Veterans Accredited Representatives: Frequently Asked Questions

Veterans Accredited Representatives: Frequently Asked Questions

Veterans Accredited Representatives:
June 25, 2020
Frequently Asked Questions
Heather M. Salazar
Veterans accredited representatives are individuals accredited by the Office of General Counsel
Analyst in Veterans Policy
(OGC) at the Department of Veterans Affairs (VA) to help veterans, their survivors, and their

dependents (“claimants”) submit benefits claims to VA. Accredited representatives also may
Tamar B. Breslauer
assist claimants in appeals to the Board of Veterans’ Appeals. To be accredited, individuals must
Research Librarian
file a formal application with VA’s OGC, accompanied by evidence that the representative has

successfully completed a VA-approved training process.

Many accredited representatives work for nongovernmental, state, county, or tribal veterans
service organizations (VSOs), which are organizations that aid and serve veterans, servicemembers, dependents, and
survivors. VA also accredits attorneys and agents who are not affiliated with VSOs. All accredited representatives must
receive initial and ongoing training, and the OGC oversees all accredited representatives. If an accredited representative
violates specific requirements or a claimant is unhappy with an accredited representative, VA provides a complaint p rocess
that can lead to administrative penalties, including rescinding the representative’s accreditation.
As attention has been given to the backlog of claims in VA, congressional offices have sought additional clarification
regarding the role of accredited representatives in the claims process. Legislation in the 116th Congress has been introduced
to allow nonaccredited representatives, such as congressional staff, access to veterans’ records (H.R. 628). Legislation has
been introduced to require this access (S. 3761), in response to a proposed rule to rescind the 48 hours currently given to
accredited representatives to review claims determinations (85 Federal Register 9435, February 19, 2020). Understanding
accredited representatives’ roles and how oversight of them can impact claimants could inform future congressional and
regulatory action regarding these representatives.

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Contents
Accredited Representatives: Overview ............................................................................... 1
Who Are Accredited Representatives? .......................................................................... 1
What Is the Difference Between an Accredited Representative and a Congressional
Staff Member Who Works on Constituent Cases?......................................................... 1
Can Federal Employees Be Accredited Representatives? ................................................. 2
Are Al Employees Who Work for Veterans Service Organizations Also Accredited
Representatives? ..................................................................................................... 2
Can a Non-Veterans Affairs-Accredited Attorney Represent Claimants? ............................. 2
Can an Accredited Representative Charge a Fee?............................................................ 2
Where Can I Find a List of Accredited Representatives? .................................................. 2
How Successful Are Accredited Representatives? ........................................................... 3
Becoming an Accredited Representative ............................................................................. 3
Who Is Responsible for Accrediting Representatives? ..................................................... 3
What Does It Mean to Be an Accredited Representative? ................................................. 3
What Training Do Accredited Representatives Receive? .................................................. 4
Training by Veterans Affairs................................................................................... 4
Training by Veterans Service Organizations.............................................................. 4
Training by Legal Associations............................................................................... 4
How Often Must Accredited Representatives Undergo Training? ...................................... 5
Complaints and Penalties ................................................................................................. 5
Who Monitors Accredited Representatives? ................................................................... 5
How Does a Claimant File a Complaint Against an Accredited Representative? .................. 5
Can Veterans Affairs Revoke a Representative’s Accreditation? ........................................ 6
How Does Veterans Affairs (VA) Address Accredited Representatives Who Violate
VA or Its Statutory Requirements? ............................................................................. 6
What Can Claimants Do If They Believe They Were Represented by an Individual
Who Falsely Claimed to Be an Accredited Representative?............................................ 6
Veterans Service Organizations and Accredited Representatives ............................................. 7
What Is the Difference Between a Veterans Service Organization and an Accredited
Representative? ...................................................................................................... 7
Do Veterans Service Organizations Provide Access to Accredited Representatives? ............. 7
Can a Claimant Use an Accredited Independent Agent, Attorney, or State or County
Veterans Service Organization Representative from Outside the Claimant’s County
or State of Residence?.............................................................................................. 7

Tables

Table A-1. Veterans Affairs (VA) Requirements for Accreditation ........................................... 8
Table B-1. Glossary of Abbreviations Related to Accredited Representatives.......................... 10

Appendixes
Appendix A. Veterans Affairs Accreditation Requirements..................................................... 8
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Appendix B. Glossary of Abbreviations ............................................................................ 10

Contacts
Author Information ....................................................................................................... 10

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Accredited Representatives: Overview
Who Are Accredited Representatives?
Accredited representatives may be independent agents or attorneys. The Department of Veterans
Affairs (VA) defines an accredited representative as follows:
An accredited representative is an individual who has undergone a formal application and
training process and is recognized by VA as being capable of assisting claimants with their
affairs before VA. Most accredited representatives work for veteran service organizations
(VSOs), many of which are private non-profit groups that advocate on behalf of Veterans,
Servicemembers, dependents and survivors. Accredited representatives may also work for
state or county government entities.1
What Is the Difference Between an Accredited Representative and a
Congressional Staff Member Who Works on Constituent Cases?
Both accredited representatives and congressional staff members may receive questions from
veterans regarding their benefits. However, accredited representatives and congressional staff
members have very different roles in, and tools for, addressing veterans’ questions.
Al accredited representatives approved to represent veterans, survivors, or their dependents
(“claimants”)
 are accredited through VA’s Office of General Counsel (OGC),2
 are subject to OGC oversight,
 have completed specific, VA-approved training,
 have access to claimants’ records,3 and
 are authorized to upload relevant documentation into VA databases.
For more information on the accreditation process, see the “Becoming an Accredited
Representative” section, below.
In contrast, congressional staff are not authorized to access VA claims files or upload documents
into VA databases on behalf of claimants.4 In addition, congressional staff are not subject to OGC
oversight. They may provide publicly-available information to veterans or send inquiries to VA,
but they may not represent claimants before VA.

1 See U.S. Department of Veterans Affairs (VA), “Accredited Representatives,” at https://benefits.va.gov/vso/
index.asp. Note that tribal veterans service organizations (VSOs) may also have accredited representatives; however,
VA’s definition does not currently include them.
2 VA, “Office of General Counsel,” at https://www.va.gov/OGC/.
3 A claims file captures service personnel records, service medical records, VA treatment records, correspondence, and
other records.
4 T he Working to Integrate Networks Guaranteeing Member Access Now (WINGMAN) Act (H.R. 628), introduced
January 19, 2019, would allow designated congressional employees to access VA databases with a claimant’s
permission. T his bill was referred to the Subcommittee on Disability Assistance and Memorial Af fairs of the House
Committee on Veterans’ Affairs on February 8, 2019. T he subcommittee held hearings on the bill on October 22, 2019.
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Can Federal Employees Be Accredited Representatives?
Federal employees cannot be accredited representatives. It is a federal crime for any officer or
employee of the United States to act “as an agent or attorney for anyone before any department,”
other than as part of the officer’s or employee’s official duties.5 In addition, 38 C.F.R.
§14.629(a)(3) prohibits service organization accredited representatives from being “employed in
any civil or military department or agency of the United States.”
Are All Employees Who Work for Veterans Service Organizations
Also Accredited Representatives?
Not al employees who work for veterans service organizations (VSOs) are accredited
representatives. See “Do Veterans Service Organizations Provide Access to Accredited
Representatives?” for more details.
Can a Non-Veterans Affairs-Accredited Attorney Represent
Claimants?
A nonaccredited attorney may not represent veterans before VA. See 38 C.F.R. §14.629(b)(1),
which states: “No individual may assist claimants in the preparation, presentation, and
prosecution of claims for VA benefits as an agent or attorney unless he or she has first been
accredited by VA for such purpose.”
Can an Accredited Representative Charge a Fee?
Accredited representatives who work for recognized VSOs are prohibited from charging or
collecting any type of fee.6
Accredited agents and attorneys not working for a recognized VSO may charge fees for their
services under certain conditions:
 No agent or attorney can charge a fee until VA issues an initial decision on a
claim.
 A fee may be charged only after the agency of original jurisdiction has made an
initial decision.
 The fee must be agreed to in writing by the claimant and submitted to a VA
Veterans Benefits Administration Regional Office.7
Where Can I Find a List of Accredited Representatives?
VA’s OGC provides an online, searchable database of al accredited attorneys, agents, and VSO
representatives at https://www.va.gov/ogc/apps/accreditation/index.asp. The site also provides
access to complete lists of these accredited representatives, which can be downloaded from the
database.

5 18 U.S.C. §205(a)(2).
6 See 38 C.F.R. §14.636(b).
7 38 C.F.R. §14.636(f)(1) explains the fee structure.
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How Successful Are Accredited Representatives?
VA does not publish data on the success rates for initial claims for claimants who use accredited
representatives versus those who represent themselves. It is unclear, therefore, if claimants who
use an accredited representative from a VSO, a VA-accredited attorney, or a VA-accredited
independent agent are more successful than claimants who file without an accredited
representative.8
Becoming an Accredited Representative
Who Is Responsible for Accrediting Representatives?
VA’s OGC reviews al applications from individuals and VSO representatives who seek
accreditation. According to VA’s FY2021 Budget Submission, the OGC reviews, on average,
3,500 to 4,000 total applications per year.9 According to the OGC’s accredited representative
directory, as of June 23, 2020, there are approximately 8,080 accredited attorneys, 525 accredited
claim agents, and 9,705 VSO representatives.10
What Does It Mean to Be an Accredited Representative?
Accredited representatives have undergone approved training and are subject to oversight by
VA’s OGC. VA provides two paths to accreditation: (1) an agent or attorney submits an
application directly to VA’s OGC, or (2) a VSO-affiliated representative provides an application
to the appropriate VSO, which submits the application to VA’s OGC on the representative’s
behalf.
In both paths, the application must include evidence that the representative has successfully
completed VA-approved training and meets other guidelines.11 Appendix A lists the requirements
for VA accreditation for each type of representative.
VA’s OGC offers additional guidance on what accredited representatives can and cannot do:
VA accreditation is for the sole purpose of providing representation services to claimants
before VA and does not imply that a representative is qualified to provide financial
planning services or is otherwise endorsed by VA. VA accreditation may not be used for
marketing financial products or promoting a financial services business. Despite VA’s
efforts to ensure accredited individuals are responsible and qualified to provide

8 VA does, however, publish data in its Board of Veterans’ Appeals (BVA) annual reports regarding the success rates
for claims appealed to BVA. Each annual report includes a table showing the success rate for claimants’ appeals,
broken down by private VSOs (listed by name), state service organizations (in total), attorneys (in total), claims agents
(in total), and those without representation (in total). T he BVA posts its annual reports at VA, Board of Veterans’
Appeals, “T he Board of Veterans Appeals Annual Reports to Congress: 1991-2019,” at https://www.bva.va.gov/
Chairman_Annual_Rpts.asp.
9 VA, Office of Budget, FY2021 Budget Submission: Benefits and Burial Programs and Departmental Administration,
Volum e 3 of 4, February 2020, p. GenAD-305.
10 T he VA Office of General Counsel directory at https://www.va.gov/ogc/apps/accreditation/index.asp, allows users to
download the following: Complete Lists of Accredited Attorneys, Claims Agents, VSO Representatives, and names of
VSOs which provide VSO representatives. T his directory is refreshed every Monday, Wednesday, and Friday evening
and does not include those individuals who are in the m idst of the accreditation process.
11 U.S. Government Accountability Office (GAO), VA Benefits: Improvements Needed to Ensure Claimants Receive
Appropriate Representation, GAO-13-643, August 2013, p. 4, at https://www.gao.gov/assets/660/656500.pdf.
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Veterans Accredited Representatives: Frequently Asked Questions

representation on VA claims, claimants should exercise caution when selecting a
representative.12
What Training Do Accredited Representatives Receive?
Accredited representatives may receive training from multiple organizations. Some of these
include VA, recognized VSOs, and legal associations.
Training by Veterans Affairs
VA trains its staff and accredited representatives using the online Training, Responsibility,
Involvement, and Preparation of Claims (TRIP) Portal. The TRIP Portal is used to strengthen
“VA’s service to veterans and the timeliness of claims processing through a nationwide
partnership between VA and al recognized VSOs.” This online training program provides
recognized VSOs and accredited representatives with “essential claims processing policy and
procedure requirements,”13 including updated training on claims filing and processing for
accredited representatives. Both recognized VSOs and accredited representatives can coordinate
access with a Regional Office TRIP coordinator to create an account.14 The TRIP Portal is a VA-
based system, only for use by those who are VA-accredited through either a VSO training
program or a legal association’s VA-approved training.
Training by Veterans Service Organizations
VSOs may apply for VA recognition to provide training for representatives. To become
recognized, VSOs must show that they offer training programs to prepare their representatives to
qualify for accreditation.15 The training can take various forms—some organizations require
months of on-the-job training, others require a certain number of classroom hours, and others
hold one- or two-day workshops.16
Training by Legal Associations
The American Bar Association (ABA) and the National Veterans Legal Services Program
(NVLSP) provide training opportunities for attorneys and agents. ABA’s Veterans Claim
Assistance Network (VCAN) offers attorneys the opportunity to learn “how to obtain and
maintain VA accreditation, view webinars for VA accreditation, and locate organizations with pro
bono opportunities.”17 The webinars posted on the VCAN website also qualify for continuing
legal education (CLE) credits, which are part of the ongoing training requirement for accredited
representatives. One of NVLSP’s missions is “to train advocates in veterans’ law so that they can

12 VA, Office of General Counsel, “Accreditation and Discipline,” at https://www.va.gov/ogc/accreditation.asp.
13 VA, Office of Budget, FY2020 Budget Submission: Benefits and Burial Programs and Departmental Administration,
Volum e 3 of 4, 2019, p. VBA-170 (hereafter FY2020 VA Budget , Volume III).
14 See VA, Stakeholder Enterprise Portal (SEP), “SEP FAQs,” at https://www.sep.va.gov/web/guest/faq.
15 See 38 C.F.R. §14.628(d)(1)(v).
16 U.S. Congress, House Committee on Veterans’ Affairs, From The Inside Out: A Look at Claims Representatives’
Role in The Disability Claim s Process, 112th Cong., 2nd sess., April 18, 2012 (Washington DC: GPO, 2013) , at
https://www.govinfo.gov/content/pkg/CHRG-112hhrg74176/pdf/CHRG-112hhrg74176.pdf.
17 See American Bar Association, “ABA Veterans Claims Assistance Network,” at https://www.americanbar.org/
groups/legal_services/milvets/aba_home_front/Military_Pro_Bono/aba-veterans-claims-and-assistance-network/.
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Veterans Accredited Representatives: Frequently Asked Questions

efficiently help veterans secure benefits.”18 NVLSP’s programs are conducted through webinars,
in-person classes, or online.
How Often Must Accredited Representatives Undergo Training?
The frequency of ongoing training required for accredited representatives varies. VSOs may set
the frequency of training for their members and must demonstrate to VA that the accredited
individuals have the knowledge and ability to represent claimants. At least once every five years,
VSOs must recertify that their training prepares individuals to represent claimants.
Accredited attorneys and agents must complete a minimum of three hours of CLE within the first
12 months after their accreditation. In addition, agents must successfully pass a written exam
administered by VA. Within the first three years following initial accreditation and every two
years thereafter, attorneys and agents must complete an additional three hours of CLE on
veterans’ benefit law and procedure.
Complaints and Penalties
Who Monitors Accredited Representatives?
VA’s OGC, in coordination with the Federal Trade Commission (FTC), monitors accredited
representatives.19
How Does a Claimant File a Complaint Against an Accredited
Representative?
Veterans, dependents, and survivors may file a complaint against any accredited representative.
VA provides two ways to file a complaint. First, a claimant may submit a complaint through the
FTC’s web-based Complaint Assistant. The FTC is to relay the complaint to VA’s OGC.20
Second, a claimant may submit VA Form 3288,21 along with a written explanation of the
complaint, directly to VA’s OGC.
To streamline this process, the OGC and the FTC signed an information-sharing Memorandum of
Agreement in November 2018 to place a direct link to FTC’s complaint page on the OGC’s
website. These complaints are added to the FTC’s “Sentinel” database, which provides
federal, state, and local law enforcement agencies access to consumer complaints.22

18 See National Veterans Legal Services Program, “What We Do,” at https://www.nvlsp.org/what-we-do/training.
19 T he OGC explained in VA’s FY2020 Budget Submission that it is continuing to coordinate with the Federal T rade
Commission (FT C) to increase oversight and enforcement activities in addressing complaints regarding VA-accredited
claims representatives. FY2020 VA Budget , Volume III, pp. GenAD-296-297.
20 FT C, “FT C Complaint Assistant,” available at https://www.ftccomplaintassistant.gov.
21 VA Form 3288, Request for and Consent to Release of Information from Individual’s Records, is available at
https://www.va.gov/vaforms/va/pdf/VA3288.pdf.
22 T he Memorandum of Agreement can be found at FT C, Memorandum of Agreement Between the Federal Trade
Com m ission and the Departm ent of Veterans Affairs, at https://www.ftc.gov/system/files/documents/
cooperation_agreements/ftc-va_memorandum_of_agreement_2018_1.pdf.
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Veterans Accredited Representatives: Frequently Asked Questions

Can Veterans Affairs Revoke a Representative’s Accreditation?
VA’s OGC may revoke a representative’s accreditation. The reasons and authority for the OGC to
revoke an accreditation are provided in 38 C.F.R. §14.633(b) and (c). For accredited
representatives who are attorneys, one such reason for revocation is if he or she becomes
disbarred or suspended by a court, bar, or federal or state agency. In addition, 38 C.F.R.
§14.633(a) permits an organization to request that VA suspend or revoke one of their
representative’s accreditation.
How Does Veterans Affairs (VA) Address Accredited
Representatives Who Violate VA or Its Statutory Requirements?
VA is authorized by 38 U.S.C. §5904(b) to suspend or exclude from any further practice
accredited attorneys or agents who violate certain practices established by VA, such as failing to
meet VA’s CLE requirements or engaging in activities that would statutorily suspend those
representatives. The OGC recently revoked the accreditation of more than 1,000 attorneys for
failing to meet VA’s CLE requirements.23 In addition, the OGC estimated that 60% of accredited
attorneys were not in compliance with their CLE requirements. The OGC sent out Intent-to-
Cancel letters requiring proof of CLE completion within 30 days or risk suspension of VA
accreditation.24 Activities that could disqualify an accredited representative from practicing or
appearing before any federal agency could include being involved in unlawful, unprofessional, or
dishonest practices or being suspended or disbarred by any court or bar. In addition, if an
accredited representative wrongly withholds part of a claimant’s benefits award, he or she could
face criminal charges resulting in a fine or possible imprisonment.25
VA’s OGC may also cancel accreditation for VSO representatives who present a fraudulent claim
or accept compensation. A VSO can also ask VA to rescind accreditation for one of its
representatives.26
What Can Claimants Do If They Believe They Were Represented by
an Individual Who Falsely Claimed to Be an Accredited
Representative?
Claimants should file a complaint through the FTC’s web-based Complaint Assistant. The FTC
wil forward the complaint to VA’s OGC, which wil investigate and take action. Other federal or
state law enforcement authorities may also launch investigations, depending on the nature of the
complaint.27

23 FY2020 VA Budget, Volume III, pp. GenAD-296.
24 VA, Office of Budget, FY2021 Budget Submission: Benefits and Burial Programs and Departmental Admin istration,
Volum e 3 of 4, 2020, p. GenAd-311.
25 T he penalty for this type of action is defined by 38 U.S.C. §5905, which states that an individual “shall be fined as
provided in T itle 18, or imprisoned not more than one year, or both.” S. 2407, introduced in the 116th Congress, would
expand the penalty to include those who act as agents or attorneys for veterans but are not accredited.
26 GAO, VA Benefits: Improvements Needed to Ensure Claimants Receive Appropriate Representation, GAO-13-643,
August 2013, p. 6, at https://www.gao.gov/assets/660/656500.pdf.
27 See FT C, FT C Complaint Assistant, at https://www.ftccomplaintassistant.gov/Information?OrgCode=
USVABLGhttps://www.ftccomplaintassistant.gov/Information?OrgCode=USVABLG#crnt&panel1-1.
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Veterans Service Organizations and Accredited
Representatives
What Is the Difference Between a Veterans Service Organization
and an Accredited Representative?
VSOs are organizations that serve and advocate for veterans. In contrast, accredited
representatives are individuals who represent claimants before VA.
For more information on VSOs, see CRS Report R46412, Veterans Service Organizations
(VSOs): Frequently Asked Questions.
Do Veterans Service Organizations Provide Access to Accredited
Representatives?
Not al VSOs provide access to accredited representatives. Only VSOs recognized by VA may
provide accredited representatives.
Can a Claimant Use an Accredited Independent Agent, Attorney, or
State or County Veterans Service Organization Representative from
Outside the Claimant’s County or State of Residence?
Claimants may consult their state or county veterans office to determine whether they may hire a
state or county VSO representative from outside their county of residence. Many state veterans
offices provide a list of county VSOs that can serve veterans in those counties. In addition,
national VSOs may have internal rules governing who may represent claimants in certain states or
counties. To access accredited agents and attorneys, claimants can ask the individual agent or
attorney about restrictions in their jurisdiction. However, most attorneys authorized to practice
before VA may represent any claimant before the agency, regardless of where the claimant lives.
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Appendix A. Veterans Affairs Accreditation
Requirements
Table A-1. Veterans Affairs (VA) Requirements for Accreditation

VSO Representativesa
Attorneys
Agents
Description
Representative means a
Attorney means a member
Agent means a person who is
person who has been
in good standing of a state not an attorney and has met
recommended by a
bar who has met the
the standards and
recognized organization
standards and
qualifications outlined in
and accredited by VA’s
qualifications in 38 C.F.R.
38 C.F.R. §14.629(b).
Office of General
§14.629(b).
Counsel. Veterans
Service Organization
(VSO) representatives
must meet the standards
and qualifications in
38 C.F.R. §14.629(a).
Application
VA Form 21 (each state,
VA Form 21ac
VA Form 21ac
tribal, regional, or local
organization must
complete the form, and
each individual
representative of a
national VSO must
complete the form).b
Individual
Be of good character and
Be of good character and
Be of good character and
Qualificationsd
reputation. Provide
reputation. Provide
reputation. Provide
competent and prompt
competent and prompt
competent and prompt
representation. Be a
representation. Be in
representation. Provide
member in good standing
good standing with state
character references &
or a paid employee
bar association. Provide
details for background
working more than 1,000
character references &
check. VA makes affirmative
hours annual y. Cannot
details for background
determination of character.
be a federal employee.e
check. Cannot be a
Cannot be a federal
federal employee.e
employee.e
Initial Training
VSO certifies an
Complete three hours of
Complete three hours of
individual has
qualifying continuing legal
qualifying CLE within 12
demonstrated the ability
education (CLE) within 12 months and pass a written
to represent claimants
months.
exam administered by VA.
before VA.
Ongoing Training
VSO must recertify
Complete three hours of
Complete three hours of
representatives’ ability to
qualifying CLE on
qualifying CLE on veterans’
represent claimants every
veterans’ benefits law and
benefits law and procedure
five years.
procedure no more than
no more than three years
three years after initial
after initial accreditation and
accreditation and every
every two years thereafter.
two years thereafter.
Fees Charged to Client
Prohibited
May charge “reasonable
May charge “reasonable
fees.”f
fees.”f
Source: Congressional Research Service (CRS), compiled from the Code of Federal Regulations, U.S. Code, and VA
publications.
Notes:
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Veterans Accredited Representatives: Frequently Asked Questions

a. 38 C.F.R. §14.628 defines and explains the criteria for a national, state, tribal, regional, or local organization
to be recognized by VA.
b. VA Form 21, Application for Accreditation as Service Organization Representative, can be found at
https://www.va.gov/vaforms/va/pdf/VA21.pdf.
c. VA Form 21a, Application for Accreditation as a Claims Agent or Attorney Service Organization Representative, can
be found at https://www.va.gov/vaforms/va/pdf/VA21a.pdf.
d. 38 U.S.C. §5901-5905; 38 C.F.R. §§14.626-14.637.
e. 38 C.F.R. §14.629(a)(3).
f.
38 C.F.R. §14.636.
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Appendix B. Glossary of Abbreviations
Table B-1. Glossary of Abbreviations Related to Accredited Representatives
Acronym
Entity
BVA
Board of Veterans’ Appeals
CLE
Continuing Legal Education
FTC
Federal Trade Commission
OGC
Office of General Counsel
TRIP
Training, Responsibility, Involvement, and Preparation
of Claims Portal
VA
Department of Veterans Affairs
VBA
Veterans Benefits Administration
VSO
Veterans Service Organization
WINGMAN
Working to Integrate Networks Guaranteeing Member
Access Now Act
Source: Compiled by CRS.

Author Information

Heather M. Salazar
Tamar B. Breslauer
Analyst in Veterans Policy
Research Librarian

Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
shared staff to congressional committees and Members of Congress. It operates solely at the behest of and
under the direction of Congress. Information in a CRS Report should n ot be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not
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