This is the accessible text file for GAO report number GAO-13-89 
entitled 'Veterans' Disability Benefits: Timely Processing Remains a 
Daunting Challenge' which was released on January 18, 2012. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

December 2012: 

Veterans' Disability Benefits: 

Timely Processing Remains a Daunting Challenge: 

GAO-13-89: 

GAO Highlights: 

Highlights of GAO-13-89, a report to congressional requesters. 

Why GAO Did This Study: 

For years, VA has struggled with an increasing workload of disability 
compensation claims. The average time to complete a claim was 188 days 
in fiscal year 2011, and VA expects an increase in claims received as 
1 million servicemembers leave military service over the next 5 years. 
As GAO and other organizations have previously reported, VA has faced 
challenges in reducing the time it takes to decide veterans’ claims. 
GAO was asked to review these issues. Specifically, this report 
examines (1) the factors that contribute to lengthy processing times 
for disability claims and appeals, and (2) the status of VBA’s recent 
efforts to improve disability claims and appeals processing 
timeliness. To do this, GAO analyzed VBA performance data and program 
documents, reviewed relevant studies and evaluations, met with staff 
from five VA regional offices, and interviewed VBA officials and 
Veterans Service Organizations. 

What GAO Found: 

A number of factors-—both external and internal to the Veterans 
Benefits Administration (VBA)-—have contributed to the increase in 
processing timeframes and subsequent growth in the backlog of veterans’
disability compensation claims. As the population of new veterans has 
swelled in recent years, the annual number of claims received by VBA 
has gone up. Compared to the past, these claims have a higher number 
of disabling conditions, and some of these conditions, such as 
traumatic brain injuries, make their assessment complex. Moreover, due 
to new regulations that have established eligibility for benefits for 
new diseases associated with Agent Orange exposure, VBA adjudicated 
260,000 previously denied and new claims. Beyond these external 
factors, issues with the design and implementation of the compensation 
program have contributed to timeliness challenges. For example, the 
law requires the Department of Veterans Affairs (VA) to assist 
veterans in obtaining records that support their claim. However, VBA 
officials said that lengthy timeframes in obtaining military records—-
particularly for members of the National Guard and Reserve—-and Social 
Security Administration (SSA) medical records impact VA’s duty to 
assist, possibly delaying a decision on a veteran’s disability claim. 
As a result, the evidence gathering phase of the claims process took 
an average of 157 days in 2011. Further, VBA’s paper-based claims 
processing system involves multiple hand-offs, which can lead to 
misplaced and lost documents and can cause unnecessary time delays. 
Concerning timeliness of appeals, VBA regional offices have shifted 
resources away from appeals and toward claims in recent years, which 
has led to lengthy appeals timeframes. 

VBA is currently taking steps to improve the timeliness of claims and 
appeals processing; however, prospects for improvement remain 
uncertain because timely processing remains a daunting challenge. VBA 
is using contractors to handle some aspects of the claims process, and 
is also shifting some workload between regional offices. Also, VBA is 
modifying and streamlining certain claims and appeals processing 
procedures for veterans who opt to participate in these initiatives in 
exchange for an expedited decision. For example, veterans receive 
expedited processing when they submit a claim that is certified as 
having all required evidence. Not many veterans have elected this 
option, but VA is making adjustments to increase its attractiveness. 
In addition, VBA is trying to decrease the amount of time it takes to 
gather medical evidence. For example, VBA recently encouraged medical 
providers to use a standardized form when responding to VBA’s request 
for information. However, results of this initiative have been mixed. 
VBA is also taking steps to streamline the claims process, including 
implementing initiatives to create (1) standardized language for 
decision letters sent to veterans, (2) specialized teams that process 
claims based on level of complexity, and (3) a paperless claims 
system. According to VBA officials, these efforts will help VA process 
veterans’ claims within 125 days by 2015. However, the extent to which 
VA is positioned to meet this ambitious goal remains uncertain. 
Specifically, VBA’s backlog reduction plan—-its key planning document-—
does not articulate performance measures for each initiative, 
including their intended impact on the claims backlog. Furthermore, VA 
has not yet reported on how these efforts have affected processing 
times, a condition which raises concern given the mixed results that 
have emerged to date. 

What GAO Recommends: 

GAO recommends that VBA (1) partner with military officials to reduce 
timeframes to gather records from National Guard and Reserve sources, 
(2) partner with SSA to reduce timeframes to gather SSA medical 
records, and (3) ensure the development of a robust plan for its 
initiatives that identifies performance goals that include the impact 
of individual initiatives on processing timeliness. In response to a 
draft of this report, VA officials generally agreed with GAO’s 
conclusions and concurred with the recommendations, and summarized 
efforts that are planned or underway to address the recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-13-89]. For more 
information, contact Daniel Bertoni at (202) 512-7215 or 
bertonid@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Rising Workloads, along with Program Rules and Inefficient Processes, 
Contribute to Lengthy Processing Time Frames: 

VBA Is Taking Steps to Improve Claims and Appeals Processing, but 
Future Impact Is Uncertain: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Veteran Notification during the Claims and Appeals 
Processes: 

Appendix III: Selected VBA Efforts to Improve Claims and Appeals 
Timeliness: 

Appendix IV: Comments from the Department of Veterans Affairs: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Table: 

Table 1: Selected VBA Efforts to Improve Claims and Appeals Timeliness: 

Figures: 

Figure 1: Selected VA Regional Offices That GAO Reviewed: 

Figure 2: Overview of VA's Disability Claims Process: 

Figure 3: Average Days VA Compensation Rating Claims Were Pending and 
Average Days It Took to Complete Claims, Fiscal Year 2009 to August 
2012: 

Figure 4: Timeliness of Phases in VA's Claims Process for Fiscal Year 
2011: 

Figure 5: VA Timeliness Measures of Notices of Disagreement and 
Appeals Certification, Fiscal Year 2009 to August 2012: 

Figure 6: VA Compensation Rating Claims Received, Completed, and 
Backlogged, Fiscal Years 2009 to 2011: 

Figure 7: Notices of Disagreement Received by VA and Awaiting a 
Decision, Fiscal Years 2009 to 2012: 

Figure 8: Selected VBA Improvement Efforts: 

Figure 9: VBA Notifications to Veterans throughout the Claims Process: 

Figure 10: VBA Notifications to Veterans throughout the Appeals 
Process: 

Abbreviations: 

ACE: Acceptable Clinical Evidence: 

Board: Board of Veterans' Appeals: 

DBQ: Disability Benefits Questionnaire: 

DOD: Department of Defense: 

DRO: Decision Review Officer: 

FDC: Fully Developed Claim: 

FTE: full-time equivalent: 

IRIS: Inquiry Routing and Information System: 

MAP-D: Modern Award Processing-Development: 

MSA: Metropolitan Statistical Area: 

OIG: Office of Inspector General: 

QRT: Quality Review Team: 

RVSR: Rating Veterans Service Representative: 

SNL: Simplified Notification Letter: 

SOC: Statement of the Case: 

SSA: Social Security Administration: 

SSOC: Supplemental Statement of the Case: 

VA: Department of Veterans Affairs: 

VACOLS: Veterans Appeals Control and Locator System: 

VBA: Veterans Benefits Administration: 

VBMAP: Veterans Benefits Management Assistance Program: 

VBMS: Veterans Benefits Management System: 

VCAA: Veterans Claims Assistance Act of 2000: 

VETSNET: Veterans Services Network: 

VHA: Veterans Health Administration: 

VONAPP: Veterans On Line Application: 

VOR: VETSNET Operations Reports: 

VSO: Veterans Service Organization: 

VSR: Veterans Service Representative: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

December 21, 2012: 

Congressional Requesters: 

The Department of Veterans Affairs (VA) disability compensation 
program provides monetary support to veterans with disabling 
conditions that were incurred or aggravated during military service. 
In fiscal year 2011, the program provided $39.4 billion in benefits to 
3.35 million veterans. For years, the disability compensation claims 
process has been the subject of concern and attention by VA, Congress, 
and Veterans Service Organizations (VSO), due in large part to long 
waits for decisions and the large number of claims pending a decision. 
Moreover, VA's backlog of claims--defined as claims awaiting a 
decision for over 125 days--has more than tripled since September 
2009. Against this backdrop, 1 million servicemembers are expected to 
become veterans in the next 5 years according to VA officials, with a 
significant number expected to apply for disability benefits. As we 
and other organizations have reported over the last decade, VA has 
faced challenges in reducing the time it takes to decide veterans' 
claims. For example, the average length of time to complete a claim 
has increased from 161 days in 2009 to 260 days in 2012.[Footnote 1] 
Moreover, in August 2012, 568,043 claims--approximately two-thirds of 
all compensation rating claims--were backlogged.[Footnote 2] In 
addition, timeliness of appeals processing at VA regional offices has 
also slowed by 56 percent over the last several years. The Veterans 
Benefits Administration (VBA) has a number of ongoing initiatives in 
place to help meet its stated timeliness goals. In this context, we 
were asked to examine issues VA regional offices face in processing 
disability claims and appeals in a timely fashion. Specifically, we 
addressed the following questions: 

What factors contribute to lengthy processing times for disability 
claims and appeals? 

What is the status of VBA's recent efforts to improve disability 
claims and appeals processing timeliness? 

To address our objectives, we collected and analyzed information 
through multiple methods. We reviewed relevant federal laws and 
regulations, court decisions, VBA policy manuals and documents, and 
training materials. We also reviewed past GAO and VA Office of 
Inspector General (OIG) reports, VBA studies and evaluations, and 
other documents relevant to claims and appeals processing at VBA 
regional offices. We collected data on claims and appeals processing 
workload and timeliness from VBA's internal dashboard.[Footnote 3] To 
assess the reliability of the data, we conducted interviews with VBA 
officials in charge of maintaining VBA's internal dashboard about 
their quality control procedures and practices used to extract 
timeliness and workload data from underlying data sources. We relied 
on past GAO data reliability assessments of the underlying data 
sources where enterprise-wide data on workload and timeliness of 
claims and appeals processing is stored and extracted into the 
internal dashboard tool. In addition, we collected data on claims 
processing resources from VBA's Personnel and Accounting Integrated 
Database. To assess the reliability of these data, we interviewed 
officials in VBA's Office of Human Resources about practices to record 
personnel actions, quality control procedures conducted within the 
Office of Human Resources to ensure the quality of the data, as well 
as potential limitations to the data. We reviewed the data and found 
it to be sufficiently reliable for the purpose of analyzing 
timeliness, workload, and resources assigned to claims processing. We 
interviewed VBA central office officials, including officials in VBA's 
Implementation Center (which was established as a project management 
office to manage improvement initiatives), and VSO representatives who 
assist veterans with their claims and appeals. We also met with staff 
from five VA regional offices--Atlanta, Georgia; Houston, Texas; Los 
Angeles, California; New York, New York; and Philadelphia, 
Pennsylvania. We selected offices based on size of metropolitan area, 
claims workload, and timeliness of claims and appeals processing. For 
each location, we interviewed regional office management and staff, 
analyzed workload management documents, and reviewed written 
notifications sent to veterans (see fig. 1). For additional 
information on our scope and methodology, see appendix I. 

Figure 1: Selected VA Regional Offices That GAO Reviewed: 

[Refer to PDF for image: illustrated U.S. map] 

Region: Eastern; 
Office: New York, New York; 
MSA Rank: 1; 
Total claims: 16,799; 
Percent pending less than 125 days: 22%; 
Percent pending more than 125 days: 78%. 

Region: Eastern; 
Office: Philadelphia, Pennsylvania; 
MSA Rank: 5; 
Total claims: 15,874; 
Percent pending less than 125 days: 34%; 
Percent pending more than 125 days: 66%. 

Region: Southern; 
Office: Atlanta, Georgia; 
MSA Rank: 9; 
Total claims: 33,000; 
Percent pending less than 125 days: 38%; 
Percent pending more than 125 days: 62%. 

Region: Central; 
Office: Houston, Texas; 
MSA Rank: 6; 
Total claims: 37,805; 
Percent pending less than 125 days: 28%; 
Percent pending more than 125 days: 72%. 

Region: Western; 
Office: Los Angeles, California; 
MSA Rank: 2; 
Total claims: 25,322; 
Percent pending less than 125 days: 20%; 
Percent pending more than 125 days: 80%. 

Source: GAO analysis of 2010 Census and April 2012 VBA data; National 
Atlas of the United States (base map). 

Note: MSA rank refers to the rank order of the population of all 
Metropolitan Statistical Area (MSA) across the nation, according to the 
2010 Census. An MSA is a geographic entity defined by the federal 
Office of Management and Budget for use by federal statistical 
agencies, based on the concept of a core area with a large population 
nucleus, plus adjacent communities having a high degree of economic and 
social integration with that core. 

[End of figure] 

We conducted this performance audit from March 2012 through December 
2012 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 that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

Disability Claims Process: 

VA pays monthly disability compensation to veterans with service-
connected disabilities (i.e., injuries or diseases incurred or 
aggravated while on active military duty) according to the severity of 
the disability.[Footnote 4] VA also pays additional compensation for 
certain dependent spouses, children, and parents of veterans.[Footnote 
5] VA's disability compensation claims process starts when a veteran 
submits a claim to VBA (see fig. 2). A claim folder is created at 1 of 
VA's 57 regional offices, and a Veterans Service Representative (VSR) 
then reviews the claim and helps the veteran gather the relevant 
evidence needed to evaluate the claim. Such evidence includes the 
veteran's military service records, medical examinations, and 
treatment records from Veterans Health Administration (VHA) medical 
facilities and private medical service providers. Also, if necessary 
to provide support to substantiate the claim, VA will provide a 
medical examination for the veteran. Once VBA has gathered the 
supporting evidence, a Rating Veterans Service Representative (RVSR)--
who typically has more experience at VBA than a VSR--evaluates the 
claim and determines whether the veteran is eligible for benefits. If 
so, the RVSR assigns a percentage rating. Later, the veteran can 
reopen a claim to request an increase in disability compensation from 
VA if, for example, a service-connected disability has worsened or a 
new disability arises. 

Figure 2: Overview of VA's Disability Claims Process: 

[Refer to PDF for image: process illustration] 

Veteran submits claim to VA: 

Establishing claim: 
* Claim file created or requested from storage; 
* Record entered into VA's tracking system. 

Initiating development: 
* Service medical records requested; 
* Medical examination requested; 
* Private medical records requested; 
* 30-day VCAA notice to veterans. 

Evidence gathering: 
* Requested evidence received; 
* 30-day VCAA notice period ends; 
* If evidence outstanding, follow-up request and additional 30-day VCAA 
notice period ends. 

Rating decision: 
* Claim and evidence reviewed; 
* Rating decision prepared. 

Processing award: 
* VSO review; 
* Award prepared; 
* Decision notification. 

Source: GAO analysis of VBA procedures. 

Note: The Veterans Claims Assistance Act (VCAA) requires VA to notify 
veterans of the information necessary to evaluate a claim. If the 
veteran does not respond to this notice within 30 days, VA may make a 
decision on the claim based on the information and evidence in the file 
at that time. 

[End of figure] 

Appeals Process: 

If the veteran disagrees with VA's decision regarding a claim, he or 
she can submit a written Notice of Disagreement to the regional office 
handling the claim.[Footnote 6] In response to such a notice, VBA 
reviews the case and provides the veteran with a written explanation 
of the decision if VBA does not grant all appealed issues.[Footnote 7] 
Appendix II contains more information regarding VBA's notifications to 
veterans throughout the disability compensation claims and appeals 
processes. If additional evidence is provided, VBA reviews the case 
again and if this new evidence does not result in a grant of all 
appealed issues, VBA produces another written explanation of the 
decision. If the veteran further disagrees with the decision, he or 
she may appeal to the Board of Veterans' Appeals (the Board). Before 
transferring the appeal to the Board, VBA reviews the case again and 
then certifies that the appeal is ready for review by the Board. After 
the appeal has been certified, the Board conducts a hearing if the 
veteran requests one, then grants benefits, denies the appeal, or 
returns the case to VBA to obtain additional evidence necessary to 
decide the claim. If the veteran is dissatisfied with the Board's 
decision, he or she may appeal, in succession, to the U.S. Court of 
Appeals for Veterans Claims, to the Court of Appeals for the Federal 
Circuit, and finally to the Supreme Court of the United States. 
[Footnote 8] 

VA's Duty to Assist Requirements: 

Congress clarified VA's duties with regard to assisting in the 
development of claims in the Veterans Claims Assistance Act of 2000 
(VCAA).[Footnote 9] VCAA eliminated the requirement that a veteran 
submit a "well-grounded" claim before VA could assist in developing 
the claim and instead obligated the agency to assist a claimant in 
obtaining evidence that is necessary to establish eligibility for the 
benefit being sought. Specifically, VA must: (1) notify claimants of 
the information necessary to complete the application;[Footnote 10] 
(2) indicate what information not previously provided is needed to 
substantiate the claim;[Footnote 11] (3) make reasonable efforts to 
assist claimants in obtaining evidence to substantiate claimants' 
eligibility for benefits, including relevant records;[Footnote 12] and 
(4) notify claimants when VA is unable to obtain relevant records. 
[Footnote 13] According to VA regulations, VA efforts to obtain 
federal records should continue until the records are obtained or 
until VA has deemed it reasonably certain that such records do not 
exist or that further efforts to obtain those records would be futile. 
[Footnote 14] 

Timeliness of Claims and Appeals Processing: 

Timeliness of VA compensation rating claims and appeals processing has 
worsened in recent years. As a key indicator of VBA's performance in 
claims and appeals processing, timeliness is measured in various ways. 
To measure overall claims processing timeliness, VBA uses two 
measures: (1) the number of days the average pending claim has been 
awaiting a decision (Average Days Pending) and (2) the average number 
of days that VBA took to complete a claim where a decision has been 
reached (Average Days to Complete). Both measures of claims processing 
timeliness have worsened substantially over the last several years 
(see figure 3).[Footnote 15] 

Figure 3: Average Days VA Compensation Rating Claims Were Pending and 
Average Days It Took to Complete Claims, Fiscal Year 2009 to August 
2012: 

[Refer to PDF for image: vertical bar graph] 

Fiscal year: 2009; 
Average days pending: 116; 
Average days to complete: 161. 

Fiscal year: 2010; 
Average days pending: 117; 
Average days to complete: 166. 

Fiscal year: 2011; 
Average days pending: 198; 
Average days to complete: 188. 

Fiscal year: 2012 (August); 
Average days pending: 254; 
Average days to complete: 260. 

Source: GAO analysis of VBA data. 

[End of figure] 

VBA also collects data on the timeliness of the different phases of 
the claims process, which is used to identify trends and bottlenecks 
throughout the process. In fiscal year 2011, each phase took longer on 
average than its stated agency timeliness target (see fig. 4). The 
evidence gathering phase is the most time-intensive phase, taking over 
5 months (157 days) on average in fiscal year 2011 and continuing to 
grow throughout fiscal year 2012. 

Figure 4: Timeliness of Phases in VA's Claims Process for Fiscal Year 
2011: 

[Refer to PDF for image: stacked horizontal bar graph] 

National average: 
Establishing claim: 11 days; 
Initiating development: 64 days; 
Evidence gathering: 157 days; 
Rating decision: 72 days; 
Processing award: 14 days; 
Total: 318 days. 

National target: 
Establishing claim: 7 days; 
Initiating development: 20 days; 
Evidence gathering: 85 days; 
Rating decision: 15 days; 
Processing award: 5 days; 
Total: 132 days. 

Source: GAO analysis of VBA data. 

Note: While VBA's stated goals are to process all claims within 125 
days by fiscal year 2015, VBA established targets for each phase in the 
claims process for fiscal year 2011 that collectively add up to 132 
days. 

[End of figure] 

The timeliness of appeals processing at VA regional offices has 
worsened as well. The average timeframes in VBA's response to Notices 
of Disagreement and the certification of appeals to the Board have 
increased since fiscal year 2009 (see fig. 5). 

Figure 5: VA Timeliness Measures of Notices of Disagreement and Appeals 
Certification, Fiscal Year 2009 to August 2012: 

[Refer to PDF for image: vertical bar graph] 

Fiscal year: 2009; 
Average days awaiting decision on Notice of Disagreement: 199; 
Average days awaiting certification of appeal to Board: 359. 

Fiscal year: 2010; 
Average days awaiting decision on Notice of Disagreement: 212; 
Average days awaiting certification of appeal to Board: 362. 

Fiscal year: 2011; 
Average days awaiting decision on Notice of Disagreement: 315; 
Average days awaiting certification of appeal to Board: 489. 

Fiscal year: 2012 (August); 
Average days awaiting decision on Notice of Disagreement: 390; 
Average days awaiting certification of appeal to Board: 560. 

Source: GAO analysis of VBA data. 

[End of figure] 

Rising Workloads, along with Program Rules and Inefficient Processes, 
Contribute to Lengthy Processing Time Frames: 

Rise in Claims Submitted Is Outpacing Claims Production: 

In recent years, VA's claims processing production has not kept pace 
with the increase in incoming claims. In fiscal year 2011, VA 
completed over 1 million compensation rating claims, a 6 percent 
increase from 2009. However, the number of VA compensation rating 
claims received has grown 29 percent--from 1,013,712 in fiscal year 
2009 to 1,311,091 in fiscal year 2011 (see fig. 6). As a result, the 
number of backlogged claims--defined as those claims awaiting a 
decision for more than 125 days--has increased substantially since 
2009. As of August 2012, VA had 856,092 pending compensation rating 
claims, of which 568,043 (66 percent) were considered backlogged. 

Figure 6: VA Compensation Rating Claims Received, Completed, and 
Backlogged, Fiscal Years 2009 to 2011: 

[Refer to PDF for image: vertical bar graph] 

Fiscal year: 2009; 
Claims received: 1.0 million; 
Claims completed: 1.0 million; 
Claims backlogged: 0.1 million. 

Fiscal year: 2010; 
Claims received: 1.2 million; 
Claims completed: 1.1 million; 
Claims backlogged: 0.2 million. 

Fiscal year: 2011; 
Claims received: 1.3 million; 
Claims completed: 1.0 million; 
Claims backlogged: 0.5 million. 

Source: GAO analysis of VBA data. 

[End of figure] 

Similar to claims processing, VA regional office appeals processing 
has not kept pace with incoming appeals received. The number of 
Notices of Disagreement--the first step in the appeals process when 
the veteran provides a written communication to VBA that he or she 
wants to contest the claims decision--received by VBA fluctuated over 
the last 4 years, yet those awaiting a decision grew 76 percent over 
that time period (see figure 7). Moreover, the number of Statements of 
the Case--an explanation of VBA's decision on the appellant's case--
that were mailed by VBA decreased 24 percent over the last 4 years--
from 100,291 in 2009 to 76,685 in 2012. In addition, the time it took 
to mail a Statement of the Case increased 57 percent over that time 
period--from 293 days to 460 days on average. 

Figure 7: Notices of Disagreement Received by VA and Awaiting a 
Decision, Fiscal Years 2009 to 2012: 

[Refer to PDF for image: vertical bar graph] 

Fiscal year: 2009; 
Number of cases received: 124,435; 
Number of cases awaiting a decision: 92,799. 

Fiscal year: 2010; 
Number of cases received: 140,934; 
Number of cases awaiting a decision: 115,906. 

Fiscal year: 2011; 
Number of cases received: 116,048; 
Number of cases awaiting a decision: 149,993. 

Fiscal year: 2012; 
Number of cases received: 121,786; 
Number of cases awaiting a decision: 163,638. 

Source: GAO analysis of VBA data. 

[End of figure] 

A number of factors have contributed to the substantial increase in 
claims received. One factor was the commencement in October 2010 of 
VBA's adjudication of 260,000 previously denied and new claims when a 
presumptive service connection was established for three additional 
Agent Orange-related diseases.[Footnote 16] VBA gave these claims a 
high priority and assigned experienced claims staff to process and 
track them. VBA officials said that 37 percent of its claims 
processing resources nationally were devoted to adjudicating Agent 
Orange claims from October 2010 to March 2012. VBA officials in one 
regional office we spoke to said that all claims processing staff were 
assigned solely to developing and rating Agent Orange claims for 4 
months in 2011, and that no other new and pending claims in the 
regional office's inventory were processed during that time. Also 
during this time period, special VBA teams--known as brokering 
centers--which previously accepted claims and appeals from regional 
offices experiencing processing delays, were devoted to processing 
Agent Orange claims exclusively. According to VBA, other factors that 
contributed to the growing number of claims include an increase in the 
number of veterans from the military downsizing after 10 years of 
conflict in Iraq and Afghanistan, improved outreach activities and 
transition services to servicemembers and veterans, and difficult 
financial conditions for veterans during the economic downturn. In 
conjunction with an increase in claims received, VBA officials said 
that claims today are more complex than in the past. As we reported in 
2010, VBA said it is receiving more claims for complex disabilities 
related to combat and deployments overseas, including those based on 
environmental and infectious disease risks and traumatic brain 
injuries.[Footnote 17] Claims with many conditions can take longer to 
complete because each condition must be evaluated separately and then 
combined into a single percentage rating. According to VA, in 2011, 
the number of medical conditions claimed by veterans who served in 
Iraq and Afghanistan averaged 8.5, an increase from 3-4 conditions per 
claim for Vietnam veterans. 

Some claims processing staff have been assigned additional 
responsibilities that can impede their ability to process claims or 
appeals in a timely fashion. According to VBA officials, because of a 
large influx of newly hired and promoted claims processing staff--
1,973 new staff were hired since 2009 and approximately 50 percent of 
claims processing staff have been in their current role for less than 
2 years--many staff have not yet become fully proficient in their new 
roles and experienced staff have been diverted from their claims 
processing responsibilities to conduct training, mentor new hires, and 
review others' work.[Footnote 18] In addition to training and 
mentoring, some claims processing staff at each of the five regional 
offices we met with had been assigned to exclusively conduct quality 
reviews instead of processing claims as part of the Quality Review 
Team initiative.[Footnote 19] At one regional office, 17 of 277 claims 
processing staff were assigned to this team. Regional office officials 
said that while this initiative has increased the quality of the 
ratings produced, it has negatively affected the overall timeliness of 
claims processing. Furthermore, officials at several regional offices 
we met with noted that they diverted staff away from processing the 
oldest claims to respond to inquiries from Congress, the 
administration, and veterans. Moreover, VBA officials at one regional 
office said the number of claims processing staff assigned to outreach 
activities has increased. Specifically, at the time of our review, 37 
out of 302 claims processing staff were conducting outreach activities 
to servicemembers and veterans, such as giving briefings and 
distributing materials at military bases about pre-discharge and 
transition assistance programs.[Footnote 20] 

According to VBA officials, a primary reason that appeals timeliness 
at VA regional offices has worsened is a lack of staff focused on 
processing these appeals. VBA officials at each of the five regional 
offices we met with stated that over the last several years appeals 
staff have also had to train and mentor new staff, conduct quality 
reviews, as well as develop and rate disability claims to varying 
degrees. For example, at one regional office, all staff on the appeals 
team focused exclusively on rating disability claims for a 9-month 
period in 2010 instead of processing appeals. Officials at another 
regional office stated that until 2012, their appeals staff spent up 
to 2 weeks per month on non-appeals tasks. In addition, we reported in 
2011 that regional office managers estimated that Decision Review 
Officers (DRO) spent on average 36 percent of their time on non-
appeals processing tasks.[Footnote 21] A 2012 VA OIG report noted that 
VA regional office managers did not assign enough staff to process 
appeals, diverted staff from processing appeals, and did not ensure 
that appeals staff acted on appeals promptly because, in part, they 
were assigned responsibilities to process initial claims, which were 
given higher priority.[Footnote 22] The VA OIG recommended that VBA 
identify staffing resources needed to meet their appeals processing 
goals, conduct DRO reviews on all appeals, and revise productivity 
standards and procedures to emphasize processing appeals in a timely 
manner, such as implementing criteria requiring appeals staff to 
initiate a review or develop for Notices of Disagreement and certified 
appeals within 60 days of receipt. VBA agreed with the VA OIG's 
findings and is conducting a pilot to assess the feasibility of 
addressing these recommendations. 

Program Requirements Contribute to Long Processing Times: 

According to VA officials, federal laws[Footnote 23] and court 
decisions[Footnote 24] over the past decade have expanded veterans' 
entitlement to benefits but have also added requirements that can 
negatively affect claims processing times. For example, the VCAA 
requires VA to assist a veteran who files a claim in obtaining 
evidence to substantiate the claim before making a decision.[Footnote 
25] This requirement includes helping veterans obtain all relevant 
federal records and non-federal records.[Footnote 26] VA is required 
to continue trying to obtain federal records, such as VA medical 
records, military service records, and Social Security records, until 
they are either obtained or the associated federal entity indicates 
the records do not exist. VA may continue to process the claim and 
provide partial benefits to the veteran, but the claim cannot be 
completed until all relevant federal evidence is obtained. 

While VA must consider all evidence submitted throughout the claims 
and appeals processes, if a veteran submits additional evidence or 
adds a condition to a claim late in the claims process it can require 
rework and may subsequently delay a decision, according to VBA central 
office officials. VBA officials at regional offices we spoke to said 
that submitting additional evidence may add months to the claims 
process. New evidence must first be reviewed to determine what 
additional action, if any, is required. Next, another notification 
letter must be sent to the veteran detailing the new evidence 
necessary to redevelop the claim and additional steps VA will take in 
light of the new evidence. Then, VA may have to obtain additional 
records or order another medical examination before the claim can be 
rated and a decision can be made. Furthermore, while VA may continue 
to process the claim and provide partial benefits to the veteran, a 
claim is not considered "complete" until a decision is made on all 
conditions submitted by the veteran. Moreover, a veteran has up to 1 
year, from the notification of VA's decision, to submit additional 
evidence in support of the claim before the decision is considered 
final. In addition, a veteran may submit additional evidence in 
support of their appeal at any time during the process. If the veteran 
submits additional evidence after VA completes a Statement of the 
Case, VA must review the new evidence, reconsider the appeal, and 
provide another written explanation of its decision--known as a 
Supplemental Statement of the Case. Congress recently passed a law 
allowing VA to waive review of additional evidence submitted after the 
veteran has filed a substantive appeal and instead have the new 
evidence reviewed by the Board to expedite VA's process of certifying 
appeals to the Board.[Footnote 27] 

While federal law requires veterans to use an application form 
prescribed by VA when submitting a claim for original disability 
compensation benefits, VBA central office officials said they accept 
reopened claims or claims requesting an increase in disability 
compensation benefits in any format, which can contribute to lengthy 
processing times.[Footnote 28] VBA will accept an original disability 
claim informally if it is submitted in a non-standard format, but 
within 1 year the veteran must submit a VA Form 21-526, Veteran's 
Application for Compensation and/or Pension.[Footnote 29] VBA does not 
track the number of claims submitted in non-standard formats; however, 
officials at three regional offices we met with said they receive 
claims submitted in various formats, including hand-written letters. 
Officials at these three regional offices said that when such claims 
are submitted, there is a risk that claims staff may not be able to 
identify all the conditions the veteran would like to claim during 
initial development. For example, officials at one regional office 
stated that if these conditions are discovered later in the process, 
then VA must redevelop the claim--which could include sending another 
letter to the veteran, obtaining additional records, and conducting 
another medical exam--before the claim can be rated and a benefit 
amount determined and disbursed. VBA officials said they expect the 
number of non-standard applications for disability claims to decrease 
as more veterans file claims electronically through the Veterans On 
Line Application (VONAPP), which is available at VA's eBenefits 
website.[Footnote 30] 

Similar to processing for reopened claims, VA's procedures allowing 
veterans to submit appeals in any format can negatively affect appeals 
processing times, according to VBA officials. For example, a veteran's 
intention to appeal a prior decision may be overlooked initially by 
staff because there is no standard appeals submission form and a 
veteran's statement to appeal a prior decision may be included along 
with other written correspondence for other purposes, such as 
submitting a new claim, according to VBA officials. When appeals are 
overlooked and later found, it can delay recording Notices of 
Disagreement in appeals data systems and result in longer processing 
times, according to VBA officials. 

Gathering Records from Federal Agencies and Others Can Take Months: 

According to VBA officials, delays in obtaining military service and 
medical treatment records, particularly for National Guard and Reserve 
members, is a significant factor lengthening the evidence gathering 
phase. According to VBA officials, 43 percent of Global War on Terror 
veterans are National Guard and Reserve members. According to a VA 
official, Department of Defense (DOD) Instruction 6040.45 requires 
military staff to respond to VA requests for National Guard and 
Reserve records in support of VA disability compensation claims. 
However, VBA area directors and officials at all five regional offices 
we met with acknowledged that delays in obtaining these records are a 
system-wide challenge. Military records of National Guard or Reserve 
members can often be difficult to obtain, in particular, because these 
servicemembers typically have multiple, non-consecutive deployments 
with different units and their records may not always be held with 
their reserve units and may exist in multiple places. Moreover, 
according to VBA officials, National Guard and Reserve members may be 
treated by private providers between tours of active duty and VA may 
have to contact multiple military personnel and private medical 
providers to obtain all relevant records, potentially causing delays 
in the evidence gathering process. 

Difficulties in obtaining timely and complete medical information, 
especially from private medical providers, can also contribute to a 
lengthy evidence gathering phase. For example, officials at one 
regional office said the process may be delayed if veterans are slow 
to return their consent forms that allow VA to pursue private medical 
records. Also, according to VBA officials, private medical providers 
may not respond to VA records requests in a timely fashion. In 
addition, officials at one regional office we met with mentioned that 
time frames can also be affected if veterans fail to show up for 
scheduled examinations. Officials at two regional offices we met with 
said that even when medical records are obtained, medical exams and 
opinions may include erroneous information or be missing necessary 
evidence, which then requires VA officials to follow-up with medical 
providers to clarify information. In some cases, another examination 
must be ordered before a decision can be made on the claim, which can 
add months to the process. VBA area directors acknowledged that 
obtaining complete and sufficient medical information is a system-wide 
challenge. 

Difficulties obtaining Social Security Administration (SSA) medical 
records, as one specific example, can also lengthen the evidence 
gathering phase. Currently, an interagency agreement exists that 
establishes the terms and conditions under which SSA discloses 
information to VA for use in determining eligibility for disability 
benefits, according to VBA officials. Although VBA regional office 
staff have direct access to SSA benefits payment histories, they do 
not have direct access to medical records held by SSA. If a veteran 
submits a disability claim and reports receiving SSA disability 
benefits, VA is required to help the veteran obtain relevant federal 
records, including certain SSA medical records, to process the claim. 
VBA's policy manual instructs claims staff to fax a request for 
medical information to SSA and if no reply is received, to wait 60 
working days before sending a follow-up fax request. If a response to 
the follow-up request is not received after 30 days, the manual 
instructs claims staff to send an email request to an SSA liaison. VBA 
officials at four of the five regional offices we reviewed told us 
that when following this protocol, they have had difficulty obtaining 
SSA medical records in a timely fashion. Moreover, they reported 
having no contact information for SSA, beyond the fax number, to help 
process their requests. In complying with VA's duty to assist 
requirement, VBA staff told us they continue trying to retrieve SSA 
records by sending follow-up fax requests until they receive the 
records or receive a response that the records do not exist. VBA area 
directors said some regional offices have established relationships 
with local SSA offices and have better results, but obtaining 
necessary SSA information has been an ongoing issue nationally. For 
example, officials at one regional office said a response from SSA 
regarding a medical records request can sometimes take more than a 
year to receive. 

Some Work Processes Are Inefficient: 

VBA's work processes, stemming mainly from its reliance on a paper-
based claims system, can lead to misplaced or lost documents, which 
can contribute to lengthy processing times. VBA officials at three of 
the five regional offices we met with mentioned that errors and delays 
in handling, reviewing, and routing incoming mail to the correct claim 
folder can delay the processing of a claim or cause rework. For 
example, VBA officials at one regional office said that a claim may be 
stalled in the evidence gathering phase if a piece of mail that 
contains outstanding evidence is misplaced or lost. In addition, 
claims staff may rate a claim without knowledge of the additional 
evidence submitted and then, once the mail is routed to the claim 
folder, have to rerate the claim in light of the new evidence 
received. Furthermore, VBA officials at one regional office we met 
with said that processing can also be delayed if mail staff are slow 
to record new claims or appeals into IT systems. As of August 2012, 
VBA took 43 days on average to record Notices of Disagreement in the 
appeals system--36 days longer than VBA's national target. In May 
2011, the VA OIG reported that VA regional office mailroom operations 
needed strengthening to ensure that staff process mail in an accurate 
and timely manner. Specifically, the VA OIG found that staff did not 
always record incoming mail into IT systems within 7 days of receipt 
and that they did not properly process and route mail to existing 
claims folders in a timely fashion in 10 of the 16 VA regional offices 
they reviewed.[Footnote 31] VBA area directors said that mail 
processing timeliness varies by regional office and that the more 
efficient offices in general do a better job of associating mail with 
the correct claims folder. In addition, VBA area directors said that 
standardizing the mail handling and sorting process in an integrated 
mail processing center--a component of the Claims Organizational Model 
implemented in 18 regional offices in fiscal year 2012--is intended to 
improve mail processing by involving more senior staff in the process. 
VBA officials also said that moving claims folders among regional 
offices and medical providers contributes to lengthy processing times. 
According to a 2011 VA OIG report, processing delays occurred 
following medical examinations because staff could not match claims-
related mail with the appropriate claim folders until the folders were 
returned from the VA Medical Center.[Footnote 32] In addition, 
processing halts while a claim folder is sent to another regional 
office or brokering center. 

Lastly, according to VBA officials, the lack of an integrated IT 
system that provides all necessary information and functionality to 
track and process claims and appeals can decrease the productivity of 
claims processing staff. For example, according to staff at one VA 
regional office we spoke with, currently, they must use different 
systems to track claims folders, order medical exams, record claim 
processing actions taken by VBA staff and evidence received on a 
claim, rate claims, process awards, and record the status of appeals 
to the Board. The lack of an integrated system requires staff to enter 
claim information multiple times, search through multiple systems for 
claim information, and maintain processing notes on the status of the 
claim or appeal in multiple systems. For example, officials at two 
regional offices we met with said RVSRs must enter information into 
the Rating Board Automation system that was already entered in the 
Modern Award Processing-Development (Map-D) system. In addition, 
appeals staff must maintain claim processing notes and information on 
the status of appeals in two different systems--one maintained by the 
Board (Veterans Appeals Control and Locator System) and one maintained 
by VBA (MAP-D). According to regional office staff, the redundant data 
entry takes extra time that could have been spent working on other 
cases. Moreover, staff at one regional office said they did not always 
keep their claim processing notes up-to-date in both systems. 

VBA Is Taking Steps to Improve Claims and Appeals Processing, but 
Future Impact Is Uncertain: 

VBA is currently taking steps to improve the timeliness of claims and 
appeals processing. Based on a review of VA documents and interviews 
with VBA officials, we identified 15 efforts with a stated goal of 
improving claims and appeals timeliness. We selected 9 for further 
review--primarily based on interviews with VBA officials and a review 
of recent VA testimonies. VBA's improvement efforts include using 
existing VBA staff and contractors to manage workload, modifying and 
streamlining procedures, improving records acquisition, and 
redesigning the claims and appeals processes (see fig. 8). Although 
VBA is monitoring these efforts, the planning documents provided to us 
lack key aspects of sound planning, such as performance measures for 
each effort. 

Figure 8: Selected VBA Improvement Efforts: 

[Refer to PDF for image: illustration] 

VBA improvement efforts: 

Leveraging resources: 
* Brokering centers: Special teams within VBA established to assist 
regional offices with processing claims; 
* Veteran Benefits Management Assistance Program: Contractor 
assistance with claims development. 

Modifying program requirements: 
* Fully Developed Claims Program: Expedited processing for claims 
submitted with all relevant medical evidence; 
* Appeals Design Pilot: Standardized Notice of Disagreement form for 
all appeals; and waiver of VBA review of additional evidence submitted 
in substantive appeals. 

Improving records acquisition: 
* Vendors for Private Medical Records: Pilot program to use a 
contractor to acquire veteran medical records from private physicians; 
* Disability Benefits Questionnaires: Standardized medical form for 
medical providers to capture necessary medical information to evaluate 
a disability. 

Claims process redesign: 
* Simplified Notification Letter: Standardizes and streamlines the 
decision notification processes; 
* Claims Organizational Model: Reorganization of claims processing 
staff into cross-functional teams, claims assigned to teams based on 
claims complexity, and integrated mailroom and triage functions; 
* Veteran Benefits Management System: Paperless claims system will 
allow electronic submission of claims and supporting evidence, convert 
paper-based claims folders into electronic claims folders. 
                                                        
Source: GAO summary of VBA efforts. 

[End of figure] 

VBA Is Using Existing VBA Staff and Contractors to Manage Its Growing 
Workloads: 

VBA has several ongoing efforts to leverage internal and external 
resources to help manage its workload (see fig. 8).[Footnote 33] One 
ongoing effort that began in 2001 is the use of brokering centers--
which are 13 special teams that process claims transferred from 
regional offices experiencing a large backlog of claims. As we 
reported in 2010, these teams are staffed separately from other 
regional office teams.[Footnote 34] According to VA officials, 
brokering centers gather evidence for the claim, make a decision, 
process awards payments, and work on appeals. Brokering center teams 
processed nearly 171,000 claims in fiscal year 2009, according to the 
VA OIG. VA central office officials told us that in fiscal years 2010 
and 2011, all brokering centers focused exclusively on the re-
adjudication of Agent Orange claims. Through the first 11 months of 
fiscal year 2012, brokering centers processed approximately 24,000 
claims. VBA officials at several regional offices told us that 
brokering, over the past year, has helped to manage their overall 
claims workload. 

VBA also began the Veterans Benefits Management Assistance Program 
(VBMAP) in late fiscal year 2011 to obtain contractor support for 
evidence gathering for approximately 279,000 disability claims. 
[Footnote 35] Under VBMAP, regional offices send cases to a contractor 
to gather evidence. After evidence has been gathered for an individual 
claim, the contractor sends the file back to the originating regional 
office, which reviews the claim for completeness and quality and then 
assigns a rating. Contractor staff are required to complete their work 
within 135 days of receiving the file.[Footnote 36] As of June 2012, 
VBA regional offices we spoke with were awaiting the first batch of 
claims that were to be sent to the contractors, so it remains to be 
seen if VBMAP reduces processing times. Contractors are required to 
provide VBA with status reports that include several measures of 
timeliness, including the time it took to receive medical evidence 
from providers and the time it took to return a claim to VBA for 
rating. 

VBA Is Changing Procedures and Modifying Requirements to Expedite 
Claims and Appeals Processing: 

With the intent of speeding up the claims and appeals processes, VBA 
has several efforts that modify program requirements or relieve VA of 
certain duties (see figure 8). One effort is the Fully Developed 
Claims (FDC) program, which began as a pilot in December 2008 and was 
implemented nationwide in June 2010. The FDC program was implemented 
in response to a congressional mandate that required VBA to conduct a 
pilot program to expedite processing of fully developed claims in 90 
days or less.[Footnote 37] Normally, once a veteran submits a claim, 
VBA will review the claim and then send the veteran a letter detailing 
additional evidence required to support the claim. The FDC program 
eliminates this step and saves time because the required notification 
is provided to the veteran directly on the FDC form. The program also 
attempts to reduce the time VBA would normally spend gathering 
evidence for the veteran. In exchange for expedited processing, 
veterans participating in the FDC program send VBA any relevant 
private medical evidence with the claim and certify that they have no 
additional evidence to provide. While VBA officials and VSOs expect 
the program to reduce processing delays for veterans, claims submitted 
without the required evidence are considered incomplete. Furthermore, 
claims submitted under the FDC program with incomplete evidence 
sometimes lose their priority status and are processed with VBA's non-
expedited workload, which can result in additional processing time. 
According to VBA officials, in the first 2 years of the program, VBA 
has processed 33,001 FDC claims, taking an average of about 98 days to 
complete--8 days longer than the goal of 90 days for these claims. VBA 
officials attribute not meeting FDC processing time goals to the 
increased workload resulting from processing Agent Orange claims. As 
of July 2012, veteran participation in the FDC program has been low--
only 4 percent of all compensation rating claims submitted in 2012. A 
VBA official told us that in response to VSO input, they have made the 
FDC form easier to use. Moreover, the VBA official we spoke with 
expects more FDC claims once veterans are able to electronically file 
claims. While FDC claims are currently submitted by paper, the 
proposed electronic system will guide veterans through the steps to 
gather the necessary evidence in support of their claim and draw 
information needed on the form from VBA electronic databases. 

VBA also began the Appeals Design Pilot--implemented at a single 
regional office--in spring 2012 to expedite appeals processing. The 
pilot modifies several program procedures with the goal of decreasing 
appeals processing times, according to management at the regional 
office conducting the pilot. For example, veterans participating in 
the pilot do not file appeals in non-traditional formats. Instead, 
they use a standardized Notice of Disagreement form. The pilot also 
forgoes the election of a traditional versus a DRO review of an 
appeal--providing DRO reviews for all appeals from veterans 
participating in the pilot.[Footnote 38] This change eliminates the 
need for VBA to wait up to 60 days for a veteran to make an election 
on the type of regional office review in an appeal. In addition, 
veterans submitting new evidence during the appeal can opt to have 
their case expedited directly to the Board without having the regional 
office review the additional evidence submitted. In addition to those 
mentioned above, the Appeals Design Pilot also has several other 
elements. For example, expedited processing is provided to appeals 
that are filed with only one or two disabling conditions. Under the 
pilot, some VSOs are also waiving the right to a local review of the 
appeal, but preserving the current practice of permitting VSOs to 
review the appeal once it goes before the Board.[Footnote 39] From 
March through June 2012, 2,300 veterans participated in the pilot. 
According to VBA, pilot changes have, based on early results, 
significantly improved processing times. 

Efforts to Improve Records Acquisition Have Produced Mixed Results: 

VBA has established efforts to standardize and expedite the process 
for acquiring medical records of veterans (see fig. 8). According to a 
VBA official, in September 2010, in seven regional offices, VBA began 
the Vendors for Private Medical Records initiative, which uses a 
contractor to obtain veterans' medical records from private 
physicians.[Footnote 40] According to VBA, as of July 2012, the 
contactor had obtained 39,662 treatment records from private medical 
providers. VBA officials at one site told us that the contractor is 
frequently able to communicate with doctors more quickly because 
unlike claims staff who are tasked with multiple duties, the 
contractor focuses solely on obtaining medical records. 

VBA has another effort intended to reduce the amount of time spent 
processing medical documentation. Specifically, physicians are asked 
to complete Disability Benefits Questionnaires (DBQ), which are 
standardized medical forms-downloaded from VA's website--that are 
designed to speed up the evidence gathering process by using check 
boxes and standardized language that are intended to more accurately 
capture information needed from providers.[Footnote 41] The DBQ forms 
have been available since March 2012, and VBA claims staff at the 
sites we visited reported mixed results. For instance, the forms have 
helped to standardize the medical evidence gathering process, but 
regional office claims staff in four of the regional offices we met 
with said that some DBQ forms are quite lengthy, requiring them to 
scan through multiple pages to find certain information, which can be 
time-consuming. Claims staff also reported that some of the medical 
terminology used in the forms is not current, which may make it 
difficult for providers to complete. VBA officials said that 
improvements will be made to the forms when the agency converts to a 
paperless claims system, which might make it easier for claims staff 
to locate information contained in them. VBA has begun to track 
through their performance reporting system the number of DBQs 
completed and the completeness of those submitted by physicians, but 
is not measuring the initiative's impact on timeliness. 

Efforts to Redesign Key Aspects of the Process Are Under Way without a 
Comprehensive Plan: 

In March 2012, VBA implemented a nationwide initiative that requires 
staff to use the Simplified Notification Letter (SNL), a process to 
communicate ratings decisions to veterans.[Footnote 42] According to 
VBA officials, the goal of the SNL is to reduce the time it takes 
claims staff to provide veterans with claims decisions that are more 
consistent and easier to understand. The SNL aims to reduce the time 
that VA staff spend composing rating decisions for claims by providing 
staff with codes that are associated with template language for rating 
decisions instead of the previous practice of composing a free-form 
narrative for each claims decision. According to claims staff at each 
of the regional offices we visited, SNL has decreased the time it 
takes to rate claims, but claims staff in three regional offices told 
us it created additional steps in preparing the decision letter sent 
to the veteran, adding time to the processing awards phase. Claims 
staff we interviewed in one regional office estimated that the time 
needed to authorize a claim had increased from 3 minutes to 15 
minutes. VBA officials said they have provided additional guidance to 
staff experiencing challenges with the SNL. In spite of these 
challenges, VBA reports an increase in production in two regional 
offices that piloted the SNL initiative. 

The Claims Organizational Model initiative is aimed at streamlining 
the overall claims process (see fig. 8). For this initiative, VBA 
created specialized teams that process claims based on their 
complexity. Specifically, an "express team" processes claims with a 
limited number of conditions or issues; a "special operations" team 
processes highly complex claims, such as former prisoners of war or 
traumatic brain injury cases; and a core team works all other claims. 
Each of these teams is staffed with both development and ratings 
staff, which VBA believes will lead to better coordination and 
knowledge-sharing. As of August 2012, VBA had implemented the 
initiative at 18 regional offices.[Footnote 43] Under this model, VBA 
also redesigned the procedures that mailrooms use to sort and process 
incoming claims. According to VBA central office staff, these changes 
entail incorporating more experienced claims staff to improve the 
process of routing incoming mail to the appropriate team and claims 
folder. This change aims to reduce the time it takes for claims-
related mail to be entered into the claims processing systems. VBA 
tracks the impact of the claims process model using existing 
timeliness metrics and regional office performance measures. 

In 2010, VBA began to develop the Veterans Benefits Management System 
(VBMS), a paperless claims processing system that is intended to help 
streamline the claims process and reduce processing times. According 
to VBA officials, VBMS is intended to convert existing paper-based 
claims folders into electronic claims folders that will allow VBA 
employees electronic access to claims and evidence. Once completed, 
VBMS will allow veterans, physicians, and other external parties to 
submit claims and supporting evidence electronically. VBMS is 
currently being piloted in four VA regional offices. Although the most 
recent VBMS operating plan calls for national deployment of VBMS to 
start in 2012, VBA officials told us that VBMS is not yet ready for 
national deployment, citing delays in scanning claims folders into 
VBMS as well as other software performance issues. According to VBA 
officials, the Claims Organizational Model and VBMS will work together 
to reduce processing times and help VA process veterans' claims within 
125 days by 2015. Although VBMS began its pilot in 2010, VBA has not 
yet reported on how VBMS has affected processing times. 

These ongoing efforts should be driven by a robust, comprehensive 
plan; however when we reviewed VBA's backlog reduction plan, we found 
that it fell short of established criteria for sound planning. 
[Footnote 44] Specifically, VBA provided us with several documents, 
including a PowerPoint presentation and a matrix that provided a high-
level overview of over 40 initiatives, but could not provide us with a 
robust plan that tied together the group of initiatives, their inter-
relationships, and subsequent impact on claims and appeals processing 
times. Although there is no established set of requirements for all 
plans, components of sound planning are important because they define 
what organizations seek to accomplish, identify specific activities to 
obtain desired results, and provide tools to help ensure 
accountability and mitigate risks. Some of VBA's planning documents 
identify problems, summarize the overall purpose and goals of the 
redesign effort, and include some general estimates of project 
completion dates for some of the initiatives, as well as identify 
resources for managing the overall implementation efforts. However, 
the planning documents lack key elements of results-oriented planning. 
For example, they do not identify implementation risks or strategies 
to address them. In addition, the planning documents do not include 
performance goals, measures to assess the effectiveness of each 
initiative, or their impact on claims and appeals processing 
timeliness. VBA officials pointed out to us the challenges in 
isolating the impact of any one initiative on processing times. 
Nonetheless, sound practices require assessing the effectiveness of 
each initiative. 

Conclusions: 

VA provides a critical benefit to veterans who have incurred 
disabilities as a result of their military service. For years, VA's 
disability claims and appeals processes have received considerable 
attention as VA has struggled to process disability compensation 
claims in a timely fashion. Despite this attention, VA continues to 
wrestle with several ongoing challenges--some of which VA has little 
or no control over--that contribute to lengthy processing timeframes. 
For instance, the number and complexity of VA claims received has 
increased. And that number is projected to continue to increase as 1 
million servicemembers become veterans over the next 5 years due to 
the drawdown of troops from a decade of conflict in Afghanistan and 
Iraq. Moreover, the evidence gathering phase in fiscal year 2011, 
which took over 5 months (157 days) on average, continues to worsen in 
2012, partly due to difficulties in obtaining records for National 
Guard and Reserve and SSA medical records, according to VBA officials. 
While recent process and technology improvements hold some promise, 
without improved evidence gathering, VBA may struggle to meet its goal 
of processing all compensation claims within its 125 day goal by 2015. 
Although VBA is attempting to address processing challenges through 
various improvement initiatives, without a comprehensive plan to 
strategically manage resources and evaluate the effectiveness of these 
efforts, the agency risks spending limited resources on initiatives 
that may not speed up disability claims and appeals processes. This 
may, in turn, result in forcing veterans to continue to wait months 
and even years to receive compensation for injuries incurred during 
their service to the country. 

Recommendations for Executive Action: 

We recommend the Secretary of Veterans Affairs direct the Veterans 
Benefits Administration to: 

1. Develop improvements for partnering with relevant federal and state 
military officials to reduce the time it takes to gather military 
service records from National Guard and Reserve sources. 

2. Develop improvements for partnering with Social Security 
Administration officials to reduce the time it takes to gather medical 
records. 

3. Ensure the development of a robust backlog reduction plan for VBA's 
initiatives that, among other best practice elements, identifies 
implementation risks and strategies to address them and performance 
goals that incorporate the impact of individual initiatives on 
processing timeliness. 

Agency Comments and Our Evaluation: 

VA provided us with comments on a draft of this report, which are 
reprinted in appendix IV. In its comments, VA stated it generally 
agreed with our conclusions and concurred with our recommendations, 
and summarized efforts that are planned or underway to address the 
recommendations. Specifically, VA agreed with our recommendation to 
partner with relevant federal and state military officials to develop 
improvements to reduce the time it takes to gather military service 
records for National Guard and Reservists. VA stated it has recently 
initiated several interagency efforts to improve receipt of military 
service records. According to VA, on December 3, 2012, the joint VBA 
and DOD Disability Claims Reduction Task Force met to begin to 
evaluate the process to request records, among other issues, with the 
aim of improving the timeliness of record exchanges between the two 
agencies. In addition, VA stated that the joint VA-DOD Virtual 
Lifetime Electronic Record initiative is focused on developing a 
complete electronic health record for each servicemember that will be 
transmitted to VA upon the service member's military discharge, 
including National Guard and Reservists. VA identified a targeted 
completion date of November 2013. We believe these initiatives are 
heading in the right direction in order to improve the timeliness of 
meeting VA requests for National Guard and Reservists records. 

VA agreed with our recommendation to work with SSA officials to 
develop improvements to reduce the time it takes to gather SSA medical 
records. VA stated that it is working with SSA to pilot a web-based 
tool to provide VA staff a secure, direct communication with SSA staff 
and to automate VA's requests for SSA medical records. VA officials 
did not mention this pilot during the course of our data collection 
and it was not included on the agency's list of efforts to improve 
claims and appeals processing initiatives provided to us. VA 
identified a targeted completion date of November 2013. 

VA agreed with our recommendation to develop a robust backlog plan for 
VBA's initiatives that, among other elements, identifies 
implementation risks and strategies as well as performance goals that 
incorporate the impact of individual initiatives on processing 
timeliness. VA describes a number of approaches it has taken to 
address our recommendation. Most relevant are the Transformation Plan, 
which was provided to us during the data collection phase and which we 
determined fell short of established criteria for sound planning, and 
the Operating Plan, which was not mentioned during the course of our 
data collection. According to VA, the operating plan, currently under 
development, will focus on: (1) integration of people, process, and 
technology initiatives, (2) identification of new ways to improve 
efficiency and reengineer the claims process, (3) efforts to automate 
the current paper-based claims process, and (4) the measurement 
process. However, it is unclear at this time how the key elements of 
the operating plan will better position VA to address our 
recommendation. Moreover, without further information on how the 
operating plan will focus on the measurement process, it is difficult 
for us to determine at this time if VA will sufficiently address our 
recommendation to include performance goals that incorporate measuring 
the impact of individual initiatives to processing timeliness. 

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 28 days 
from its issue date. At that time, we will send copies of this report 
to the appropriate congressional committees, the Secretary of Veterans 
Affairs, and other interested parties. In addition, the report will be 
made available at no charge on GAO's website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me 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 report. GAO staff who made key contributions 
to this report are listed in appendix V. 

Signed by: 

Daniel Bertoni: 
Director, Education, Workforce, and Income Security Issues: 

List of Requesters: 

The Honorable Jeff Miller: 
Chairman: 
Committee on Veterans' Affairs: 
House of Representatives: 

The Honorable Karen Bass: 
House of Representatives: 

The Honorable Shelley Berkley: 
House of Representatives: 

The Honorable Howard L. Berman: 
House of Representatives: 

The Honorable Brian P. Bilbray: 
House of Representatives: 

The Honorable Mary Bono Mack: 
House of Representatives: 

The Honorable Ken S. Calvert: 
House of Representatives: 

The Honorable John Campbell: 
House of Representatives: 

The Honorable Lois Capps: 
House of Representatives: 

The Honorable Judy Chu: 
House of Representatives: 

The Honorable Jim Costa: 
House of Representatives: 

The Honorable Susan Davis: 
House of Representatives: 

The Honorable David Dreier: 
House of Representatives: 

The Honorable Elton Gallegly: 
House of Representatives: 

The Honorable Joe Heck: 
House of Representatives: 

The Honorable Duncan D. Hunter: 
House of Representatives: 

The Honorable Darrell Issa: 
House of Representatives: 

The Honorable Jerry Lewis: 
House of Representatives: 

The Honorable Kevin McCarthy: 
House of Representatives: 

The Honorable Howard P. McKeon: 
House of Representatives: 

The Honorable Gary Miller: 
House of Representatives: 

The Honorable Grace Napolitano: 
House of Representatives: 

The Honorable Laura Richardson: 
House of Representatives: 

The Honorable Dana Rohrabacher: 
House of Representatives: 

The Honorable Lucille Roybal-Allard: 
House of Representatives: 

The Honorable Ed Royce: 
House of Representatives: 

The Honorable Loretta Sanchez: 
House of Representatives: 

The Honorable Adam Schiff: 
House of Representatives: 

The Honorable Brad Sherman: 
House of Representatives: 

The Honorable Henry A. Waxman: 
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This report examines the (1) factors that contribute to lengthy 
processing times for disability claims and appeals at the Department 
of Veterans Affairs (VA) and (2) status of the Veteran Benefits 
Administration's (VBA) recent efforts to improve disability claims and 
appeals processing timeliness. 

To examine factors that contribute to lengthy processing times for 
disability claims and appeals, we reviewed past GAO and VA Office of 
Inspector General (OIG) reports and other relevant studies on VA's 
claims and appeals processing, such as the Veterans' Disability 
Benefits Commission's 2007 report, Honoring the Call to Duty: 
Veterans' Disability Benefits in the 21st Century.[Footnote 45] We 
reviewed congressional testimonies, federal statutes, relevant court 
decisions, and policy manuals and documents, including VA's Web 
Automated Reference Manual System to understand the program rules and 
procedures that govern the claims and appeals processes. We also 
analyzed disability compensation and pension rating claims processing 
data from VBA's internal dashboard and data on claims processing 
resources from VBA's Personnel and Accounting Integrated Database. 
Moreover, we interviewed VBA officials, including VBA area directors, 
the Office of Field Operations, Compensation Service, and the Office 
of Performance Analysis and Integrity to gain a national perspective 
on factors affecting the timeliness of claims and appeals processing. 
To identify factors within VA regional offices that contribute to 
lengthy processing times, we conducted reviews of five VA regional 
offices--Atlanta, Georgia; Houston, Texas; Los Angeles, California; 
New York, New York; and Philadelphia, Pennsylvania. These reviews 
consisted of interviewing regional office management and claims 
processing staff and supervisors, reviewing workload management and 
performance documents, and reviewing written notifications sent to 
veterans. We did not conduct case file reviews in these regional 
offices. We also spoke with representatives of Veterans Service 
Organizations (VSO) in Los Angeles and in Washington, D.C. to gather 
perspectives of veterans' representatives on challenges in the claims 
and appeals processes. 

To examine the status of VBA's recent efforts to improve disability 
claims and appeals processing timeliness, we reviewed past GAO and VA 
OIG reports and congressional testimonies. We conducted interviews 
with officials from the VBA Implementation Center, Office of Strategic 
Planning and Office of Field Operations. Also, during our review of 
five VA regional offices, we interviewed claims and appeals processing 
staff about their experiences with VBA's initiatives. To identify 
which VBA efforts were designed to improve timeliness, we reviewed 
documents providing an overview of the efforts, which included 
documentation identifying the purpose of each effort. We requested 
additional information for those initiatives that VBA identified as 
having the purpose of reducing disability claims and appeals 
processing times. Furthermore, we selected a sample of nine of VBA's 
efforts identified as having the purpose of reducing disability claims 
and appeals processing times for further review primarily based on 
interviews with VBA officials and a review of recent VA testimonies. 
In addition, we spoke with representatives of national VSOs to gather 
their perspectives on the impact on the veterans they represent of 
recent and ongoing efforts. (For more information on VBA's improvement 
efforts, see appendix III). 

Analysis of VBA Claims and Appeals Processing Timeliness and Resource 
Data: 

To assess VBA disability claims workload and processing timeliness, we 
obtained monthly regional office and national data from VBA's internal 
dashboard, which aggregates key metrics used to assess performance 
from a variety of data sources into one integrated tool. We limited 
our analysis to timeliness and workload metrics used to measure the 
performance of the disability compensation and pension rating claims 
and appeals processing. We analyzed data from fiscal year 2009 through 
August 2012. To verify the reliability of VBA's internal dashboard, we 
conducted interviews with officials from VBA's Office of Performance 
Analysis and Integrity about quality control procedures of VBA's 
internal dashboard and practices used to extract timeliness and 
workload data from underlying data sources. We relied on past GAO data 
reliability assessments on the Veterans Services Network (VETSNET) 
system and accompanying VETSNET Operations Reports (VOR), and the 
Veterans Appeals Control and Locator System (VACOLS), where enterprise-
wide workload and timeliness of claims and appeals processing data, 
respectively, are stored and extracted into the internal dashboard 
tool. We found the dashboard data to be reliable for reporting 
regional office and national workload and timeliness trends. 

To analyze VBA's claims and appeals processing resources, we obtained 
data from VA's Personnel and Accounting Integrated Database and 
accompanying ProClarity system. We limited our analysis to data on VBA 
job titles that typically include claims or appeals processing 
responsibilities--Veterans Service Representatives (VSR), Rating 
Veterans Service Representatives (RVSR), and Decision Review Officers 
(DRO)--from fiscal years 2009 through 2012. We reviewed data on full-
time equivalents (FTE), number of employees, and personnel actions. To 
assess the reliability of these data, we interviewed officials in 
VBA's Office of Human Resources about practices to record personnel 
actions, quality control procedures conducted within the Office of 
Human Resources to ensure the quality of the data, as well as 
potential limitations to the data. We found the data provided to us by 
the Office of Human Resources reliable for reporting on claims and 
appeals processing resources. 

Selection of VA Regional Offices for Review: 

We selected five VA regional offices for review to gather information 
on the challenges these selected regional offices face in not only 
processing disability claims and appeals in a timely fashion, but also 
in implementing initiatives designed to address processing timeliness. 
Our five selected sites, which account for 15 percent of all 
disability compensation and pension rating claims, were Atlanta, 
Georgia; Houston, Texas; Los Angeles, California; New York, New York; 
and Philadelphia, Pennsylvania. We conducted site visits with the Los 
Angeles, Philadelphia, and Atlanta regional offices and 
teleconferences with the New York and Houston regional offices. 

We selected regional offices for review based on the following 
criteria: 

* Geography: We selected at least one VA regional office in each of 
VBA's four areas. The New York and Philadelphia regional offices are 
in the Eastern Area, Atlanta is in the Southern Area, Houston is in 
the Central Area, and Los Angeles is in the Western Area. 

* Size of metropolitan area: We limited our selection process to 
regional offices in the Top 15 Metropolitan Statistical Areas (MSA) 
according to 2010 Census data, due to concerns about the ability of 
these offices to recruit and retain staff and upper management. 

* Workload: We selected VA regional offices with medium or high 
disability compensation and pension rating claims workloads. All 
regional offices in the top 15 MSAs had more than 10,000 disability 
compensation and pension rating claims pending. According to VBA's 
internal dashboard, the median regional office had 8,850 disability 
compensation and pension rating claims pending as of April 2012. The 
sites we selected had workloads ranging from 15,874 to 37,805 pending 
disability compensation and pension rating claims in April 2012. 

* Timeliness: To examine the timeliness of claims processing at VA 
regional offices, we examined two metrics: the percentage of 
backlogged disability compensation and pension rating claims--defined 
as claims pending over 125 days-and the average number of days a 
disability compensation and pension rating claim was pending. 
According to VBA's internal dashboard, 65.6 percent of disability 
compensation claims nationally were pending over 125 days in April 
2012. For the regional offices we selected, the percent of backlogged 
claims ranged from 61.6 percent to 79.9 percent. Claims were pending 
an average 243.2 days nationally. For the regional offices we 
selected, the average days pending ranged from 219.6 days to 325.3 
days. 

We conducted this performance audit from March 2012 through December 
2012 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 that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Veteran Notification during the Claims and Appeals 
Processes: 

After VBA receives a disability claim, it generally sends 
notifications to veterans to either help gather evidence or to let 
them know that a decision has been made (see fig. 9). Throughout the 
claims process, VBA sends a standard form letter at the 60-, 120-, and 
180-day marks, as applicable, to inform the veteran that VBA has 
received the claim and that the claim is still pending. During the 
initiating development phase, VBA sends the Veteran Claims Assistance 
Act (VCAA) letter acknowledging receipt of the claim, explaining the 
claims process, and outlining what additional information is needed 
and what steps VBA will take to substantiate the claim. Much of the 
notification to veterans occurs during the evidence gathering phase. 
During this phase, VBA sends the veteran a notification every time VBA 
makes an attempt to obtain additional evidence or when attempts to 
obtain evidence have been unsuccessful. Finally, at the end of the 
award processing phase, a decision letter is sent to the veteran. 

Figure 9: VBA Notifications to Veterans throughout the Claims Process: 

[Refer to PDF for image: illustration] 

Veteran submits claim: 

Establishing claim: 
Confirmation letter sent within 60 days of claim, notifying veteran
VA is determining if more information is needed to substantiate claim; 
If needed, another letter is sent at 120 days; and, if needed a third
letter is sent at 180 days. 

Initiating development: 
Veterans Claims Assistant Act (VCAA) letter sent to explain VA process 
and ask for any information needed to substantiate veteran's claim. 

Evidence gathering: 
Development letter sent any time claim needs more information or 
substantiating evidence from veteran;   
A follow-up development letter sent if VA's request for more evidence 
goes unanswered. 

Rating decision: 
Examination scheduling letter sent if a medical exam is needed to 
substantiate claim. 

Processing award: 
Decision letter sent to veteran explaining why VA granted or denied 
the veteran's claim. 

Source: GAO analysis of VA procedures. 

[End of figure] 

During the appeals process, VBA generally reaches out to veterans when 
additional evidence or the veteran's input is needed, or to announce 
and explain a decision. The appeals process generally begins when a 
veteran disagrees with VA's decision on their disability claim, and 
files a Notice of Disagreement (see fig. 10). If the veteran does not 
specify the type of review in the Notice of Disagreement, VBA sends an 
election letter that details the differences between a traditional and 
DRO review and asks the veteran to choose a review process. Once a 
veteran indicates the type of review desired, VBA sends a process 
letter that explains the review process chosen and details the 
veteran's rights throughout the appeals process.[Footnote 46] Then, if 
additional evidence is needed to make a decision, such as ordering 
another Veterans Health Administration (VHA) examination, VBA sends 
notifications to the veteran throughout the evidence gathering 
process, similar to the initial claims process. Once all additional 
evidence is gathered, VBA will review the case. If VBA grants the 
appeal in full, a decision letter is sent. If VBA denies the appeal or 
does not grant the appeal in full, it sends a Statement of the Case 
(SOC) explaining the decision. At this point, the veteran has the 
option to send in additional evidence, which VBA must consider, and if 
this evidence does not lead to a full grant, then VBA must send a 
Supplemental Statement of the Case (SSOC) explaining their decision. 

Figure 10: VBA Notifications to Veterans throughout the Appeals 
Process: 

[Refer to PDF for image: process illustration] 

Notice of Disagreement (NOD): 

Veteran specifies review type: 
Process letter sent to veteran explaining what happens next depending 
on which type of review (traditional or DRO) veteran specified in NOD; 
or: 
Veteran doesn't specify review type: 
Election letter sent explaining the differences and asking veteran to 
select a traditional or DRO review; 
Appropriate process letter (traditional or DRO). 

Evidence Review: 

Veteran can add additional evidence at any time; 
Development letter; 
Follow-up development letter; 
Examination scheduling letter, 

Award Decision: 

Appeal denied or only partially denied: 
Statement of the Case (SOC) is sent to explain VA's reasoning and 
detail the veteran's remaining appeal rights; 
Supplemental State of the Case (SSOC): If additional evidence is 
submitted by the veteran either 60 days after the SOC or within 1 year 
of the NOD, VA considers the new evidence and sends an SSOC if full 
grant is not awarded. 

Full grant awarded: 
Award letter. 

Substantive appeal. 

Certify to board: 
Certification letter sent to veteran when the regional office 
certifies that the appeal is ready for review by the Board. 

Decision Review Officer (ORO) hearing notice sent to veteran whenever 
a DRO hearing is requested, which can happen at any time during the 
appeals process. 

Source: GAO analysis of VA procedures. 

Note: If the veteran chooses the traditional review, the reviewer, who 
may be a RVSR or DRO, examines the claim file and any new evidence that 
the veteran submits and may hold a formal, transcribed hearing with the 
veteran. The reviewer may overturn the original decision based only on 
(1) new evidence or (2) a clear and unmistakable error made in the 
original decision. However, if a veteran chooses the DRO review, a DRO 
conducts a de novo review of the claim, meaning a new and complete 
review without deference to the original decision, and can revise that 
decision without new evidence or a clear and unmistakable error--in 
other words, based on a difference of opinion. 38 C.F.R. §3.2600. 

[End of figure] 

In addition to receiving written notifications during the claims and 
appeals processes, veterans can proactively learn about the status of 
their claims in several ways. For example, veterans can use eBenefits, 
a website that VA and the Department of Defense launched in 2009 to 
help servicemembers and veterans manage their benefits and personal 
information. Veterans can also speak with staff in VA's national call 
center or can contact VA through VA's web-based Inquiry Routing and 
Information System (IRIS). Veterans can also visit a VA regional 
office to speak with VA public contact staff. 

[End of section] 

Appendix III: Selected VBA Efforts to Improve Claims and Appeals 
Timeliness: 

According to VBA, there are currently over 40 ongoing improvement 
efforts that are tracked by VBA's Implementation Center. Below is a 
list of 15 improvement efforts we identified as having a stated 
purpose of improving timeliness of claims or appeals processing, based 
on a review of VA documents and interviews with VBA officials. 

Table 1: Selected VBA Efforts to Improve Claims and Appeals Timeliness: 

VBA effort: Acceptable Clinical Evidence (ACE) Pilot; 
Description: The ACE process allows a VHA clinician to complete a 
Disability Benefit Questionnaire in lieu of conducting a medical exam 
if a veteran's existing medical record contains sufficient evidence; 
Purpose: To improve the timeliness of obtaining medical examinations; 
Status: Piloted in one regional office; 
Selected for in-depth review by GAO: No. 

VBA effort: Agent Orange Development Assistance ("Fast Track"); 
Description: The Fast Track Claims Processing System is an accelerated 
claims process dedicated to Vietnam veterans who are diagnosed with an 
Agent Orange presumptive condition, such as ischemic heart disease, 
hairy cell and other B-cell leukemias, and Parkinson's disease; 
Purpose: To reduce average days to complete Agent Orange claims; 
Status: Implemented nationally in October 2010; 
Selected for in-depth review by GAO: No. 

VBA effort: Appeals Design Pilot; 
Description: The Appeals Design Pilot 
has made several changes to the appeals process during the pilot 
including: 
* Creating an express lane for appeals with one or two issues; 
* Developing a standard Notice of Disagreement form; 
* Obtaining waivers from veterans to allow VBA to expedite their 
substantive appeal directly to the Board of Veterans' Appeals without 
having the regional office review new evidence submitted; 
* Conducting Decision Review Officer (DRO) reviews for all appeals; 
* Proactive phone outreach to veterans to reduce the need for formal 
DRO hearings; and; 
* Obtaining waivers of local VSO review period prior to certifying 
the appeal to the Board of Veterans Appeals; 
Purpose: To improve appeals processing timeliness; 
Status: Pilot stage began in March 2012; 
Selected for in-depth review by GAO: Yes. 

VBA effort: Brokering centers; 
Description: The brokering process is used to manage workload across 
regional offices by permitting a regional office to shift claims 
either to another regional office or to a specialized brokering center 
for processing; 
Purpose: To reduce workload at regional offices experiencing 
processing delays; 
Status: Implemented nationally in 2001; 
Selected for in-depth review by GAO: Yes. 

VBA effort: Claims Organizational Model; 
Description: The Claims Organizational Model streamlines the claims 
process by organizing claims staff into cross-functional teams, 
creating segmented lanes based on type and complexity of claims, and 
standardizing the mail triage and sorting process in an integrated 
mail processing center; 
Purpose: To reduce the average days to complete claims by 40 days; 
Status: Implemented at selected regional offices; national 
implementation scheduled for completion by end of fiscal year 2013; 
Selected for in-depth review by GAO: Yes. 

VBA effort: Disability Benefits Questionnaire (DBQ); 
Description: DBQs are standard checklists that VA asks physicians to 
fill out instead of preparing a narrative report of an examination; 
Purpose: To increase the use of standard evaluation forms to speed up 
claims determination; 
Status: Implemented nationally in March 2012; 
Selected for in-depth review by GAO: Yes. 

VBA effort: Fully Developed Claims (FDC); 
Description: The FDC initiative expedites processing of claims 
submitted by veterans who submit all relevant private medical evidence; 
Purpose: To reduce the average days to complete a decision by 140 days; 
Status: Implemented nationally in May 2010; 
Selected for in-depth review by GAO: Yes. 

VBA effort: Immersion Teams; 
Description: Management teams from high performing offices observe low 
performing offices and help codify best practices to help the low 
performing offices improve; 
Purpose: To improve regional office performance management; 
Status: Implemented in four regional offices in October 2011; 
Selected for in-depth review by GAO: No. 

VBA effort: National Level Challenge Training; 
Description: Challenge training is a course designed for newly-
assigned claims processing staff. In 2011, the curriculum was 
redesigned to lengthen the training period and incorporate the hands-
on instruction previously conducted within regional offices into 
training at centralized sites. Additionally, challenge training is 
sometimes used to retrain experienced staff as well; 
Purpose: To increase the number and accuracy of completed claims per 
claims processing staff FTEs; 
Status: Implemented nationally in fiscal year 2011; 
Selected for in-depth review by GAO: No. 

VBA effort: Proactive Phone Development; 
Description: In place of writing letters to gather evidence, VBA will 
use phone calls to speed the development process and clarify veteran 
information/requests; 
Purpose: To decrease average days to completion of a claim; 
Status: Implemented nationally in May 2010; revised in March 2012; 
Selected for in-depth review by GAO: No. 

VBA effort: Simplified Notification Letter (SNL); 
Description: SNL is a standardized process that integrates decision 
information into one simplified letter for veterans; 
Purpose: To increase the number of claims rated per year by 250,000; 
Status: Implemented nationally in March 2012; 
Selected for in-depth review by GAO: Yes. 

VBA effort: Timeliness Performance Standards; 
Description: One VA regional office has an effort to improve 
timeliness by changing individual performance goals for claims staff 
by incorporating timeliness goals into their performance goals; 
Purpose: To improve timeliness of claims processing; 
Status: Implemented at the one regional office in March 2012; 
Selected for in-depth review by GAO: No. 

VBA effort: Vendors for Private Medical Records; 
Description: Vendors for Private Medical Records is an initiative in 
which a contractor collects medical records from private physicians; 
Purpose: To reduce average record collection time from 40 days to 7-10 
days and substantially increase physician response rate; 
Status: Piloted at seven regional offices since September 2010; 
Selected for in-depth review by GAO: Yes. 

VBA effort: Veterans Benefits Management Assistance Program (VBMAP); 
Description: VBMAP is an effort to manage workload by permitting a 
regional office to shift a pre-determined number of claims to a 
contractor for evidence gathering; 
Purpose: To reduce evidence gathering workload at regional offices; 
Status: Implemented nationally; contract began in September 2011; 
Selected for in-depth review by GAO: Yes. 

VBA effort: Veterans Benefit Management System (VBMS); 
Description: VBMS is an effort to design a paperless file system and 
implement rules-based claims development tools to help aid ratings 
decisions; 
Purpose: To decrease the average days to complete a claim; 
Status: Partially implemented; plans to implement nationally in 2013; 
Selected for in-depth review by GAO: Yes. 

Source: GAO analysis of VBA documentation and interviews with VBA 
officials. 

Note: Primarily based on a review of VA documents and interviews with 
VBA officials, we selected for review a sample of 9 VBA efforts (out of 
15) that have the purpose of reducing disability claims and appeals 
processing times. 

[End of table] 

Appendix IV: Comments from the Department of Veterans Affairs: 

Department of Veterans Affairs: 
Washington DC 20420: 

December 10, 2012: 

Mr. Daniel Bertoni: 
Director, Education, Workforce, and Income Security Issues: 
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' Disability 
Benefits: Timely Processing Remains a Daunting Challenge" (GAO-13-89). 
VA generally agrees with GAO's conclusions and concurs with GAO's 
recommendations to the Department. 

The enclosure specifically addresses GAO's recommendations and 
provides technical comments to the draft report. VA appreciates the 
opportunity to comment on your draft report. 

Sincerely, 

Signed by: 

John R. Gingrich: 
Chief of Staff: 

Enclosure 

[End of letter] 

Enclosure: 

Department of Veterans Affairs (VA) Comments to Government 
Accountability Office (GAO) Draft Report "Veterans' Disability 
Benefits: Timely Processing Remains a Daunting Challenge" (GAO-13-89): 

Recommendation 1: Develop improvements for partnering with relevant 
federal and state military officials to reduce the time it takes to 
gather military service records for National Guard and Reserve sources. 

VA Response: Concur. VA has initiated several interagency efforts to 
improve its receipt of military service records. First, VA will 
include separating Reserve and National Guard members in its 
implementation of the Seamless Transition provisions of "VOW (Veterans 
Opportunity to Work) to Hire Heroes Act of 2011." VA's Transition 
Assistance Program already covers these members, and allows them to 
start the claims process before leaving service. Veterans and their 
survivors are also eligible to participate in the Veterans Benefits 
Administration's (VBA) fully developed claims program, under which VBA 
may expedite claims that are submitted with all the necessary evidence 
to support a claim. 

Furthermore, on December 3, 2012, a joint VBA and Department of 
Defense (DoD) Disability Claims Reduction Task Force began examining 
VBA's oldest claims awaiting responses to military service records 
requests. The group will coordinate with Federal records storage 
facilities and the military services to expedite receipt of the 
requested records. In addition, the group will evaluate current 
requests and exchange processes and develop strategies for improved 
records exchanges. 

An additional joint VA-DoD Virtual Lifetime Electronic Record (VLER) 
initiative is specifically tasked with improving information sharing 
amongst Federal partners, to include the National Guard and Reserve 
components. The effort is focusing on enabling DoD to generate a 
complete electronic health record for each Servicemember and 
transmitting it to VA upon discharge. Recently, VA successfully tested 
the VLER components designed to enable DoD to send medical records to 
VA. Additionally, the two agencies are working together to implement 
solutions specifically focused on the Guard and Reserve components. 
Targeted Completion Date: November 30, 2013. 

Recommendation 2: Develop improvements for partnering with SSA 
officials to reduce the time it takes to gather Social Security 
Administration (SSA) medical records. 

VA Response: Concur. VA is currently working closely with SSA in 
several different ways as part of its ongoing efforts to streamline 
the claims adjudication process. VA and SSA have partnered via the SSA 
Government Services Online initiative to pilot a Web-based tool that 
will allow VA personnel to communicate directly with SSA
personnel regarding records requests. This will further VA's goal of 
establishing a paperless environment by automating VA requests for SSA 
medical records through a secure, electronic messaging system. In 
addition, SSA has agreed to eliminate VA-provided records from the 
materials it sends to VA, thereby reducing the amount of duplicate 
records that VA adjudicators must review when deciding a claim. 

Finally, on October 4, 2012, senior SSA officials traveled to VBA 
headquarters in Washington, DC, to learn about VBA's programs and 
transformation plan. On November 16, 2012, senior VBA officials 
traveled to SSA headquarters in Baltimore to hear about lessons 
learned in SSA's transformation. The agencies plan to expand these 
meetings to address specific transformation or program-related issues 
that will facilitate VBA's efforts to eliminate the backlog of 
compensation claims. Targeted Completion Date: November 30, 2013. 

Recommendation 3: Ensure the development of a robust backlog reduction 
plan for VBA's initiatives that, among other best elements, identifies 
implementation risks and strategies to address them and performance 
goals that incorporate the impact of individual initiatives on 
processing timeliness. 

VA Response: Concur. VBA has drafted a plan that is in coordination 
for transforming the processing of disability claims. 

1. Background — Transformation Ideas Identified: 

Starting in 2009, when the Secretary of VA approved the initial 
strategic plan for the Department, VBA encouraged its employees and 
stakeholders to identify and evaluate opportunities to achieve the 
Department's strategic goals. Hundreds of ideas were identified, 
including many from the employees in the Regional Offices (RO) who had 
first-hand, field-based experience and solutions to the challenges and 
opportunities posed in transforming the claims process. From hundreds of
people, process, and technology ideas, VBA selected those with the 
highest transformative impact in supporting VA's priority goal to 
eliminate the backlog in 2015, and process all disability claims in 
125 days or less at a 98-percent accuracy level. 

2. VBA Transformation Plan: 

a. In 2011, VBA created a Transformation Plan that included people, 
process, and technology transformation initiatives designed to improve 
claims production and enhance quality to achieve VA's claims 
processing goal. The Transformation Plan was an illustrative 
presentation including charts, graphs, and briefing slides describing 
our transformation efforts. This Transformation Plan was provided to 
GAO in support of this report. 

b. This Transformation Plan presents the "To Be" compensation claims 
model and contrasts it to the "As Is" model; improves capacity to 
support access, outreach, and services; and addresses the integration 
of people, process, and technology initiatives and expected 
performance and quality improvement. 

3. VBA Common Operating Picture: 

a. In 2012, as requested by external stakeholders, VA and VBA 
transformation continued to evolve, including the creation of an 
operating plan (the common operating picture) with the goal of 
eliminating the compensation claims backlog in 2015. The plan is 
awaiting official release. The plan focuses on: 

(1) Integration of people, process, and technology initiatives to 
address the way we are organized and trained to do claims work; 

(2) New ways to improve efficiency, and reengineer the claims process; 

(3) Automation to speed the largely manual paperbound claims process 
of today; and; 

(4) Measurement process. 

b. The complicating factors and risks that could impact the plan's new 
production capacity include potential growth in demand caused by the 
VOW Act/Veterans Employment Initiative, and the impact of Camp Lejeune 
environmental exposure on Veterans and their families. 

c. Key performance measures for the Transformation Plan include 
quality, number of claims received, number of claims completed 
(nationally and individually), productivity, claims pending over 125 
days (number and percent), average days to complete, and average days 
pending, as well as performance modeled against expected gains by 
initiatives within the plan. 

4. VBA Governance Process: 

The identification of these initiatives required VBA to further evolve
transformation and change-management activities by establishing a VBA 
Transformation Governance Board and process. Our governance process is 
designed to ensure that changes to VBA operations and services from 
these initiatives are implemented in a standardized, structured, and 
sustainable manner to improve accuracy and reduce the amount of time 
it takes to process Veterans' disability benefit claims, increase 
access to services and benefits, and end Veteran homelessness in 2015. 

5. VBA's Implementation Center (IC): 

In August 2011, VBA established the IC as a program management office 
streamlining the process of transformation by ensuring new ideas are 
approved through the governance process, and implementation and 
training are carefully planned and executed utilizing a comprehensive 
change management approach. This allows us to focus on implementing 
initiatives that will achieve the greatest gains in a standardized 
manner without impacting current performance. 

6. Moving Forward: 

Moving forward in 2013 and beyond, VBA transformation will continue to 
evolve and change the manner in which VBA delivers benefits. VBA's 
transformation is a people-centric, results-driven, and forward-
looking integration of solutions that will ensure total lifelong 
engagement with Servicemembers, Veterans, their families, and 
survivors. 

Targeted Completion Date: VBA transformation actively continues. The 
release of the updated common operating picture is pending completion 
of the coordination process. 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO contact: 

Daniel Bertoni, Director, Education Workforce and Income Security, 
bertonid@gao.gov, 202-512-7215: 

Staff Acknowledgments: 

In addition to the contact named above, Brett Fallavollita (Assistant 
Director); Lucas Alvarez; Michelle Bracy; and Ryan Siegel made key 
contributions to this report. In addition, key support was provided by 
James Bennett, Robert Campbell, Susan Chin, James Rebbe, Almeta 
Spencer, Kathleen van Gelder, and Walter Vance. 

[End of section] 

Related GAO Products: 

VA Disability Compensation: Actions Needed to Address Hurdles Facing 
Program Modernization. [hyperlink, 
http://www.gao.gov/products/GAO-12-846]. Washington, D.C.: September 
10, 2012. 

VA Enhanced Monthly Benefits: Recipient Population Is Changing, and 
Awareness Could Be Improved. [hyperlink, 
http://www.gao.gov/products/GAO-12-153]. Washington, D.C.: December 
14, 2011. 

Veterans Disability Benefits: Clearer Information for Veterans and 
Additional Performance Measures Could Improve Appeal Process. 
[hyperlink, http://www.gao.gov/products/GAO-11-812]. Washington, D.C.: 
September 29, 2011. 

Information Technology: Department of Veterans Affairs Faces Ongoing 
Management Challenges. [hyperlink, 
http://www.gao.gov/products/GAO-11-663T]. Washington, D.C.: May 11, 
2011. 

GAO's 2011 High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-11-394T]. Washington, D.C.: February 
17, 2011. 

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. 

Social Security Disability: Additional Outreach and Collaboration on 
Sharing Medical Records Would Improve Wounded Warriors' Access to 
Benefits. [hyperlink, http://www.gao.gov/products/GAO-09-762]. 
Washington, D.C.: September 16, 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' 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. 

[End of section] 

Footnotes: 

[1] From the beginning of fiscal year 2012 through August 2012, which 
was the most recent data available at the time of publishing, the 
average number of days it took VA to complete a claim was 260 days. 

[2] Compensation rating claims include pension rating and disability 
compensation rating claims. Workload and timeliness data provided to 
us by VBA include all compensation rating claims. Furthermore, VBA 
does not report out on disability rating compensation claims 
separately. 

[3] VBA's internal dashboard is a data report that aggregates key 
metrics that are used to assess performance from a variety of data 
sources into one integrated tool. 

[4] 38 U.S.C. §§ 1110, 1155. VA's ratings are awarded in 10 percent 
increments, from 0 to 100 percent. Generally, VA does not pay 
disability compensation for disabilities rated at 0 percent. As of 
December 2011, basic monthly payments ranged from $127 for a veteran 
with 10 percent disability and no dependents to $ 3,285 for a veteran 
with 100 percent disability and dependents. 

[5] 38 U.S.C. § 1115. 

[6] 38 U.S.C. § 7105. A Notice of Disagreement is a written 
communication that a claimant uses to express disagreement with a 
decision. 

[7] If VBA grants some, but not all, of the issues in an appeal or if 
the grant is less than the maximum allowable benefit for the issues 
under appeal, VBA must send a written explanation of the reasons for 
the decision. VBA is also obligated to send a letter explaining the 
decision in cases where the veteran's appeal includes a request to be 
rated at a specific percentage, but VBA has decided to grant the 
appeal at less than that requested percentage. 

[8] 38 U.S.C. §§ 7252 and 7292. 

[9] Pub. L. No. 106-475, 114 Stat. 2096, amending various provisions 
of Chapter 51 of title 38, U.S. Code. 

[10] 38 U.S.C. § 5102(b). 

[11] 38 U.S.C. § 5103(a). 

[12] 38 U.S.C. §§ 5103A(a)(1) and 5103A(b)(1). 

[13] 38 U.S.C. § 5103A(b)(2). 

[14] 38 C.F.R. § 3.159(c)(2). 

[15] VBA calculates the Average Days Pending for a fiscal year on the 
last day of the year and for the month on the last day of every month. 
The Average Days to Complete measures the average processing time for 
claims completed within a given time period. 

[16] VBA was required to adjudicate these claims as a result of 
requirements related to the Nehmer litigation. Nehmer v. U.S. 
Department of Veterans Affairs, Civ. Action No. 86-6160 (N.D. Cal.). 
In the preamble to a proposed rule amending its claim adjudication 
regulations (75 Fed. Reg. 14,391 (March 25, 2010)), VA summarized the 
Nehmer litigation generally as follows: this litigation was initiated 
in 1986 to challenge a VA regulation, which has since been rescinded, 
that limited the diseases shown to be associated with herbicide 
exposure. In an order issued May 3, 1989, the court invalidated the 
portion of the regulation that limits diseases associated with 
herbicide exposure and voided all VA decisions denying benefit claims 
under that portion of the regulation. Nehmer v. United States 
Veterans' Administration, 712 F. Supp. 1404 (N. D. Cal. 1989). 
Pursuant to a stipulation agreed to by the parties, VA must provide 
for readjudication of class members' claims and payment of retroactive 
benefits whenever VA identifies a new disease that is associated with 
herbicide exposure and adds a new disease to its regulatory list. In 
addition, pursuant to the Agent Orange Act of 1991, VA is required to 
issue new regulations establishing additional presumptions of service 
connection for diseases that the Secretary finds to be associated with 
exposure to an herbicide agent. 38 U.S.C. § 1116(b). Accordingly, VA 
amended its adjudication regulations in August 2010 to establish 
presumptive service connection for ischemic heart disease, Parkinson's 
disease, as well as hairy cell leukemia and other chronic B-cell 
leukemias. 75 Fed. Reg. 53,202 (August 31, 2010). 

[17] GAO, 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). 

[18] As we reported in 2010, VBA's goal is for newly hired VSRs to be 
proficient within 18 months and new RVSRs to be proficient within 2 
years. See [hyperlink, http://www.gao.gov/products/GAO-10-213]. 
However, becoming proficient often takes longer--about 3 to 5 years 
for RVSRs. While VBA hired additional temporary staff using American 
Recovery and Reinvestment Act of 2009 funds, they were given limited 
training and less complex claims processing tasks. According to VBA 
officials, in 2011, VA received authority to convert temporary 
employees into permanent staff, which required additional training and 
mentoring. 

[19] The Quality Review Team (QRT) initiative was implemented 
nationally in March 2012 and consists of specially trained teams at 
regional offices that review claims files in the development and 
rating phases to provide immediate feedback to employees and catch 
adjudicative errors, as well as provide immediate feedback to claims 
processing staff before their claims are finalized. 

[20] The pre-discharge program is a joint VA and Department of Defense 
(DOD) program that affords service members the opportunity to file 
claims for disability compensation up to 180 days prior to separation 
or retirement from active duty or full-time National Guard or Reserve 
duty. There are four components of the pre-discharge program: Benefits 
Delivery at Discharge, Quick Start, Disability Evaluation System, and 
Seriously Injured/Very Seriously Injured. The Transition Assistance 
Program consists of comprehensive 3-day workshops that are designed to 
help servicemembers as they transition from military to civilian life. 
The program includes job search, employment and training information, 
as well as VA benefits information for servicemembers who are within 
12 months of separation or 24 months of retirement. A companion 
workshop, the Disabled Transition Assistance Program, provides 
information on VA's Vocational Rehabilitation and Employment Program, 
as well as other programs for the disabled. 

[21] In 2001, VA established the Decision Review Officer (DRO) review-
-an alternative review process at the regional level. If a veteran 
chooses the DRO review, a DRO conducts a de novo review of the claim, 
meaning a new and complete review without deference to the original 
decision, and can revise that decision without new evidence or a clear 
and unmistakable error--in other words, based on a difference of 
opinion. A DRO also may make a new decision based on new evidence or 
clear and unmistakable error. See GAO, Veterans Disability Benefits: 
Clearer Information for Veterans and Additional Performance Measures 
Could Improve Appeal Process, [hyperlink, 
http://www.gao.gov/products/GAO-11-812] (Washington, D.C.: September 
29, 2011). 

[22] VA Office of Inspector General, Veterans Benefits Administration: 
Audit of VA Regional Office's Appeals Management Processes, 
(Washington D.C.: May 30, 2012). 

[23] Veterans' Benefits Improvement Act of 2008, Pub. L. No. 110-389; 
Veterans' Benefits Improvement Act of 2004, Pub. L. No.108-454; 
Veterans Benefits Act of 2003, Pub. L. No. 108-183; and Veterans 
Claims Assistance Act of 2000, Pub. L. No. 106-475. 

[24] See, for example, Haas v. Nicholson, 20 Vet. App. 257 (2006); 
Moody v. Principi, 360 F.3d 1306 (Fed. Cir. 2004); Szemraj v. 
Principi, 357 F.3d 1370 (Fed. Cir. 2004); and Disabled American 
Veterans v. Secretary of Veterans Affairs, 327 F.3d 1339 (Fed. Cir. 
2003). 

[25] 38 U.S.C. § 5103A(a)(1). 

[26] VA will make reasonable efforts to obtain relevant records that 
are not in the custody of a federal department or agency, which can 
include records from state or local governments, private medical-care 
providers, current or former employers, and other non-federal 
governmental sources. Reasonable efforts generally consist of an 
initial request for the records, and, if the records are not received, 
at least one follow-up request 15 days later. A follow-up request is 
not required if a response to the initial request indicates that the 
records sought do not exist or that a follow-up request for the 
records would be futile. 38 C.F.R. § 3.159. 

[27] The Honoring America's Veterans and Caring for Camp Lejeune 
Families Act of 2012, (Pub. L. No. 112-154, § 501, 126 Stat. 1165, 
1190). A claimant may request in writing that the VA regional office 
initially review the evidence. 

[28] 38 U.S.C. § 5101(a). VA defines an original claim as an initial 
formal application on the form prescribed by VA under the statute, and 
a reopened claim to include any application for a benefit received 
after final disallowance of an earlier claim, or any application based 
on additional evidence. 38 C.F.R. § 3.160(b) and (e). 

[29] Under VA regulations, an informal claim is generally defined as 
any communication or action indicating an intent to apply for one or 
more VA benefits, but which must identify the benefit being sought. 38 
C.F.R. § 3.155(a). 

[30] The VONAPP website, created by VA in 2008, enables 
servicemembers, veterans, and their beneficiaries, as well as other 
designated individuals, to apply for benefits, including VA disability 
compensation, using the Internet. VA and DOD launched the eBenefits 
website in 2009 to help servicemembers and veterans manage their 
benefits and personal information. 

[31] VA Office of Inspector General, Systemic Issues Reported During 
Inspections at VA Regional Offices, (Washington D.C.: May 18, 2011). 

[32] VA Office of Inspector General, Systemic Issues Reported During 
Inspections at VA Regional Offices. 

[33] For more information on all VBA initiatives to reduce claims and 
appeals processing times, see appendix III. 

[34] See [hyperlink, http://www.gao.gov/products/GAO-10-213]. 

[35] To implement VBMAP, VBA has contracted with ACS Federal Solutions 
to conduct evidence gathering for VBA claims, among other tasks, 
through a one-time, 12-month professional services contract using 
funds from the fiscal year 2011 VA budget. ACS employs contract staff 
at its London, Kentucky site to gather supporting evidence. Once the 
evidence gathering is complete, the ACS contractor returns the 
evidence package to VBA. ACS receives a fixed price for each completed 
evidence package. 

[36] The contractor is required to complete all claims requesting an 
increase in existing disability benefits within 120 days of receipt. 

[37] Veterans' Benefits Improvement Act of 2008, Pub. L. No. 110-389, 
§ 221, 122 Stat. 4145, 4154. A fully developed claim is one where the 
veteran indicates that he or she received appropriate assistance or 
does not intend to submit any additional information and certifies 
that no additional information or evidence is available or needs to be 
submitted. 

[38] As we reported in 2011, a veteran can appeal to the VA regional 
office that made the initial decision. And if the veteran remains 
dissatisfied, he or she can appeal to the Board. Appealing to the 
Board, however, can add more than 2 years, on average, to the wait 
time for a decision. To resolve more appeals at the regional level and 
avoid waits at the Board, VA established the DRO review as an 
alternative to the traditional regional office appeal review. A DRO is 
given authority to grant additional benefits after reviewing an appeal 
based on a difference of opinion with the original decision, without 
new evidence or a clear and unmistakable error, as required in a 
traditional review; see [hyperlink, 
http://www.gao.gov/products/GAO-11-812]. Under this process, veterans 
who submit a Notice of Disagreement are sent an election letter asking 
them to decide between a traditional or DRO review of their appeal 
(veterans would typically be given up to 60 days to make this 
selection). 

[39] VBA's procedures allow a veteran's representative, often a VSO, 
an opportunity to review an appeal and submit a statement regarding 
the appeal. 

[40] VBA's claims staff remain responsible for gathering evidence from 
VHA records. 

[41] There are more than 70 DBQs that cover a full range of medical 
conditions. While some DBQs are specific to a single condition--such 
as hypertension, arthritis, or prostate cancer--most forms can be used 
for several related conditions. 

[42] According to one VBA central office official, claims staff are 
not required to use the SNL in all circumstances. For example, claims 
staff may opt to use a traditional decision letter for decisions 
involving complex issues that require more information to explain the 
rationale for the decision. 

[43] Before the initiative is rolled out to 18 of VA's regional 
offices, VA commenced a pilot in three regional offices in March 2012. 

[44] Past GAO reports have identified best practices in planning. A 
results-oriented plan to achieve established goals should include (1) 
purpose, scope, and methodology; (2) problem definition and risk 
assessment; (3) goals, subordinate objectives, activities, and 
performance measures; (4) resources, investments, and risk management; 
(5) organizational roles, responsibilities, and coordination; and (6) 
integration. See GAO, Social Security Disability: Additional 
Performance Measures and Better Cost Estimates Could Help Improve 
SSA's Efforts to Eliminate Its Hearings Backlog, [hyperlink, 
http://www.gao.gov/products/GAO-09-398] (Washington, D.C.: September 
9, 2009). 

[45] Veterans' Disability Benefits Commission, Honoring the Call to 
Duty: Veterans' Disability Benefits in the 21st Century (Washington, 
D.C.: October 2007). 

[46] If the veteran does not reply to the election letter within 60 
days, the appeal proceeds as a traditional review. 

[End of section] 

GAO’s Mission: 

The Government Accountability Office, the audit, evaluation, and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the 
performance and accountability of the federal government for the 
American people. GAO examines the use of public funds; evaluates 
federal programs and policies; and provides analyses, recommendations, 
and other assistance to help Congress make informed oversight, policy, 
and funding decisions. GAO’s commitment to good government is 
reflected in its core values of accountability, integrity, and 
reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO’s website [hyperlink, http://www.gao.gov]. Each 
weekday afternoon, GAO posts on its website newly released reports, 
testimony, and correspondence. To have GAO e-mail you a list of newly 
posted products, go to [hyperlink, http://www.gao.gov] and select 
“E-mail Updates.” 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of 
production and distribution and depends on the number of pages in the 
publication and whether the publication is printed in color or black 
and white. Pricing and ordering information is posted on GAO’s 
website, [hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 
MasterCard, Visa, check, or money order. Call for additional 
information. 

Connect with GAO: 

Connect with GAO on facebook, flickr, twitter, and YouTube.
Subscribe to our RSS Feeds or E mail Updates. Listen to our Podcasts.
Visit GAO on the web at [hyperlink, http://www.gao.gov]. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 
Website: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]; 
E-mail: fraudnet@gao.gov; 
Automated answering system: (800) 424-5454 or (202) 512-7470. 

Congressional Relations: 

Katherine Siggerud, Managing Director, siggerudk@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, DC 20548. 

Public Affairs: 
Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, DC 20548. 

[End of document]