home care costs. Other financial
planners and attorneys said if claimants do not conduct financial or estate
planning to qualify for the VA pension and instead spend down their
assets prior to applying, the monthly amount of the pension benefit they
eventually receive may be insufficient to pay for their long-term care.
They said that, as a result, these claimants may decide to seek Medicaid
coverage for nursing home care because of their lack of financial
resources, when they could have remained in an assisted living facility or
at home with the aid of the VA pension. Some of these organizations told
us that nursing home care financed by Medicaid is more costly for the
government than if the veteran had received the VA pension benefit and
obtained care in a lower-cost assisted living facility.

Many organizations we identified also conduct presentations on VA
pension benefits at assisted living or retirement communities to identify
prospective clients. According to attorneys and officials from state attorneys
general offices we spoke with, managers of assisted living facilities or
retirement communities may have an interest in inviting organization
representatives to conduct presentations on VA pension benefits because
these benefits allow them to obtain new residents by making the costs
more affordable. For example, we obtained documentation indicating that
one retirement community paid an organization representative a fee for a
new resident he helped the facility obtain. Another community in another
state paid organization representatives fees to assist residents in
completing the VA pension application.

Page 8                                                             GAO-12-784T
Some Products and        Some products may not be suitable for elderly veterans because they
Services May Adversely   may lose access to funds they may need for future expenses, such as
Affect Claimants         medical care. To help elderly clients become financially eligible for VA
                         pension benefits, some organizations may sell deferred annuities which
                         would make the client unable to access the funds in the annuity during
                         their expected lifetime without facing high withdrawal fees, according to
                         some attorneys we spoke with. An elderly advocacy organization
                         representative we spoke with also noted that elderly individuals are
                         impoverishing themselves by purchasing these products when they may
                         need the transferred assets to pay for their long-term care expenses. As
                         part of our investigative work, one organization provided a financial plan
                         to qualify for VA pension benefits that included both an immediate annuity
                         as well as a deferred annuity for an 86-year-old veteran that would
                         generate payments only after the veteran’s life expectancy.

                         Some organizations that assist in transferring assets to qualify people for
                         VA pension benefits may not consider the implications of these transfers
                         on eligibility for Medicaid coverage for long-term care. Individuals who
                         transfer assets to qualify for the VA pension may become ineligible for
                         Medicaid coverage for long-term care services they may need in the
                         future. For example, asset transfers that may enable someone to qualify
                         for the VA pension program, such as gifts to someone not residing in a
                         claimant’s household, the purchase of deferred annuities, or the
                         establishment of trusts, may result in a delay in Medicaid eligibility if the
                         assets were transferred for less than fair market value during Medicaid’s
                         60-month look-back period. According to several attorneys we spoke with,
                         some organization representatives are unaware or are indifferent to the
                         adverse effects on Medicaid eligibility of the products and services they
                         market to qualify for the VA pension. As a result, potential pension
                         claimants may be unaware that the purchase of these products and
                         services may subsequently delay their eligibility for Medicaid.

                         In addition to the potential adverse impact of transferring assets, we heard
                         concerns that marketing strategies used by some of these companies may
                         be misleading. According to several attorneys we spoke with, some
                         organization representatives market their services in a way that may lead
                         potential pension claimants and their family members to believe they are
                         veterans advocates working for a nonprofit organization, or are endorsed
                         by VA. As a result, they may fail to realize these representatives are
                         primarily interested in selling financial products. For example, some
                         organization representatives may tell attendees during presentations at
                         assisted living facilities that their services consist of providing information
                         on VA pension benefits and assisting with the application, and do not

                         Page 9                                                              GAO-12-784T
disclose they are insurance agents selling annuities to help people qualify
for these benefits. One elder law attorney we spoke with said many
attendees at these presentations may have Alzheimer’s disease or
dementia and are not in a position to make decisions about their finances.
Therefore, they are vulnerable to being convinced that they must purchase
a financial product to qualify for these benefits.

Concerns have also been raised that VA’s accreditation of individuals to
assist with applying for VA benefits may have unintended consequences.
According to attorneys and officials in one state, organization
representatives use their VA accreditation to assist in preparing claims as a
marketing tool that generates trust and allows them to attract clients.
Claimants may not understand that this accreditation only means that the
individual is proficient in VA’s policies and procedures to assist in preparing
and submitting VA benefits claims and does not ensure the products and
services these individuals are selling are in claimants’ best interests.

Finally, some organizations may provide erroneous information to clients,
or fail to follow through on assisting them with submitting the pension
application, which can adversely affect pension claimants. For example,
one veteran said he was told by an organization representative to sell his
home prior to applying for the VA pension and that he did not have to
report the proceeds from the sale on the application. He followed this
advice and was approved for benefits, but VA later identified these
assets, which caused him to incur a debt to VA of $40,000 resulting from
a benefit overpayment. Organizations may also promise assistance with
the application process to any interested pension claimant but,
unbeknownst to the claimant, may not follow through in providing this
service if the claimant does not want to transfer assets. For example, the
daughter of a veteran we spoke with, who sought application assistance
from an organization representative, told us the representative never
submitted her father’s pension claim to VA as promised. She learned of
this about a year after she thought the claim was submitted and had to
reapply through a county veterans service officer. Her father was
approved 2 months later but passed away less than a month after his
approval. She believes her father could have received benefits for a year
if the representative had submitted the claim, and believes the
representative did not do so because she did not want to use his services
to transfer assets.

Page 10                                                             GAO-12-784T
                        The costs of services provided by these organizations to assist in
Costs for Services to   qualifying for VA pension benefits varied, but organizations may be
Transfer Assets         charging prohibited fees. Among the 19 organizations our investigative
                        staff contacted for this review, about one-third said they did not charge for
Varied, but Some        their services to help qualify claimants for VA pension benefits. For
Organizations May be    example, financial planners told us that, generally, there are no direct
Charging Prohibited     costs associated with transferring assets into an annuity, but that costs
                        would be included in the terms of the annuity, such as the commission
Fees                    earned by the insurance agent. Among organizations that did charge for
                        services, fees ranged from a few hundred dollars for benefits counseling
                        up to $10,000 for the establishment of a trust. Also, although federal law
                        prohibits charging fees to assist in completing and submitting applications
                        for VA benefits, 16 representatives from veterans advocacy groups and
                        some attorneys we spoke with raised concerns that these organizations
                        may be charging for fees related to the application, or find ways to
                        circumvent this prohibition, such as by claiming they are charging for
                        benefits counseling. For example, one organization our investigative staff
                        contacted charged $850 to have an attorney work on the application
                        process, a $225 analysis fee, and $1,600 for the establishment of a trust.
                        Another organization representative indicated he charged a “long term
                        planning fee” of $1,200 to be paid prior to services being provided. The
                        organization representative asked that someone other than the veteran
                        pay this fee, claiming that only disinterested third parties can be charged
                        fees but not the veteran. Also, in a case identified by officials in one state,
                        a veteran was charged $3,000 by an individual for assistance in applying
                        for VA pension benefits which were ultimately denied. In addition,
                        concerns have been raised that fees charged may be excessive for the
                        services provided. For example, in July 2011, California enacted a law
                        generally prohibiting unreasonable fees from being charged for these
                        services. 17

                        The VA pension program provides a critical benefit to veterans, many of
Concluding              whom are elderly and have limited financial resources to support
Observations            themselves. Current federal law allows individuals to transfer assets prior
                        to applying for VA pension benefits and still be approved. As a result,

                         See 38 U.S.C. §§ 5902(b)(1)(A), 5903(a)(1), and 5904(c)(1).
                         See Cal. Civ. Code § 1770(a)(24). An “unreasonable fee” is defined as a fee that is
                        exorbitant and disproportionate to the services performed.

                        Page 11                                                                      GAO-12-784T
                   claimants who have sufficient assets to pay for their expenses can
                   transfer these assets and qualify for this means-tested benefit. This
                   arrangement circumvents the intended purpose of the program and
                   wastes taxpayer dollars. A number of organizations help claimants with
                   these asset transfers, but some of the products and services provided
                   may have adverse implications for the claimant such as delaying eligibility
                   for Medicaid coverage for long-term care or causing claimants to lose
                   access to their financial resources. Accordingly, we asked Congress to
                   consider establishing a look-back and penalty period for pension
                   claimants who transfer assets at less than fair market value prior to
                   applying for pension benefits, similar to other federally supported means-
                   tested programs.

                   Chairman Kohl, Ranking Member Corker, and Members of the
                   Committee, this concludes my prepared statement. I would be pleased to
                   answer any questions that you may have at this time.

                   For further information about this testimony, please contact Daniel Bertoni
GAO Contact and    at (202) 512-7215 or bertonid@gao.gov. Contact points for our Offices of
Staff              Congressional Relations and Public Affairs may be found on the last page
                   of this testimony. Other key contributors to this testimony include Jeremy
Acknowledgements   Cox, Paul Desaulniers, Alex Galuten, Nelson Olhero, Martin Scire, and
                   Walter Vance.

                   Page 12                                                         GAO-12-784T
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