Veterans' Benefits
Training for Experienced Disability Claims Processors Gao ID: GAO-10-1029T September 16, 2010GAO was asked to present its views on the training requirements and procedures for VA personnel responsible for processing compensation and pension claims. This statement is based primarily upon an April 2010 GAO report on VA's training for experienced disability claims processors (GAO-10-445) and includes information on actions VBA says it has taken in response to our recommendations. This statement focuses on (1) experienced disability claims processors' views regarding training, and (2) VBA's efforts to monitor and assess training for experienced disability claims processors.
Experienced claims processors had concerns about the amount of training they were required to complete and their ability to meet that requirement. In addition, they had mixed views on the amount of training received on specific topics, the way in which training was delivered and the timing of training. GAO's survey results indicated that 60 percent of experienced claims processors found it difficult to meet the 80 hour annual training requirement given their workload. In addition, based on its survey, GAO estimates that 45 percent of supervisors of experienced Rating Veterans Service Representatives (RVSR) and 53 percent of supervisors of experienced Veterans Service Representatives (VSR) thought that only some or few, if any, of the experienced staff they supervise need 80 hours of training annually to perform their job duties effectively. Many experienced staff also thought they received too little training on some topics and too much on others. For example, 47 percent thought they received less training than needed in how to develop appeals and remands and 34 percent thought they received more than enough training on records management. Finally, opinions varied on how helpful the various modes of training were. Nearly all claims processors, in general, considered on-the-job experience to be the method of training best suited to their needs. An estimated 39 percent of all experienced claims processors, in general, felt that the training they received was delivered too late, suggesting that regional offices may not always deliver the training needed by experienced claims processors in a timely manner. According to Standards for Internal Control in the Federal Government, federal agencies must have control mechanisms in place to help ensure that all employees receive appropriate and consistent training. Under its current annual training requirements, VBA delegates considerable responsibility for training experienced claims processors to each of its 57 regional offices. In particular, regional offices are responsible for ensuring that claims processors complete annual training requirements. Each office also determines what topics are covered for half of the required training hours, what material to provide on each of these topics, and how and when the training should occur. Regional offices also have considerable discretion in determining what activities qualify as training. However, at the time of GAO's review, VBA lacked controls to ensure that regional offices deliver required training and record completed training in a consistent manner, and did little to assess the appropriateness or consistency of all training for experienced claims processors. During the course of our review and in response to our recommendations, VBA has taken steps to improve its monitoring and assessment of training. VBA reports that they are developing guidance on what activities qualify as training, have begun to require staff to complete course evaluations for some training and are exploring the feasibility of requiring evaluations for all training. In its April report, GAO recommended that VBA (1) adopt procedures for routinely monitoring and ensuring compliance with annual training requirements, including more fully using its Web-based learning management system to ensure training requirements are met, (2) develop clear written guidance on the types of activities all regional offices should and should not count toward completion of annual training requirements, and (3) develop and implement a written strategy for systematically assessing the appropriateness of the training regional offices provide to experienced claims processors. VA concurred with these recommendations and has taken some actions in response.
GAO-10-1029T, Veterans' Benefits: Training for Experienced Disability Claims Processors
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Testimony:
Before the Subcommittee on Disability Assistance and Memorial Affairs,
Committee on Veterans' Affairs, House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery:
Expected at 10:00 a.m. EDT:
Thursday, September 16, 2010:
Veterans' Benefits:
Training for Experienced Disability Claims Processors:
Statement of Daniel Bertoni, Director:
Education, Workforce, and Income Security:
Veterans' Benefits:
GAO-10-1029T:
GAO Highlights:
Highlights of GAO-10-1029T, a testimony to the Subcommittee on
Disability Assistance and Memorial Affairs, Committee on Veterans‘
Affairs, House of Representatives.
Why GAO Did This Study:
GAO was asked to present its views on the training requirements and
procedures for VA personnel responsible for processing compensation
and pension claims. This statement is based primarily upon an April
2010 GAO report on VA‘s training for experienced disability claims
processors (GAO-10-445) and includes information on actions VBA says
it has taken in response to our recommendations. This statement
focuses on (1) experienced disability claims processors‘ views
regarding training, and (2) VBA‘s efforts to monitor and assess
training for experienced disability claims processors.
What GAO Found:
Experienced claims processors had concerns about the amount of
training they were required to complete and their ability to meet that
requirement. In addition, they had mixed views on the amount of
training received on specific topics, the way in which training was
delivered and the timing of training. GAO‘s survey results indicated
that 60 percent of experienced claims processors found it difficult to
meet the 80 hour annual training requirement given their workload. In
addition, based on its survey, GAO estimates that 45 percent of
supervisors of experienced Rating Veterans Service Representatives
(RVSR) and 53 percent of supervisors of experienced Veterans Service
Representatives (VSR) thought that only some or few, if any, of the
experienced staff they supervise need 80 hours of training annually to
perform their job duties effectively.
Many experienced staff also thought they received too little training
on some topics and too much on others. For example, 47 percent thought
they received less training than needed in how to develop appeals and
remands and 34 percent thought they received more than enough training
on records management. Finally, opinions varied on how helpful the
various modes of training were. Nearly all claims processors, in
general, considered on-the-job experience to be the method of training
best suited to their needs. An estimated 39 percent of all experienced
claims processors, in general, felt that the training they received
was delivered too late, suggesting that regional offices may not
always deliver the training needed by experienced claims processors in
a timely manner.
According to Standards for Internal Control in the Federal Government,
federal agencies must have control mechanisms in place to help ensure
that all employees receive appropriate and consistent training. Under
its current annual training requirements, VBA delegates considerable
responsibility for training experienced claims processors to each of
its 57 regional offices. In particular, regional offices are
responsible for ensuring that claims processors complete annual
training requirements. Each office also determines what topics are
covered for half of the required training hours, what material to
provide on each of these topics, and how and when the training should
occur. Regional offices also have considerable discretion in
determining what activities qualify as training. However, at the time
of GAO‘s review, VBA lacked controls to ensure that regional offices
deliver required training and record completed training in a
consistent manner, and did little to assess the appropriateness or
consistency of all training for experienced claims processors. During
the course of our review and in response to our recommendations, VBA
has taken steps to improve its monitoring and assessment of training.
VBA reports that they are developing guidance on what activities
qualify as training, have begun to require staff to complete course
evaluations for some training and are exploring the feasibility of
requiring evaluations for all training.
What GAO Recommends:
In its April report, GAO recommended that VBA (1) adopt procedures for
routinely monitoring and ensuring compliance with annual training
requirements, including more fully using its Web-based learning
management system to ensure training requirements are met, (2) develop
clear written guidance on the types of activities all regional offices
should and should not count toward completion of annual training
requirements, and (3) develop and implement a written strategy for
systematically assessing the appropriateness of the training regional
offices provide to experienced claims processors. VA concurred with
these recommendations and has taken some actions in response.
View [hyperlink, http://www.gao.gov/products/GAO-10-1029T] or key
components. For more information, contact Daniel Bertoni at (202) 512-
7215 or bertonid@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
I am pleased to have the opportunity to comment on training for
Veterans Benefits Administration (VBA) disability claims processors.
In fiscal year 2009, the Department of Veterans Affairs (VA) paid
about $44 billion to about 4 million veterans and their survivors
through its disability compensation and pension programs. For years,
the claims process has been the subject of concern and attention by
VA, the Congress, and veterans service organizations due, in large
part, to long waits for decisions, large numbers of pending claims,
and problems with the consistency of decisions. To help VBA manage its
increasing workload and replace the growing number of experienced
claims processors who are retiring, the Congress provided funding
which enabled VBA to hire several thousand new staff from fiscal year
2005 through fiscal year 2010. However, more staff alone will not
guarantee effective disability claims processing. To ensure that
decisions in disability compensation and pension cases are accurate,
consistent, and timely, training must enable claims processors to
become fully proficient and maintain their knowledge and skills.
In 2008 we reported that VBA's centralized training for new claims
processors appeared well designed but that some claims processors had
raised concerns about implementation.[Footnote 1] VBA has since
evaluated its training for new claims processors and made changes
based upon that evaluation. In April 2010, we again reported on VBA's
training as mandated in the Veterans' Benefits Improvement Act of
2008.[Footnote 2] We recommended improved monitoring of annual
training requirements, standardized recording of training taken, and a
review of course content and timing for experienced claims processors.
My remarks today will focus on 1) experienced disability claims
processors' views regarding training, and 2) VBA's efforts to monitor
and assess their training. This statement is drawn primarily from our
April 2010 report, where we obtained information on the training,
experience, and views of a nationally representative sample of claims
processing staff. We also interviewed VBA headquarters officials and
managers and training coordinators in four regional offices--Little
Rock, Arkansas; Denver, Colorado; St. Petersburg, Florida; and White
River Junction, Vermont. Our work was conducted in accordance with
generally accepted government auditing standards. Those standards
require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings
and conclusions based on our audit objectives. We believe the evidence
obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.
Background:
To process claims accurately, consistently, and in a timely manner,
Veterans Service Representatives (VSR) and Rating Veterans Service
Representatives (RVSR) must perform a complex set of tasks. When a
claim is received, a VSR reviews it and assists the veteran in
gathering the evidence, or documentation, needed to support it. The
RVSR then evaluates the evidence to determine whether the claimant's
medical condition(s) constitutes a disability, and assigns a
disability percentage rating which determines the amount of benefits
the veteran is eligible to receive. Finally a VSR calculates the
amount of monthly benefit payments. VSRs and RVSRs also perform follow-
up reviews if, for example, there is evidence a claimant's medical
condition has changed, or a court determines that a claim was
incorrectly denied.
To ensure that VSRs and RVSRs develop and maintain the knowledge and
skills needed to process disability claims accurately, consistently,
and in a timely manner, VBA has established annual training
requirements and developed a structured training program, called
"Challenge," for newly-hired or promoted claims processors.[Footnote
3] Beginning in fiscal year 2010, claims processors must receive 80
hours of training annually in topics directly related to processing
disability claims.[Footnote 4] VBA requires that 40 of those hours be
in topics designated by VBA, 20 cover topics selected by each regional
office from a list of core technical training requirements (CTTR), and
20 cover topics determined by each regional office.[Footnote 5]
In addition to its "Challenge" program and annual training
requirements, VBA issues "Fast Letters," or memoranda on policy
changes, conducts telephone conferences, and develops ad hoc required
training on emerging issues to help ensure that disability claims
processors have the information they need to do their job. VBA issued
100 Fast Letters in calendar years 2008 and 2009, on topics ranging
from cost-of-living adjustments in disability benefits to rating the
effects of traumatic brain injury (TBI). Monthly or quarterly
telephone conferences with regional offices concentrate on claims
processing issues identified through VBA's quality reviews or on new
management priorities or initiatives that may affect how claims
processors do their jobs. VBA officials also told us the agency
periodically requires training on emerging topics such as rating post-
traumatic stress disorder (PTSD) and spinal, neck, and joint injuries.
Experienced Claims Processors Had Concerns with Various Aspects of the
Training They Received:
Experienced staff responding to our survey expressed concerns with the
amount of training they were required to take and their ability to
meet those requirements. Based on the results of our survey of claims
processors, many believed that 80 training hours each year were too
many, particularly for experienced staff.[Footnote 6] An estimated 45
percent of supervisors of experienced RVSRs and 53 percent of
supervisors of experienced VSRs thought that only some or few, if any,
of the experienced staff they supervise need 80 hours of training.
Most of the regional office officials we interviewed also said 80
hours are too many for at least some experienced staff and one
regional official told us it would make sense to vary the required
number of hours based on the training needs of individual claims
processors.[Footnote 7] In 2008 we recommended that VBA collect and
review feedback from staff to determine if the 80-hour training
requirement was appropriate for all VSRs and RVSRs. VBA has not yet
implemented this recommendation.
Our survey results also indicated that it was challenging for many
experienced claims processors, in general, to meet the 80-hour annual
training requirement, given their workload. Sixty percent found it
somewhat or very difficult to meet the requirement. Moreover, 61
percent of experienced RVSRs' supervisors and 76 percent of
experienced VSRs' supervisors thought it was somewhat or very
difficult for experienced staff to complete 80 hours of training each
year.
While many experienced claims processors thought that 80 hours of
training per year was too much and difficult to complete, they had
mixed views on the amount of training they received on specific
topics. For example, an estimated 47 percent thought they received
less than sufficient training in developing appeals and remands, and
42 percent thought they received less than needed in how to rate
claims involving special monthly compensation. On the other hand, in
each case, about one-third thought they received more than enough
training in records management, rating disability compensation claims,
and calculating payment amounts based on disability ratings.
Experienced claims processors' views on the helpfulness of various
training modes and the timing of training also varied. Training for
disability claims processors can be delivered in a number of ways:
formal classroom training, online instruction, and video or satellite
conferences. Claims processors can access online training courses
through VBA's Training Performance Support System (TPSS), and learning
resources such as VBA training materials, published guidance, and
technical information are available to them on VBA's internal Web
site. Regional offices also provide claims processors with individual
coaching and mentoring, and may hold weekly meetings for claims
processing teams.
Based on our survey results, experienced claims processors, in
general, found certain training modes and learning resources more
helpful than others. Nearly all thought that on-the-job experience, to
a great or very great extent, helped them learn what they needed to
know to perform their jobs. However, only about 20 percent indicated
TPSS and other online training, and video or satellite training had,
to a great or very great extent, helped them become familiar with even
the basic information needed to handle claims.
Survey results also indicated that regional offices do not always
deliver necessary training in a timely manner. An estimated 39 percent
of all experienced claims processors felt that the formal training, in
general, they received in the last 12 months was delivered too late to
help them effectively perform their job duties. For example, although
the regulation governing ratings decisions on the effects of traumatic
brain injury (TBI) was changed in October 2008,[Footnote 8] one RVSR
wrote in a comment to the survey that, "TBI training is not projected
to come out until [2010.]"[Footnote 9] Another wrote that introductory
leadership training was not received until two years after a promotion
to a supervisory position.
VBA Did Little to Systematically Monitor or Assess Training for
Experienced Claims Processors but Has Begun to Take Steps to Do So:
VBA headquarters does not ensure that experienced claims processors
receive all required training. It is important for federal agencies to
have mechanisms in place to ensure their employees actually receive
required training and we have reported in the past that tracking the
actual receipt of required training calls for reliable data from a
comprehensive learning management system.[Footnote 10] While each
regional office is responsible for recording completed training hours
for each claims processor in VA's Web-based Learning Management System
(LMS), VBA officials told us that VBA headquarters did not use it to
centrally monitor the specific types of training individual claims
processors have completed. Based on our survey results, we found some
claims processors did not receive training they should have. An
estimated 24 percent of all RVSRs with more than one year of
experience, who should have received mandatory training on rating
spinal, neck, and joint injuries, never did.[Footnote 11] To improve
VBA headquarters' ability to systematically monitor regional office
compliance with its annual training requirements, we recommended that
it adopt procedures to routinely do so, including more fully utilizing
its LMS to ensure that claims processors received required CTTR and ad
hoc training on emerging issues. In their comments to our report, VBA
noted that it had begun to use LMS to determine what percentage of
claims processors at each office were meeting annual training
requirements. However, it is not clear if they are tracking whether
staff receive required CTTR training or ad hoc training on emerging
issues such as the training on rating spinal, neck, and joint injuries.
In addition, we found that VBA lacked controls to ensure that regional
offices record completed training in a consistent manner. Each
regional office has considerable discretion in determining what
activities qualify as training and we noted that they were not all
defining training consistently. For example, some regions counted the
time claims processors spent reading "Fast Letters" as training while
others did not. This raises questions about the reliability of the
data that regional offices enter into the LMS. We recommended that VBA
develop clear written guidance on the types of activities all regional
offices should and should not count toward completion of annual
training requirements. According to VBA, the agency is developing such
criteria and expects to complete this process by September 30, 2010.
VBA also has not systematically assessed the appropriateness or
consistency of training regional offices provide to experienced claims
processors. In prior work, we have noted that federal agencies should
have mechanisms in place to ensure that training for employees is
appropriate and consistent.[Footnote 12] However, we found that VBA
did little to determine if all regional offices provide training to
experienced claims processors that 1) covers topics relevant to what
they do; 2) helps them do their job; 3) is delivered in the most
useful and efficient way; and 4) is provided when needed.
In the past, VBA has evaluated some mandatory training to improve the
consistency of ratings, assessed training for newly-hired claims
processors, and solicited feedback from staff on TPSS. VBA officials
told us that teams from VBA headquarters also periodically visit
regional offices to monitor their compliance with VBA policies and
procedures. Since July 2009, such visits have included a training
specialist responsible for reviewing some aspects of training in the
regional office, such as training records and materials, and whether
new claims processors have completed the last phase of Challenge
Training at their regional office. Although examining some aspects of
training for claims processors during these visits may provide VBA
with some information on the appropriateness and consistency of
training, each office is only visited about once every three years.
Finally, VBA has not yet systematically collected feedback from
experienced claims processors on training received at the regional
offices even though feedback from training participants, supervisors,
instructors and other stakeholders can provide agencies with valuable
information to assess the appropriateness and consistency of their
training. VBA recently developed a training evaluation tool that all
VSRs and RVSRs are required to complete, but only for CTTR courses. As
a result, we recommended that VBA develop and implement a written
strategy to systematically assess the appropriateness (content, mode
and timing) of all training for experienced claims processors. Such a
strategy should include a standardized approach for obtaining feedback
from experienced claims processors and regional office managers and
training coordinators. VBA says it is assessing the feasibility of
requiring staff to complete an evaluation tool for all training and
expects to complete this assessment by September 30, 2010.
Concluding Observations:
Veterans who have been injured in service to their country deserve
accurate and timely disability determinations. VBA claims processors
perform a vital role in helping the nation respond to the needs of
these veterans. Through its training program for claims processors,
VBA can ensure that they develop and maintain the skills required to
do their job efficiently and well. However, VBA could do more to
monitor the training received by experienced claims processors. VBA
cannot be sure all staff are receiving the type of training the agency
believes is essential for success on the job. Furthermore, there are
questions about the reliability of the training data regional offices
record in VA's LMS. VBA has indicated that they are developing
criteria to define the types of activities that should and should not
count toward meeting training requirements. However, it is yet to be
seen if this will result in consistent reporting of what counts as
training by regional offices.
Furthermore, according to our survey, both experienced claims
processors and their supervisors had a number of concerns regarding
the training that experienced claims processors receive. Thus, it is
important that VBA continue to explore options to assess the
appropriateness of the training provided to staff.
Mr. Chairman, this concludes my prepared statement. I would be pleased
to respond to any questions that you or other Members of the
Subcommittee may have. Thank you.
GAO Contact and Staff Acknowledgments:
For further information about this testimony, please contact Daniel
Bertoni at (202) 512-7215 or bertonid@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this testimony. In addition to the contact named
above, key contributors to this statement include Clarita Mrena,
Martin Scire, Regina Santucci and Susan Aschoff.
[End of section]
Related GAO Products:
Veterans' Disability Benefits: Expanded Oversight Would Improve
Training for Experienced Claims Processors. [hyperlink,
http://www.gao.gov/products/GAO-10-445[. Washington, D.C.: April 30,
2010.
Veterans' Disability Benefits: Further Evaluation of Ongoing
Initiatives Could Help Identify Effective Approaches for Improving
Claims Processing. [hyperlink,
http://www.gao.gov/products/GAO-10-213]. Washington, D.C.: January 29,
2010.
Veterans' Disability Benefits: Preliminary Findings on Claims
Processing Trends and Improvement Efforts. [hyperlink,
http://www.gao.gov/products/GAO-09-910T]. Washington, D.C.: July 29,
2009.
Veterans' Benefits: Increased Focus on Evaluation and Accountability
Would Enhance Training and Performance Management for Claims
Processors. [hyperlink, http://www.gao.gov/products/GAO-08-561].
Washington, D.C.: May 27, 2008.
Veterans' Benefits: Improvements Needed in VA's Training and
Performance Management Systems. [hyperlink,
http://www.gao.gov/products/GAO-08-1126T]. Washington, D.C.: September
18, 2008.
Veterans' Disability Benefits: Claims Processing Challenges Persist,
while VA Continues to Take Steps to Address Them. [hyperlink,
http://www.gao.gov/products/GAO-08-473T]. Washington, D.C.: February
14, 2008.
Veterans' Benefits: VA Needs Plan for Assessing Consistency of
Decisions. [hyperlink, http://www.gao.gov/products/GAO-05-99].
Washington, D.C.: November 19, 2004.
Human Capital: A Guide for Assessing Strategic Training and
Development Efforts in the Federal Government. [hyperlink,
http://www.gao.gov/products/GAO-04-546G]. Washington, D.C.: March 2004.
Veterans' Benefits: Improvements Needed in the Reporting and Use of
Data on the Accuracy of Disability Claims Decisions. [hyperlink,
http://www.gao.gov/products/GAO-03-1045]. Washington, D.C.: September
30, 2003.
Veterans' Benefits: Training for Claims Processors Needs Evaluation.
[hyperlink, http://www.gao.gov/products/GAO-01-601]. Washington, D.C.:
May 31, 2001.
[End of section]
Footnotes:
[1] See GAO, Veterans Benefits: Increased Focus on Evaluation and
Accountability Would Enhance Training and Performance Management for
Claims Processors, [hyperlink, http://www.gao.gov/products/GAO-08-561]
(Washington, D.C.: May 27, 2008).
[2] See GAO, Veteran' Disability Benefits: Expanded Oversight Would
Improve Training for Experienced Claims Processors, [hyperlink,
http://www.gao.gov/products/GAO-10-445] (Washington, D.C.: April 30,
2010).
[3] Challenge consists of a uniform curriculum that is implemented in
three phases: initial orientation training provided at a participant's
regional office, centralized classroom instruction typically delivered
at VBA's Training Academy in Baltimore, Md., and comprehensive on-the-
job and classroom training that new claims processors receive at their
regional offices.
[4] The 80 hour annual training requirement is for RVSRs and VSRs who
have completed the Challenge training program and/or have been in
their position for six months.
[5] At the time of our survey VBA did not designate the 40 hours of
required training.
[6] Unless otherwise indicated, the margin of error for estimates
based on this survey cited in this report are within plus or minus 15
percentage points at the 95 percent confidence level.
[7] An 80-hour annual training requirement may be appropriate for
some, in particular new staff. An estimated 70 percent (ranging from
52 to 84 percent at a 95 percent confidence level) of all supervisors
of new RVSRs and 62 percent of supervisors of new VSRs thought that
all or almost all of the new staff they supervise needed 80 hours of
training.
[8] 73 Fed. Reg. 54,693 (September 23, 2008)
[9] A presentation on TBI was available on VBA's Intranet site.
[10] See GAO, Human Capital: A Guide for Assessing Strategic Training
and Development Efforts in the Federal Government, [hyperlink,
http://www.gao.gov/products/GAO-04-546G] (Washington, D.C.: March 2004)
[11] This training, delivered in September 2008, was undertaken to
clarify requirements resulting from DeLuca v. Brown, 8 Vet. App. 202
(1995), in which the court held that under federal regulations
defining joint and spine impairment severity in terms of limits on
range of motion, VA claims adjudicators must consider whether range of
motion is further limited by factors such as pain and fatigue during
"flare-ups" or following repetitive use of the impaired joint or spine.
[12] See [hyperlink, http://www.gao.gov/products/GAO-04-546G].
[End of section]
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