Oregon Department of Veterans Affairs: General Review of Veteran Services and Further Considerations for the Department s New Plans
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1 Secretary of State General Review Report Kate Brown, Secretary of State Gary Blackmer, Director, Audits Division Oregon Department of Veterans Affairs: General Review of Veteran Services and Further Considerations for the Department s New Plans Summary One in 10 Oregonians is a veteran. Oregon s 322,355 veterans span four generations and five major wars. Also, there are thousands of Oregon National Guard and active duty service members currently serving who will be returning or have recently returned from deployments in Iraq and Afghanistan. For all Oregon veterans and their families, the state has a role in ensuring they receive the benefits they have earned from their military service, and connecting them to services or support when needed. We conducted a limited review focused on the state services available specifically to veterans in Oregon, and ways in which providing such services could be improved. The Oregon Department of Veterans Affairs (ODVA) manages the system by which most veterans submit claims for federal benefits. ODVA and County Veteran Service Officers provide veterans in Oregon with legal representation through the claims process. ODVA also serves a key role in coordinating with various state agencies and community organizations to serve Oregon veterans. Further, ODVA manages a veteran home loan program, veterans homes, conservatorship program and two small veteran assistance programs. ODVA s new management has begun a strategic planning process, having developed a strategic framework that outlines broad goals such as improvements to its veteran services, partnerships and core services. Management is currently working with staff to develop strategies to support these goals, as well as legislative requests to assist with some of those strategies. As ODVA is undergoing changes in many key program areas, we decided to limit our work to a general review rather than conduct a full audit in compliance with government auditing standards. Where we saw the possibility of further improvement, we suggest additional considerations as the department is developing and implementing its strategic plan. Such considerations include ways to better identify veterans; strengthen the oversight of County Veteran Service Officers; improve and expand training ODVA General Review Page 1
2 offered by the department; and continue to develop key partnerships with other agencies and service providers. Agency Response The department response is attached at the end of the report. ODVA General Review Page 2
3 Background Who is a Veteran To be eligible for most federal and state veteran benefits, a person must be a veteran or, in some circumstances, certain members of their family. A veteran is a person who had active service in the military and was discharged or released from duty under conditions other than dishonorable. Active service means full-time service in the Army, Navy, Air Force, Marine Corps, Coast Guard, or as a commissioned officer of the Public Health Service, the Environmental Science Services Administration or the National Oceanic and Atmospheric Administration, or its predecessor, the Coast and Geodetic Survey. For individuals who enlisted after September 8, 1980, some benefits also have a minimum length of service necessary to be considered a veteran, which is typically 24 months of continuous active duty or the full period for which a person was called or ordered to active duty. Under certain conditions, National Guard and reserve members are considered eligible veterans for some veteran benefits. In many cases, such members are considered to have fulfilled the active duty requirement if they were activated for federal military service. There are additional circumstances and exceptions to active service, length of service and discharge criteria that would consider a person as a veteran for veteran benefits. For example, service-related disability compensation benefits do not have a minimum active duty requirement. Veterans are a diverse demographic within Oregon s population. Community issues facing Oregonians like homelessness, health and wellness (e.g., mental health) and employment affect veterans as well. Veterans can have specific treatment needs such as with Posttraumatic Stress Disorder (PTSD), Traumatic Brain Injury (TBI) or a combination of the two due to combat trauma. The veteran population is comprised of further subgroups such as women veterans, aging veterans, rural veterans, and veterans in crisis that can each have diverse needs. ODVA General Review Page 3
4 Veteran Benefits While veterans have access to various programs as others do, there are a broad range of benefits offered only to veterans. Among these benefits are types of financial assistance, healthcare, housing and education benefits. The extent of those benefits can vary amongst each veteran due to factors such as length of active duty and character of discharge. Additionally, some benefits may be utilized while on active duty (e.g., education and training benefits). The major federal and state veteran benefit programs include: Disability Compensation Pensions Healthcare Long-Term Care Vocational Rehabilitation & Employment Education & Training Home Loans Dependents & Survivors Burial Housing/Emergency Grants Veterans Home Recreational Passes Providing Veteran Benefits and Services Oregon Department of Veterans Affairs (ODVA) has the key role as a coordinator and advocate amongst its partners to ensure Oregon veterans are able to access and use their benefits. ODVA is responsible for maintaining a cohesive system to provide claim services for veterans. ODVA also manages funds aimed at improving programs and supporting efforts to benefit Oregon veterans, such as Veterans Suicide Awareness and Prevention Fund, and Oregon Women Veterans. The majority of benefits specifically offered to veterans are funded by the federal government, typically through the U.S. Department of Veterans Affairs (VA). For example, healthcare is provided through the VA s medical system, VA hospitals and Community Based Outpatient Clinics. The state administers some federally-funded programs through agencies such the Oregon Employment Department. The financial value of benefits provided by the VA represents a significant sum in Oregon. In 2013, Oregon veterans and their families received about $2.2 billion in VA benefits (e.g., disability compensation and pension payments, healthcare, and education benefits). ODVA General Review Page 4
5 In order to qualify for disability and pension VA benefits, veterans must file a claim proving they are eligible for those benefits. With the complexities of eligibility determination, ODVA with local County Veteran Service Officers (CVSOs) provides assistance for filing claims. While claims can also be filed by National Service Officers (e.g., Veterans of Foreign Wars), about 80% of claims in Oregon are filed through ODVA. CVSOs are generally the ones directly assisting veterans and their families with completing benefit claims, and helping locate other benefits veterans may be eligible for. If a veteran wishes to dispute the benefit award or the claim is denied, ODVA is the main representative on behalf of the veteran, dependents and survivors before the VA for the claim and appeal. See Figure 1 for the claims process and estimated timelines. Figure 1: Process for Filing Disability and Pension Claims and Estimated Timeframes Veteran meets with CVSO; CVSO prepares and submits claim to ODVA Time varies depending on number, type and complexity of claims; availability of evidence; etc. ODVA reviews claim to ensure completeness then submits claim to VA Approximately 1-2 days VA responds with initial determination about benefit (approved or denied) Approximately 9 months If claim award is appealed - VA makes final determination following appeal process Approximately 2 years (up to 4 years if appeal goes to VA board of appeals) Within the CVSO system, ODVA provides initial and ongoing training and technical assistance to CVSOs, files claims with the VA, represents veterans during the appeals process, and provides administrative oversight and quality control of CVSO services. In its oversight role, ODVA management stated they partner with CVSOs where able, as they work in concert for the same mission, which is to serve and honor veterans and their families. All but two counties participate in the CVSO program; ODVA provides the claims services in Marion and Polk counties. CVSOs, who are certified by ODVA and accredited by the federal VA, are county employees. ODVA General Review Page 5
6 CVSO offices vary from one another in terms of their location within local government, level of staffing and experience, budget size, and proximity to and relationships with other service providers. The state provides funding to counties operating the CVSO program, which uses annual base amounts and the percentage of veterans living in each county. The counties also provide funding for their CVSOs. Many services specific to veterans are administered at the local government level and by nonprofit organizations. For example, there are at least two VA programs that provide moneys directly to local housing authorities for housing assistance to veterans and their families. Three Oregon counties have a veterans treatment court that, for eligible veterans, prioritizes treatment and other counseling to reduce the costs of incarceration and reoffending. Returning Veterans Project, a nonprofit, offers free counseling and other health services and legal services for returning veterans and their families. Transitions Project, another nonprofit, has a veteran services program that provides short-term housing, rent and utility assistance, and support services (e.g., legal and employment) to low-income veterans who are homeless or are in imminent danger of becoming homeless. ODVA General Review Page 6
7 Results One in 10 Oregonians is a veteran. Oregon s veterans span four generations and five major wars. Also, there are thousands of Oregon National Guard and active duty service members currently serving who will be returning or have recently returned from deployments in Iraq and Afghanistan. For all Oregon veterans, the state, mainly through ODVA, has a key role in ensuring they receive the benefits they earned as a result of military service, and connecting them to other social services or support when needed. For this reason, we conducted a limited review on veteran services programs. ODVA serves a key role in partnering with various agencies and community organizations to serve Oregon veterans. ODVA s Veteran Services Division manages the system by which most veterans submit claims or applications to the federal veteran administration for benefits. ODVA has some oversight over County Veteran Service Officers (CVSOs) who provide veterans in Oregon with legal representation through the VA claims process. The division also manages a conservatorship program and two small veteran assistance programs. ODVA s other core veteran programs are a home loan program and veterans homes (long-term care facilities). ODVA has experienced significant turnover within the last few years and its new management has begun a strategic planning process. The department has developed a five-year strategic framework that contains high level strategies within the goals of: Target Veteran Services Serve more veterans and serve them better. Mobilize Partnerships Leverage all resources available to veterans. Drive Veteran Engagement Amplify awareness of resources and build the Oregon veteran brand. Invigorate Core Operations Build a better, stronger and more durable department for future generations through responsible, resourceful and creative management. ODVA has begun to develop and implement a strategic plan to improve services to veterans. One of the approaches to work toward its goals and strategies is to continue one-time funding to CVSOs to increase their outreach to veterans. ODVA also coordinates events like a veteran summit as another way to enhance partnerships and help ensure service providers and veterans can get connected. The department also plans to align staff in order to create a more robust claims review process to try to help veterans receive benefits more quickly. Management mentioned plans to upgrade claims management software and add key policy analysts in the areas of health/wellness and education/economic opportunity to better partner with other agencies. ODVA General Review Page 7
8 With these changes underway, we determined a full audit would not be warranted at this time. This report is not concluding on veteran services in Oregon, though our limited review of veteran services identified areas the department may wish to consider as it refines and implements its strategic goals. Advocacy with Federal Agencies for Oregon Veterans ODVA management coordinates with and regularly meets with federal partners, national veteran organizations, and congressional leaders. At several levels of government, ODVA s involvement and advocacy on veteran issues is important to help ensure veterans have access to the services they need and benefits they have earned. There are frustrations about the timeline for the federal VA to review claims and appeals, and the access and quality of VA healthcare such as with mental health care. In July of this year ODVA s Director was with other veteran s services representatives such as U.S. Representative Bonamici and Portland Veterans Affairs Regional Office and Portland VA Medical Center management at a forum discussing veteran concerns with medical care services. While ODVA s ability to influence a federal agency is limited, ODVA should consider methods to expand and continue advocacy for changes at the federal VA that demonstrates the department s commitment to helping Oregon veterans and their families thrive. Training about Veteran Eligibility and Benefits ODVA provides an array of information to communicate about benefits and services for veterans. In our conversations, though, we learned many veterans do not consider themselves a veteran, even if their military service would qualify. This lack of awareness prevents some veterans from applying for benefits. Yet, some publications and information use the term veteran rather than asking more generally about military service. To help those with military service understand their eligibility for benefits and services, ODVA should consider seeking opportunities to clarify its informational materials. ODVA s certification training of CVSOs is focused on the extensive rules of VA programs eligibility and benefits. For other benefits offered to a veteran by state programs or community organizations, ODVA is encouraging the building or expanding of local networks to partner in getting services to veterans. Though, there seem to be differing views among some CVSOs and other local partners on how pursuing VA benefits would or would not affect veterans who also receive state assistance through programs such as Medicaid. ODVA General Review Page 8
9 ODVA should consider ways to clarify how state and federal benefits affect one another for Oregon veterans and coordinate training on that to CVSOs as well as caseworkers at partner agencies. For example, CVSO training that includes eligibility and services information on Department of Human Services (DHS) programs and emphasizes coordination with DHS staff to ensure veterans are aware of those benefits and services. State Partnerships to Engage More Veterans VA data shows low percentages of Oregon veterans accessing benefits, as is the case in other states. ODVA stated a main strategy to address this issue is to increase partnerships with state agencies. Partnerships between ODVA and other state agencies can help ensure veterans are aware of their benefits and expand the number of veterans accessing those services. Our review identified several key partnerships with state agencies as well as potential goals for such partnerships, the department could consider. Other Agencies Could Expand Identification and Outreach Veterans are spread throughout Oregon and the state does not have large active military bases which can help facilitate outreach and services to veterans. More assistance from state agencies could help ODVA in conveying information to veterans and referring them to CVSOs. Oregon legislation directs three specific agencies to ask clients about their veteran status and refer contact information to ODVA for those wanting information on veteran benefits and services. Those agencies are Oregon Department of Transportation Department of Motor Vehicles, Bureau of Labor and Industries and DHS. The contact information from these agencies that can be used for outreach as well as to further understand the veteran population appears limited in some instances. In one case, it is unclear whether ODVA can directly provide the contact information to CVSOs, who mainly assist veterans in applying for veterans benefits. ODVA should consider partnering with agencies to ensure sharing information amongst agencies is effective and streamlined to foster outreach activities to veterans. ODVA should also consider opportunities to collaborate on effective methods to disseminate veteran benefit information to those eligible. Some state program applications have varying and limited questions to assess veteran status. As mentioned earlier, some veterans do not consider themselves a veteran, yet some applications use the term veteran or ask for the amount of VA income received, rather than asking more generally about military service. For example, DHS s current application for applying to programs such as the Supplemental Nutrition Assistance Program and Temporary Assistance to Needy Families, only asks if anyone in the household gets money from veterans benefits. DHS s Aging and People with Disabilities application asks whether anyone in the household is a veteran or spouse of a veteran, and receives income from veterans benefits. The Oregon Health Authority s (OHA) application for Medicaid ODVA General Review Page 9
10 includes questions related to military service only if the applicant or household members indicate they do not reside in Oregon or are not a U.S. citizen or national. ODVA should consider expanding its partnerships with agencies to ensure an effective veteran status question is included on state program applications that can be used to help connect veterans to benefits and resources. Data Matching to Expand Veteran Services and Save Money Other states use data from the Public Assistance Reporting Information System (PARIS) to help identify and facilitate veterans and their families, who are receiving state social and health services, to access the maximum federal benefits for which they are eligible. DHS is starting a pilot project in some of its programs to use the PARIS veteran information to direct an individual who may be eligible for veteran benefits to work with their CVSO to apply for benefits. It is unclear the extent OHA will be participating in the pilot. Other states manage PARIS data through partnerships among agencies. These partnerships help ensure veterans get the maximum federal benefits to which they are entitled. In some cases veterans are referred to Veteran Service Officers and move from state-funded programs to a wider array of fully federally-funded programs, and state funds are then able to be used to assist others. ODVA should consider partnering with DHS and OHA to further develop the PARIS data management and referral process to help ensure veterans receive the maximum benefits to which they are entitled. Joint Efforts Could Help Promote Veteran Employment Services ODVA promotes veteran employment events, such as hiring fairs, and provides general information on employment assistance on its web and social media sites. ODVA also is part of a newly formed legislative workgroup focusing on an effort to clarify and consistently apply the law that requires veteran preference to be given for public hiring. In 2013, the unemployment rate of veterans 18 and over in Oregon was 5.9%, lower than the national rate of 6.6%. However, the percentage of veterans participating in the labor force was lower than the national level, 46% to 51% respectively. Oregon s Employment Department staff mentioned challenges in engaging veterans and noted fewer veterans are taking advantage of employment assistance than in the past. ODVA should consider opportunities to assist the Employment Department to market the availability and advantages of employment services provided for veterans. ODVA General Review Page 10
11 Information and Resources to Help At-Risk and Homeless Veterans The annual federal homeless estimate for 2013 noted Oregon experienced increases in veteran homelessness over the past five years, and was one of five states with the highest rates of unsheltered homeless veterans. The federal VA has focused on ending veteran homelessness by the end of 2015 and has directed funding to accomplish this to local community and nonprofit organizations that provide housing assistance to veterans. However, there is no current plan for the VA to continue funding at its current rate past Recent Oregon legislation created a new program starting January 1, 2014 that sets aside a portion of property recording and filing fees collected by county clerks to be spent by the Oregon Housing and Community Services Department specifically to assist homeless veterans, veterans at risk of becoming homeless, and low-income veterans and their families. ODVA should consider the needs of homeless veterans now and past 2015, and partner collaboratively with other public agencies and local service providers to ensure that resources are known and available to the homeless and at risk veteran community. Collaboration to Encourage Veterans in Higher Education For the past three years, only about 3% of veterans in Oregon have accessed VA education benefits (e.g., GI Bill). While this percentage is similar to most states, there are six states that have at least doubled that rate, with 6-8% of veterans using their education benefit. ODVA had a program with five campus VSOs dedicated to help connect student veterans to veteran benefits and services. When the two-year program ended in 2011, some of Oregon s public universities created oncampus positions called Veteran Resource Coordinators. Those coordinators assist and advise student veterans in accessing GI Bill benefits and other available resources, and help ensure the campus community understands and serves the student veteran population in assisting with educational integration and success. While 41% of Oregon veterans have some college or an associate s degree, only 26% have a bachelor s degree or higher. This means just a little over half of the veteran population is meeting Oregon s higher education goal of having 40% of its citizens receive a bachelors or advanced degree by Oregon has more than 100 public and private higher education schools participating in VA educational benefit programs. ODVA should consider partnering with those Oregon educational institutions with approved GI Bill programs to assist in outreach for recruiting new student veterans and to maximize student veteran success. ODVA General Review Page 11
12 Strategy for Better Data about Veterans and Services ODVA management has noted the department s limited ability to collect and analyze data. This has been identified in ODVA s strategic planning, and management is developing strategies to enhance its ability to analyze data. ODVA mainly acquires its veteran data from the VA, census bureau, and CVSOs. Having further demographic information could help the department strategize outreach and service efforts, such as the programs veterans are enrolling in through the healthcare exchange, higher education recipients and retention rates, and employment benefit recipients. ODVA should consider developing a strategy to determine its data needs and uses as they relate to the department s strategic framework and improvements to services, then partner with other state agencies to collect and analyze data on veterans. In some cases, ODVA may also need to consider working with the legislature to facilitate data sharing. At the state level, gaps may exist for veterans accessing certain services. ODVA s annual summit provides a way for the department to get input and feedback on services to veterans, as well as developing partnerships with organizations such as the Association of Oregon Counties. There are also multiple local and governmental organizations working directly with veterans that have insight into needed services and improvements to services. ODVA should consider additional methods to gather strategies that could improve veteran services at the state and local level, and advocate for those strategies with relevant agencies and stakeholders. Better Understanding of CVSO Activities that Help Veterans As part of its CVSO program oversight, ODVA is responsible for ensuring CVSOs perform quality work including developing and submitting quality claims. The department requires CVSOs to submit quarterly reports with basic financial information and claims data (e.g., number of interviews, filed claims, and granted claims). ODVA told us CVSOs are also to conduct outreach activities and refer veterans to other services as needed, however, the reporting to ODVA on these activities is limited to an open-ended narrative on the quarterly reports. For example, there is no collection of data on the number or types of referrals CVSOs are providing to veterans to help identify patterns of needs. Additionally, ODVA has provided limited guidelines to CVSOs to ensure the data collected is consistent and provides sufficient information on the veteran population being served. ODVA General Review Page 12
13 As previously mentioned, ODVA relies on CVSOs to not only help veterans sign up for VA benefits, but to act as a central hub for veterans to help them find other services in their community. ODVA certifies and provides annual training for CVSOS and organizes an annual summit to bring together CVSOs and other service delivery partners. However, ODVA has no performance standards for this aspect of CVSO work and has not made it an explicit part of CVSO training. To help ODVA ensure CVSOs provide the quality of work intended, the department should consider developing essential and well-defined reporting expectations and requirements. Since CVSOs are county employees, the department should also consider developing clear CVSO performance standards, and clarify those with the individuals to whom CVSOs report. Further, ODVA should consider developing training specifically for CVSO referral work. ODVA General Review Page 13
14 Considerations Our limited review noted the following strategies ODVA could consider to further improve coordination of veteran services in Oregon: seek methods to expand and continue advocacy for changes at the federal VA; seek opportunities for clarifying its informational materials; clarify how state and federal benefits affect one another for Oregon veterans and coordinate training on that to CVSOs as well as caseworkers at partner agencies; expand its partnerships with agencies to ensure sharing information amongst agencies is effective and streamlined to foster outreach activities to veterans, and consider opportunities to collaborate on effective methods to disseminate veteran benefit information to those eligible; partner with DHS and OHA to develop the PARIS data management and referral process to help ensure veterans receive the maximum benefits to which they are entitled; seek opportunities to assist the Oregon Employment Department to market the availability and advantages of employment services provided for veterans; consider the needs of homeless veterans now and past 2015, and partner collaboratively with other public agencies and local service providers to ensure that resources are known and available to the homeless and at risk veteran community; partner with Oregon educational institutions with approved GI Bill programs to assist in outreach for recruiting new student veterans and to maximize student veteran success; develop a strategy to determine data needs and uses as they relate to the department s strategic framework and improvements to services, then partner with other state agencies to collect and analyze data on veterans; seek additional methods to gather strategies that could improve veteran services at the state and local level, and advocate for those strategies with relevant agencies and stakeholders; develop essential and well-defined CVSO reporting expectations and requirements to ensure the quality of work intended; and develop clear CVSO performance standards, and clarify those with the individuals to whom CVSOs report, and develop training specifically for CVSO referral work. ODVA General Review Page 14
15 Objectives, Scope and Methodology Our work was a limited, general review of veteran services focused on the state services available specifically to veterans in Oregon, and ways in which providing such services could be improved. We gathered information on veteran services at the federal level by interviewing current and former VA and congressional staff, reviewing federal veteran data and statistics, and touring a VA facility. At the state level, we interviewed staff from eight state agencies including ODVA, educational institutions, legislators and legislative fiscal staff. We reviewed the ODVA Advisory Committee s annual report, legislative hearings documentation, applicable laws and administrative rules, and task force and consultant reports from Oregon and other states. We also reviewed quarterly information submitted to ODVA by County Veteran Service Officers (CVSOs). At the local level, we interviewed 10 local CVSOs, a county commissioner, city manager, and several regional nonprofit organizations which provide veteran services. We interviewed staff at the Association of Oregon Counties (AOC) Veterans Committee, reviewed related AOC materials, attended public events and forums for veterans, and spoke directly with several veterans from different conflicts to gain their perspective on available services. Since ODVA is undergoing change in many program areas, we decided to limit our working to a general review rather than proceeding with a full audit. As this was a general review, we were not required to and did not follow generally accepted government auditing standards. ODVA General Review Page 15
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19 STRATEGIC FRAMEWORK VISION, MISSION, VALUES Our Vision Veterans and their families thrive in Oregon Our Mission ODVA serves and honors veterans through our leadership, advocacy and strong partnerships Our Values Respect, Integrity, Stewardship and Excellence FIVE-YEAR GOALS, OBJECTIVES and STRATEGIES Target Veteran Services Serve more veterans and serve them better Drive Veteran Engagement Amplify awareness of resources and build the Oregon veterans brand Invest in a 21st century veterans services system. Ensure veteran service offi cers across Oregon are well staffed and resourced. Focus statewide veteran services on training, claims review, advocacy, and support. Better connect veterans to community resources. Deepen the connection with the veteran community. Promote a positive image of veterans and their families. Build the Oregon veterans brand. Ensure a seamless and positive experience by veterans seeking services. Mobilize Partnerships Leverage all resources available to veterans Maximize up-front, preventative resources to reduce expensive, back-end safety net systems. Bring the veterans lens to key outcome areas in health/ wellness and education/economic opportunity. Collaborate to create, connect and support statewide networks for veterans and family resources. Invigorate Core Operations Reenergize the Veterans Home Loan program. Provide the best in care at the Oregon Veterans Homes. Support 21st century veteran services through integrated information technology. Build a better, stronger and more durable department for future generations through our responsible, resourceful and creative management Partner across federal, tribal, state and local governments. Engage private, non-profi t and philanthropic sectors. Maintain fi scal integrity and sustainability of the department s programs. Infuse a culture of service that champions our values and vision through leadership, training, communication and accountability. 700 SUMMER STREET NE SALEM, OREGON CONNECT TO VETERAN BENEFIT INFORMATION AT
20 About the Secretary of State Audits Division The Oregon Constitution provides that the Secretary of State shall be, by virtue of her office, Auditor of Public Accounts. The Audits Division exists to carry out this duty. The division reports to the elected Secretary of State and is independent of other agencies within the Executive, Legislative, and Judicial branches of Oregon government. The division audits all state officers, agencies, boards, and commissions and oversees audits and financial reporting for local governments. Audit Team William Garber, MPA, CGFM, Deputy Director Sheronne Blasi, MPA, Audit Manager Karen Peterson, Principal Auditor Terri Preeg Riggsby, MPA, Staff Auditor Elliot Shuford, MPA, Staff Auditor This report, a public record, is intended to promote the best possible management of public resources. Copies may be obtained from: website: sos.oregon.gov/audits phone: mail: Oregon Audits Division 255 Capitol Street NE, Suite 500 Salem, Oregon The courtesies and cooperation extended by officials and employees of the Oregon Department of Veterans Affairs and those of other agencies during the course of this audit were commendable and sincerely appreciated.
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