Hard bremsstrahlung produced during the deceleration of fission-product beta rays in nuclear fuel is proposed as a source of delayed photoneutrons (PNs) in heavy water reactors. Electron Gamma Shower (EGS5) code simulations of coupled electron-photon transport in seven fuel element geometries immersed in an infinite heavy water medium confirm high-energy beta rays produce sufficient bremsstrahlung yields with photon energies greater than the D(γ,n)1H reaction threshold such that the beta-ray contribution to an isotopic PN yield can be comparable to or greater than yields from hard gamma rays emitted during the isomeric transition of the daughter, especially for some short-lived fission products with high-intensity direct-to-ground-state beta transitions where the beta ray and antineutrino carry away the majority of the Q-value. Some fission products that do not have hard gamma rays in their decay schemes are in fact PN precursors due to the beta-ray-bremsstrahlung contribution. The lack of evaluated nuclear data for many short-lived fission products, data reliability issues of fission products with decay scheme data, cross-section library effects, and possible decay-chain/parent-feeding phenomenon are affecting the accuracy of PN group parameters derived from a small number of legacy experiments. The reanalysis of two legacy PN experiments supports the existence of a very-short-lived direct-delayed neutron group.