2001 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) financial policies regarding Judgment Fund liabilities and reimbursements.

Key points covered in this chapter:

  • VA will comply with 31 U.S.C. §1304, Judgments, Awards, and Compromise Settlements, which authorizes payments from the Judgment Fund to eliminate the procedural burdens involved in receiving an appropriation from Congress to pay a particular judgment, resulting in the prompt payments of judicial awards;
  • VA will reimburse the Judgment Fund for payments made pursuant to the Contract Disputes Act (CDA) and the Notification and Federal Employees Antidiscrimination and Retaliation (No FEAR) Act of 2002, and properly account for these reimbursements;
  • VA will record a contingent liability on the Department’s financial statements for unresolved claims if the Office of General Counsel (OGC) has determined that a loss related to the claim is probable and the amount is measurable; and.
  • VA will disclose unresolved claims in the Department’s financial statements if OGC has determined that the claim is reasonably possible to end in loss.

2002 Revisions

SectionRevisionOfficeReason for ChangeEffective Date
200502Removed contingent liability guidance covered in Vol VI Ch.21OFP (047G)To eliminate redundancy in policyMarch 2024
2006Added Vol VI Ch. 21 – Contingent LiabilitiesOFP (047G)Reference for contingent liability guidanceMarch 2024
VariousCompleted full policy reviewOFP (047G)To reflect current legislation and processesAugust 2023
2003Definitions  OFP (047G)For consistency with other policy chapters and to align with FARAugust 2023
2004Roles and ResponsibilitiesOFP (047G)To reflect current dutiesAugust 2023
2005PoliciesOFP (047G)To ensure policy reflects current guidanceAugust 2023
2006Authorities and ReferencesOFP (047G)To reflect current authorities and referencesAugust 2023
VariousReformatted to new policy format and completed 5-year reviewOFP (047G)  Reorganized chapter layoutMay 2018
VariousIncorporated Judgment Fund Reimbursement chapter (Vol III, Ch 11) into Judgment Fund Liabilities chapterOFP (047G)  Reorganized Financial Policy chaptersMay 2018
2004FSC is assigned responsibility of accounting for Judgment Fund liabilities, reimbursements, and oversight of VA reimbursements to TreasuryOFP (047G)      New assignmentMay 2018
2005Enhanced policy for reimbursementsOFP (047G)  For clarificationMay 2018
Appendix BAdded sample reimbursement planOFP (047G)For clarificationMay 2018

2003 Definitions

Budget Object Class (BOC) Codes – Categories in a classification system that present obligations by the items or services purchased by the Federal Government.

Claim – Legal actions taken by an individual or company against the government.

Civilian Board of Contract Appeals (CBCA) – Pursuant to section 847 of the National Defense Authorization Act for Fiscal Year 2006, the CBCA was established on January 6, 2007, to hear and decide contract disputes between government contractors and civilian executive agencies under the provisions of the Contract Disputes Act, 41 U.S.C. §§ 7101-7109 (CDA).

Contract Disputes Act (CDA) Claim – A written demand or written assertion by one of the contracting parties seeking, as a matter of right, the payment of money in a sum certain, the adjustment or interpretation of contract terms, or other relief arising under or relating to the contract.

Compromise – The settlement or forgiveness of part or all of a debt under 31 U.S.C. § 3711, in accordance with standards set forth in the Federal Claims Collection Standards and applicable Federal law.

Contingent Liability – A liability that is both probable and measurable, when a past transaction or event has occurred representing a possible future outflow or other sacrifice of resources that is recognized for financial statement reporting purposes.

Cost Center – A mechanism (data element) used to accumulate costs incurred by area of responsibility or geographic region. Cost centers are represented by a four-to-six-digit code used to identify organizational elements throughout VA, e.g., 301000, [Veterans Benefits Administration (VBA)] Executive Director. The cost center field only relates to Administrations and Staff Offices that utilize FMS. iFAMS contains a non-ACS field for the FMS cost center (does not impact the iFAMS ACS or iFAMS GL).

Division Code – Classifies financial transactions by the entities responsible for managing resources and carrying out the programs and activities of the Federal Government. The Division Code represents the top level of the hierarchical structure in iFAMS, followed by the Organization Code.

Exchange Transaction A transaction in which each party to the transaction sacrifices value and receives value in return.

Federal Tort Claims Act (FTCA) –Individuals who are injured or whose property is damaged by the wrongful or negligent act of a federal employee acting in the scope of his or her official duties may file a claim with the government for reimbursement for that injury or damage.

Judgment Fund – A permanent, indefinite appropriation which is available to pay certain judicially and administratively ordered monetary awards against the United States, as well as amounts owed under compromise agreements negotiated by the U.S. Department of Justice (DOJ) in settlement of claims arising under actual or imminent litigation.

Judgment Fund Internet Claims System (JFICS) – The web-based application used to process all Judgement Fund claims.

Imputed Financing Sources – The financing of costs by one Federal entity on behalf of another Federal entity (e.g., expenses relating to legal claims such as those paid by the Treasury Judgment Fund).

Legal Liability Representation Letter (LRL) – The primary form of communication between VA’s General Counsel and VA’s auditor, covering all litigation, claims, and assessments pertaining to VA. It includes matters handled by VA Counsel or DOJ or any other outside legal counsel on behalf of VA.

Liability – The future outflow or other sacrifice of resources as a result of past transactions or events.

Measurable – Reasonably estimable.

No FEAR Act Claims – Claims made by employees, former employees, or applicants for Federal employment arising from violations of Federal antidiscrimination laws, Federal whistleblower protection laws and/or retaliation claims arising from the assertion of rights under those laws.

Obligation – A legally binding agreement that will result in outlays, immediately or in the future.

Organization Code – Classifies financial transactions by the entities responsible for managing resources and carrying out the programs and activities of the federal government. The organization code represents the lower levels of the hierarchical structure below the Division Code in iFAMS.

Responsible Agency – The responsible agency for litigated awards will be the agency responsible for defending the United States in court. In accordance with 31 C.F.R. §256.10, the responsible agency for administrative awards, is the agency authorized to settle the claim.

Treasury Offset Program (TOP) – A centralized offset program, administered by the Bureau of the Fiscal Service’s Debt Management Services (DMS), to collect delinquent debts owed to Federal agencies and in accordance with applicable laws.

2004 Roles and Responsibilities

Secretary of VA (SECVA) is delegated authority to adjust, determine, compromise, and settle a claim involving the Department of Veterans Affairs under 28 U.S.C. §2672, relating to the administrative settlement of Federal tort claims, if the amount of the proposed adjustment, compromise, or award does not exceed $500,000.

Under Secretaries, Assistant Secretaries, and Other Key Officials are responsible for ensuring compliance with the policies set forth in this chapter.

Chief Financial Officers, Fiscal Officers, Chiefs of Finance Activities, and Chief Accountants are responsible for devising a cost allocation methodology for the eventual allocation of any unfunded Judgment Fund expense to their respective stations, services, and product lines.

Office of Management, Office of Budget is responsible for requesting budgetary resources necessary to reimburse the Judgment Fund while considering all VA funding needs.

Office of Financial Reporting (OFR) is responsible for financial statement reporting and disclosure of contingent liabilities for judgment fund claims likely to result in a loss.

Financial Services Center (FSC) is responsible for recording transactions to properly account for Judgment Fund liabilities and expenses, and for oversight of all VA Judgment Fund reimbursement activities.

Office of General Counsel (OGC) is responsible for legal issues related to CDA claims brought before the CBCA and No FEAR claims brought in an administrative forum. OGC provides the information necessary to record contingent liabilities and prepares the Legal Liability Representation Letter for the financial statement audit. OGC is also responsible for requesting Judgment Fund payments from Treasury and providing claim information to FSC when payments are requested. Additionally, OGC coordinates with the Department of Justice (DOJ) on legal issues for VA related to No FEAR Act claims and CDA claims litigated before the United States Court of Federal Claims.

Contracting Officers are responsible for documenting the contract file with evidence of the date of receipt of any submission from the contractor deemed to be a claim by the contracting officer and for providing a written decision on the claim.

2005 Policies

200501 General Claim Information

  1. In support of the Paperwork Reduction Act, as of August 1, 2020, Judgment Fund claims may only be submitted electronically via the Judgment Fund Internet Claims System (JFICS) must include all required documentation and/or FS Form 197, Judgment Fund Voucher for Payment, if applicable. Refer to the Judgment Fund electronic filing website for FS Form 197.
  2. OGC will manage a variety of claims arising from the Department’s mission, which may be adjudicated before the Agency Boards of Contract Appeals, United States District Courts, or the United States Court of Appeals for the Federal Circuit. These claims can result from medical torts and appeals, contract disputes, labor relations matters, and other administrative functions.
  3. The SECVA has been delegated the authority to adjust, determine, compromise, and settle a claim involving the Department of Veterans Affairs, as the responsible agency under 28 U.S.C. § 2672, relating to the administrative settlement of Federal tort claims if the amount of the proposed adjustment, compromise, or award does not exceed $500,000.
  4. When SECVA settles any administrative claim for an amount greater than or equal to $200,000 but less than or equal to $500,000, a memorandum fully explaining the basis for the action taken shall be executed. A copy of this memorandum will be sent to the Director, Federal Torts Claims Act (FTCA) Staff, Torts Branch of the Civil Division.
  5. Any claims asserted under the Federal Tort Claims Act that result in an award, compromise, or settlement in excess of $500,000, shall be effected only with the prior written approval of the Attorney General or his or her designee.
  6. For contract disputes, a voucher, invoice, or other routine request for payment that is not in dispute when submitted, is not a claim. The submission may be converted to a claim, by written notice to VA’s contracting officer as provided in 48 C.F.R. § 33.206(a) if it is disputed either as to liability or amount or is not acted upon in a reasonable time.
  7. A written demand or written assertion by the contractor seeking the payment of money exceeding $100,000 is not a claim under 41 U.S.C. chapter 71, Contract Disputes, until certified as required by the statute.
  8. In accordance with 41 U.S.C. §§ 7101-7109, the CBCA will hear and decide contract disputes between government contractors and VA.
  9. OGC may handle discrimination claims in the administrative setting, which are reportable to Congress pursuant to Judgment Fund requirements and the No Fear Act. However, when VA discrimination claims end up in federal court, DOJ attorneys will take over representation of VA. If amounts are payable, VA will report all such discrimination payments to Congress.
  10. When a legal claim is filed against the VA, or there is knowledge of an unasserted claim against VA, OGC will work with the VA organization where the claim arose to determine the likelihood that VA will incur a loss related to the claim.
  11. The OGC categorization of claims will be used by VA to categorize legal liabilities in the legal representation letter and financial statements.

200502 Accounting for Contingent Liabilities

  1. VA will account for Judgment Fund payments in accordance with FASAB’s Interpretation of Federal Financial Accounting Standards (SFFAS) 2, 4 and 5.
  2. OGC will categorize claims in accordance with SFFAS 5:
    • Probable: The future confirming event or events are more likely than not to occur, with the exception of pending or threatened litigation and unasserted claims. For pending or threatened litigation and unasserted claims, the future confirming event or events of pending or threatened litigation and unasserted claims are likely to occur;
    • Reasonably possible: The chance of the future confirming event or events occurring is more than remote but less than probable; or
    • Remote: The chance of the future event or events occurring is slight.
  3. In accordance with SFFAS 5, VA will estimate contingent liabilities for Judgment Fund and FTCA claims and present the estimate in the financial statements and related disclosures. Specifically, when OGC has determined that a loss is:
    • Probable and can be estimated, VA will record a contingent liability and expense for the full amount of the expected loss; or
    • Reasonably possible to end in loss and can be estimated, VA will disclose the unresolved claim in the Department’s notes to the financial statements.
  4. VA will remove the contingent liability from the accounting system and financial statements when a settlement becomes final, or a court judgment is issued.
  5. See Volume VI Chapter 21, for a complete discussion on identifying, accounting for and reporting of contingent liabilities.

200503 Judgment Fund Reimbursements

  1. In accordance with 31 C.F.R. 256 (CDA) and 31 C.F.R. 256.41 (No FEAR Act), Federal agencies must reimburse the Judgment Fund for payments made on their behalf.
  2. To inform the reimbursement process within VA, OGC must send a copy of all Judgment Fund payment requests and related documentation to the FSC upon submission to Treasury.
  3. VA organizations should immediately notify FSC if they receive a reimbursement demand directly from Treasury. Reimbursement demands usually are made by Treasury within 15 days of payment of a No FEAR Act claim, or 30 days of payment of a CDA claim.  
  4. Upon receipt of a demand for reimbursement from Treasury, VA has 45 business days to reimburse the Judgment Fund or contact Treasury’s Judgment Fund Branch to make written arrangements for reimbursement. An agency is considered noncompliant with the reimbursement provisions of the No FEAR Act if it fails to reimburse or make timely arrangements for reimbursement, 5 CFR § 724.104. FSC will ensure the timely reimbursement of the Judgement Fund.
  5. FSC will notify the responsible VA organization within three business days of receiving a demand for reimbursement from Treasury for payment of a claim made on their behalf.
  6. Within five business days the responsible organization must confirm responsibility to FSC or provide justification on why the office is not responsible for the reimbursement.
  7. Organizations responsible for reimbursement will in conjunction with their fiscal office review budgetary resources to determine available funding for making the reimbursement payment. Reimbursement plans must include a statement that additional funds are needed from Congress. See Appendix B for a sample reimbursement plan.
  8. The responsible VA organization will determine if reimbursement may be paid in full or partially within the 45-day timeframe. If a reimbursement (partial or in full) will be made to Treasury, the organization will prepare the interagency obligation (on a 1358 obligation request in FMS or a standard voucher (SBL) in iFAMS) and send the obligation information to FSC for processing.
  9. FSC will utilize the Intergovernmental Payment and Collection (IPAC) system to effectuate payment to Treasury, recording the expenditure against the appropriate obligation. Payment should be completed by the deadline established via the Treasury notification.
  10. If the reimbursement to the Judgment Fund cannot be made in full, a written reimbursement plan must be submitted to Treasury. The reimbursement plan should be provided to Treasury by the deadline established via the Treasury notification.
  11. FSC will maintain documentation regarding reimbursement plans, reimbursements and Treasury’s acceptance of a reimbursement or reimbursement plan.
  12. The Office of Budget will, as part of the normal budget formulation process, work with the Office of Management and Budget (OMB) to specifically identify requests to repay the Judgment Fund, this funding request will be included in Volume 4 of the annual Congressional Budget Submission.

200504 Requesting Payments from the Judgment Fund

  1. In accordance with 31 C.F.R. § 256.10, court judgments and compromise settlements defended by the DOJ must be paid from the Judgment Fund appropriation regardless of amount. DOJ will normally submit the request for payment from the Judgment Fund.
  2. For cases that are not handled by the DOJ, VA may request the payment of a claim on its behalf from the Judgment Fund if funds are not legally available from VA’s appropriations.
  3. Unless otherwise provided by law, VA operating appropriations are not available to pay judgments or settlements.  See Funding of State Department Settlements of Foreign Tort Claims, 21 U.S. Op. Off. Legal Counsel 102 (1997).  When VA has specific and express statutory authority to pay judgments and settlements out of its own funds, judgments are payable out of those funds rather than the Judgment Fund. 
  4. In accordance with 31 U.S.C. §1304(a)(3)(C), cases resulting in CBCA issuing a judgment (ruling or consent judgment), the Judgment Fund must be used. VA OGC will have represented the agency in those cases.
  5. Settlements that arise out of CBCA cases do not get paid from the Judgment Fund unless the parties ask the Judge to issue a consent judgment or entry of award, thus allowing the Judgement Fund to be used. See 31 U.S.C. § 1304(a)(3)(C).
  6. As not all adverse judgments must be paid from the Judgment Fund, OGC will determine if the Judgment Fund is required to pay the final monetary award or settlement. VA will not request payments from the Judgment Fund for:
    • Government life insurance adverse judgments under 38 U.S.C. Chapter 19 as VA has the authority to pay these from insurance trust funds or other VA appropriations, as  applicable;
    • Attorney fees or litigation costs awarded to a complainant who substantially prevails in Freedom of Information Act (FOIA) litigation because the OPEN Government Act of 2007, Public Law 110-175, section 4(b), requires that each Federal agency pay such fees and costs from “funds annually appropriated” for the Federal agency;
    • VA settles a CBCA case during litigation but does not obtain a consent judgment or entry of award from the CBCA judge;
    • Administrative awards of $2,500 or less on claims under the FTCA;
    • Administrative awards under the Military Personnel and Civilian Employees Claims Act; and
    • Administrative awards on tort claims arising in foreign countries under 38 U.S.C.§515 (b).
  7. A tort under the FTCA is payable from the Judgment Fund only when the award amount exceeds $2,500 (for administrative awards) and is in compliance with 28 C.F.R. Part 14, Administrative Claims Under the FTCA.
  8. In order for a valid claim to be asserted under the FTCA:
    • The claimant must demonstrate that injury or loss occurred, or claimant’s property was damaged by a federal government employee;
    • The employee was acting within the scope of his official duties;
    • The employee was acting negligently or wrongfully; and
    • The negligent or wrongful act proximately caused the injury or damage of the claimant.
    • The claimant must also provide documentation establishing that his claim satisfies all the elements of the FTCA.
  9. Under the FTCA, the federal government acts as a self-insurer and recognizes liability for the negligent or wrongful acts or omissions of its employees acting within the scope of their official duties. The United States is liable to the same extent an individual would be in like circumstances. The statute substitutes the United States as the defendant in such a suit and the United States not the individual employee bears any resulting liability.
  10. Medical malpractice claims are filed under the FTCA, and losses are paid from the judgement fund. These losses are not required to be reimbursed.
  11. OGC will submit a payment request to Treasury in accordance with the Treasury Financial Manual (TFM), Volume I, Part 6, which requires:
    • Submitting at a minimum, documentation identifying the statute that forms the basis for the claim and the settlement agreement or judgment. For more information on documentation requirements see 31 C.F.R. §256.12;
    • Submitting a request electronically through JFICS. See the Judgment Fund website for additional information; and
    • A valid taxpayer identification number (TIN), unless the situation meets one of the exceptions found on the Treasury website.
  12. VA will identify any known debt owed to the United States that Treasury is expected to collect by offset against the award.
  13. Bureau of the Fiscal Service certifies the following prior to Treasury issuing payment:
    • Awards or settlements are final;
    • Awards or settlements are monetary;
    • Payment of the award or settlement is authorized in 31 U.S.C. §1304(a)(3); and
    • Payment may not legally be made from any other source of funds.
  14. In accordance with 26 U.S.C. §6331, Treasury, in its capacity as disbursing official for the executive branch, will collect delinquent, non-tax Federal debts by automatically offsetting the debt from the payment if VA notifies Treasury of a debt; for which a court has issued a judgment against a debtor in favor of the United States or for which the IRS has issued a tax levy. Refer to Volume XII, Debt Management, for more information on VA’s financial policies for debt collection through Treasury.

200505 Recording Judgement Fund Reimbursement Requests

  1. VA will record judgment fund reimbursement requests in accordance with:
    • Interpretation of Federal Financial Accounting Standards, Interpretation 2: Accounting for Treasury Judgment Fund Transactions: An Interpretation of SFFAS 4, SFFAS 5; and
    • TFM Volume I, Part 6, Chapter 3100.
  2. Quarterly, Treasury will post outstanding receivables and revenue collected for both CDA and No FEAR Act payments on its websites, Report of Receivables from Contract Disputes and Report of Receivables from the No FEAR Act and will send FSC a confirmation notice reflecting outstanding receivables and revenue which VA must confirm:
    • With 30 calendar days from the end of the quarter; or
    • By October 24 of the calendar year for the year-end statement.
  3. FSC will compare CDA and No Fear reports provided by Treasury to the liability balance recorded in VA’s Accounting System and make adjusting entries as appropriate.
    1. FSC will record or adjust the amount owed to Treasury in the Assets and Miscellaneous Accounts Fund (AMAF) in FMS using SGL 2110.
    2. Adjusting entries  are posted in the accounting system if the report arrives before quarter-end, if the report arrives after quarter-end the entries will be recorded in MinX.
  4. FSC will record all new reimbursement requests as an expense in SGL 6100 (Operating Expense/Program Costs) and a liability in SGL 2114 (Account Payable – Federal (Non-Detail)) or record an accrued liability in SGL 2921 (Judgement Fund Reimbursable Liability) and future-funded expense in SGL 6803 (Judgement Fund, Future Funded Expense)  if VA does not have  available funds and is seeking a supplemental appropriation or is pursuing a payment plan with Treasury. See Appendix A below for example accounting entries.
  5. FSC will reduce the liability to Treasury and its fund balance with Treasury when VA reimburses the Judgment Fund.
  6. FSC will provide oversight of the use of the appropriate Judgment Fund BOC for reimbursements.
  7. In accordance with OMB Circular A-136, VA will distinguish between intragovernmental liabilities not covered by budgetary resources from other liabilities not covered by budgetary resources. VA will provide other information needed in the notes of the financial statements to understand the nature of liabilities not covered by budgetary resources.
  8. VA may not write-off a Judgment Fund payable unless authorized by Congress. VA will remain liable for the full reimbursement amount of the Judgment Fund payment in accordance with both the CDA and No FEAR Act.

200506 Appropriated Funds for Reimbursements

  1. Funds to pay both CDA and No FEAR Act reimbursements to the Judgment Fund will come from the appropriation of the organization that was initially charged when the claim arose.
  2. The reimbursement will be prorated against appropriations if more than one appropriation is involved in the monetary judgment. Proration between or among appropriations will be based on the nature of the claim and the basis of the monetary judgment in the particular case.
  3. Each Administration’s CFO will devise a cost allocation methodology for the allocation of Judgment Fund payments to their respective stations, services, and product lines.
  4. VA may charge an appropriation account currently available for the same purpose as authorized by 31 U.S.C. §1553 if insufficient unobligated balances exist in the original appropriation or the appropriation account has closed. VA may also seek a supplemental appropriation from Congress as permitted by 41 U.S.C. §612. The supplemental appropriation request must be coordinated with the Office of Budget and OMB.

200507 Judgment Fund Reimbursement Oversight

  1. FSC will maintain oversight of all of VA’s reimbursements to the Judgment Fund, from notification by Treasury to full repayment.
  2. As a part of this oversight, FSC will:
    • Monitor VA Judgment Fund reimbursements and take actions necessary to ensure that reimbursement or written arrangements for reimbursement occur within 45 days as required by the CDA and the No FEAR Act of 2002.
    • Coordinate with the Office of Budget, as needed, to ensure that Treasury is reimbursed;
    • Track reimbursements to Treasury until all reimbursements are paid in full;
    • Calculate and post transactions for the annual Judgment Fund liabilities and expenses;
    • Promptly notify the Office of Management of any program office that fails to comply with the requirements of this policy; and
    • Submit a quarterly report to OGC on all settlement payments.
  3. VA will be listed on Treasury’s annual report of agencies which have failed to reimburse the Judgment Fund should VA become non-compliant by failing to reimburse or to make timely arrangements for reimbursement. VA will remain on this noncompliance list until it repays the Judgment Fund or makes written arrangements for reimbursement.

2006 Authorities and References

2007 Rescissions

Volume VI, Chapter 20 – Judgment Fund, dated August 10, 2023

2008 Policy Approval

This policy was approved by the VA Chief Finance Officer’s council on April 18, 2024.

Appendix A: Example Accounting Entries for Contingent Liabilities

  1. VA will determine the previous fiscal year’s Judgment Fund expenses for each VA Administration and Staff Office at the beginning of each fiscal year. VA will maintain a Judgment Fund liability account reflecting the total current estimates of all its probable legal claims and will record a contingent liability for the Judgment Fund in the Assets and Miscellaneous Accounts Fund (AMAF), Station Number 150. VA is required to record an operating expense and imputed financing source for the Judgment Fund’s pending claims and settlements.
    1. VA will obtain the advice of OGC to determine the probability that a legal claim will end in a loss to VA and that the loss is estimable.
    2. If the loss is probable and estimable, VA will recognize an expense and liability for the full amount of the expected loss. VA will make the following journal entry to record the expense and liability:
  2. Recognition of Other Financing Sources (From contingent liability to liability.)
    1. Once the Judgment Fund is determined to be the appropriate source for payment of the claim and the legal claim is either settled or a court judgment is assessed against VA, VA will remove the accrued liability for the claim from its accounting records and recognize the transaction as an actual liability.
    2. If the Judgment Fund is responsible for the claim or settlement, the imputed financing source amount would reflect only that amount to be paid by the Judgment Fund on behalf of VA.
Example Accounting Entries for Judgment Fund Transactions
Line of AccountingReimbursableNon-reimbursableNo Fear
or CDA
Portion of CDA
Imputed Portion

Appendix B: Sample Reimbursement Plan

Sample Reimbursement Plan