The VA OIG Rewards Program
A source of information ("source") may receive a cash OIG Investigations Reward for disclosing to the VA OIG information concerning criminal or unlawful activities involving VA programs and personnel. Types of criminal or unlawful activity include, but are not limited to, false or fraudulent claims for benefits, medical care, services, or payment from VA to beneficiaries, survivors, fiduciaries, contractors, veterans, and VA employees; theft of identity of veterans or fictitious or exaggerated military service claims against VA (including offenses known as "Stolen Valor"); fraud related to pharmaceutical firms' illegal defective pricing or off-label marketing activities; acts of embezzlement, extortion, and bribery committed by VA employees; theft and diversion of legal drugs by VA staff and others; sale of contraband drugs and pharmaceuticals by and to VA staff and patients; theft of VA resources and data; assaults involving VA employees and patients, including homicide, manslaughter, and rape; threats against VA employees, patients, facilities, and computer systems; mortgage fraud; and workers' compensation fraud. The VA OIG may pay cash rewards to a source of information for providing substantial information not previously known by the VA OIG, which leads to a felony charge or a substantial monetary recovery from individuals who defrauded VA programs. The information must be essential to the effective administration and enforcement of the laws. The information must be more than helpful or desirable. Nothing in this policy is intended to create any rights in third parties, and the decision whether or not to make a reward rests solely in the Inspector General's discretion and is not subject to further review.
OIG Hotline Rewards may be paid for Hotline complaints that result in significant improvements to, or savings in, VA operations and programs. Examples of issues that may result in a Hotline Reward include allegations that prompt actions to address systemic patient safety issues, gross mismanagement of VA programs and resources, misconduct by senior VA officials, and abuse of VA benefits and services.
The specific procedures for rewards under this policy follow.
Rewards authorized hereunder may be given to any person, including VA employees, former employees, contractor employees, or others, except current and former VA OIG employees or anyone who becomes aware of the information being provided as a result of their interactions with a current or former VA OIG employee. Employees of other law enforcement agencies are also not eligible to receive any monetary rewards under this program.
B. Reward Process
Any source who requests payment for information will be informed that payments may be made only if the information provided is new to the VA OIG and meets OIG reward criteria. In order for a complaint to result in an OIG Investigation Reward it must lead directly to a felony charge or substantial monetary recovery from parties who defrauded VA programs. Hotline Rewards may be provided for complaints that result in significant administrative sanctions or corrective actions. No promises should be made that a reward will be given under any circumstances. The information provided will be documented in writing and forwarded to either the VA OIG Hotline or to a VA OIG supervisor for evaluation. Hotline or VA OIG supervisors will screen all reward requests and forward recommendations for rewards under this policy to the designated Assistant Inspector General (AIG). The transmittal will include a synopsis of the information provided by the source, the significance of that information to the VA OIG's review, the results of the VA OIG review, and a recommended reward amount. The AIG will then make a recommendation in writing to the Inspector General, who will make the final decision on any rewards.
C. Criteria for Granting Monetary Rewards
Final approval of any reward is solely within the discretion of the Inspector General, who will be guided by the criteria established in this policy. As a prerequisite to approving a reward, the Inspector General may require the person under consideration for a reward to submit a sworn affidavit detailing how he/she obtained the information that formed the basis for the disclosure. In determining whether to approve a reward, the Inspector General may consider the timeliness, accuracy, specificity, scope, and usefulness of the disclosure, and whether the VA OIG likely would have discovered the information without the source's assistance. The Inspector General also may consider (1) the circumstances under which the source acquired the information, (2) the source's culpability, if any, for the matters disclosed, and (3) the potential risk to the source, if any, for having made the disclosure.
D. Computation of Reward
The amount of reward may not exceed the lesser of $10,000 or an amount equal to one percent of VA's total recovery as determined by the Inspector General. The Inspector General or Deputy Inspector General may authorize a reward greater than $10,000 if he or she deems such higher amount appropriate to the circumstances of the investigation. If the VA OIG receives information about the same matter from more than one source, the Inspector General may divide any reward for the disclosure among the sources based on the criteria set forth in this policy. The amount of any reward will be based on any relevant factors deemed appropriate by the Inspector General; e.g., the significance of the information provided, risks involved, time spent, expenses incurred, extent of fraud, and cost savings to VA.
E. Reward Presentation
The source will be contacted to determine if he/she wishes to have a public or private reward presentation. The source's request for a private presentation takes precedence over the public relations value of a public ceremony. The source is to be informed that such compensation must be reported as income when filing Federal income tax forms or other appropriate tax forms. The identity of any person who receives a reward under this program shall remain confidential at that person's request. Although the names of reward recipients will not be released without their consent, the Inspector General will as appropriate disseminate information within VA and to the public regarding the number and amount of rewards, recoveries, and a synopsis of actions taken because of the disclosures.
F. Anonymous Sources
A person can provide information anonymously through VA OIG Hotline and still be eligible for the OIG reward program if the complaint resulted in a felony charge or substantial monetary recovery. The person would need to contact the VA OIG Hotline and provide sufficient information (e.g. method of submission, date of submission, details of the submission) regarding the complaint to identify them as the originating source. However, prior to actually receiving a reward, the individual would have to identify himself or herself in order for the Inspector General to complete the evaluation of the reward prerequisites. Identification would also be necessary for reward payment and tax records.
G. Funding for Rewards
Rewards will be funded from the VA OIG budget.