VA’s Compliance with the VA Transparency & Trust Act of 2021 Semiannual Report: March 2025

To comply with the VA Transparency & Trust Act of 2021 (Transparency Act), VA must provide a detailed plan to Congress outlining its intent and justification for obligating and expending COVID-19 relief funds covered by the act. The Transparency Act also requires VA to submit biweekly reports to Congress detailing its obligations, expenditures, planned uses, and justification for any deviation from the plan. The VA OIG is required to submit semiannual reports comparing actual VA obligations and expenditures to those planned for three years or until all covered funds have been expended, whichever comes first. This report is the seventh and last report, published after November 22, 2024, which marked the passage of three years.

This report focused on American Rescue Plan (ARP) Act funds because they had the largest outstanding balance and open obligations. Also, VA deobligated many ARP Act obligations after the funds expired. The OIG found ARP fund transactions reviewed by the team followed the Transparency Act and followed financial policy for all but two of the 20 transactions reviewed.

The OIG also found VA did not comply with the financial reporting requirements of the Transparency Act. At the time of this report’s publication, VA had not submitted biweekly reports required by the act. Additionally, the third and fourth quarter fiscal year 2024 reports required by the Consolidated Appropriations Acts of 2022 and 2023 were submitted late.

No new recommendations are being issued because ARP fund transaction errors found by the OIG team do not appear to be material to the ARP fund balance. Moreover, the OIG’s recommendations from the September 2024 report to submit biweekly reports and timely submit quarterly reports have not been fully implemented, requiring ongoing OIG monitoring.