Veterans' Benefits
Improved Operational Controls and Management Data Would Enhance VBA's Disability Reevaluation Process Gao ID: GAO-08-75 December 6, 2007To help ensure that veterans are properly compensated for disabilities, VA is required to perform disability reevaluations for specific disabilities. VA also performs reevaluations whenever it determines there is a need to verify either the continued existence or current severity of veterans' disabilities. VBA completed about 17,700 reevaluations in fiscal year 2005. GAO was asked to review the Veterans Benefits Administration's (VBA) disability reevaluation program. This report assesses (1) the operational controls VA uses to ensure the effectiveness of the disability reevaluation process and (2) the management information VA collects and uses to manage the disability reevaluation process. To conduct this study, GAO analyzed VBA data, reviewed federal regulations and VBA procedures, conducted site visits, and interviewed VBA officials.
VBA's operational controls do not adequately ensure that staff schedule or conduct disability reevaluations as necessary; however, VBA is planning to improve some of the controls. VBA claims processing software does not automatically establish or prompt regional office staff to schedule a time - known as a diary date - to determine whether a disability reevaluation should proceed. Consequently, some cases that require a reevaluation may never receive it. After the diary date matures, staff perform a preliminary review of a veteran's claim file to determine if a more comprehensive reevaluation should be conducted. If staff determine during this review that a reevaluation is no longer needed, the reevaluation is cancelled. However, cancellations are not tracked or subject to quality assurance reviews to ensure adherence to program policies and procedures. VBA plans on improving some of its control mechanisms through its new claims management system, the Veterans Service Network (VETSNET), including developing the ability to track cancellations. However, VBA has no plans to include a prompt for scheduling reevaluation diary dates in VETSNET. VBA cannot effectively manage the disability reevaluation process because some of the data it collects are inconsistent and it does not systematically collect and analyze key management data. While VBA collects data on the amount of time regional offices take to conduct disability reevaluations, these data are not consistentbecause regional offices use different starting points for measuring timeliness. Also, VBA does not know the types of disabilities being reevaluated, the length of time before reevaluations are conducted, or the results of the reevaluations. As a result, VBA cannot ensure that it is effectively and appropriately using its resources.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-08-75, Veterans' Benefits: Improved Operational Controls and Management Data Would Enhance VBA's Disability Reevaluation Process
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
December 2007:
Veterans' Benefits:
Improved Operational Controls and Management Data Would Enhance VBA's
Disability Reevaluation Process:
GAO-08-75:
GAO Highlights:
Highlights of GAO-08-75, a report to congressional requesters.
Why GAO Did This Study:
To help ensure that veterans are properly compensated for disabilities,
VA is required to perform disability reevaluations for specific
disabilities. VA also performs reevaluations whenever it determines
there is a need to verify either the continued existence or current
severity of veterans‘ disabilities. VBA completed about 17,700
reevaluations in fiscal year 2005. GAO was asked to review the Veterans
Benefits Administration‘s (VBA) disability reevaluation program. This
report assesses (1) the operational controls VA uses to ensure the
effectiveness of the disability reevaluation process and (2) the
management information VA collects and uses to manage the disability
reevaluation process. To conduct this study, GAO analyzed VBA data,
reviewed federal regulations and VBA procedures, conducted site visits,
and interviewed VBA officials.
What GAO Found:
VBA‘s operational controls do not adequately ensure that staff schedule
or conduct disability reevaluations as necessary; however, VBA is
planning to improve some of the controls. VBA claims processing
software does not automatically establish or prompt regional office
staff to schedule a time – known as a diary date – to determine whether
a disability reevaluation should proceed. Consequently, some cases that
require a reevaluation may never receive it. After the diary date
matures, staff perform a preliminary review of a veteran‘s claim file
to determine if a more comprehensive reevaluation should be conducted.
If staff determine during this review that a reevaluation is no longer
needed, the reevaluation is canceled. However, cancellations are not
tracked or subject to quality assurance reviews to ensure adherence to
program policies and procedures. VBA plans on improving some of its
control mechanisms through its new claims management system, the
Veterans Service Network (VETSNET), including developing the ability to
track cancellations. However, VBA has no plans to include a prompt for
scheduling reevaluation diary dates in VETSNET.
VBA cannot effectively manage the disability reevaluation process
because some of the data it collects are inconsistent and it does not
systematically collect and analyze key management data. While VBA
collects data on the amount of time regional offices take to conduct
disability reevaluations, these data are not consistent because
regional offices use different starting points for measuring
timeliness. Also, VBA does not know the types of disabilities being
reevaluated, the length of time before reevaluations are conducted, or
the results of the reevaluations. As a result, VBA cannot ensure that
it is effectively and appropriately using its resources.
VBA Reevaluation Process with an Added Data Driven Feedback Component:
[See PDF for image]
This figure is a graphic illustration of the VBA Reevaluation Process
with an Added Data Driven Feedback Component. The illustration depicts
the following data:
Schedule a disability reevaluation diary date at time disability
compensation claim decided; Disability Reevaluation:
* Diary date matures;
* Regional office notified;
* RVSRs preliminary assessment;
* Cancel reevaluation or Conduct reevaluation; Increase, decrease, or
retain disability rating level.
Data-driven feedback component:
Beginning at the 'Increase, decrease, or retain disability rating
level' step listed above:
* Collect data on disability reevaluations, including results and
timing of reevaluations;
* Analyze data to aid decisions on selection and scheduling of
disability reevaluations;
* Develop guidance to improve decisions based on data analysis;
* continue on to 'Schedule a disability reevaluation diary date at time
disability compensation claim decided' step listed above.
What GAO Recommends:
GAO recommends that VA modify its electronic diary date system to
ensure that the appropriate reevaluations are scheduled to occur;
develop additional methods to ensure accuracy of completed and canceled
reevaluations; clarify its guidance so that all regional offices use
the same criteria for measuring the timeliness of reevaluations; and
develop a plan to collect and analyze data on the results of
reevaluations. VA concurred with our recommendations.
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-75].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Daniel Bertoni at (202)
512-7215 or bertonid@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
VBA's Operational Controls Do Not Ensure That Disability Reevaluations
Occur, but VBA Is Planning to Update Some of Its Processes and
Procedures:
VBA Lacks Adequate Program Information to Effectively Manage the
Disability Reevaluation Process:
Conclusions:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Veterans Affairs:
Appendix III: GAO Contact and Staff Acknowledgments:
Figures:
Figure 1: Summary of VBA's Disability Reevaluation Process:
Figure 2: VBA Disability Reevaluation Process with an Added Data Driven
Feedback Component:
Abbreviations:
BDN: Benefits Delivery Network:
RVSR: Rating Veterans Service Representative:
STAR: Systematic Technical Accuracy Review:
VA: Department of Veterans Affairs:
VBA: Veterans Benefits Administration:
VETSNET: Veterans Service Network:
[End of section]
United States Government Accountability Office: Washington, DC 20548:
December 6, 2007:
The Honorable Richard Burr:
Ranking Member:
Committee on Veterans' Affairs:
United States Senate:
The Honorable Larry E. Craig:
United States Senate:
In fiscal year 2006, the Department of Veterans Affairs (VA) paid about
$26.5 billion in cash benefits to approximately 2.7 million veterans to
compensate them for disabling medical conditions connected to injuries
or illnesses incurred or aggravated during active military service. To
help ensure that veterans are properly compensated for these service-
connected disabilities, VA is required to perform disability
reevaluations for specific disabilities. VA also performs disability
reevaluations whenever it determines there is a need to verify either
the continued existence or current severity of veterans' disabilities.
In fiscal year 2005 the Veterans Benefits Administration (VBA)
completed about 17,700 disability reevaluations. During this same time
period, VBA completed about 629,000 disability compensation claims.
At your request, we reviewed VBA's disability reevaluation program.
Specifically, we assessed (1) the operational controls VA uses to
ensure the effectiveness of the disability reevaluation process and (2)
the management information VA collects and uses to manage the
disability reevaluation process. To develop the information for this
report, we analyzed VBA workload and timeliness data and reviewed
federal regulations on disability reevaluations, VBA's written guidance
and training materials on reevaluations, and VBA's procedures for
conducting reevaluations. We discussed the procedures for ensuring that
reevaluations are conducted and the information used to manage the
reevaluation program with headquarters and regional office officials
and observed control procedures at 5 of VA's 57 regional offices. We
selected these five offices based on the number of reevaluations they
completed, the time it took to complete reevaluations, and geographic
dispersion. For more details on our scope and methodology, see appendix
I. We conducted our review from October 2006 through October 2007 in
accordance with generally accepted government auditing standards.
Results in Brief:
VBA's operational controls do not adequately ensure that the
administration is conducting reevaluations of veterans with
disabilities that are likely to change in the future; however, VA is
planning to improve some of the controls. VBA claims processing
software does not automatically establish or prompt regional office
staff to schedule a time--known as a diary date--to determine whether a
disability reevaluation should be conducted. To the extent that staff
do not enter a diary date, some cases that need reevaluations may never
be brought to the attention of claims processing staff. In fact, the VA
Office of Inspector General has found instances where this has
occurred. After a regional office is notified of a maturing diary date,
staff perform a preliminary assessment of the veteran's claim file to
determine if a more comprehensive reevaluation should be conducted.
According to VBA guidance, if staff determine during this assessment
that a reevaluation is no longer needed, the reevaluation is canceled.
For example, a reevaluation may be canceled if a veteran reopens their
claim because the disability has worsened. However, the number of
cancellations and their associated reasons are not tracked or subject
to quality assurance reviews. As a result, VBA does not know if
reevaluations are being canceled appropriately. Also, completed
reevaluations--which represent a small proportion of regional offices'
total disability compensation claims workload--are not likely to be
selected for quality assurance review due to VBA's methodology for
selecting cases. VBA plans on improving some of its control mechanisms
through its new claims management system, the Veterans Service Network
(VETSNET), including developing the ability to track cancellations.
However, VBA has no plans to include in VETSNET prompts for scheduling
disability reevaluations. VBA expects to complete the rollout of
VETSNET for disability compensation claims in May 2008.
VBA cannot effectively manage the disability reevaluation process
because some of the management data it collects are inconsistent and it
does not systematically collect and analyze other key management data.
While VBA does collect data on the amount of time regional offices take
to conduct disability reevaluations, regional offices use different
starting points for measuring timeliness. As a result, the amount of
time to complete a disability reevaluation may be undercounted for some
offices and overcounted for others. VBA also does not know the types of
disabilities being reevaluated, the length of time before reevaluations
are conducted, or if the reevaluation decisions result in an increase,
decrease, or no change in VBA's assessment of the severity of the
veteran's disability. Without such key management data, VBA cannot
ensure that it is effectively using its resources to reevaluate those
veterans with disabilities where reevaluation is mandated or whose
disabilities are likely to change, and that it is reevaluating those
disabilities at the appropriate point in time.
We are recommending that VBA (1) modify its electronic claims
processing system so that a rating decision cannot be completed without
staff completing the diary date field, (2) modify its electronic claims
processing system to ensure that a diary date is automatically
generated by the system for all disabilities where a reevaluation is
required by VA's Schedule for Rating Disabilities, (3) include canceled
reevaluations in its quality assurance reviews and evaluate the
feasibility of periodically sampling a larger number of completed
disability reevaluations for quality assurance, (4) clarify its
guidance so that all regional offices use the date they are notified of
a matured diary date as the starting point for measuring timeliness,
and (5) collect and analyze data on the results of disability
reevaluations in order to refine guidance on the selection and timing
of future disability reevaluations. In its comments on a draft of this
report, VA generally agreed with our conclusions and concurred with our
recommendations.
Background:
Through its disability compensation program, VBA pays monthly benefits
to veterans for injuries or diseases incurred or aggravated while on
active military duty. VBA rates such disabilities by using its Schedule
for Rating Disabilities.[Footnote 1] For each type of disability, the
Schedule assigns a percentage rating that is intended to represent the
average earning reduction a veteran with that condition would
experience in civilian occupations. Veterans are assigned a single or
combined (in cases of multiple disabilities) rating ranging from 0 to
100 percent, in increments of 10 percent. Basic monthly payments range
from $115 for a 10 percent disability to $2,471 for a 100 percent
disability. About 58 percent of veterans receiving disability
compensation have disabilities rated at 30 percent and lower; about 9
percent have disabilities rated at 100 percent. The most common
impairments for veterans who began receiving compensation in fiscal
year 2005 were, in order, hearing impairments, diabetes, post-traumatic
stress disorder, back-related injuries, and other musculoskeletal
conditions.[Footnote 2]
VA performs disability reevaluations for disabilities required by
regulation and whenever it determines that it is likely that a
disability has improved, or if evidence indicates there has been a
material change in a disability or that the current rating may be
incorrect. Federal regulations generally instruct VA to conduct
reevaluations between 2 and 5 years after any initial or subsequent VA
examination, except for disabilities where another time period is
specifically mentioned in the regulations. The latter generally require
a reexamination 6 or 12 months after the discontinuance of treatment or
hospitalization.
The reevaluation process starts when a VBA Rating Veterans Service
Representative (RVSR) completes a disability compensation claim and
determines whether the veteran should be reevaluated at some time in
the future. RVSRs base this decision on a number of factors. The
disability reevaluation may be mandated by the Schedule for Rating
Disabilities. For example, a veteran with a 100 percent disability
rating due to a heart valve replacement is required to be reevaluated 6
months after discharge from the hospital. Alternatively, the RVSR may
determine that the severity of the disability may change. For instance,
medical evidence may suggest that a veteran with limited range of
motion will be continuing physical rehabilitation and is expected to
improve. To ensure that the disability is reviewed in the future, the
RVSR enters a diary date into VBA's claims processing system, which
later generates a reminder that the disability needs to be reviewed.
When this reminder is generated, the veteran's file is retrieved and an
RVSR performs a preliminary assessment of whether a reevaluation should
be conducted. If the RVSR determines that a reevaluation is no longer
needed, the reevaluation is canceled. For example, staff may cancel a
reevaluation when a veteran dies or if the file is already being
reviewed by VBA following the veteran's claim that his disability has
worsened. If the RVSR determines that a reevaluation of the disability
should be conducted, the RVSR can simply review the information in the
file or, if needed, collect supplemental medical information which can
include the results of a physical examination. Once all of the
information has been analyzed, an RVSR can make a decision to increase,
decrease, or continue the current rating. Figure 1 summarizes the
disability reevaluation process.
Figure 1: Summary of VBA's Disability Reevaluation Process:
[See PDF for image]
This figure is a graphic illustration of the VBA Reevaluation Process.
The illustration depicts the following data:
Schedule a disability reevaluation diary date at time disability
compensation claim decided; Disability Reevaluation:
* Diary date matures;
* Regional office notified;
* RVSRs preliminary assessment;
* Cancel reevaluation or Conduct reevaluation; Increase, decrease, or
retain disability rating level.
Source: GAO.
[End of figure]
VBA maintains a quality assurance review program known as the
Systematic Technical Accuracy Review (STAR) program. VBA selects random
samples of each regional office's disability compensation decisions and
assesses the regional office's accuracy in processing and deciding such
cases. For each decision, the STAR quality review unit reviews the
documentation contained in the regional office's claim file to
determine, among other things, whether the regional office complied
with the Veterans Claims Assistance Act[Footnote 3] duty-to-assist
requirements for obtaining relevant records, made correct service
connection determinations for each claimed condition, and made correct
disability rating evaluations for each condition.[Footnote 4] VBA has a
fiscal year 2008 performance goal that 90 percent of compensation
decisions contain no errors that could affect decision outcomes; its
long-term strategic goal is 98 percent.[Footnote 5] In addition to
STAR, regional offices conduct their own local quality assurance
reviews. The guidance for these local quality assurance reviews calls
for reviewing a random sample of an average of five claims for each
RVSR, per month.
VA is currently projecting that it will fully implement a new
processing and benefits payment system--VETSNET, for their disability
compensation process in May 2008. VA anticipates that VETSNET will be
faster, more flexible, and have a higher capacity than VBA's aging
Benefits Delivery Network (BDN). For the past 40 years, BDN has been
used to process compensation and pension benefits payments to veterans
and their dependents each month. However, this system is based on
antiquated software programs that have become increasingly difficult
and costly to maintain.
VBA's Operational Controls Do Not Ensure That Disability Reevaluations
Occur, but VBA Is Planning to Update Some of Its Processes and
Procedures:
VBA's operational controls do not adequately ensure that staff schedule
or conduct disability reevaluations as necessary. VBA's claims
processing software does not ensure that diary dates are established.
To the extent that staff do not enter diary dates, some cases that need
reevaluations may never be brought to the attention of claims
processing staff. As a result, some reevaluations may not be conducted.
Staff can also cancel disability reevaluations and VBA does not track
or review canceled reevaluations. Thus, VBA does not have assurances
that reevaluations are being canceled appropriately. Also, completed
reevaluations are not likely to receive quality assurance reviews. VBA
plans on improving some of its control mechanisms through its new
claims management system, VETSNET. However, VETSNET will not address
all of the issues we found regarding VBA's operational controls.
Controls Do Not Ensure Staff Schedule or Conduct Disability
Reevaluations:
VBA operational controls do not ensure that cases that should be
reevaluated are scheduled for disability reevaluations. VA's
regulations require VBA to schedule disability reevaluations either
when VBA determines that a veteran's disability is likely to change or
when mandated by the Schedule for Rating Disabilities. For cases where
VA determines that a disability is likely to change, VBA staff must
manually enter diary dates into VBA's claims processing system in order
to ensure that a reminder is generated. The diary date is the only VBA
procedural trigger that alerts regional offices that a claim needs to
be reviewed. However, claims processing staff can complete a rating
decision on a disability claim without entering a reevaluation diary
date. To the extent that staff do not enter a diary date, a case that
needs to be reevaluated may never be brought to the attention of claims
processing staff. As a result, the case will likely not be
reevaluated.[Footnote 6] The VA Office of Inspector General has found
some instances where this has occurred.[Footnote 7] For example, during
a review at the Little Rock, Arkansas regional office, the VA IG found
that staff failed to enter required dates for 10 of 41 cases sampled at
that office.
VBA's electronic claims processing system also does not automatically
set up diary dates for all disabilities where a reevaluation is
mandated by VA's Schedule for Rating Disabilities. According to VA,
there are 31 disabilities where reevaluations are required by the
Schedule. VBA has automated diary dates for 14 of these disabilities.
As a result, staff must manually enter diary dates into the system for
the remaining 17 disabilities. VBA does not currently have a plan for
expanding its automated diary date protocol to include all disabilities
where reevaluations are mandatory. VBA officials said that their first
priority is to ensure VETSNET is operational and their conversion plan
is completed.
Once diary dates have been entered by RVSRs into the claims processing
system, the dates are transferred to VBA's centralized data processing
center in Hines, Illinois. When the diary dates mature, the data
processing center prints and mails out paper notices to VBA's regional
offices alerting them that reevaluations are needed. However, once the
centralized data processing center prints out these notifications, the
diary dates are erased from the centralized computer system. In
addition, VBA does not track which disability cases were identified for
reevaluation. Since the notices are single pieces of paper, they could
be lost or misplaced. If this occurs, these disability reevaluations
would likely be delayed or not performed at all. VBA is planning on
improving its ability to track reevaluations. According to VBA
officials, VETSNET will eliminate the paper notification of a matured
diary date. Instead, once a disability reevaluation diary date matures,
VETSNET will automatically create an electronic record, which can be
tracked. Although VA plans on processing all disability compensation
claims using VETSNET by May 2008, VBA officials told us that the
automatically created electronic record would not be included. These
officials were unable to provide us with a timetable for when such a
control system would be rolled out.
Some Disability Reevaluations Not Tracked or Reviewed:
Once the regional office receives the paper notice that a reevaluation
is due, staff perform a preliminary assessment of the veteran's claim
file to determine if more comprehensive reevaluation should be
conducted. If staff determine during this preliminary assessment that a
reevaluation is no longer needed, they can cancel the reevaluation.
Regional office staff noted several reasons for canceling
reevaluations, such as when a veteran dies. Additionally, a
reevaluation would be canceled if the veteran reopens their claim
because the disability has worsened. However, VBA does not track the
number or reasons for cancellations. Also, canceled reevaluations are
not subject to quality assurance reviews. VBA plans on improving its
ability to track cancellations using VETSNET. According to VBA
officials, when VETSNET is fully implemented for disability
compensation claims in May 2008, VBA will be able to track the number
and reasons for canceled disability reevaluations.
While completed disability reevaluations are subject to quality
assurance review, very few are likely to be reviewed. Disability
reevaluations represent a small portion of the total disability claims
workload that VBA reviews for quality. For example, reevaluations
represented about 2 percent of the total number of disability claims
decisions completed in fiscal year 2005. Since VBA randomly selects
claims for review from the total number of disability decisions, it is
not likely that VBA will review many reevaluations. Similarly, each
regional office's quality assurance review would not likely select many
reevaluation claims. Specifically, the local quality assurance guidance
calls for reviewing a random selection of an average of five claims for
each RVSR per month. Disability reevaluations are part of the sample,
but since they are a small portion of the total caseload, they have a
low likelihood of being selected. Some of the regional office quality
assurance review staff we spoke with reported that in the course of a
month, they may only see a handful of disability reevaluation claims.
Thus, VBA may not have a sufficient handle on the accuracy and
consistency of these reevaluations agencywide.
VBA Lacks Adequate Program Information to Effectively Manage the
Disability Reevaluation Process:
VBA cannot effectively manage the disability reevaluation process
because some of the data it collects are not consistent and it does not
systematically collect and analyze key management data. While VBA
collects data on the amount of time regional offices take to conduct
disability reevaluations, these data are not reliable. Also, VBA does
not know the number of reevaluation diary dates that mature in a year
or the types of disabilities being reevaluated, the length of time
before reevaluations are conducted, or if the reevaluation decisions
result in an increase, decrease, or no change in the severity of
veterans' disabilities. VBA's electronic system is unable to capture
the entire amount of time it takes to complete a disability
reevaluation and VBA does not currently collect and analyze outcome
data.
Timeliness Data Are Inconsistent:
VBA's disability reevaluation timeliness data are inconsistent because
regional offices use different starting points for measuring how long
it takes to complete reevaluations. For example, staff at one regional
office told us they start measuring the length of time to complete
disability reevaluations from the date that VBA's centralized data
processing center in Hines, Illinois, prints the paper notifications.
Since the paper notifications are mailed from Hines to the regional
office, several days can pass before the regional office receives the
paper notifications. As a result, the actual time it takes this office
to complete disability reevaluations would be overcounted. Other
regional offices we visited indicated that measuring timeliness is not
started until the date that staff review the claims file and determine
that a reevaluation should proceed. Staff at one regional office we
visited stated that it takes about 10 days for the claim to reach the
desk of staff who perform the review. Since this review may not always
take place as soon as the office receives the notification, the actual
time it takes to complete disability reevaluations for these offices
would be undercounted.
VBA Does Not Collect Key Disability Reevaluation Management Data:
VBA does not collect and analyze key management data on disability
reevaluations. Thus, VBA does not have a firm grasp on its performance
in handling claims that are due for a reevaluation. That is, while VA
collects data on the number of revaluations that it completes, it does
not compare this information to the number of claims that were
initially scheduled for a reevaluation. Therefore, VA does not know if
it is performing well in completing the claims scheduled for review. By
not tracking this information, VA does not have a clear sense of the
extent to which reevaluations are being canceled (as noted) or whether
some reevaluations are simply never started.
According to VBA officials, VBA also does not collect data on the types
of disabilities being reevaluated and how far in the future
reevaluations are scheduled. Also according to VBA officials, VBA does
not collect data on the outcomes of reevaluations and, as a result,
does not have the benefit of historical results data that could be used
to calibrate its decisions on which disabilities are likely to change
and thus should be a higher priority for reevaluation. Regional office
staff stated that such information on the disability reevaluation
process could be useful in aiding their daily decision making on which
disabilities to reevaluate and when to schedule them. Having such
historical data could also aid VBA in workload management decisions.
For example, in January 2002, as a temporary effort to free up staff
for processing its backlog of disability compensation and pension
claims, VBA postponed most of their currently scheduled reevaluations
for 2 years. VBA made this decision without historical data on the
extent to which reevaluations affect the benefit levels of disabilities
and lost an opportunity to target only those cases likely to result in
a change in status. As such, VBA did not know the potential number of
veterans it could be over-or under-compensating for the 2 years the
reevaluations were postponed. If VBA had a better data-driven feedback
component, it could have avoided wholesale postponement of reviews for
2 years. Figure 2 summarizes the disability reevaluation process with
an added data-driven feedback loop.
Figure 2: VBA Disability Reevaluation Process with an Added Data Driven
Feedback Component:
[See PDF for image]
This figure is a graphic illustration of the VBA Reevaluation Process
with an added Data Driven Feedback Component. The illustration depicts
the following data:
Schedule a disability reevaluation diary date at time disability
compensation claim decided; Disability Reevaluation:
* Diary date matures;
* Regional office notified;
* RVSRs preliminary assessment;
* Cancel reevaluation or Conduct reevaluation; Increase, decrease, or
retain disability rating level.
Data-driven feedback component:
Beginning at the 'Increase, decrease, or retain disability rating
level' step listed above:
* Collect data on disability reevaluations, including results and
timing of reevaluations;
* Analyze data to aid decisions on selection and scheduling of
disability reevaluations;
* Develop guidance to improve decisions based on data analysis;
* continue on to 'Schedule a disability reevaluation diary date at time
disability compensation claim decided' step listed above.
Source: GAO.
[End of figure]
Conclusions:
It is important that veterans have confidence in the system designed to
compensate them for their service-connected disabilities and that
taxpayers have faith in VBA's stewardship of the disability
compensation program. Inadequate management controls could result in
some veterans being under-compensated for conditions that have worsened
or over-compensated for conditions that have improved. VBA is improving
some of its operational controls over reevaluations. For example,
through its VETSNET system VBA plans to track the number and reasons
for cancellations. However, without a system to remind staff to
schedule disability reevaluation diary dates or a system that
automatically schedules diary dates for all claims that require
reevaluation, staff could inadvertently fail to enter diary dates, and
reevaluations may not be scheduled and performed as needed. Meanwhile,
measuring regional office performance requires reliable performance
data. VBA cannot adequately measure how long it actually takes regional
offices to complete disability reevaluations since offices use
different starting points for measuring timeliness. For offices that
start measuring their timeliness after the claim review has been
started, the measurement can result in undercounting the total amount
of time to complete a disability reevaluation. Also, without reliable
performance data, VBA cannot accurately evaluate regional office
timeliness or compare regional offices' performance. Therefore, VBA
cannot reward good performance and take actions to improve lagging
performance. In addition, without data on the results of reevaluations,
VBA cannot ensure that it is prioritizing its resources to reevaluate
those veterans whose disabilities are likely to change, and that it is
reevaluating those disabilities at the appropriate point in time.
Moving in this direction becomes increasingly more important given
Operation Enduring Freedom and Operation Iraqi Freedom. Outcome data on
the reevaluation process could be used to target certain disabilities
in the future. For example, if VBA found that reevaluating a certain
disability never resulted in a change in the rating level, then it
could consider not reevaluating that disability in the future. In
addition, data on the timing of reevaluations could also be used
strategically to refine when disabilities are reevaluated. For example,
some regional offices may be scheduling reevaluations for 2 years into
the future for a particular disability, whereas other regional offices
may be using a 3-year time period. This information could be combined
with the outcomes of such reevaluations to refine guidance and training
on scheduling reevaluations.
Recommendations:
We recommend that the Secretary of the Department of Veterans Affairs
direct the Under Secretary for Benefits to take the following five
actions to enhance VBA's disability reevaluation process:
* VA should modify its electronic claims processing system so that a
rating decision cannot be completed without staff completing the diary
date field.
* VA should modify its electronic claims processing system to ensure
that a diary date is automatically generated by the system for all
disabilities where a reevaluation is required by VA's Schedule for
Rating Disabilities.
* VBA should include canceled reevaluations in its quality assurance
reviews and should evaluate the feasibility of periodically sampling a
larger number of completed disability reevaluations for quality
assurance review.
* VBA should clarify its guidance so that all regional offices
consistently use the date they are notified of a matured diary date as
the starting point for measuring timeliness.
* VBA should develop a plan to collect and analyze data on the results
of disability reevaluations. To the extent necessary, this information
could be used to refine guidance on the selection and timing of future
disability reevaluations.
Agency Comments:
In its written comments on a draft of this report (see app. II), VA
generally agreed with our conclusions and concurred with our
recommendations.
As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution until two weeks after the date
of this report. At that time, we will send copies of this report to the
Secretary of Veterans Affairs, appropriate congressional committees,
and other interested parties. The report will also be available at
GAO's Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions regarding this report, please
call me at (202) 512-7215. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. Other contacts and staff acknowledgments are
listed in appendix III.
Daniel Bertoni:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Scope and Methodology:
To develop the information for this report, we analyzed Veterans
Benefits Administration (VBA) workload and timeliness data on
disability reevaluations. We found that VBA workload reports, which
detail the length of time it takes regional offices to complete
disability reevaluations are not reliable, since VBA guidance allows
regional offices the ability to begin measuring when disability
reevaluations begin at different points in time. Because VBA does not
routinely collect and analyze data on the time allowed prior to
reevaluating disabilities or the results of reevaluations, we requested
a VBA analysis of claims-level data. In November 2006, VBA agreed to
develop a one-time analysis of reevaluations completed in 2006.
However, because of difficulties in developing the data VBA was unable
to provide the analysis in time for us to incorporate the results into
this report. We also reviewed federal regulations on disability
reevaluations, VBA's written guidance and training materials on
reevaluations, and VBA's procedures for conducting reevaluations. We
discussed the procedures for ensuring that reevaluations are conducted
and the information used to manage the reevaluation program with VBA
headquarters and regional office officials and observed control
procedures at 5 of VBA's 57 regional offices. Specifically, we visited
VA's regional offices in Chicago, Illinois; Columbia, South Carolina;
Muskogee, Oklahoma; Nashville, Tennessee; and Seattle, Washington. We
selected the Columbia, Muskogee, and Nashville regional offices based
on fiscal year 2005 VBA data that showed they completed reevaluations
faster than the national average. Chicago and Seattle took longer than
the national average. All five offices also completed a greater than
average number of reevaluations. We also selected these five offices
based on their geographic dispersion. During our site visits, we toured
the regional office's facilities and interviewed regional office
management, 30 staff involved in regional office claims processing, 6
staff tasked with quality assurance, and other staff. We did not
perform a case file review during our visits. The VA Office of
Inspector General had performed a limited case file review and found
that in some instances reevaluations were not scheduled where required.
We built on the Inspector General's work by looking at VBA's processes
for ensuring that reevaluations are scheduled when required.
[End of section]
Appendix II: Comments from the Department of Veterans Affairs:
The Secretary Of Veterans Affairs: Washington:
November 26, 2007:
Mr. Daniel Bertoni:
Director, Education, Workforce and Income Security: U.S. Government
Accountability Office: 441 G Street, NW:
Washington, DC 20548:
Dear Mr. Bertoni:
The Department of Veterans Affairs (VA) has reviewed the Government
Accountability Office's (GAO) draft report, Veterans' Benefits:
Improved Operational Controls and Management Data Would Enhance VBA's
Disability Reevaluation Process (GAO-08-75) and generally agrees with
GAO's conclusions and concurs with GAO's recommendations.
The enclosure specifically addresses each of GAO's recommendations and
provides comments to the draft report. VA appreciates the opportunity
to comment on your draft report.
Sincerely yours,
Signed by:
Gordon H. Mansfield:
Acting:
Enclosure:
Department of Veterans Affairs (VA) Comments to Government
Accountability Office (GAO) Draft Report Veterans' Benefits: Improved
Operational Controls and Management Data Would Enhance VBA's Disability
Reevaluation Process (GAO-08-75).
To enhance VBA's disability reevaluation process, GAO recommends that
the Secretary of Veterans Affairs direct the Under Secretary for
Benefits to take the following actions:
* VA should modify its electronic claims processing system so that a
rating decision cannot be completed without staff completing the diary
date field.
Concur - Rating Veterans Service Representatives (RVSR) determine
whether a disability is static. VA will change Rating Board Automation
(RBA) 2000 programming to provide an edit to require a "yes or no"
decision about reexamination. Programming to accomplish this change
will be scheduled at a future date to avoid any diversion of resources
currently devoted to VETSNET implementation.
* VA should modify its electronic claims processing system to ensure
that a diary date is automatically generated by the system for all
disabilities where a reevaluation is required by VA's Schedule for
Rating Disabilities.
Concur - Determining the need for reevaluation is based on the facts
and circumstances of each individual claim. VA will assess the
technical feasibility of this recommendation. Programming to accomplish
this change will be scheduled at a future date to avoid any diversion
of resources currently devoted to VETSNET implementation.
* VBA should include canceled reevaluations in its quality assurance
reviews and should evaluate the feasibility of periodically sampling a
larger number of completed disability reevaluations for quality
assurance review.
Concur - Quality assurance review selection criteria will be modified
to include canceled requests for disability reexaminations. A larger
proportion of reevaluations are being selected for review. A total of
38,899 reevaluations were completed during fiscal year 2007, accounting
for 4.72 percent of the rating workload. Quality assurance reviews were
conducted on 485 reevaluation cases, which represent 7.7 percent of the
total quality assurance reviews.
* VBA should clarify its guidance so that all regional offices
consistently use the date they are notified of a matured diary date as
the starting point for measuring timeliness.
Concur - Using the date printed on the system-generated exam request as
the starting date to measure how long it takes to complete
reevaluations would provide consistency in timeliness measurements. VA
will clarify its guidance to the regional offices to ensure
consistency.
* VBA should develop a plan to collect and analyze data on the results
of disability reevaluations. To the extent necessary, this information
could be used to refine guidance on the selection and timing of future
disability reevaluations.
Concur - A one-time review will be conducted. Data involving end
products will be matched against reevaluation requests and results
analyzed to determine if guidance for scheduling disability
reevaluations needs to be refined.
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Daniel Bertoni, Director (202) 512-7215:
Staff Acknowledgments:
The following individuals made important contributions to the report:
Brett Fallavollita, Assistant Director; Martin Scire; David Forgosh; as
well as Susannah Compton; James Rebbe; Christine San; and Walter Vance.
[End of section]
Footnotes:
[1] Schedule for Rating Disabilities is primarily a guide for
evaluating disabilities resulting from all types of diseases and
injuries encountered as a result of, or incident to, military service.
[2] VA specifically identifies these conditions as tinnitus, defective
hearing, diabetes mellitus, post-traumatic stress disorder, lumbosacral
or cervical strain, and generalized musculoskeletal conditions.
[3] The Veterans Claims Assistance Act of 2000 (Pub. L. No. 106-475,
Nov. 9, 2000) obligates VA to assist a claimant in obtaining evidence
that is necessary to establish eligibility for the benefit being
sought.
[4] Service connected disabilities are injuries or diseases incurred or
aggravated while on active military duty.
[5] Department of Veterans Affairs FY 2008 Budget Submission, National
Cemetery Administration, Benefits Programs, and Departmental
Administration, Volume 2 of 4, February 2007.
[6] VBA claims processing staff explained to us that a claim could be
reevaluated if a veteran submits a claim to increase the benefit for a
current disability or claim a new disability.
[7] VA Office of Inspector General, Combined Assessment Program Review
of the VA Regional Office Little Rock, Arkansas, Report No. 04-03331-91
(Washington, D.C.: Feb. 25, 2005).
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