Review of Enterprise Technology Solutions, LLC Compliance ......department was accused of overspending on two 2011 conferences, allegations now under investigation." 9. Social And

From Wayne Gatewood JrTo Wayne Gatewood JrSubject Veterans News for Wednesday August 22 2012Date Wednesday August 22 2012 84114 PMAttachments VAOIG-12-01235-132pdf

HVAC Ltr to Secretary Shinseki regarding CVE Verificationpdf

Happy Wednesday good people Do hope that you and yours are well and in the best ofhealth Lot of news today because of some Veterans input regarding SDVOSBverification the Center for Veterans Enterprise (CVE) and the issue of fraud and fronting (Please keep on sending in your comments and ideas) How can we identify the crooks otherthan CVE performing unannounced site visits Again please send in yourrecommendations Also what can CVE do to simplify the verification processwhat wouldyou change For Today As a small businessperson you have no greater leverage than the truth John Greenleaf Whittier One CVE recommendation I have The HCVA Subcommittees on OampI and EO just senta letter to the Secretary of VA telling him the CVE must stop overreaching (See attached)I have to believe that if the rules and regs are made very simple and very clear it would bequite difficult for someone to overreach The major reason I believe this overreaching isbeing done by CVE is many of their staff are themselves confused with existing clausesregswithin the Law Make it clear make it simpleand have less confusion and less roomfor subjectivity and so-called overreaching And this from an old USMC Master Sergeant -) In Toll of 2000 New Portrait of Afghan War httpwwwnytimescom20120822uswar-in-afghanistan-claims-2000th-american-lifehtmlemc=na Thanks to Colonel Wayne Morris USMC (Ret) for forwarding this articleto us Review of Enterprise Technology Solutions LLC Compliance with Service-Disabled Veteran-Owned Small Business Program SubcontractingLimitations Report Please see attached VA IG Report on ETS LLC These are thetypes of SDVOSBs that are not helping our community one bit Shameful conductand it is good to see that they got busted Also go to this link to reada NextGovcom article on this Sham httpwwwnextgovcomhealth201208ig-health-care-contractor-benefited-sham-veteran-owned-businesses57575oref=nextgov_today_nl CVE Issues and SDVOSBVOSB Verification For those of you interested in commentsfrom the field regarding how CVE might best identify and deal with pre-meditated fraudsand fronts please see the information at the bottom of this News edition Reserve Officers Association (ROA) SmartBrief for Wednesday August 22 2012 httpwwwsmartbriefcomservletwirelessissueid=E0561D38-CB33-42F5-BE4A-05AD3E967084ampsid=22cbe9eb2d3ef02d4eca2d81052def9f466dc32d Prayers and blessings for you and your loved ones and for our dear Troops and their lovedones everywhere The 1 of America that serves

Department of Veterans Affairs

Office of Inspector General

Review of Enterprise Technology Solutions LLC Compliance with Service-Disabled Veteran-Owned Small Business Program

Subcontracting Limitations

Report No 12-01235-132 August 20 2012 VA Office of Inspector General

Washington DC 20420

To Report Suspected Wrongdoing in VA Programs and Operations

Telephone 1-800-488ndash8244

E-Mail vacoighotlinevagov

(Hotline Information httpwwwvagovoighotlinedefaultasp)

Review of Enterprise Technology Solutions LLC Compliance with Service-Disabled Veteran-Owned Small Business Program Subcontracting Limitations

Contents

Executive Summary i

Introduction

Purpose 1 Background 1 Scope and Methodology 5

Results and Conclusions

Finding 1 ETS Did Not Comply with Subcontracting Limitations 6

1 ETS Intended for Health Net to Perform All Claims Re-pricing 6 2 ETS Misrepresented Its Capability to Perform Tasks Under

NAICS Code 524291 8

Finding 2 The SDVOSB Set-aside Determination Was Not Properly Justified 9

Additional Issue 12

Conclusions 14

Recommendations 15

Acronyms 16

Exhibits Exhibit A Claims Re-pricing Process 17 Exhibit B FY 2011 ETS Contract Fees 19

Appendixes A Management Comments 20 B OIG Contact and Staff Acknowledgements 26 C Report Distribution 27

VA Office of Inspector General

Executive Summary

The VA Office of Inspector General (OIG) Office of Contract Review initiated and conducted a review of Enterprise Technology Solutions LLCrsquos (ETS) compliance with subcontracting limitations contained in its five contracts for claims re-pricing These contracts were awarded in 2007 and 2008 for a base year plus four one-year option periods ETS is a service-disabled veteran-owned small business (SDVOSB) concern All five contracts for claims re-pricing were awarded as SDVOSB set-asides Claims reshypricing is the process of comparing VA allowable rates based on fees charged by non-VA health care providers to rates that the contractor may have established with health care providers who are a part of their network If the network rates are lower than the VA allowable rates the contractor re-prices the claim and calculates the potential savings The re-pricing contractor ETS then receives a percentage of the potential savings as a fee under the contract

Our review determined that ETS was not in compliance with the contract provisions limiting subcontracting We determined that ETS subcontracted all of the claims reshypricing tasks under all five contracts to its subcontractor Health Net Federal Services (Health Net) We found that Health Net a large business was doing claims re-pricing work for VA prior to the ETS contracts According to the ETS Program Manager Health Net encouraged the owner of ETS (Mr Donald Neilson a former VA employee) to start ETS as an SDVOSB concern which allowed Health Net to increase business by subcontracting with an SDVOSB that obtained the contract through a small business set-aside As VA was consolidating its claims re-pricing contracting at the Health Administration Center (HAC) in Denver Colorado VA changed the acquisitions for reshypricing services to SDVOSB set-asides ETS and another SDVOSB Primeaux (subsequently acquired by ETS in April 2009) were awarded the claims re-pricing contracts and both used Health Net to actually process and re-price the claims

We concluded that ETS did not process any of the claims nor did they have the expertise or capability of re-pricing claims and never intended to perform the work despite the terms and conditions of the contracts VA personnel responsible for administering the contracts were fully aware that ETS was subcontracting all of the work to Health Net in violation of the provision in the contract limiting subcontracting because ETS had VA forward all claims directly to Health Net for processing In fact ETS never actually handled the claims in any manner ETSrsquos sole function was to use its SDVOSB status to obtain the contract on behalf of Health Net

Based on our review of the acquisition planning and other relevant documents we determined the SDVOSB set-asides were not properly justified We found no evidence that VA conducted any analysis to determine if there were any SDVOSB concerns that were capable of performing the required work

VA Office of Inspector General i

We note that this is the third report issued by the OIG identifying improper sole-source contracting by the Veterans Health Administration (VHA) to former VA employees who have formed or work for SDVOSBs (Department of Veterans Affairs Office of Inspector General Review of Allegations of Improper Contract Awards to Watkins Sinclair LLC Report No 09-02322-192 Administrative Investigation Improper Contracts Conflict of Interest Failure to Follow Policy and Lack of Candor Health Administration Center Denver Colorado Report No 10-02328-154)

We recommended that the Chief Procurement and Logistics Officer terminate the five ETS contracts for claims re-pricing for default and that the Chief Procurement and Logistics Officer coordinate with the Under Secretary for Health to determine if there is a need for any contract(s) to re-price non-VA care fee claims We also recommended that VHA ensure that the requirements for future contracts do not preclude competition when the vendor is a former VA employee or composed primarily of VA employees We referred the issues identified in our review to the OIG Office of Investigations and will refer ETS to VArsquos Suspension and Debarment Committee for possible action in accordance with FAR Subpart 94 and VAAR Subpart 809406

We recommended that the Under Secretary for Health establish procedures to ensure that all non-VA fee claims are submitted to VArsquos Medicare pricer to determine the appropriate Medicare rate We also are recommending that the Under Secretary for Health determine whether claims re-pricing for non-VA care have resulted in rates that are lower than Medicare rates and achieved in any actual savings taking into consideration the fee paid for the re-pricing services We also recommended that the Under Secretary for Health implement mandatory training requirements for program offices to ensure requirements are not written to preclude competition or give former VA employees an unfair advantage and to ensure the appropriate approvals are in place to ensure competition to the maximum extent practicable

The Chief Procurement and Logistics Officer and the Under Secretary for Health concurred with our findings and recommendations and provided comments Their comments and planned actions are attached to this report We believe their planned course of action addresses our finding and recommendations We will follow up on the planned actions until implemented

MARK A MYERS

Director Healthcare Resources Division Office of Contract Review

VA Office of Inspector General ii

Introduction Purpose

In January 2012 the Office of Inspector General (OIG) Office of Contract Review initiated a review on five contracts for re-pricing of non-VA health care providersrsquo claims with Enterprise Technology Solutions LLC (ETS) The primary purpose was to determine whether ETS was in compliance with the contract terms and conditions limiting subcontracting

Background

During 2007 and 2008 the Health Administration Center (HAC) in Denver Colorado awarded five contracts for re-pricing claims submitted by non-VA health care providers1

The five contracts covered five different regions that the HAC created by grouping several Veterans Integrated Service Networks (VISNs) together for the purpose of reshypricing claims These procurements were all conducted as service-disabled veteran-owned small business (SDVOSB) set-asides VA awarded these five contracts to two different SDVOSB companies ETS was awarded three contracts2 for Region 5 (VISNs 19 20 21 and 22) Region 1 (VISNs 1 2 3 4 5 and 10) and Region 3 (VISNs 11 12 15 and 23) and Primeaux Health Strategies LLC (Primeaux) was awarded two contracts3

for Region 2 (VISNs 6 7 8 and 9) and Region 4 (VISNs 16 17 and 18)4 In April 2009 ETS acquired Primeaux and became responsible for the two contracts awarded to Primeaux ETS did provide a novation agreement executed with the Secretary of State of Louisiana to the Contracting Officer (CO) however ETS did not request a novation with VA and continued to operate under the Primeaux name All five contracts included a contract clause and FAR clauses limiting subcontracting Paragraph 10 of the statement of work states

Subcontractor Requirements If a subcontractor is used to complete the requirements of the contractor the contractor shall provide that information in their proposal The prime contractor shall conduct a minimum of 51 of the requirements of the contract

1 Under the VArsquos Fee Basis Program eligible veterans may obtain health care services in the private sector The Program provides coverage for inpatient care outpatient care ambulatory surgery dental services and related professional and ancillary services2 ETS was awarded contract VA741-P-0011 for Region 5 on September 26 2007 contract VA741-P-0026 for Region 1 on September 9 2008 and contract VA741-P-0027 for Region 3 on September 9 20083 Primeaux was awarded contract VA741-P-0028 for Region 2 on September 17 2008 and contract VA741-P-0030 for Region 4 on September 24 20084 These contracts were awarded for a base year plus four option years

VA Office of Inspector General 1

The contracts also included FAR clauses 52219-14 Limitations on Subcontracting and 52219-27 Notice of Service-Disabled Veteran-Owned Small Business Set-Aside FAR Clause 52219-14 states

(c) By submission of an offer and execution of a contract the OfferorContractor agrees that in performance of the contract in the case of a contract formdash

(1) Services (except construction) At least 50 percent of the cost of contract performance incurred for personnel shall be expended for employees of the concern

FAR Clause 52219-27 states

(d) Agreement A service-disabled veteran-owned small business concern agrees that in performance of this contract in the case of a contract formdash

(1) Services (except construction) at least 50 percent of the cost of personnel for contract performance will be spent for employees of the concern or employees of other service-disabled veteran-owned small business concerns

For these contracts VA assigned the North American Industry Classification System (NAICS) code of 524291 (Claims Adjusting) The size limitation established by the Small Business Administration (SBA) for this NAICS code is $7 million in annual revenue To be eligible for award as an SDVOSB an offeror must represent in good faith that it is an SDVOSB at the time of its written representation After the contract was awarded the contractor must continue to represent that it is compliant with the size limitations established by the SBA for the assigned NAICS code

Both ETS and Primeaux used Health Net as their subcontractor Health Net has a network of health care providers and provides claims re-pricing services The contracts required the contractor to identify potential cost savings by comparing claims that VA received from non-VA health care providers for services for veterans to rates established by the contractor if the provider was part of their network If the network rates established between the contractor and the provider were lower than the VA-allowable amounts the difference between the two amounts was considered a potential savings to VA and the contractors received a percentage of the potential savings as the agreed upon fee Exhibit A shows the claims re-pricing process graphically The fee percentages ranged from 135 to 16 percent plus 5 percent for performance incentives ETS reported their total contract fee was $82 million for all five contracts for the period of January 2009 to December 2011

The fee that VA paid to ETS is determined and based strictly on the percentage of the difference between the VA-allowable amount and the reported network rate with that

provider and not based on any actual savings realized by VA In other words the fee is not based on any recovery by VA or future savings due to adjustments in the amounts claimed by the provider (See Exhibit B for FY 2011 contractorrsquos fee data as an example)

Records show that VA had a contractual relationship with Health Net for claims reshypricing beginning in 1999 shortly after regulations were promulgated establishing fees that VA would pay for services provided by non-VA hospitals and physicians Regulations promulgated at 38 Code of Federal Regulations (CFR) sect 1756 in July 1998 provided that payment for non-VA physician services associated with outpatient and inpatient care provided at non-VA facilities would be the ldquolesser of the amount billed or the amount calculated using the formula developed by the Department of Health amp Human Services Health Care Financing Administration (HCFA) under Medicarersquos participating fees schedule for the period on which the service is providedrdquo The regulation also provided that if no amount has been calculated under Medicarersquos participating physician fee program or the services constituted anesthesia services the payment would be the ldquolesser of the actual amount billed or the amount calculated using the 75th percentile methodology set forth in paragraph (c) of the regulation or the usual and customary rate if there were fewer than eight treatment occurrences for a procedure during the previous fiscal yearrdquo This regulation was amended in November 2000 to allow payment at rates negotiated between VA and hospitals or physicians It is clear from the information published in the Federal Register that payment at other than Medicare rates was to be the exception rather than the rule The regulations did not provide for a re-pricing agent or re-pricing services such as those provided by Health Net and subsequently ETS and Primeaux Therefore it is not clear what if any benefit VA derived for these services prior to February 2010

In February 2010 VA issued a proposed rule to amend sect1756 The rule became final in December 2010 The new regulations provided the following payment methodology hierarchy

(a) (1) If a specific amount has been negotiated with a specific provider VA will pay that amount

(2) If an amount has not been negotiated under paragraph (a)(1) of this section VA will pay the lowest of the following amounts (i) The applicable Medicare fee schedule or prospective payment system

amount (Medicare rate) for the period in which the service was providedhellip

(ii) The amount negotiated by a repricing agent if the provider is participating within the repricing agentrsquos network and VA has a contract with that repricing agent For the purposes of this section repricing agent means a contractor that seeks to connect VA with discounted rates from non-VA providers as a result of existing

contracts that the non-VA provider may have within the commercial health care industry

(iii) The amount that the provider bills the general public for the same service

Although an amount negotiated by a re-pricing agent such as Health Net was an option after the regulations were amended this amount could only be used if a specific amount has not been negotiated with a specific provider under paragraph

(a)(1) of 38 CFR sect 1756 VA has a contract with the re-pricing contractor the provider is participating within the re-pricing agentrsquos network and the re-priced amount is the lowest in the payment methodology hierarchy under

paragraph (a)(2) of 38 CFR sect 1756

In 2010 the contracts awarded in 2007 and 2008 to ETS and Primeaux were still in effect The contracts should have been terminated because the regulation defines a reshypricing agent as a ldquocontractor that seeks to connect VA with discounted rates from non-VA providers as a result of existing contracts that the non-VA provider may have within the commercial health care industryrdquo (emphasis added) Neither ETS nor Primeaux qualify as re-pricing agents under this definition

Although the percentage fee to ETS was not based on actual savings we attempted to determine whether HAC used the information provided under the contract to obtain cost savings However we were unable to identify any actual savings The current COTR at the HAC did not have information on whether the potential savings were actually realized for each VA Medical Center (VAMC) because each one was responsible for submitting claims to Health Net and paying for the services Each VAMC prepared a purchase order generally once a year using its respective contract obligated funds for re-pricing services and made payments to ETS To validate any actual savings from claims re-pricing we visited a local fee service office but we could not substantiate actual savings We were provided data that showed payment to non-VA providers at the price provided VA by Health Net however the data also indicated that the Health Net prices were significantly higher than the Medicare rates According to the provisions in 38 CFR sect1756 after 2010 payment should have been at the Medicare rate because it was lower Prior to 2010 there was no provision to use re-pricing data to establish reimbursement rates for non-VA care

Scope and Methodology

For our review we interviewed VA and contractorsrsquo personnel for issues relevant to the review objectives and obtained reviewed and analyzed the following information and data

Five claims re-pricing contracts ETSrsquos fee data reported to VA financial records relevant to the review objectives

and payment data to its employees and subcontractors Contractorsrsquo status data reported in the Online Representations and Certifications

Application (ORCA)

We used the following guidance applicable to the review objectives

Subcontractor Requirements prescribed in the five claims re-pricing contracts FAR Subpart 412 Representations and Certifications FAR Subpart 193 Determination of Small Business Status for Small Business

Programs FAR Subpart 1914 Service-Disabled Veteran-Owned Small Business

Procurement Program FAR Subpart 52219-14 Limitations on Subcontracting FAR Subpart 52219-27 Notice of Total Service-Disabled Veteran-Owned Small

Business Set-Aside VAAR Subpart 852219-10 VA Notice of Total Service-Disabled Veteran-Owned

Small Business Set-Aside VAAR Subpart 8094 Debarment Suspension and Ineligibility VAAR Part 849 Termination of Contracts Title 31 USC sect 1352 Limitation on Use of Appropriated Funds to Influence

Certain Federal Contracting and Financial Transactions Public Law 109-461 Title V sect 502 Paragraph 8127(g) Enforcement Penalties for

Misrepresentation Small Business Administration (SBA) ldquoTable of Small Business Size Standards

Matched to North American Industry Classification System Codesrdquo 38 CFR sect 1756 Payment for non-VA physician and other health care professional

services (2007 to 2010 Editions) 38 CFR sect 1756 VA payment for inpatient and outpatient health care professional

services at non-departmental facilities and other medical charges associated with non-VA outpatient care (7-1-2011 Edition)

Results of Review

Finding 1 ETS Did Not Comply with Subcontracting Limitations

All five contract awards for claims re-pricing were SDVOSB set-aside procurements As such all five contracts had subcontracting limitations contained in the contract that limited how much ETS could outsource to subcontractors Our review determined that ETS did not have the ability to re-price claims and notwithstanding the provisions in the contract limiting subcontracting always intended to subcontract the total contract requirements to Health Net Also our review of ETSrsquos financial information demonstrates that the majority of contract revenues ultimately went to its subcontractor Health Net

1 ETS Intended for Health Net to Perform All Claims Re-pricing In 1999 Health Net approached VA with a concept of Preferred Pricing for claims generated from non-VA health care providers which is also known as claims re-pricing In August 1999 VA awarded its first VISN level contract in Northern California to Health Net for claims re-pricing In 2006 the HAC planned to centralize and consolidate the VISN level reshypricing contracts to five regions Our review of early planning documents found that VA originally intended a full and open competition acquisition Based on an interview with the ETS Program Manager we learned that during this same time frame Health Net encouraged Mr Donald Neilson a former VA senior official to set up an SDVOSB concern for claims re-pricing contracts According to ETSrsquos history on its website Mr Neilson established the business in October 2006

Based on documents obtained from the VA Contracting Specialist (CS) we determined that during February 2006 HAC officials discussed the then-future contract information with Health Net One official at the HAC stated in an e-mail with the subject line ldquonational re-pricing agreementrdquo

Irsquom not aware of any major changes regarding the technical requirements but if there are any we just need to get them into a new draft SOWhellip Attached for your info [sic] only at the moment is the latest version of my proposed letter to Health Net assuming there isnt a hard push-back from Health Net Also we will need to be thinking about how we want Health Net reports to be re-worded going forward The visit from Frank Kelly in a couple weeks may be a good forum to start discussing that

Mr Frank Kelly was Health Nets Director of VA Programs in 2006 and the e-mail clearly shows that VA was including Health Net in discussions regarding the statement of work and how Health Net reports should be re-worded under the new national agreements In March 2008 Mr Kelly left Health Net to establish Primeaux which was the SDVOSB that received two of the claims re-pricing contracts in September 2008

The data shows when taken in its entirety that ETS and Primeaux were set up to obtain SDVOSB set-aside contracts for claims re-pricing with the intention to subcontract most if not all of the requirements to Health Net Once VA awarded the contracts to ETS and Primeaux Health Net performed 100 percent of the claims re-pricing work for ETS Health Net performed more than 80 percent of the claims reprocessing for Primeaux until ETS acquired it in April 2009 afterwhich time Health Net performed 100 percent of the work ETS and Primeaux were merely SDVOSB pass-throughs

We determined that ETS did not comply with the contract provision and FAR clauses on subcontracting limitations

ETS Did Not Perform Did Not Intended to Perform and Was Not Capable of Performing Any of the Required Tasks All five re-pricing contracts contained a contract clause (statement of work paragraph 10) stating ldquoIf a subcontractor is used to complete the requirements of the contractor the contractor shall provide that information in their proposal The prime contractor shall conduct a minimum of 51 of the requirements of the contractrdquo ETS did not perform any work under the contracts much less a minimum of 51 percent of the tasks required by the contracts An ETS official admitted to us that ETS did not perform any of the claims re-pricing In fact ETS never actually received or reviewed claims from VA that were to be reshypriced Notwithstanding the fact that the contracts were awarded to ETS and Primeaux as SDVOSB set-asides and included requirements that ETS and Primeaux perform a percentage of the work VHA sent all claims directly to Health Net not ETS or Primeaux These actions by VHA officials shows that HAC intentionally misshyused the SDVOSB set-aside authority to ensure that Health Net would provide the required services which otherwise may not have been possible if Health Net had to compete for the award

Based on ETSrsquos profitloss (PL) statements for calendar years (CY) 2009 2010 and 2011 Health Net was the only subcontractor who performed re-pricing of claims for ETS under the five contracts (see Exhibit A) We found that ETS paid Health Net 79 percent of its contract revenue in 2009 62 percent in 2010 and 53 percent in 2011 Conversely ETS kept 14 to 25 percent of its entire contract revenues In addition to further demonstrating that Health Net was performing the actual work under the reshypricing contracts this information also indicates that VHA was overpaying for the services as ETS and Primeaux were paid a significant fee just for using their SDVOSB status to obtain the contract awards on behalf of Health Net In addition the figures show that VHA paid millions of dollars without any evidence of cost savings recovery or avoidance

ETS Did Not Expend 50 Percent of The Personnel Cost On Their Own Employees All five contracts contained FAR Subparts 52219-14 and 52219-17 that require the prime contractor to expend at least 50 percent of the cost of personnel for contract performance on their own or another SDVOSBrsquos employees We determined that ETS did not comply with requirements of these FAR clauses We compared the ETS personnel costs to the total payments made to Health Net a large business which actually conducted the claims re-pricing for ETS Using the data in the ETSrsquos PL statements we determined that ETSrsquos personnel costs ranged from 092 to 374 percent compared to the payments made to Health Net Conversely ETS paid Health Net 96 to 98 percent of the cost for contract performance which is claims re-pricing

2 ETS Misrepresented Its Capability to Perform Tasks Under NAICS Code 524291 Contractors are required to annually certify their status and applicable NAICS codes in ORCA FAR Subparts 191403(b)(2) and 19301-2(c) require that at the time an SDVOSB submits its offer it must represent to the CO that it is a small business concern under the NAICS code specifically assigned to the acquisition We determined that ETS misrepresented that they were a small business concern relative to the NAICS code assigned to these contracts ETS did not have the ability to re-price the contracts as they had neither the systems expertise nor the network of providers necessary to re-price the claims and intended to subcontract all the requirements to Health Net Table 1 shows ETS certified they were an SDVOSB capable of performing work related to NAICS code 524291 from October 2007 to January 2011 For the period from January 26 2011 to January 26 2012 ETS did not use the NAICS code of 524291 which means ETS no longer meets the small business size standard corresponding to the NAICS code assigned to the five contracts in effect at the time of contract award

Table 1mdashORCA Certification of NAICS Code 524291

Certification Period in ORCA

NAICS Code 524291 Used

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

According to FAR 41201 submission of the certification and disclosure of a company is a prerequisite for entering into a contract with a Federal Government entity By certifying that they had the ability to perform work related to NAICS code 524291 ETS misrepresented its status in order to qualify for SDVOSB set-aside contracts for claims re-pricing

Finding 2 The SDVOSB Set-aside Determination Was Not Properly Justified

HAC personnel did not properly justify the SDVOSB set-aside procurements FAR Subpart 191202-2 requires that the extent of participation of SDVOSB concerns in performance of the contract for the assigned NAICS code be evaluated in competitive negotiated acquisitions expected to exceed $650000 That is VA should determine that SDVOSB concerns are capable of satisfying the contract requirements in terms of the NAICS code assigned to the contract when the receipt amount by the potential contractor exceeds $650000 Each of the five contracts listed $65 million5 as the maximum receipt amount by the potential contractor for the assigned NAICS code 524291 which is for claims adjusting primarily in investigating appraising and settling insurance claims

Of the five contracts we selected the contract VA741-P-0011 awarded on September 26 2007 for a detailed review of the acquisition plan and source selection documents Based on the acquisition plan HAC personnel initially planned to solicit offers through an unrestricted full and open competition because prior VISN competitions and an informal market survey did not support a set-aside acquisition The documentation shows that HAC officials changed the acquisition from full and open competition to an SDVOSB set-aside procurement Our review of the contract file found that it lacked documentation providing insight as to the reason for the change in the type of acquisition As stated earlier in this report we know VA officials at the HAC were discussing the national re-pricing effort with Health Net officials who at the same time were encouraging a VA former employee to start up an SDVOSB company HAC officials also stated that they became aware of other SDVOSB companies that were identified in a local claims re-pricing contract solicitation that was conducted as an SDVOSB set-aside procurement in VISN 1011 The CS for VISN 1011 stated that there were five offers from SDVOSBs (one of them being ETS) in response to the VISN 1011 solicitation The CS stated that ETS received the highest ranking and the remaining four contractors finished at a distance Based on this information the CO stated that they decided at that time to award the contract VA741-P-0011 and subsequently process all five national reshypricing procurements as SDVOSB set-asides However there is no documentation supporting the statements that there were five potential SDVOSBs there is no evidence that VA issued a sources sought notice to determine if there were two or more SDVOSBs capable of performing the work and there is no support that shows that VA attempted any technical evaluation of ETSrsquos performance under the VISN 1011 contract Upon posting of the solicitation for contract VA741-P-0011 on the Federal Business Opportunities website the CO received one proposal from ETS and denied another company that requested an extension

5 The contracts included the small business size limitation of $65 million for NAICS code 524291

Contract VA741-P-0011 was the first claims re-pricing contract awarded by the HAC in September 2007 and it was signed by the initial CO In August 2008 a new CO at the HAC was assigned the remaining four procurement actions and was told that they were complete and ready to be awarded The new CO stated that his only involvement in the procurement process was to award the contracts and administer them

We briefly reviewed documents contained in eCMS (VArsquos electronic contract management system) for the four remaining contracts and did not find any evidence of additional market research in these four procurements We did observe documentation for one of the contracts where the Contracting Officerrsquos Technical Representative (COTR) doubted whether one of the SDVOSB concerns could actually perform 50 percent of the work (this SDVOSB was not selected) However this same concern did not appear to be raised in reference to ETS or Primeaux Documents also show that after award to ETS and Primeaux facilities would continue to send claims directly to Health Netmdashnothing had changed except for the invoicing

After VHA awarded the contracts to ETS and Primeaux in 2007 and 2008 the COTR learned that Health Net was performing the majority if not all of the re-pricing work on behalf of both ETS and Primeaux In December 2008 the COTR raised a concern to the CO that Primeaux and ETS potentially violated the SDVOSB requirement prescribed in FAR 52219-27(c)(1) On January 8 2009 the CO requested ETS and Primeaux to self-certify the percentage of the contractors personnel cost incurred for the performance of all five contracts On January 21 2009 ETS President Mr Neilson submitted a memorandum stating ETS provides approximately 62 percent of the cost of personnel for contract performance as required by FAR 52219-27(c)(1)

In response the COTR documented her concern that ETS employed six individuals did not identify all of its subcontractors in its proposal and suggested that they may have misinterpreted the request by the CO According to the COTRrsquos document in January 2009 the CO conducted numerous discussions with VArsquos Office of Small and Disadvantaged Business Utilization concerning appropriate actions and guidance but does not indicate what advice or guidance was given The COTR documented on January 27 2009 that the President of Primeaux stated 129 percent of the contract revenue was retained by Primeaux for the contract performance including employee compensation This low percentage showed Primeaux was in clear violation of the restrictions on subcontracting According to the COTR there was a telephone conversation held with Primeaux on January 28 2009 and it included the Chief Business Office (CBO) Chief of Logistics CBO Deputy Chief of Logistics CO and COTR However the COTR did not document the details of the conversation and there is no evidence that any action was taken to ensure compliance or terminate the contract for default Shortly thereafter in April 2009 ETS acquired Primeaux and became the prime contractor for the two contracts awarded to Primeaux However ETS did not request a novation and instead retained the companyrsquos name (Primeaux) which was inappropriate

Our review found that the statements made by ETS and Primeaux in response to the COrsquos request for verification of compliance with the applicable contract provisions were false and misleading

Additional Issue

During our review we attempted to determine if VA actually received any cost savings as a result of the re-pricing work by ETS As stated earlier the COTR had no information whether the potential savings identified by ETS were actually realized by VA We visited the fee office in Perry Point MD and reviewed selected individual claims to determine if VA realized any savings due to the ETS re-pricing Under the current regulations when no contract is present with the provider VA pays the lower of the Medicare rate the rate from the re-pricer (Health Net) or billed charges The only time VA would recognize savings by a re-pricer like Health Net would be when their rate is lower than the Medicare or actual billed rate Our review of fee claims for four patients for a one month period at Perry Point MD found no instances where ETSrsquos rate was less than the Medicare rate in fact it was substantially higher than the Medicare rate as shown in Table 2

Table 2mdashComparison of ETS Re-priced Amounts vs Medicare Amount for Perry Point MD Fee Claims

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

Difference (b) - (a)

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

The OIG Office of Healthcare Inspections (OHI) identified overpayments of non-VA care claims as part of their on-going reviews of Community Based Outpatient Clinics (CBOC) OHI conducted a preliminary review of fee claims for non-VA care for three CBOCs for the period of February 15 2011 through September 30 2011 Their review was limited to CT MRI and PET scans OHI found that VA overpaid at rates significantly above Medicare rates when the amount submitted by the re-pricer was used as shown in Table 3 on the next page

Table 3mdashComparison of VA Payments vs Medicare Amounts for Three CBOCs

CBOC Actual VA Payments

Amounts per Medicare

Overpayment Overpayment

Payson AZ $32479 $11310 $21169 187 ShowLow AZ 174024 77441 96583 125 Savannah GA 17786 8414 9372 111

Totals $224289 $97165 $127124 131

OHI determined that the majority of the overpayments was due to the fact that the local fee offices were not submitting the claims to Affiliated Computer Services Inc (ACS) VArsquos Medicare pricer We saw no circumstance where the Health Net re-pricer amount was lower than Medicare

Under the new regulations VA must determine which of three prices is the lowest To do so VA must pay both a Medicare pricer and a re-pricer to make this determination As discussed above the fees for the re-pricer are significant since they are based on a percentage of potential cost savings not savings actually realized In other words we pay a percentage of the cost savings even if the amount submitted by the re-pricer is not lower than Medicare However at the same time VA would have to pay the Medicare pricer the contract fee of almost $200 per claim Unless there is evidence that the amounts submitted by the re-pricer are lower than the rate paid by Medicare in amounts significant enough to justify the paying fees to the re-pricer we recommend not using a re-pricer or limiting the re-pricer to those procedures for which there is no Medicare rate or for which VA is certain the re-pricer amount would be less than the Medicare rates established by the Centers for Medicare and Medicaid Services (CMS)

Conclusions

Our review determined that ETS did not comply with the contract provisions limiting subcontracting ETS did not perform any of the re-pricing tasks under its five contracts nor did ETS have the capability to perform the tasks required under the contract even though ETS officials certified in the ORCA system that it was qualified to perform tasks related to the NAICS code 524291 Claims Adjusting Health Net encouraged the president of ETS to establish ETS as an SDVOSB concern in order to compete for SDVOSB set-asides with the intention that Health Net would perform all the requirements under the contract ETS simply acted as an SDVOSB front for Health Net and funneled all the work and the majority of contract revenues to Health Net

Our review of the acquisition planning documents shows that HAC officials did not properly justify the SDVOSB set-asides for the claims re-pricing contracts HAC personnel changed the initial acquisition method of an unrestricted full and open competition to a total set-aside acquisition for SDVOSB without adequate market research or proper justification or support to show that two or more qualified SDVOSB concerns existed that could perform the work associated with the NAICS code assigned to the procurements

We also determined that the revised regulations allow for VA to use the amount submitted by a re-pricer if the amount is lower than the Medicare rate established by CMS Our review and work done by OHI did not show that the amounts submitted by the re-pricer were lower than the established Medicare rates therefore we question whether it is fiscally sound to pay for both a Medicare pricer and a re-pricer to review each claim for VA to determine which is lower This is especially true given the significant fees paid to the re-pricer regardless of whether there is a cost savings

Recommendations

We recommend that the Chief Procurement and Logistics Officer

1 Terminate the five claims re-pricing contracts for default based on breach of contract in accordance with FAR Subpart 494 and VAAR Part 849

2 Coordinate with the Under Secretary for Health to determine if there is a need for any contract(s) for repricing of non-VA fee claims

3 If the vendor is a former VA employee or primarily composed of former VA employees ensure that the requirements do not preclude competition by giving former VA employees an unfair advantage

We recommend that the Under Secretary for Health

4 Determine whether claims re-pricing provides access to prices lower than Medicare prices for non-VA fee based care and whether there has been actual cost savings Evaluate whether these contracts are necessary and are in the best interest of the taxpayer taking into consideration the fact that VA must pay to have each claim reviewed by a Medicare pricer and the re-pricer to determine which is lower

5 Ensure all fee claims are forwarded to ACS VArsquos Medicare pricer to determine the Medicare rates

6 Implement mandatory training requirements for program offices to ensure requirements are not written to preclude competition or give former VA employees an unfair advantage

7 Ensure justifications for sole-source awards receive appropriate approvals to ensure that competition is achieved to the maximum extent practicable

Acronyms

ACS Affiliated Computer Services Inc

CBOC Community Based Outpatient Clinic

CMS Centers for Medicare and Medicaid Services

CO Contracting Officer

COTR Contracting Officers Technical Representative

CS Contract Specialist

CY Calendar Year

eCMS Electronic Contract Management System

ETS Enterprise Technology Solutions LLC

FAR Federal Acquisition Regulation

FBCS Fee Basis Claims System

FY Fiscal Year

HAC Health Administration Center

IRS Internal Revenue Service

NAICS North American Industry Classification System Code

OHI Office of Healthcare Inspections

OIG Office of Inspector General

ORCA Online Representations and Certifications Application

PL ProfitLoss

SBA Small Business Administration

SDVOSB Service-Disabled Veteran-Owned Small Business

VA Department of Veterans Affairs

VAAR VA Acquisition Regulation

VAMC VA Medical Center

VISN Veterans Integrated Service Networks

Exhibit A Claims Re-pricing Process Page 1 of 2

Exhibit B FY 2011 ETS Contract Fees

Solutions LLC Compliance with Serviceimitations

anagement

Review of Enterprise Technolog edontracting

DisabReview of Enterprise Technology y Solutions LLC Compliance with Service-Disablled Veteran-Owned Small Business Program Subcontracting L Limitations

Appendix A Page 1 of 6

MManagement Comments

VETERANS HEALTH ADMINISTRATION Action Plan

OIG Draft Report Review of Enterprise Technology Solutions LLC Compliance with Service-Disabled Veteran-Owned Small Business Program Subcontracting Limitations (VAIQ 7243742)

Date of Draft Report July 5 2012

Recommendations Status Completion Actions Date

Recommendation 1 We recommend that the Chief Procurement and Logistics Officer terminate the five claims re-pricing contracts for default based on breach of contract in accordance with FAR Subpart 494 and VAAR Part 849

VHA Comments Concur

Pursuant to the Federal Acquisition Regulations (FAR) Subpart 494 and Veterans Affairs Acquisition Regulations (VAAR) Part 849 the Veterans Health Administration (VHA) Chief Procurement and Logistics Officer (CPampLO) intends to terminate for default all five contracts for claims re-pricing Upon termination of the contracts VHArsquos Chief Business Office (CBO) will take the following actions

1 Notify field sites to immediately stop transmitting claims to Enterprise Technology Solutions (ETS) for re-pricing

2 Initiate an information technology (IT) solution to disable the Fee Basis Claims System (FBCS) functionality to transmit claims to ETS

In process October 31 2012

Recommendation 2 We recommend that the Chief Procurement and Logistics Officer coordinate with the Under Secretary for Health to determine if there is a need for any contract(s) for repricing of non-VA fee claims

VHA Comments Concur

VHArsquos CBO will work with CPampLO to take steps to determine the availability of reshypricing contract opportunities that would be beneficial to the Department of Veterans Affairs (VA) This would include taking steps to do a Request for Information to see if savings below Centers for Medicare amp Medicaid Services (CMS) rates are available

Recommendation 3 We recommend that the Chief Procurement and Logistics Officer if the vendor is a former VA employee or primarily composed of former VA employees ensure that the requirements do not preclude competition by giving former VA employees an unfair advantage

VHA Comments Concur

VHA CPampLO will review and integrate into the existing customer checklists for Services and Advisory and Assistance requirements that the customer must provide a statement notifying the Contracting Officer (CO) if the proposed or potential vendor is a former VA employee or if the staff of the vendor is primarily composed of former VA staff VHA CPampLO will also prepare a memorandum to the procurement staff to remind them to carefully review requirement documentation to ensure documents do not contain restrictive language that would inhibit competition

Recommendation 4 We recommend that the Under Secretary for Health determine whether claims re-pricing provides access to prices lower than Medicare prices for non-VA fee based care and whether there has been actual cost savings Evaluate whether these contracts are necessary and are in the best interest of the taxpayer taking into consideration the fact that VA must pay to have each claim reviewed by a Medicare pricer and the re-pricer to determine which is lower

VHA Comments Concur

VHArsquos CBO will conduct analysis to determine if re-pricing did provide prices lower than Medicare rates and if there have been actual cost savings This will be done by auditing what the Medicare price would be re-pricing amount and amount paid

Additionally CBO will perform a cost benefit ratio in order to determine if continued use of re-pricing continues to be beneficial with the use of Medicare rates

Recommendation 5 We recommend that the Under Secretary for Health ensure all fee claims are forwarded to AC VArsquos Medicare pricer to determine the Medicare rates

VHA Response Concur

While VHA agrees with the intent of this statement which is to ensure that VHA pays CMS pricing as extensively as possible the requirement to pay a Medicare pricing contractor is becoming obsolete because of a technical upgrade to the FBCS software that allows sites to process claims at Medicare rates Currently the Medicare pricing contractor ACS prices the following claims for the Non-VA Care Program Ambulatory Surgical Center Anesthesia Dialysis and Hospital Outpatient Until the FBCS software upgrade is complete at a site VHA expects

sites to continue submitting these claims to the Medicare pricing contractor The FBCS upgrade is scheduled for completion in August 2012

In process August 31 2012

Recommendation 6 We recommend that the Under Secretary for Health implement mandatory training requirements for program offices to ensure requirements are not written to preclude competition or give former VA employees an unfair advantage

VHA Response Concur

In fiscal year (FY) 2013 the Deputy Under Secretary for Health for Operations and Management will mandate that identified program office officials and Contracting Officer Representatives will complete a performance-based statement of work course to ensure that requirements are not written to preclude competition or give former VA employees an unfair advantage

In process September 30 2013

Recommendation 7 We recommend that the Under Secretary for Health ensure justifications for sole-source awards receive appropriate approvals to ensure that competition is achieved to the maximum extent practicable

VHA Response Concur

VHA CPampLO developed and implemented an Other Than Full and Open Competition standard operating procedure (dated March 22 2011) to address appropriate review and approval of sole source awards Current approval thresholds require NetworkProgram Contract Manager approval for proposed sole source contracts estimated at $3000 to $500000 Contracts over $500000 require approval from the Head of the Contracting Activity

In FY 2011 and FY 2012 VHA CPampLO also instituted metrics to track the number and dollar value of sole source awards issued by each VHA contracting office

Complete

Veterans Health Administration August 2012

Appendix B

OIG Contact and Staff Acknowledgements

Contact For more information about this report please contact the OIG at (202) 461-4720

Acknowledgments Myong Brown Joseph Houston Victor Rhee Murray Leigh Thomas Seluzicki

Appendix C

Report Distribution

VA Distribution Office of the Secretary Veterans Health Administration Veterans Benefits Administration National Cemetery Administration Assistant Secretaries Office of General Counsel

Non-VA Distribution House Committee on Veteransrsquo Affairs House Appropriations Subcommittee on Military Construction

Veterans Affairs and Related Agencies House Committee on Oversight and Government Reform Senate Committee on Veteransrsquo Affairs Senate Appropriations Subcommittee on Military Construction

Veterans Affairs and Related Agencies Senate Committee on Homeland Security and Governmental Affairs National Veterans Service Organizations Government Accountability Office Office of Management and Budget

This report is available at httpwwwvagovoigpublicationsreports-listasp

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Veterans Health Administration Action Plan

OIG contact amd Staff Acknowledgements

Report Distribution

BestWayne------------------------------From Mitchell Amy [AmyMitchellmailhousegov]Sent Wednesday August 22 2012 915 AM Subj Committee Releases VA Conference Inquiry and Patton-Style Videos IMMEDIATE RELEASE August 22 2012 CONTACT Amy Mitchell (202) 225-3527

Committee Releases VA Conference Inquiry and ldquoPatton-Stylerdquo Videos

WASHINGTON DCmdashToday Rep Jeff Miller Chairman of the House Committee onVeteransrsquo Affairs along with Rep Bob Filner Ranking Member of the Committee releaseda letter sent August 16 2012 to Secretary of the Department of Veterans Affairs theHonorable Eric K Shinseki regarding VA conferences expenditures and the VA OIGconference investigation To view the letter please click here The Committee also obtained the ldquoPatton-stylerdquo videos produced for the two VAconferences last year at an approximate cost of $52000 To view the video click hereChairman Jeff Miller said of the videos ldquoI question the excessiveness in which taxpayer dollars are being used to fund multi-milliondollar conferences The Committee will continue to investigate these conferences I haverequested all budgets and materials for VA conferences that have occurred over the past threeyears to see if these two conferences are an anomaly or are part of a bigger patternrdquoTo learn more about the investigation click here

For more news from the House Committee on Veteransrsquo Affairs please visitVeteransHouseGov

Find us on Facebook at FacebookcomHouseVetsAffairs or follow us on Twitter atHouseVetAffairs

---------------------------------------VA Veterans News for Wednesday August 22 2012 Thanks to Kevin Secor VA VSOLiaison

1 Cold War spy tunnel under Berlin found in forest after 56 years 2 Australian general chosen as US Army Pacific deputy 3 Australian mining companies seeking US vets for high-paying jobs 4 Asbestos and mustard gas close part of Miss island for years 5 Groups call on Marines to sever ties with UFC6 Chesapeake firm regains veteran-owned status 7 Mitt Romney Coming To Indianapolis To Address American Legion

Convention 8 Concern About Two VA Conferences Noted In Story On Generals Spending Of

Government Funds 9 Social And Collaborative Technologies Are A Compelling Fit For Health Care 10 The Challenges Female Vets Face When Coming Home 11 Trauma And Technology New Tools Teach Veterans Clinicians About PTSD 12 Va Vet Detained After Radical Facebook Posts 13 Health Calendar

14 Behind Mental Health Stigmas In Black Communities 15 Can Nasal Spray Help Prevent Military Suicides 16 VA Restoring Function To Those With Limb Loss 17 VA And Defense Drop Vendor-Specific Database Requirement For Joint

Pharmacy System 18 Veterans Agency Overturns Decision On Navy SEAL Denied Contracts 19 Veterans Invited To Resource Forum 20 Survey Reveals Increasing Hostility In US Towards Religion 21 Suits For Soldiers Initiative Begins Helping Wounded Veterans Find Civilian

Jobs 22 Unemployment Hits Some Population Groups Harder 23 USMC Investigates GI Bill Anomaly 24 Who Will Stop The American Veteran Suicide Epidemic 25 Mountain View Man Sets Record With 600th Donation At Stanford Blood

Center 26 Veterans In The Justice System Pose Special Challenges For Courts

Corrections 27 Dakota Meyer Blasts Army Brass In New Book 28 Recovering Veteran Ready To Run 29 VA Counseling Available 30 VA VSO-MSO Hearings as August 22 201231 Today in History 1 Cold War spy tunnel under Berlin found in forest after 56 years A section of an

ingenious tunnel built by US and British spies to intercept Russian phoneconversations in Cold War Berlin has been found after 56 years in a forest 93 milesfrom the German capital

2 Australian general chosen as US Army Pacific deputy In one of the highest-

ranking assignments of its kind a two-star general with the Australian Defense Forcehas been named a deputy commanding general of US Army Pacific headquarteredat Fort Shafter

3 Australian mining companies seeking US vets for high-paying jobs Australian

mining companies are head-hunting US war veterans to work Down Under aselectricians carpenters and heavy equipment operators

4 Asbestos and mustard gas close part of Miss island for years Thirty acres of

Horn Island are off limits to the public -- and may be closed for years -- afterhazardous materials from a World War II chemical and biological test site werediscovered by environmentalists with a BP oil cleanup crew

5 Groups call on Marines to sever ties with UFC A group of veterans is asking the

Marine Corps to stop sponsoring the Ultimate Fighting Championship saying themixed martial arts organization tolerates inappropriate and offensive speech and isinconsistent with the Corpsrsquo values

6 Chesapeake firm regains veteran-owned status The Virginian-Pilot Veterans and

business groups spotlighted Lillys case as an example of over-regulation by the US

Department of Veterans Affairs to stamp out fraud in the veteran certificationprogram Syncon initially received the veteran designation in September

7 Mitt Romney Coming To Indianapolis To Address American Legion

Convention Indianapolis Star Mitt Romney will address the American Legionsnational convention in Indianapolis on Aug 29 the day before he accepts theRepublican nomination for president President Obama meanwhile will give avideotaped speech to the Legion that will be shown Aug 28 The Legionscommander Faye Wong said I think its very important that we hear from theprincipal candidates for president on how they plan on leading the country for thenext four years as far as getting us to a more solid ground especially with defenseand the caring of the veterans and returning warriors coming back The Star pointsout that Veterans Affairs Secretary Eric Shinseki is scheduled to speak at the Legionsconvention though it does not say when that will happen

8 Concern About Two VA Conferences Noted In Story On Generals Spending Of

Government Funds Federal Computer Week Gen William Kip Ward a formerfour-star US Army general was reduced to the two-star rank last year after aninternal Defense Department Inspector General report revealed he improperly spenthundreds of thousands of dollars in government funds including on travel andunauthorized use of military vehicles The findings on Ward are the latest incidentin a series of government scandals that have put a spotlight on financial misuse insome of Washingtons most powerful organizations Federal Computer Week takesnote of the 2010 GSA conference then adds More recently the Veterans Affairsdepartment was accused of overspending on two 2011 conferences allegations nowunder investigation

9 Social And Collaborative Technologies Are A Compelling Fit For Health

Care ComputerWorld As health care becomes increasingly participatory andcollaborative digital-social health has the potential to transform the patient populacefrom being mere passengers to responsible drivers of their health Chai notes that theUS Veterans Affairs Department of Veterans Affairs has outlined a social mediapolicy which encourages veterans to use social media to seek information from theVA Veterans should have consistent and convenient access to reliable VAinformation real time using social media - whether on a smartphone or a computeraccording to VA Secretary Eric Shinseki

10The Challenges Female Vets Face When Coming Home NPR audio As more

troops return home the transition can be difficult especially for women who servedServices designed to help veterans are not always equipped to deal with the needs ofthe nearly two million female veterans NPR discussed the unique challenges withwomen involved in the film SERVICE When Women Come Marching Home

11Trauma And Technology New Tools Teach Veterans Clinicians About PTSD

Boston Globe The US departments of Defense and Veterans Affairs are developinga host of tools online and on smartphones to help veterans dealing with post-traumatic stress disorder (PTSD) Conaboy adds The Home Base Program apartnership of the Red Sox Foundation and Massachusetts General Hospital earlierthis year launched a webcast training program for clinicians Called From the War

Zone to the Home Front the program which was created in collaboration with theVAs National Center for PTSD included 14 weeks of live webcast trainingsessions which are now archived and can be viewed for free continuing medicaleducation credits through Feb 23

12Va Vet Detained After Radical Facebook Posts AP A former Marine

involuntarily detained for psychiatric evaluation for posting strident anti-governmentmessages on Facebook has received an outpouring of support from people who sayauthorities are trampling on his First Amendment rights The 26-year-old BrandonJ Raub has been in custody since FBI and Secret Service agents and ChesterfieldCounty police questioned him Thursday evening about what they considered ominousposts talking of a coming revolution FBI Richmond spokeswoman Dennette Rybiskicommented on the situation stating Given the circumstances with the things thathave gone on in the country with some of these mass shootings it would be horriblefor law enforcement not to pay attention to complaints

13Health Calendar Steuben (NY) Courier The Bath VA Medical Center through the

Support and Family Education (SAFE) program will host a monthly support groupfor family members of veterans who are dealing with mental health issuesincluding post-traumatic stress disorder (PTSD) This months session will be heldfrom 430-6 pm Monday August 27 in the main hospital building building 76room 511 on the VA campus The Courier adds The Bath VA offers the Quit SmartProgram to assist eligible veterans who want to stop smoking

14Behind Mental Health Stigmas In Black Communities NPR audio Rep Jesse

Jackson Jrs recent diagnosis of bipolar disorder has focused attention on the shamethat sometimes accompanies mental health diagnoses in the African-Americancommunity NPRs John Donvan interviewed psychiatrist William Lawson MDPhD professor and chairman of the Department of Psychiatry at Howard UniversityCollege of Medicine who discussed the reasons why such stigma may exist includingthe fact that many African-Americans may believe that to be mentally ill is a sign ofweakness or a sign of a character fault Donvan also criticized Veterans Affairssaying We just dont see our veterans getting the access to services especially ourblack veterans that they should

15Can Nasal Spray Help Prevent Military Suicides CNN In the midst of a crisis

that saw its highest rate of suicide in July the Army has greenlighted a grant for DrMichael Kubek an Indiana University of Medicine professor to dig deeper intowhether a nasal spray could be a safe and effective way to administer aspecific antidepressive neurochemical to the brain and help calm suicidalthoughts Kubek helped discover thyrotropin-releasing hormone or TRH which isknown to have antisuicidal and antidepression effects The military is hopingKubekcan use a three-year grant to work with other researchers to use a nasal sprayto get TRH safely into the brain and calm soldiers thoughts

16VA Restoring Function To Those With Limb Loss Arkansas Medical News The

Department of Veterans Affairs (VA) Veterans Health Administration (VHA)provides medical care for those who are discharged from the military including thosewho are severely injured during their military service Escarda said restoring function

to those with limb loss is one of the VAs highest priorities Dr Jose Escarda staffpsychiatrist and the medical director of the Prosthetic Amputee Clinic CentralArkansas Veterans Healthcare System said they have state-of-the-art equipment anda highly knowledgeable experienced and skilled prosthetist and prosthetic assistant

17VA And Defense Drop Vendor-Specific Database Requirement For Joint

Pharmacy System NextGov The Defense and Veterans Affairs departments havedropped a mandate that any vendor planning to bid on the pharmacy system for theintegrated electronic health record use a drug database supplied by First Databank aSan Francisco-based subsidiary of media conglomerate Hearst Corp In 2011 theattorneys general of Kentucky and Michigan slammed First Databank and drugwholesaler McKesson Corp with lawsuits charging the companies conspired to inflateprices for drugs prescribed under the states Medicaid programs The iEHR pharmacysystem will manage 190 million Defense and VA drug prescriptions per year fornearly 10 million TRICARE beneficiaries and 85 million veterans

18Veterans Agency Overturns Decision On Navy SEAL Denied Contracts

Bloomberg News US Veterans Affairs Department has overturned its decisionrejecting a retired Navy SEAL from a contracting program designed to help veteran-owned businesses The agency told 23-year veteran Mark Lilly that Syncon LLC hisChesapeake Virginia-based construction company is now allowed to compete for thecontracts according to a VA letter sent to the decorated Afghanistan vet on MondayIn the past VA said it was concerned about who was running Syncon in part becausethe retired SEALs minority partner who isnt a veteran has more constructionexperience than Lilly In a phone interview Lily commented on VAs Monday letterstating Im very happy thatI can get back to work

19Veterans Invited To Resource Forum Roswell (GA) Patch Veterans of all

branches of the military are invited to attend a Resource Forum on Tuesday Aug 21starting at 11 am at the North Fulton Service Center at 7741 Roswell Road SandySprings The event is sponsored by Fulton County Health Services to inform veteransabout services available for them and their families The forum will also featurepresentations from 11 am to 1230 pm by three leading veterans organizationsVeterans Heart Georgia BraveHeart and the US Department of Veterans Affairs

20Survey Reveals Increasing Hostility In US Towards Religion Catholic News

Agency A report examining court cases from recent years has found that hostilitytowards religion has grown to unprecedented levels in the United States The newly-updated Survey of Religious Hostility in America serves as a testament to the radicalshift in our cultures worldview on religion said Kelly Shackelford president ofLiberty Institute and Tony Perkins president of Family Research CouncilAccording to the Catholic News Agency the new report says the US Department ofVeterans Affairs banned funerals at national cemeteries from including religiouscontent even if the grieving family wanted the ceremony to include references toGod

21Suits For Soldiers Initiative Begins Helping Wounded Veterans Find Civilian

Jobs Florida Times-Union Jacksonville-based Dignity U Wear recently distributedthe first of 3000 Suits for Soldiers Brooks Brothers suits designated for wounded

veterans The first distribution held Aug 17 went to participants in WoundedWarrior Projects TRACK Program according to a news release Cravey addsSuits for Soldiers is a strategic partnership with the Wounded Warrior Project thetransition team of the Marines and the US Veterans Affairs Department

22Unemployment Hits Some Population Groups Harder BizTimes Wisconsins

unemployment rate is at 7 percent and the national unemployment rate is at 83percent but the unemployment numbers are even higher for people in some segmentsof the population including young adults veterans and minorities The BizTimescontinued More than 2000 veterans attended the first 12 career fairs hosted by thestate Department of Veterans Affairs this year said Secretary John ScocosThe BizTimes added Since he became secretary of the department in August 2011the DVA has sent out more than 7000 emails and letters to veterans in an effort toconnect them with jobs Scocos said

23USMC Investigates GI Bill Anomaly Marine Corps Times US Marine Corps is

examining how its two boot camps inform recruits about their GI Bill educationbenefits The move was prompted when officials realized that so far this year nearlyall West Coast recruits have elected to buy into the Montgomery GI Bill while thevast majority of East Coast recruits have enrolled in the new Post-911 GI Bill whichis more generous than its predecessor and includes no buy-in fees The Times addsThe Post-911 GI bill is widely considered one of the best benefits available toservice members - primarily because it requires no buy-in and fully covers the cost oftuition and fees at public schools and up to $17500 for private institutions an amountscheduled to grow to $18000 according to the Veterans Affairs Department website

24Who Will Stop The American Veteran Suicide Epidemic Washington Examiner

25Mountain View Man Sets Record With 600th Donation At Stanford Blood

Center San Jose Mercury News A Mountain View man made history Mondaywhen he donated blood for the 600th time at the Stanford Blood Center David MitchMitchell 75 shrugged off his accomplishment as a whirring machine extracted theprecious red liquid from his left arm The Mercury News adds Only four othershave eclipsed the 500 mark at the center which provides life-saving blood productsto eight medical facilities including Lucile Packard Childrens Hospital the VA PaloAlto Health Care System and El Camino Hospital saidspokeswoman Dayna Kerecman Myers

26Veterans In The Justice System Pose Special Challenges For Courts

Corrections Oregonian

27Dakota Meyer Blasts Army Brass In New Book Military Times

28Recovering Veteran Ready To Run Steubenville (OH) Herald Star

29VA Counseling Available Woodland (CA) Daily Democrat

30VA VSO-MSO Hearings as August 22 2012

September 13 2012 HVAC Subcommittee on Health will hold a hearing on thePatient-Centered Community Care (PCCC) and Non-VA Care Coordination (NVCC)programs

September 20 2012 HVAC Subcommittee on Economic Opportunity will hold ahearing entitled ldquoExamining the Re-Design of the Transition Assistance Program(TAP)rdquo

31 Today in History

1654 ndash Jacob Barsimson arrives in New Amsterdam He is the first known Jewishimmigrant to America1711 ndash Ships from British Admiral Hovenden Walkers Quebec Expedition founders onrocks at the mouth of the Saint Lawrence River1717 ndash Spanish troops land on Sardinia1777 ndash American Revolutionary War British forces abandon the Siege of Fort Stanwixafter hearing rumors of Continental Army reinforcements1780 ndash James Cooks ship HMS Resolution returns to England (Cook having beenkilled on Hawaii during the voyage)1791 ndash Beginning of the Haitian Slave Revolution in Saint-Domingue1798 ndash French troops land in Kilcummin harbour County Mayo Ireland to aid WolfeTones United Irishmens Irish Rebellion1831 ndash Nat Turners slave rebellion commences just after midnight in SouthamptonVirginia leading to the deaths of more than 50 whites and several hundred AfricanAmericans who are killed in retaliation for the uprising1848 ndash The United States annexes New Mexico1849 ndash The first air raid in history Austria launches pilotless balloons against the cityof Venice1851 ndash The first Americas Cup is won by the yacht America1864 ndash 12 nations sign the First Geneva Convention The Red Cross is formed1875 ndash The Treaty of Saint Petersburg between Japan and Russia is ratified providingfor the exchange of Sakhalin for the Kuril Islands1902 ndash Cadillac Motor Company is founded1902 ndash Theodore Roosevelt becomes the first President of the United States to ride inan automobile1910 ndash Korea is annexed by Japan with the signing of the JapanndashKorea AnnexationTreaty beginning a period of Japanese rule of Korea that lasted until the end of WorldWar II1914 ndash World War I in Belgium British and German troops clash for the first time inthe war1922 ndash Michael Collins Commander-in-Chief of the Irish Free State Army is shotdead during an Anti-Treaty ambush at Beacuteal na mBlaacuteth County Cork during the IrishCivil War1941 ndash World War II German troops reach Leningrad leading to the siege ofLeningrad1942 ndash World War II Brazil declares war on Germany and Italy1944 ndash World War II Romania is captured by the Soviet Union1944 ndash World War II Holocaust of Kedros in Crete by German forces1950 ndash Althea Gibson becomes the first black competitor in international tennis1952 ndash The penal colony on Devils Island is permanently closed1962 ndash An attempt to assassinate French president Charles de Gaulle fails

1963 ndash American Joe Walker in an X-15 test plane reaches an altitude of 106 km(66 mi)1966 ndash Labor movements NFWA and AWOC merge to become the United FarmWorkers Organizing Committee (UFWOC) predecessor of the United Farm Workers1971 ndash J Edgar Hoover and John Mitchell announce the arrest of 20 of the Camden 281972 ndash Rhodesia is expelled by the IOC for its racist policies1989 ndash The first ring of Neptune is discovered1989 ndash Nolan Ryan strikes out Rickey Henderson to become the first Major LeagueBaseball pitcher to record 5000 strikeouts1992 ndash FBI HRT sniper Lon Horiuchi shoots and kills Vicki Weaver during an 11-daysiege at her home at Ruby Ridge Idaho1996 ndash Bill Clinton signs welfare reform into law representing major shift in USwelfare policy2003 ndash Alabama Chief Justice Roy Moore is suspended after refusing to comply with afederal court order to remove a rock inscribed with the Ten Commandments from thelobby of the Alabama Supreme Court building2004 ndash A version of The Scream and Madonna two paintings by Edvard Munch arestolen at gunpoint from a museum in Oslo Norway2007 ndash The Texas Rangers rout the Baltimore Orioles 30ndash3 the most runs scored by ateam in modern MLB history2007 ndash The Storm botnet a botnet created by the Storm Worm sends out a record 57million e-mails in one day

----------------------------------------From JS Pentagon OCJCS Mailbox Warrior and Family SupportSent Wednesday August 22 2012 655 PMSubj Warrior amp Family Support News for Wednesday 22 August 2012 COMMUNITIES IN ACTION Fund helps Pentagon add clinics for veteran carePennLivecomNikki Butler director of the rehabilitation and reintegration division for the office of theArmy surgeon general said the Army is not dependent on the Intrepid Fund but doesappreciate the help The Army has already been treating soldiers with Moorhead military nonprofit to be honoredIn-ForumBeyond the Yellow Ribbon is a nonprofit organization designed to help meet the needs ofservice members and their families during times of deployment and reintegration TheMoorhead chapter Along with Moorhead the communities of Fergus Falls St Louis Celebrates Veterans and CommunityThe Herald | HeraldOnlinecomST LOUIS Aug 22 2012 mdash PRNewswire -- The three-day Veterans Festival in ForestPark on Labor Day has snowballed Beginning Saturday September 1 from 9 am to 10 am a40+ line up parade headed by the famous eight-hitch Clydesdales starts at WELLNESS

Returning soldiers get healing Homestead from mother of 3 war veteransFox NewsLeslie has three children whove all done multiple tours in Iraq or Afghanistan and hasdedicated her life to helping service members struggling with Post Traumatic StressDisorder Traumatic Brain Injury or war-related substance abuse issues When Grant program assists homeless or struggling veterans find a homeTulsa WorldOver the next year the nearly $1 million received for the Barrier Removal and ResidenceExchange for Veterans program will help the Community Services Council help about 500veterans and their families in northeastern Oklahoma who are homeless or EDUCATION Veteran on mission to educate public about militaryDayton Daily NewsldquoThey seem to be either pro-military or anti-military but they dont seem to have a grasp orunderstanding of what the military does for our countryrdquo Miller said ldquoOne of the first thingsI do is tell people a veteran is someone who at some point in NAS Jax hosts Navys largest DEFY summer campFlorida Times-UnionStarted in 1993 the DEFY program is in its 19th year of providing mentorship characterdevelopment drug education and essential life skills to military kids The NAS Jacksonvilleprogram which began in 1996 offers a yearlong mentoring and support EMPLOYMENT Non-profit to help pair former Beaufort County military personnel with private Bluffton TodayThe group called the Transitional Workforce Educational Assistance Collaborative willidentify military personnel from the pool of about 2000 that leave Beaufort Countys twomilitary bases annually and help pair them with employers said retired Lt Vets Job Hunt May Be Thwarted By Disability BiasWBURClaus does not share the fact that he also suffers from post-traumatic stress disorder butsuspects employers assume that any veteran who served after Sept 11 has PTSD He has noproof hes not getting hired because of his disabilities But for some Our best regardshellipRandall E Smitty Smith Lt Col USAFDeputy Director Warrior amp Family Support Office of the Chairman----------------------------------------------------------------InputComments regarding CVEVerification and Fraud and Fronting -Received from Veteran readers from around the US (1) From A Vet in Southern California Good morning Wayne Thank you for theopportunity to submit my thoughts regarding the verification process I am in full support ofwhy this verification is required although I question why it takes so longhellip I have heard ofwide spread abuse and have been unsuccessful in competing for SDVOSB set-asides when

my verification was active against the ldquobad apples that are still on what I consider sacred VAproperties in the Los Angeles areardquo It makes me sick to my stomach to have to experienceand know that the ldquobad applesrdquo are still around I believe that the way the process is managed from CVE in DC makes it even more difficultto facilitate a more efficient and thorough process I have been in this re-verification processsince the end of 2011 and have had a site-visit and while I have missed opportunities tocompete for SDVOSB set-asides I just bite my tongue and know that CVE is doing the bestthat they can I was also approved into the VA Mentor Proteacutegeacute Program and this has been onhold through this entire process I am just thankful that my Mentor has been patient as wellas I was vetted thoroughly during the MPP process and yet I wait like so many othersUnfortunately CVE best is not good enough nor does it meet let alone exceed theexpectations of all parties involved including oversight committees in DC We have been able to keep our doors open without VA projects and believe me it tests mypatience and allegiance to a country that I served and was wounded in combat like so manyothers in my shoes Legitimate companies like us and many others are being tested by havingto endure more than we should and the VA has to realize that this time consuming processcreates stress that doesnrsquot help those with PTSD I believe there should be some form of oversight by the various VISN office networks andthus I recommend that it would be much more efficient to have a small CVEteamrepresentative in each VISN area to ensure that legitimate SDVOSBs are verified ontheir current time zones and with the ability to satisfy verification requirements muchquicker Remember we are talking about efficiency and eliminating waste Thank you for theopportunity to allow me to vent and share some constructive points God bless the USA (2) From a Great Veteran Advocate and SDVOSB in Michigan Waynealthough the mood of CVE reflects our modern day drift toward skepticism I lamentthe presumption of innocence once held dear to our ethos in America The mediahas altered our perspective toward a more cynical view of human nature To your point as to what may be done to catch the cheats and the frauds I suggestthat we examine the methods employed by the MMSDSC and WEBNC to police theminority and woman owned businesses The standards for veterans ought be nohigher than those The first rule I would use is to direct the audits (surprise visits) tothose who hold contracts or are deemed finalist for substantial contracts (pick adollar amount) Spending time on those not engaged in contracts owing to the VOBor SDVOB nature is not in my opinion using the resources of CVE wisely While I recognize the intent in surprise visits I think it should be acknowledged thatthey are disruptive to the daily function of a business and show little regard for thevalue of time for the business owner Perhaps a prospective client is visiting thebusiness Perhaps important contract negotiations are lsquoin processrsquo Moreover theowner may be traveling on business vacationing (yes sometimes we do that) orotherwise off-site Employees or other officers of the company may not have accessto the documents sought in the visit nor feel comfortable providing them in theowners absence It is imperative that these visits be respectful and dignified They ought not beconducted as would a Drug Enforcement Administration bust

(3) From a Veteran residing in Missouri a friend and a great Vets Advocate Waynewe know there are no magic ways to eliminate fraud as charlatans AND uninformed vets willlook for ways to game the system I do have 4 ideas that might help make a difference

1] Impose civil and criminal penalties in every instance where the deception is prov en to beintentional2] Create a public profile list of all those who are proven frauds and we all drive folks to seeand utilize that list3] Review the experience of the California SDVOSB program as it has had certification forappx 20 years what has Calif learned and is it applicable to the national effort4] Create an EBV like program specifically focused on becoming a federal contractor andprepare people to have an operating and verifiable business model that fits with being asuccessful federal (sub) contractor (4) From a lifelong Vets Advocate a good friend and SDVOSB in thegreat State of Tennessee ldquoWayne While one can maybe understand this needof more site visits on verified companies (even though some have already beenreviewed a few times) what is more troubling to me is why is the Government not asaggressive when it comes to enforcing the 3 SDVOSB goal under PL 106-50Especially the GAO not investigating and calling for the enforcement of such by allagencies (during two wars no less) Seems they are trying to draw the attention oftaking blood money from the Program to give to other programs and Large Primesand turning us on ourselves and each other Also how can the CVE use a GAOreportmandate as justification to hold more unannounced site visits when they (theCVE) themselves continue to refuse to adhere to other GAO rulings regardingmatters such as Veterans First priority and such Seems we are letting them bait us into agreeing to excuses to slowly cut back onmore on our SDVOSB Program while they get away with well to be honest slowmurder of not only our Veteran Program but hope for many to even attempt tobetter themselves when all else has been taken I myself am wary of this excuse oftheirs on this I would expect the same courtesy of a visit that I would give them orany business prior to just dropping in This rule could be more understood if acompany is actually performing work for the VA or a contract otherwise I find itwitch hunting with ill intentions in mind This ldquodo as I say and not as I dordquo has tostop some whererdquo (5) From a SDVOSB Vet and Small Business Advocate from the State ofKansas Wayne To address the issue of how to stop fraud it is simpleIncrease the penalties for fraudulent behavior Also please consider these sevenpoints

a Since the VA established the regulation on 100 control and too many denialsseem to be concentrated on this issue of CVE CertificationRe-Certification pendingresolution of this legal matter for the SDVOSB is a priority for all With the rates ourlawyers are charging and the vagueness of the regulation and the interruptions inlegal terms along with the variances in business models my recommendation isthat the CVE should certify SDVOSB pending legal revisions over a 90 day period toallow for the SDVOSBs lawyers to speak with the CVE lawyers and knock thisrequirement out Without this exchange the SDVOSB has to explain in layman termsto their lawyers what is required by CVE and any lawyers will have to read all theexchangescomments on this issue which still could be inconclusive This matter of

control does not challenge whether the business is valid providing a valid serviceto the VA nor does it reflect poorly on the Veteran It is in fact a legal matter thatrequires a quick legal exchange and 90 days should be enough time to work out asolution See 2

b My recommendation is that the issue provision directed at control should be afirst check in the recertification process and should be turned around in 7 daysback to the SDVOSB before moving forward with the CertificationRecertificationprocess This will allow the key issue of control to be addressed head on and quicklywithin the current CVE 90 day processing policy and if the SDVOSB cannot addresscontrol in 7 days properly the certificationrecertification process should bestopped and put on hold because this is a deal breaker This action would preservethe resources of the CVE so that the CVR resources can be better dedicated towardthose applications that have successfully satisfiedcleared this threshold This wouldallow the CVE to stay within budget addressing the GAO comments on resources andtimelines

c I still think my analogy regarding a doctor visit or getting your car certified isvalid I strongly recommend a brief exchange with the CVE for the record during the90 day process this could help whoever is assessing an application to givefeedback and get feedback in hopes that little matters can be handed within the 90days thus avoiding a decision that would send a SDVOSB into the 200 days phaseafter being turned down on the last day of the 90 days period that had nocommunication No business can handle profitability a wait of 90 days to 12 monthsand then a 200 days wait That statement today was scary and I feel for theVeterans in that situation You knoweven when we went to basic training we weretaught to assess and then retrain to standard some communication must takeplace to be efficient at assessing a business considering the dynamics of businessmodels which are changing everyday due to technology and the demand of our VAcustomers

d I also recommend that there should be a provision to allow submissions 2 timesevery 30 days during the 90 day process The Verification Self-Assessment Tool wasexcellent but it just came out a month ago in Detroit with some QampA with the CVEat the booth I was able to understand the interpretation of control and went tomy partner and lawyer and redacted all clauses in our operating agreement dealingwith control Three points 1) it did not take long to turn around a sign amendmentto my operating agreement with my partners signature once I could explain it to mylawyer and partner even though both had challenges with the request 2) Once I hadthe signed document in hand there was no provisions to submit a solution once Ihad to help address a known issue of control the CVE was bent on continuing theprocess when all know the deal killer was and is control The good news was Inow had a solution after attending the conference in Detroit and I was clearly madeaware of the matter (Consider when you need to get your car certified and youhave a light out you fix it and come back to the certification point you drive inand get checked out The certification station wants you to be certified to drive) and3)I knew nothing about a Verification Assistance Briefing I recommend thatnotification should be flagged within the CCR process since SDV owner has to checkthe box for being SDVOSB I think this would be an accountable place for themajority 51 owner to know for a fact they need to meet a specific CVErequirement In fact the control issue should be questioned in that process to helpthe SDV owner know this is required

e CVE has made errors but there is no one to be held accountable for thoseerrors CVE has misinformed and thus mislead the SDVOSB We have documentationof CVE staff saying we were certified and then would turn around and say we arenot certified we are in the queue and then out the queue the system is downand the system is not down etc Thus I recommend where this has been the caselets share in the responsibility of getting recertified not just make it thru theprocess For there has been no one allow to take responsibility for these manyerrors that has cost the SDVOSB hours of admin time reloading information multipletimes for unknown reasons I recommend the CVE official say when they have madean error We know the process is evolving It is simply is poor Quality Control whenerrors are not accounted for I recommend that there be some accountability forerrors and feedback be given to the SDVOSB when it is not their doing We havebeen made to feel this has been totally our problem and yes we have missed somethings but arent we in this together As a former Commander I want to knowthe issueserrors in order to fix them I recommend that we allow for the oldsuggestion box for feedback and that the box be check it weekly In todays worldset up an anonymous website for complaints and suggestions (smile)

f The standard response letters to inquiries are lets say vague andinconsistence with statement others have made within CVE I recommend theresponses have a person attached once in the process so an atmosphere ofconfidence is established The CVE will have an answer on a specific date Or thedeadline is August 1st and it requires etc Right now the SDVOSB does not getthe warm fuzzy feeling CVE is in 100 control (smile) All the standard responseshighlight a sense of unaccountability and do not reflect the hard work we know isgoing on

For example

CVEstandard response you can expect to receive a decision around August1 2012Point Since the SDVOSB has to meet deadlines why cant the CVE give a firm dateThe word around is vague most SDVrsquos would say And thus my Company has astaff person dedicated to calling CVE every week to find out the status of ourrecertification just in case

CVE standard response By regulation you will receive a decision no later than90 days after we receive and acknowledge receipt of a completed application OnMay 1 2012 your company was sent notification acknowledging a completeapplication

Point I am just saying as we would say casually (smile) how do youunderstand no later than 90 days and then the if word is there then there weword as in who is we within CVE then receipt of the completed applicationNext sentence surprise the CVE admits notification so why not give a firm dateof August 1st then speak to us if the date is missed and share something tell ussomething about what was observed over the 90 days tell us what we need to doand allow us to get what needs to be done accomplished within the 90 days Beproactive as Stephen Covey states tell us what you found provide some accuratefeedback from a CVE entity that has all our financial and personal information Ihope I made my point It feel the standard responses are too cookie cutter like forbusiness and the CVE has too much information to be in silence after 30 or 60days an SDVOSB has to question what is going on because we have not talked to

anyone for 90 days and in my case 12 months Note the CVE is mentioned inchurch every Sunday (smile)

g My last recommendation knowing my legal counsel it would be helpful to havean acceptable template offered to those in certificationre-certification that wouldreflect the two or three most acceptable forms of legal language acceptable to thosewho enforce the regulation on control that these templates be share with the legalcases to back up the legal precedent for such proposed templates so that thatan SDVOSBs legal counsel can reference the template and engrave the properlanguage into the operating and ownership agreements that support the SDVOSBsbusiness mode and workings I do not know if I have stated this correctly but for aLLC Sub Chapter S etc the language should be basicsimilar and couldwould bringoperating agreements in compliance quickly and cut legal costs for the Veteran Evena redaction template would be helpful (6) From a Veterans Advocate and a verified SDVOSB here in Washington DC Whenthe frauds are caught and there is no doubt they are guilty and knowingly committed fraudand participated in frontingand prior to or subsequent to their criminal trials a Terminate all of their contracts Government-wide and have them repay the USGovernment every penny that was fraudulently obtained b Bar them for LIFE from ever owning another federal government contracting company orever being employed by one c If they are Veterans that are receiving VA Veterans benefits immediately ceasethe disbursment of such benefts for life d Fraudulent activity should be considered a Felony and carry with it no less that 5 years injail e Place their names and their crimes on a Wall of Shame for all to read I believe that some if not all of these punishmentsconsequences will make the crooks thinktwice before they consider engaging in fraudulent and criminal activity Also the samewould hold true for members of the other small business groups because what would apply toour bad apples should apply to theirs as well 7) From a Washington DC Vets Advocate and SDVOSB ldquoWayne - Irsquom not surewhy CVE continues to believe that if you read their documentation and follow their guidanceyou will sail through the verification process I was recently contacted by a SDVOSBcompany that wishes to remain anonymous They were denied and sought assistance fromone of the Verification Assistance Counselors After reviewing their documentation thecounselor noticed a discrepancy in their by-laws and called for clarification It was a fiveminute phone call and as the company told me a couple of questions The company knewexactly where to find the board minutes that resolved the problem So now what CVE asks for your companyrsquos first and last board meeting minutes But what happens if theinformation required is in other board meeting minutes How would a company know whatto look for Simple answer is folks that communicate with the Vet and ask the rightquestions Would have resulted in a speedy approval Now all those folks in CVE are going

to have to put in a couple of extra hours because someone couldnrsquot pick up the phone andmake a five minute phone callrdquo----------------------------------News from Al Bunting Colonel USAF Ret in NJ Thanks Al Military satire news site manages to fool some people The stories mdash like Chaos GeneralJames Mattis Announced as Next Commandant of Marine Corps (complete with anexpertly Photoshopped picture of the US Central Command chief with tatted-up arms) mdashare as outrageously funny as they are outrageously phony US Significant In Iraq Despite Troop Exit Dempsey(Yahoocom) Top US military officer General Martin Dempsey insisted during a quick trip toIraq that Washington was still playing an important role there eight months after the lastAmerican troops departed Pentagon Showing Only Modest Progress Toward Clean Books(GovExeccom) The Defense Department is at considerable risk of not meeting its internalgoal of a clean budgetary statement by 2014 and fulfilling Congresss mandate of auditablefinancial statements by 2017 a key auditor said on Tuesday Defense Shuts Down Biggest Health IT Contract(Bloomberg Government (bgovcom)) The Defense Department wont renew its largest healthinformation technology contract with 19 companies Over the next two years Defense willshift those orders to companies on other agencies multiple-award contacts or MACs Income Tax Return Filing Issues for Members of the Armed ForcesAugust 28 20121230 pm EDTRegistration is not requiredLearn more or join the event Building The Best For Injured Soldiers(Washington Examiner) Faced with tighter budgets after the Iraq War but still in charge oftreating tens of thousands of injured troops the military is getting a hand from a privatefoundation that is building medical centers specializing in the signature physical andpsychological injuries of Iraq and Afghanistan Mother Of Navy Son Killed In 911 Attack Goes To Gitmo For Pre-Trial Hearing(FNC) 911 victims family members are there in Gitmo to witness the proceedings OurCatherine Herridge spoke to them Appeals Court Removes Key Civil Service Protection(Yahoocom) A federal appeals court ruling that has taken key civil service protection awayfrom government employees involved in national security work will have far-reachingimplications advocates for federal workers say Air Force general chosen as next JPAC commander Air Force Maj Gen Kelly KMcKeague a 1977 Damien Memorial School graduate has been selected to becomecommander of the Joint Prisoner of WarMissing in Action Accounting Command on Oct31

VA To Adjust List Of Agent Orange Disorders Military Times Veterans sufferingperipheral neuropathy from exposure to the toxic herbicide Agent Orange could be eligiblefor compensation from the Veterans Affairs Department as the result of an Aug 10 action tosubstitute that condition for acute and subacute neuropathy among those related to theherbicide The change removes the requirement that the symptoms resolved themselves intwo years after they appeared The Times notes that veterans who served in Southwest Asiamay be affected and should apply if they developed the condition within one year ofexposure to a degree that it is at least 10 percent disabling although they may not becompensated until the ruling is final

US Army Suicides Reached Record Monthly High In July Reuters Higher suicide rateamong active-duty soldiers in July according to the US Army which tracks the statistics At26 suicides Julys rate more than doubled from Junes 12 such deaths and was believed to bethe most ever recorded in a single month Through July the Army said it likely had 116suicides compared to 165 for all of 2011 The Army said 12 reserve soldiers also werebelieved to have committed suicide in July for a total this year of 71 Separately the MarineCorps said it experienced eight likely suicides in July compared to six in June bringing its2012 total to date to 32 which was the total for all suicides in 2011 38 suspected suicides in July may mark grim record for Army In July 38 soldiersincluding 26 active-duty soldiers are believed to have killed themselves the Army saidThursday setting what appears to be a grim record as the military struggles to addressincreasing numbers of suicides

Special Operators To Anti-Obama Groups Zip It(Yahoocom) A group of retired special operations and CIA officers who claim PresidentBarack Obama revealed secret missions and turned the killing of Osama bin Laden into acampaign centerpiece are coming under criticism from some of their own After Afghanistan A New Great Game(New York Times) SINCE 911 Americas priority in Central Asia has been to defeat theTaliban in Afghanistan But as the United States and NATO pull out there is a new dangerthat the West could become entangled in regional rivalries local strongman politics andcompetition with Russia and China Cuts Will Cripple Military And Make It Hollow Force Of 70s (Charlotte Observer) Unless President Obama and Congress change current law our armedforces will face an indiscriminate across-the-board cut or sequestration of more than $500billion on Jan 2 2013 There is bipartisan agreement that sequestration will cripple militaryreadiness and return the US military to the hollow force of the 1970s US And Russia In A New Standoff (Washington Times) Tucked away in what is colloquially known as the post-Soviet space thetiny landlocked Central Asian republic of Tajikistan seems like an unlikely strategic prizeYet a potentially significant geopolitical tug of war is brewing there between the UnitedStates and Russia The stakes of this unfolding contest are high and involve continuedWestern access to Central Asia and quite possibly the political future of at least part of theregion

Cooling The Fever For War With Iran US Generals Visit To Iraq Includes Talks OnSyria(New York TImes) The US Embassy says the top US generals talks with Iraqs primeminister included discussions about Syria underscoring concerns that the civil war there risksdestabilizing Iraqs own fragile security Iraq To Get First US F-16s In Sept 2014 Officials(Yahoocom) The first batch of F-16 fighter jets bought by Iraq are due to be delivered in twoyears US officials said on Tuesday as the top American military officer was on a visit toBaghdad Iran Unveils More Defense Projects(New York Times) Irans president unveiled an upgraded short-range missile and several newdefense projects on Tuesday saying the Islamic Republic needed new weapons andnavigation systems in order to defend itself against foreign threats In Toll Of 2000 New Portrait Of Afghan War(New York Times) His war was almost over Or so Marina Buckley thought when her sonLance Cpl Gregory T Buckley Jr told her that he would be returning from southernAfghanistan to his Marine Corps base in Hawaii in late August three months early Dispute Over Islands Reflects Japanese Fear Of Chinas Rise(New York Times) When the flotilla of 21 fishing boats arrived at an island chain at thecenter of a growing territorial dispute with China the captains warned the dozens of activistsand politicians aboard not to attempt a landing Progress Is Cited On New Reactor In North Korea (New York Times) While the regions attention has remained focused on whether the newNorth Korean leader Kim Jong-un can consolidate his power his country has been makingsignificant progress in the construction of a new reactor widely seen as a cover for makingmore fuel for nuclear weapons analysts say citing satellite imagery of the building site US Japan Begin Military Exercises(CNN) US Marines today began month-long military exercises in the Western Pacific today Defense Secretary Will Visit Naval Base(Tacoma News Tribune) An unmanned American aircraft fired missiles at a vehicle in aPakistani tribal area bordering Afghanistan Tuesday killing five suspected militants andinjuring two Pakistani intelligence officials said Secretary Of Defense Visiting Bremerton Aircraft Carrier Wednesday(KitsapSuncom (Bremerton WA)) Secretary of Defense Leon Panetta will join USS JohnC Stennis sailors and families on the aircraft carrier Wednesday morning to thank them forredeploying next week to the Middle East Risks Of Syrian Intervention Limit Options For US (New York Times) Despite President Obamas warning to Syria not to use its arsenal ofchemical weapons or allow them to fall into the hands of extremists the administrationsoptions for intervening remain limited by what its officials have described as a simplecalculus It would make the conflict even worse

Service Dogs(CBS) As the war in Afghanistan drags on the number of American troops suffering post-traumatic stress disorder grows And the suicide rate is way up too Among active dutytroops its now averaging almost one a day And some of those most at risk can benefit fromthe companionship of service dogs But therersquos a problem Ethiopian Leader Was US Military Ally(Washington Post) Ethiopian Prime Minister Meles Zenawi who was once hailed as a majorUS ally against terrorism but whose 21-year rule was tarnished by the killing and jailing ofpolitical protesters and a grisly border war with former ally Eritrea died Aug 20 of anundisclosed illness He was 57alternative to war Since then the rumors of an impending Israeli military strike have grownalmost daily but whatever happened to the negotiations No Excuse For Former Soldier Noah Galloway(Columbus (GA) Ledger-Enquirer) When you first look at Noah Galloway its what youdont see that is so striking No Time To Delay (Washington Post) Syrias agonizing descent into civil war has cost 18000 lives What beganas a peaceful protest against President Bashir al-Assad hardened after Mr Assad ordered histroops to open fire on demonstrators The opposition fragmented at first now appears to bewaging street-by-street combat in the main cities including Damascus and Aleppo Flags ofthe resistance are flying in some areas they control Unfriendly Fire (Baltimore Sun) The increasing frequency of attacks on US and NATO troops by membersof the Afghan security forces they are supposed to be helping has reached the point whereAmerican commanders are rightly concerned that the mistrust engendered by such incidentsthreatens to interfere with the completion of their mission That has prompted a shift inpolicy that may or may not work but in any case it underscores the reality that the sooner ourtroops get out of Afghanistan the better off well be Portraits in Courage - Pararescueman braves frigid Alaska to save crash victims08202012 0908 AM CDTThe Air Force has released the latest Portraits in Courage whichhighlights the courage of Airmen One of them is Master Sgt Christopher Uriarte an AirForce reservist with the 306th Rescue Squadron at Davis-Monthan AFB Ariz-------------------------------------Godspeed allWayne Wayne M Gatewood Jr USMC (Ret)PresidentCEOQuality Support IncA Service Disabled Veteran and Minority Owned-Small Business8201 Corporate Drive Suite 220Landover MD 20785301-459-3777 EXT 101 - Fax 301-459-6961wwwqualitysupportcom

The willingness with which our young people are likely to serve in any war no matterhow justified shall be directly proportional as to how they perceive the Veterans of earlierwars were treated and appreciated by their Nation - George Washington

Department of Veterans Affairs

Office of Inspector General

Review of Enterprise Technology Solutions LLC Compliance with Service-Disabled Veteran-Owned Small Business Program

Subcontracting Limitations

Report No 12-01235-132 August 20 2012 VA Office of Inspector General

Washington DC 20420

Contents

Executive Summary i

Introduction

NAICS Code 524291 8

Additional Issue 12

Conclusions 14

Recommendations 15

Acronyms 16

Executive Summary

MARK A MYERS

Background

Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Contents

Executive Summary i

Introduction

NAICS Code 524291 8

Additional Issue 12

Conclusions 14

Recommendations 15

Acronyms 16

Executive Summary

MARK A MYERS

Background

Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Contents

Executive Summary i

Introduction

NAICS Code 524291 8

Additional Issue 12

Conclusions 14

Recommendations 15

Acronyms 16

Executive Summary

MARK A MYERS

Background

Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Executive Summary

MARK A MYERS

Background

Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













MARK A MYERS

Background

Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Background

Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Application (ORCA)

Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Results of Review

10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













10042007-08182008 Yes

08182008-08122009 Yes

08122009-12032009 Yes

02092010-01262011 Yes

01262011-01262012 No

Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Additional Issue

Patient

Period of Service

ETS Reshypriced

Amount (b)

Medicare Amount

1 April 2009 $2694114 $483243 $2210871

2 March 2009 5949380 1064897 4884483

3 April 2009 6030661 1080263 4950398

4 April 2009 3631637 935895 2695742

Total $18305792 $3564298 $14741494

Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Totals $224289 $97165 $127124 131

Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Conclusions

Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Recommendations

Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Acronyms

CY Calendar Year

FY Fiscal Year

PL ProfitLoss

anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













anagement

VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













VHA Comments Concur

VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













VHA Response Concur

Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Complete

Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Appendix B

Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













Appendix C

Report Distribution

Contents

Executive Summary

Introduction

Results of Review

Conclusions

Recommendations

Acronyms

Management Comments

Report Distribution











































































31 Today in History















For example













31 Today in History

For example

31 Today in History

For example

31 Today in History

For example

31 Today in History

For example

31 Today in History

For example

31 Today in History

For example

31 Today in History

For example