Administration of Veterans' Affairs (United States)

NAICS 2022 code 923140 — an investor's primer

1. Overview

This industry is the government machinery that decides who is a veteran, what benefits they are owed, and cuts the checks. In plain terms, it is the administrative and benefits arm of the U.S. Department of Veterans Affairs (VA) — the largest civilian agency in the federal government — plus the state and county offices that help veterans file claims [1][2]. It does not include VA hospitals or clinics, which sit in a different classification (see Section 2) [1].

Why should an investor care about a government function that earns no profit? Two reasons. First, it moves enormous, politically protected money: the VA's total budget crossed $400 billion in fiscal year (FY) 2025, the FY2026 request was $434.8 billion, and the FY2027 request reached $488.2 billion — roughly one dollar in every fifteen the federal government spends [5][6][7]. Second, and more directly, the government increasingly does not do this work itself. It buys disability medical exams, health-record software, claims-processing systems, and private-network health care from contractors — some public, some private. Those contracts are how private capital actually gets exposure to this industry.

• Public-market route: you cannot buy "the VA." You buy its vendors — federal IT and services firms (Leidos, Booz Allen Hamilton, SAIC), disability-exam and health-services companies (Maximus, UnitedHealth's Optum), the electronic-health-record prime (Oracle), and the banks that originate VA-guaranteed mortgages.
• Private route: privately held government-services firms (TriWest, Peraton, Guidehouse, Loyal Source, Veterans United, and private-equity-owned contractors) do the same work off the public markets.

Everything that follows treats this as what it is — a tax-funded public administration whose economics are set by caseloads, policy, and appropriations, not sales — and then maps that to the handful of ways private capital plugs in. The single most useful conclusion up front: VA demand is structurally durable, but supplier earnings are concentrated, contract-driven, and hard to isolate from each vendor's larger business.

2. What it is and how it's structured

Formal scope. NAICS (North American Industry Classification System) 923140 covers government establishments that administer "programs of assistance, training, counseling, and other services to veterans and their dependents, heirs or survivors," including veterans' affairs offices that coordinate with other agencies and service organizations [1]. It sits inside industry group 9231 (Administration of Human Resource Programs), in Sector 92, Public Administration [1].

Adjacent codes it is NOT — its siblings in group 9231, easy to confuse [1]:

• 923110 — Administration of Education Programs
• 923120 — Administration of Public Health Programs
• 923130 — Administration of Human Resource Programs (except education, public health, and veterans')
• 923150 — Administration of Housing Programs

What it deliberately excludes (each maps to its own code) [1]:

• VA hospitals and clinics → Sector 62 / NAICS 622, Hospitals. This is the big one. The Veterans Health Administration (VHA) — 371,000-plus clinical and support staff at roughly 1,250–1,380 facilities, including about 170 medical centers — is classified as health care, not veterans' administration [8]. So most of the VA's ~448,000-person workforce is not counted in 923140.
• Veterans' insurance → NAICS 524, Insurance Carriers.
• Veterans' civic and social organizations (VFW, American Legion posts) → NAICS 813410, Civic and Social Organizations.

Who actually operates in 923140. The VA is organized around three administrations; only the non-hospital pieces belong here [2]:

1. The Veterans Benefits Administration (VBA) — the federal benefits engine and the heart of this code. About 32,000 employees across 56 regional offices, running six benefit lines: disability compensation; pension; education (the GI Bill); the home-loan guaranty; life insurance; and Veteran Readiness and Employment (VR&E, formerly vocational rehabilitation) [9].
2. VA central administration and the National Cemetery Administration (NCA) — headquarters, policy, IT, and cemetery/memorial operations [2].
3. State departments of veterans affairs and roughly 3,000 county/city veterans service officers (CVSOs) — the state and local layer that helps veterans prepare and file claims. This is government employment too, and genuinely part of the industry even though it rarely shows up in national tallies.

(The VHA — direct health-care delivery — is the third administration but is classified out of 923140 into health care.)

Ownership mix: essentially 100% government — federal, with a state and county tail. There is no private ownership of the function itself. Private capital enters only as contractors hired to perform pieces of it: publicly traded firms, privately held government-services companies, nonprofit-owned health-care administrators, and veteran-owned small businesses.

3. How big it is

The honest data caveat first. Our ground-truth statistics file reports no ingested figures for NAICS 923140 — no establishments, employment, payroll, receipts, or operator count. That is not zero; it is a genuine gap, and no suppressed value is invented here. The reason is structural: the entire Public Administration sector (NAICS 92) is excluded from both the Economic Census and County Business Patterns (CBP) [3]. There is no Census "receipts" or "paid employees" figure for this code because it is government, not business, and Small Business Administration (SBA) business statistics don't cover it either. Real measurements come from agency budgets, the Office of Personnel Management, and the Census of Governments — not the business datasets we normally cite. Treat this as an industry that is nearly invisible in standard federal business data by design, and undercounted in any employer survey.

Using the government sources that do measure it:

• Money administered. The VA total budget exceeded $400 billion in FY2025; the FY2026 request was $434.8 billion (split $300.4 billion mandatory — benefit checks that flow automatically — and $134.4 billion discretionary — mostly medical care and operations), and the FY2027 request was $488.2 billion, up 7.7% over FY2026 enacted [5][6][7]. A budget request is an agency funding envelope covering benefits, health care, personnel, and construction — not NAICS 923140 revenue — but most of the benefits dollars are administered by the VBA piece that defines this code.
• Claims and benefit payments. In FY2025 the VA processed 3,001,734 disability-compensation and pension claims and paid roughly $195 billion in compensation and pension to more than 6.9 million veterans and survivors, after cutting its claims backlog 57% [11]. Disability compensation alone paid about $150 billion to roughly 6 million veterans in 2024, an average near $25,446 each [10].
• Home-loan guaranty: the VA backed 416,374 home loans in FY2024 and 528,340 in FY2025, and stands behind roughly 3.7 million active VA mortgages [13].
• Workforce. The VA requested 448,170 full-time-equivalent (FTE) employees for FY2025 and is the largest civilian federal employer [4]. But most of that is VHA health staff coded to hospitals; the administrative/benefits core (VBA ~32,000, plus headquarters, NCA, and state/county offices) is a fraction of it [9].
• People served. There are roughly 17.9 million living veterans as of FY2024, about 9 million of them enrolled in VA health care [8][12].
• Contractor opportunity (supplier scale, not industry output). The Government Accountability Office (GAO) found the VA obligated almost $3 billion in FY2022 for professional, administrative, and management services across about 1,400 vendors [35], and more than $25 billion for information technology (IT) products and services from FY2017 through FY2021 [36]. These measure how much of the work is bought from the private sector — the real investable pool.

4. The investable universe

There is no pure-play public company in this industry — it is a government agency. Investors get exposure through the firms the VA pays to run pieces of the system. The table lists the most direct public proxies; for the diversified giants (Oracle, UnitedHealth, Accenture) VA work is a small slice of a much larger company, and none breaks out VA as a standalone segment.

Major private / other owners and operators:

• TriWest Healthcare Alliance (private) — administers CCN Regions 4–5; describes itself as owned by nonprofit health plans and university hospital systems [15][29].
• Peraton (private, backed by Veritas Capital) — federal IT contractor; its VA infrastructure-as-a-managed-service award was reported at up to $497 million over seven years [30].
• Guidehouse (private) — consulting and managed services, acquired by Bain Capital in 2023; supports the VA and other federal health agencies [31].
• Loyal Source Government Services (private) — a disability-exam contractor, the fourth major exam player alongside Leidos QTC, Maximus VES, and UnitedHealth Optum Serve [14].
• Veterans United Home Loans (private) — the largest VA mortgage lender.
• Other PE-owned / private govcon firms — GovCIO, Cognosante (acquired by Accenture in 2024), ManTech (Carlyle-owned), CGI Federal (unit of Canada-listed CGI Inc.) — all on VA IT vehicles [24].
• Veteran-owned and service-disabled veteran-owned small businesses (VOSB/SDVOSB) — an important supplier tier in specialized services, staffing, construction, and IT, certified through the SBA's Veteran Small Business Certification program [32].
• Government itself — the VBA, VA headquarters, NCA, and the state/county veterans offices that are the actual industry.

If you want breadth without single-name risk, broad federal-services and defense-IT exposure (via govcon-heavy holdings) is the practical way in; there is no dedicated "veterans administration" fund. Private-company disclosure is thin, so private investors lean on contract records, customer references, and debt documents rather than public filings.

5. How the money works

This industry does not earn revenue or profit — it is a cost center funded by taxes, so ordinary owner-economics don't apply to the function itself. What matters is how the dollars are structured and how the private proxies get paid.

Funding mechanics (the government side).

• Mandatory vs. discretionary. The benefit checks — disability compensation, pension, education, insurance — are largely mandatory (entitlement) spending: if a veteran qualifies, the law requires payment, so outlays rise automatically with caseload and cost-of-living adjustments [5]. Running the agency (staff, IT, medical care) is discretionary, set annually by appropriations [5]. A special Toxic Exposures Fund (TEF) pays for the PACT Act expansion (Section 6) [5].
• The real cost drivers are therefore caseload (how many claims arrive and get approved), benefit generosity (rating levels and COLAs), and administrative cost per claim (how efficiently the agency and its contractors move a claim from filing to decision).

The economic chain to contractors.

1. The VA receives federal funding and determines eligibility and service requirements.
2. It provides some care and administration directly through its own workforce and facilities.
3. It purchases outside care through the CCN, Veteran Care Agreements, and local contracts.
4. Contractors provide claims administration, medical exams, IT, EHR integration, cybersecurity, staffing, facilities, and consulting.
5. Community providers get paid for authorized care; third-party administrators earn fees for network, referral, and claims functions.

How the private proxies actually make money.

• Per-exam fees. Disability (C&P) exams are outsourced to contractors paid per completed exam. Contractors performed about 93% of C&P exams by 2024, up from 44% in 2017 — a large, recurring stream that grows with claims volume [14].
• Contract vehicles. IT and services work runs through big indefinite-delivery/indefinite-quantity (IDIQ) vehicles (e.g., T4NG2) as task orders — fixed-price, labor-based, or software/managed services [28][30].
• Health-network administration fees. CCN administrators (Optum, TriWest) earn fees to build provider networks and process claims for veterans treated outside VA facilities [15].
• Mortgage economics. The VA guaranty lets lenders originate zero-down loans they then sell/service; they earn origination and servicing income (not a VA fee), and volume tracks rates and the eligible veteran pool [13].

Metrics that matter here differ from ordinary sectors: funded backlog versus ceiling value; task-order awards and obligation-to-revenue conversion; recompete win rates and option-year renewals; VA (and total federal) revenue concentration; labor utilization and retention; contract gross margin and cash conversion; claims cycle time and payment accuracy; provider-network breadth; and EHR uptime and deployment progress. The classic analytical error is treating a large contract ceiling as booked revenue — it is not. The throughline: the more the government chooses to buy rather than build, the bigger the private revenue pool, and that make-vs-buy choice is the central variable for equity investors here.

6. What drives demand

• The veteran population — and its long decline. The VA's own VetPop model projects living veterans falling from ~17.9 million in FY2024 to ~11.2 million by FY2053 [12]. All else equal, a shrinking customer base over decades is a structural headwind for volume-based benefits far out.
• …offset by expanding eligibility. Legislation repeatedly widens who qualifies, swamping the demographic decline in the near term. The biggest recent example is the PACT Act (the 2022 Sergeant First Class Heath Robinson Honoring our Promise to Address Comprehensive Toxics Act), which added presumptive conditions for burn-pit and other toxic exposures; the VA accelerated major eligibility expansions beginning in March 2024 [20]. Through August 2025 it had driven 1.9 million-plus approved claims, over $11 billion paid, and 6.3 million toxic-exposure screenings [18].
• Record claims workload. Claims activity hit a record in FY2025 (over 3 million processed), sustaining demand for exam contractors, claims processing, and IT [11].
• Community access. The CCN connects the VA to more than 1 million community providers, and matters most where the VA lacks local or specialty capacity [15].
• Health-care and administrative modernization. The Oracle Health EHR program — which the VA renewed for another option period in 2025 while shifting to annual reviews — plus digitization, identity management, cybersecurity, and automation, can cut processing friction even when the underlying benefit obligation stays high [22][23][24].
• Political tailwind. Veterans' benefits are among the most bipartisan lines in the budget and are rarely cut, which is why the top-line grows through administrations of both parties — though a request is not an enacted appropriation [6][7].

Demand is more cyclical around budgets, procurement, and policy than around the business cycle. The strongest opportunities cluster in measurable bottlenecks: claims processing, medical exams, community-care coordination, rural access, and secure health data.

7. Regulation

This industry is regulation — it administers federal law rather than being policed by an outside regulator — but it is tightly governed and overseen:

• Statute. Veterans' benefits run on Title 38 of the U.S. Code and Title 38 of the Code of Federal Regulations (CFR). The agency began as the Veterans Administration in 1930 and became a Cabinet department in 1989.
• The MISSION Act of 2018 created a permanent community-care program and required the VA to establish networks of private providers — the legal basis for the CCN [19].
• The PACT Act (2022) expanded eligibility for toxic-exposed veterans and funded it through the TEF [20].
• Procurement rules. The Federal Acquisition Regulation (FAR) and the VA Acquisition Regulation (VAAR) govern contracting, with VA-specific rules for health-care resources [33]. The SBA's Veteran Small Business Certification program supports VOSB/SDVOSB set-asides and sole-source awards [32].
• Data privacy. The Health Insurance Portability and Accountability Act (HIPAA) applies to claims administrators and technology providers handling protected health information (PHI) as covered entities or business associates [34].
• Appeals. Denied claims flow to the Board of Veterans' Appeals and then to the independent Court of Appeals for Veterans Claims (CAVC); the 2017 Appeals Modernization Act restructured that process. Only VA-accredited representatives, attorneys, and recognized veterans service organizations may formally represent claimants — a rule that shapes the claims-help market.
• New CCN precertification requirements take effect September 16, 2026 for Regions 1–3 and September 26, 2026 for Regions 4–5 [17].
• Oversight. The VA Office of Inspector General (OIG), the GAO, the House and Senate Veterans' Affairs Committees, contracting officers, and bid-protest processes supervise it continuously — the EHR program and claims accuracy are recurring targets [22][36]. The net effect is a market with high compliance costs and outsized reputational stakes.

8. Competitive dynamics and consolidation

There is no competition to be the VA — it holds a legal monopoly on federal veterans' benefits. The competitive action is entirely in the contractor layer, and it is consolidating on several fronts:

• CCN concentration, and a pending super-consolidation. Today two administrators split the country — Optum (UnitedHealth) runs Regions 1–3, TriWest runs Regions 4–5 [15]. In late 2025 the VA moved to collapse the network from five regions to two, restructuring contracts worth up to $1 trillion over ten years — a shift that raises the stakes enormously for Optum and TriWest and reshapes who administers private care for veterans [16].
• Exam-market consolidation. Disability exams moved from in-house to contractors (44% → 93% in seven years), concentrating a large recurring workload in four firms — Leidos (QTC), Maximus (VES), UnitedHealth (Optum Serve), and private Loyal Source — several of them roll-ups of smaller exam companies [14].
• Fewer, larger IT primes. The GAO found VA IT spending rose while the number of contractors receiving awards fell during FY2017–FY2021 — incumbency and scale advantages compounding [36].
• Private capital absorbing federal-health capabilities. Accenture acquired Cognosante in 2024; Guidehouse moved from Veritas Capital to Bain Capital in 2023 — examples of large primes and PE sponsors buying specialized VA-facing shops [24][31].
• One health record to rule them all. The EHR program is consolidating the VA's fragmented systems onto a single Oracle platform (Section 10) [22].
• Internal reorganization. The VA announced a VHA management reorganization expected to unfold over 18–24 months, aiming for clearer decision-making across more than 1,300 medical facilities; its effect on future procurement is a forward-looking judgment, not a reported outcome [37].

For contractors this is a classic government-services dynamic: few buyers, large recompetes, and incumbency advantages — so scale and consolidation matter more than price wars.

9. Risks

• Budget and workforce whiplash. In 2025 the VA cut roughly 30,000 positions (headcount fell from ~484,000 in January to ~467,000 by June) via a hiring freeze, deferred-resignation offers, and the Department of Government Efficiency (DOGE) push — after initially floating cuts of 70,000-plus [21]. Thinner staffing threatens claims timeliness and can shift work (and dollars) toward — or abruptly away from — contractors when contracts are cancelled.
• Appropriations and policy risk. A budget request can be cut, delayed, or reshaped by Congress, continuing resolutions, or shifting administrative priorities [7].
• Contract risk. Large ceilings may never be fully funded; options, recompetes, protests, and terminations can swing supplier revenue sharply [28].
• Customer concentration. A vendor can look diversified yet still depend heavily on the VA or the broader federal government — Booz Allen's ~10% VA revenue share is the clearest public case [25].
• Execution risk. The EHR modernization is years behind and over budget and remains the single most-scrutinized program; claims-accuracy, referral-coordination, and cybersecurity failures can trigger penalties or lost renewals [22].
• Labor risk. Exams, claims processing, and systems integration require scarce clinical, technical, and security-cleared staff.
• Data and privacy risk. Contractors handling PHI face contractual, regulatory, litigation, and reputational exposure under HIPAA [34].
• Private-equity/leverage risk. Debt-funded roll-ups add refinancing and covenant risk if award flow slows.
• Entitlement cost pressure and program integrity. Mandatory benefits grow largely on autopilot, inviting future eligibility or means-testing debates; improper payments and rating errors are perennial OIG/GAO findings and a political liability [36].
• Long-run demographics. The projected roughly one-third decline in the veteran population by mid-century is a slow structural drag on volume-based work [12].
• Mission and reputational risk. Poor service to veterans draws unusually strong political and public scrutiny.

10. How to invest, and the outlook

Public-market routes (the practical menu). Since you can't own the agency, the levers are its vendors:

• Federal IT & services: Leidos (LDOS), Booz Allen (BAH), SAIC (SAIC), Accenture (ACN) — priced on funded backlog and recompete wins.
• Disability exams / health services: Maximus (MMS) and UnitedHealth/Optum (UNH), which ride claims volume and CCN administration.
• The EHR prime: Oracle (ORCL) — though the VA is immaterial to Oracle's valuation.
• VA-loan mortgage lenders: Rocket (RKT), UWM (UWMC), PennyMac (PFSI) — geared to rates and origination volume, not to a VA fee. There is no dedicated ETF; diversified defense/government-services exposure is the closest packaged proxy.

What to actually check before buying a proxy: VA revenue and profit contribution; funded backlog rather than contract ceilings; contract-expiration and option dates; recompete exposure; customer/program concentration; labor intensity and margin resilience; and cash collection. The mistake to avoid is buying a name just because its contracts carry a large headline ceiling.

Private routes. Privately held operators — TriWest (community care), Peraton and Guidehouse (IT/consulting), Loyal Source (exams), Veterans United (VA mortgages), and PE-owned govcon shops — offer the same exposure off-market, typically via private equity or private credit. The most attractive targets are specialized contractors with repeatable capabilities, strong past performance, veteran-owned certification, secure data practices, and a credible path from subcontractor to prime. Diligence customer concentration, contract-assignment rights, labor availability, security obligations, and debt.

Near-term catalysts to watch:

1. The PACT Act claims wave should keep exam and processing demand elevated well past 2025, benefiting exam contractors even as the agency sheds staff [18].
2. The EHR restart. After a three-year pause, the VA plans to resume Oracle Health deployments at Michigan sites in mid-2026, targeting broader rollout in 2027 and every medical center by 2031 — a multi-year, ~$37 billion lifecycle program whose pace is the key catalyst (and risk), now with Accenture Federal Services added for integration [22][24].
3. The Community Care recompete — the move to two mega-regions worth up to $1 trillion over a decade — will decide the winners in VA private-care administration [16].
4. Workforce cuts vs. mandated service levels. If attrition outruns automation, backlogs grow, pressuring Congress to fund more contractor capacity — a plausible tailwind for outsourced exams and IT, and a headwind for service quality [21].

Bottom line: as a stand-alone business, this industry is invisible in the usual statistics and un-buyable directly — it is government. But it directs hundreds of billions of dollars a year through an expanding roster of outsourced exams, health networks, IT systems, and guaranteed loans, and that is a real, growing, politically durable revenue pool. The investable thesis is not "the VA"; it is "whoever the VA pays to run it." The near-term setup — a PACT-driven claims bulge, a restarting EHR, a consolidating community-care market, and a shrinking federal workforce that must lean harder on vendors — tilts that pool toward the scaled contractors, even as the very-long-run veteran population declines. Demand is favorable; earnings visibility and direct investability are mixed.

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Sources

1. U.S. Census Bureau / NAICS, "923140 — Administration of Veterans' Affairs" (definition, sibling codes 923110/923120/923130/923150, and exclusions), 2022. https://www.census.gov/naics/?details=923140&input=923140&year=2022; industry description via https://www.naics.com/naics-code-description/?code=923140
2. U.S. Department of Veterans Affairs, "Administrations and Offices" (VHA / VBA / NCA structure), 2026. https://department.va.gov/administrations-and-offices/
3. U.S. Census Bureau, "County Business Patterns FAQs" and Economic Census NAICS guidance (Public Administration, NAICS 92, excluded from CBP and the Economic Census), 2024–2026. https://www.census.gov/programs-surveys/cbp/about/faqs.html; https://www.census.gov/programs-surveys/economic-census/year/2022/guidance/understanding-naics.html
4. U.S. Department of Veterans Affairs, "FY 2025 Budget Submission — Budget in Brief" (448,170 FTE), 2024. https://department.va.gov/wp-content/uploads/2024/03/fy-2025-va-budget-in-brief.pdf
5. Congressional Research Service, "Department of Veterans Affairs FY2026 Appropriations" (R48968; $434.8B request, $300.4B mandatory / $134.4B discretionary; Toxic Exposures Fund), 2026. https://www.congress.gov/crs-product/R48968
6. The American Legion, "VA budget tops $400 billion for 2025," 2025. https://www.legion.org/information-center/news/veterans-healthcare/2025/june/va-budget-tops-400-billion-for-2025
7. U.S. Department of Veterans Affairs, "Budget — President's Budget Request for FY2027" ($488.2B request, +7.7% over FY2026 enacted), 2026. https://department.va.gov/administrations-and-offices/management/budget/
8. U.S. Department of Veterans Affairs, "About VHA — Veterans Health Administration" (371,000+ staff; ~1,255–1,380 facilities; ~170 medical centers; ~9M enrolled), 2024–2026. https://www.va.gov/health/aboutvha.asp
9. Veterans Benefits Administration, "About VBA" (~32,000 employees; 56 regional offices; six benefit lines; 5.5M+ veterans served), 2024; and "Veterans Benefits Administration," Wikipedia, 2025. https://www.benefits.va.gov/benefits/about.asp; https://en.wikipedia.org/wiki/Veterans_Benefits_Administration
10. American Enterprise Institute, "Veterans' Disability Compensation: Growth and Policy" (≈6M recipients, avg ≈$25,446, ≈$153B in 2024), 2025, drawing on the VBA Annual Benefits Report 2024. https://www.aei.org/health-care/veterans-disability-compensation-growth-and-policy/; https://www.benefits.va.gov/REPORTS/abr/docs/2024-compensation.pdf
11. U.S. Department of Veterans Affairs, "VA reduces backlog of Veterans waiting for VA benefits by 57%" (FY2025: 3,001,734 claims processed; ~$195B compensation and pension paid to 6.9M+ veterans and survivors), 2025. https://news.va.gov/press-room/va-reduces-backlog-of-veterans-waiting-for-va-benefits-by-57/
12. U.S. Department of Veterans Affairs, VetPop2023 / National Center for Veterans Analysis and Statistics (17.9M veterans FY2024 → 11.2M FY2053), 2024. https://www.va.gov/vetdata/veteran_population.asp
13. U.S. Department of Veterans Affairs / VBA Annual Benefits Report, "Loan Guaranty" (416,374 loans guaranteed FY2024; 528,340 FY2025; ~3.7M active VA mortgages), 2024–2025. https://www.benefits.va.gov/REPORTS/abr/docs/2024-loan-guaranty.pdf; VA News, "VA guarantees 29 millionth home loan," 2025. https://news.va.gov/press-room/va-guarantees-29-millionth-home-loan/
14. claim.vet, "VA C&P Exam Contractors: LHI vs VES vs QTC vs Optum" (four contractors; 93% of exams by contractors in 2024 vs 44% in 2017), 2026; and Leidos, "VBA Awards Medical Disability Examination Services Contract to Leidos QTC," 2024. https://claim.vet/blog/cp-exam-contractors-lhi-ves-qtc-optum/; https://www.leidos.com/insights/veterans-benefits-administration-awards-medical-disability-examination-services-contract
15. U.S. Department of Veterans Affairs, "Community Care Network" (Optum administers Regions 1–3, TriWest administers Regions 4–5; 1M+ community providers), 2026; and CCN Regions 1–5 Fact Sheet, 2022. https://department.va.gov/vha/community-care/partnerships/community-care-network/; https://www.va.gov/COMMUNITYCARE/docs/pubfiles/factsheets/FactSheet_26-03.pdf
16. Military Officers Association of America, "VA to Reorganize Community Care Contracts, Reducing Regions to 2" (Optum + TriWest; up to $1 trillion over 10 years; five regions to two), 2025; and Military Times, 2025. https://www.moaa.org/content/publications-and-media/news-articles/2025-news-articles/health-care-and-earned-benefits/va-to-reorganize-community-care-contracts,-reducing-regions-to-2/; https://www.militarytimes.com/veterans/2025/12/15/va-to-reorganize-community-care-contracts-reducing-regions-to-2/
17. U.S. Department of Veterans Affairs, "Precertification Requirements" (Regions 1–3 effective Sept 16, 2026; Regions 4–5 effective Sept 26, 2026), 2026. https://department.va.gov/vha/community-care/care-coordination/precertification-requirements/
18. U.S. Department of Veterans Affairs, PACT Act Dashboard (1.9M+ approved claims, $11B+ paid, 6.3M screenings through Aug 2025), 2025; and Stars and Stripes, "VA awards 1 million claims for toxic-exposure health benefits," 2024. https://www.va.gov/resources/the-pact-act-and-your-va-benefits/; https://www.stripes.com/veterans/2024-05-21/pact-act-veterans-toxic-exposure-health-benefits-claims-13927692.html
19. Congressional Research Service, "VA MISSION Act of 2018" (R45390; permanent community-care program), 2018. https://www.congress.gov/crs-product/R45390
20. U.S. Department of Veterans Affairs, "Expansion of Health Care Eligibility for Toxic-Exposed Veterans" (PACT Act; major expansions from March 2024), 2024. https://www.va.gov/HEALTHBENEFITS/resources/publications/10-1745_Toxic-exposed_Veterans_20240320v2.pdf
21. Federal News Network, "VA on track to cut nearly 30K jobs by end of fiscal 2025" (484,000 → 467,000; DOGE; hiring freeze), 2025; and VA News, "VA to reduce staff by nearly 30K by end of FY2025," 2025. https://federalnewsnetwork.com/workforce/2025/07/va-on-track-to-cut-nearly-30k-jobs-by-end-of-fiscal-2025-eliminating-need-for-rif/; https://news.va.gov/press-room/va-to-reduce-staff-by-nearly-30k-by-end-of-fy2025/
22. Nextgov/FCW, "VA readies to restart EHR deployments in 2026" (Oracle Health; $16B+ contract, ~$37B lifecycle; restart at Michigan sites; every medical center by 2031), 2025. https://www.nextgov.com/modernization/2025/12/va-readies-restart-ehr-deployments-2026-despite-lingering-lawmaker-unease/
23. U.S. Department of Veterans Affairs, "VA continues partnership with Oracle Health to deploy Federal Electronic Health Record" (2025 contract option period; shift to annual reviews), 2025. https://news.va.gov/140212/va-continues-partnership-with-oracle-health-to-deploy-federal-electronic-health-record/
24. Accenture, "Accenture Federal Services Selected to Support the Mission-Critical Modernization of Veteran Health Records," 2026; Accenture acquisition of Cognosante, 2024. https://newsroom.accenture.com/news/2026/accenture-federal-services-selected-to-support-the-mission-critical-modernization-of-veteran-health-records-for-the-department-of-veterans-affairs
25. Booz Allen Hamilton, "Form 10-K for Fiscal 2026" (VA is the largest civil-government customer, ~10% of revenue), 2026. https://investors.boozallen.com/static-files/1f0fd5ef-8cc0-4e23-bcad-9cc87fbad2fa
26. Leidos, Form 10-K / investor materials (total revenue ≈$16–17B; QTC disability exams), 2024–2025. https://investors.leidos.com/
27. Maximus, investor materials (total revenue ≈$5B; Veterans Evaluation Services), 2024–2025. https://investor.maximus.com/
28. Science Applications International Corporation, "SAIC to Deliver IT Services on Department of Veterans Affairs $60.7B Contract" (T4NG2 ceiling), 2024. https://investors.saic.com/news-releases/news-release-details/saic-deliver-it-services-department-veterans-affairs-607b
29. TriWest Healthcare Alliance, "About TriWest" (nonprofit health-plan and university-hospital ownership; CCN Regions 4–5), 2026. https://www.triwest.com/en/about/
30. Peraton, "Peraton Receives $497M Department of Veterans Affairs Contract" (infrastructure-as-a-managed-service, up to 7 years; Veritas Capital backing), 2021. https://www.peraton.com/news/peraton-receives-497m-department-of-veterans-affairs-contract-to-provide-infrastructure-as-a-managed-service-iaams
31. Guidehouse, "Guidehouse Completes Transaction with Bain Capital," 2023. https://guidehouse.com/news/corporate-news/2023/guidehouse-completes-transaction-with-bain-capital
32. U.S. Small Business Administration, "Veteran Contracting Assistance Programs" (Veteran Small Business Certification; VOSB/SDVOSB set-asides), 2025. https://www.sba.gov/federal-contracting/contracting-assistance-programs/veteran-contracting-assistance-programs
33. Acquisition.gov, "Department of Veterans Affairs Acquisition Regulation System" (VAAR; and the FAR), 2022. https://www.acquisition.gov/vaar/part-801%E2%80%94department-veterans-affairs-acquisition-regulation-system
34. U.S. Department of Health and Human Services, "Business Associates" (HIPAA obligations for contractors handling PHI), 2018. https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/business-associates/index.html
35. Government Accountability Office, "Veterans Affairs: Information on Professional Services Contracting Data and Conflict of Interest Regulations" (GAO-23-106961; ~$3B obligated FY2022 across ~1,400 vendors), 2023. https://www.gao.gov/products/gao-23-106961
36. Government Accountability Office, "VA IT Contracting: Observations on Trends, Competition, and Past Performance Information" (GAO-23-105446; >$25B FY2017–FY2021; fewer contractors), 2022. https://www.gao.gov/products/gao-23-105446
37. U.S. Department of Veterans Affairs, "VA Launches Veterans Health Administration Reorganization" (18–24 month reorganization; 1,300+ facilities), 2025. https://news.va.gov/press-room/va-launches-veterans-health-administration-reorganization/