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United States General Accounting Office: 
GAO: 

Report to the Ranking Democratic Member, Committee on Veterans' 
Affairs, House of Representatives: 

April 2002: 

Veterans Benefits Administration: 

Clarity of Letters to Claimants Needs to Be Improved: 

GAO-02-395: 

Contents: 

Letter: 

Results in Brief: 

Background: 

In Many VBA Letters, Certain Key Aspects Were Clear but Others Were 
Not: 

Multiple Factors Contribute to Deficiencies; Some Initiatives Are 
Under Way, but an Evaluation System Is Needed: 

Conclusions: 

Recommendations: 

Agency Comments and Our Response: 

Appendix I: Comments from the Veterans Benefits Administration: 

Appendix II: Scope and Methodology: 

Appendix III: GAO Contacts and Staff Acknowledgments: GAO Contacts: 
GAO Acknowledgments: 

Tables: 

Table 1: Percentages of VBA’s Notification Letters That Were Unclear, 
by Type: 

Table 2: Percentages of VBA’s Development Letters That Were Unclear: 

Table 3: Writing Deficiencies That Obscured Development Letters’ 
Explanation of Actions That Claimants Should Take: 

Table 4: Status of VBA Initiatives That Can Improve Clarity of Letters 
and Attachments: 

Table 5: Similarity of Technical Language in Medical Criteria from the 
Schedule for Rating Disabilities and a Rating Decision Document: 

Figures: 

Figure 1: Compensation Letter That Clearly Stated the Decision: 

Figure 2: Pension Letter That Did Not Clearly State the Decision: 

Figure 3: Rating Decision Document That Clearly Summarized, Despite 
Medical Terminology, the Reasons for the Decision: 

Figure 4: Compensation Letter That Clearly Stated Financial 
Information about the Claimant’s Benefits: 

Figure 5: Compensation Letter Illustrating VBA’s Policy of 
Communicating the Gross Benefit Amount: 

Figure 6: Compensation Letter in Which the Date the Claimant Was First 
Eligible for Benefits Was Unclear: 

Figure 7: Notification Letter That Clearly Stated the Claimant’s 
Rights and Responsibilities, Contact Information, and Other Benefits 
for Which the Claimant Could Be Eligible: 

Figure 8: Development Letter That Clearly Set Forth What VBA Needed 
from the Claimant: 

Figure 9: Letter Attachment with Technical Jargon and Lengthy 
Sentences That Made It Difficult to Understand: 

Figure 10: Form That Was Clear and Easy to Read: 

Figure 11: Respondents to the Customer Satisfaction Survey Who 
Appealed or Contacted VBA to Discuss a Decision on a Compensation or 
Pension Claim: 

Abbreviations 

RO: regional office: 

VBA: Veterans Benefits Administration: 

VA: Department of Veterans Affairs: 

VCAA: Veterans Claims Assistance Act: 

[End of section] 

United States General Accounting Office: 
Washington, DC 20548: 

April 23, 2002: 

The Honorable Lane Evans: 
Ranking Democratic Member: 
Committee on Veterans’ Affairs: 
House of Representatives: 

Dear Mr. Evans: 

In fiscal year 2001, the Department of Veterans Affairs’ (VA) Veterans 
Benefits Administration (VBA) provided more than $23 billion in 
monthly cash benefits to approximately 3.2 million disabled veterans 
and their families through its compensation and pension program. In 
the same year, VBA mailed approximately 1.2 million “notification” 
letters to veterans and their families, informing them of VBA’s 
decisions regarding claims that they had filed to receive compensation 
or pension benefits. VBA also sent about 1.2 million “development” 
letters in fiscal year 2001 requesting information that the agency 
needed to reach a decision on claims.[Footnote 1] Because these 
letters serve as VBA’s official means of communicating its decisions 
to claimants and requesting information to support claims, it is 
important that the letters be clearly written and easy to understand. 

In 1995, VBA found that its notification and development letters, 
among other types of letters, failed to communicate adequately, and it 
launched a still ongoing initiative, called Reader-Focused Writing, to 
improve its written communications. Because of your concern about the 
current understandability of VBA’s letters, you asked us to assess (1) 
the extent to which VBA’s notification and development letters are 
understandable to the reader and (2) the causes of any deficiencies 
and whether VBA has implemented initiatives to correct these 
deficiencies. 

To address these issues, we analyzed a random sample of each of three 
types of letters: (1) letters notifying claimants of original and 
reopened compensation decisions, (2) letters notifying claimants of 
original and reopened pension decisions, and (3) compensation and 
pension development letters sent to claimants.[Footnote 2] We selected 
these letters from VBA’s national sample of cases. This sample was 
likely to have included both letters that had been rewritten under the 
agency’s initiative to improve the quality of its compensation and 
pension program letters, as well as letters that had not been 
rewritten. We limited the sample of development letters to those 
written in 2001, to assure that they were written after promulgation 
of a new law, the Veterans Claims Assistance Act (VCAA). The VCAA 
defines VBA’s duty to assist claimants in gathering evidence to 
support their claims. 

We reviewed the letters against a set of decision rules that we had 
developed for assessing letter clarity. We developed these rules in 
consultation with writing consultants, taking into consideration VBA’s 
legal and policy requirements for its notification and development 
letters. Writing consultants verified that the decision rules were 
reliable for assessing, and were a valid measure of, letter clarity. 
Writing consultants also reviewed the clarity of standard forms 
commonly attached to VBA’s letters. 

We also interviewed officials at VBA’s central office and at 7 of 
VBA’s 57 regional offices (ROs), as well as representatives of 
veterans service organizations. In addition, we reviewed VBA laws, 
regulations, and policies on notification and development letters and 
VBA documentation on initiatives to improve letter clarity. We 
conducted our work between March 2001 and March 2002 in accordance 
with generally accepted government auditing standards. For more 
details about our scope and methodology, see appendix II. 

Results in Brief: 

In its letters, VBA clearly explained some, but not all, of the key 
aspects that claimants needed to understand. In most of its 
notification letters, VBA clearly stated the decision concerning 
claimants’ entitlement to benefits, claimants’ responsibilities, their 
right to appeal, how they could contact VBA for more information, and 
other benefits for which they might be eligible. However, other key 
aspects that claimants needed to understand were unclear. About half 
of VBA’s compensation letters did not clearly explain pertinent 
financial information concerning the claimants’ benefit. Similarly, 
nearly 30 percent of compensation letters did not clearly explain the 
reason for VBA’s decision regarding whether or not to award benefits. 
Among the letters that did not clearly explain the reason for the 
decision, many had legal and medical terminology in the attached 
rating decision document that would be difficult for a layperson to 
understand. Further, about 43 percent of the development letters did 
not clearly explain the actions that claimants were to take to support 
their claims. Beyond the lack of clarity in these key aspects of the 
letters, various writing deficiencies, such as sequencing and 
formatting problems, reduced the overall clarity of VBA’s letters. 
Unclear notification and development letters confuse and frustrate 
claimants. As a result, claimants are more likely to contact VBA to 
discuss or appeal the decision, adding to VBA’s workload, or they may 
not pursue benefits to which they are entitled. 

Four key factors contribute to deficiencies in VBA’s letters, and VBA 
has initiated efforts to address some of these deficiencies. First, in 
many of its rating decision documents and development letters, VBA 
attempts to achieve more than one objective and, in doing so, 
compromises clarity for the reader. For example, in its development 
letters, in attempting to explain VBA’s new legal duties for assisting 
veterans in gathering evidence, the agency obscures its request that 
the claimant provide information to support the claim. Second, 
although VBA’s central office and some ROs have developed boilerplate 
paragraphs for letters and their attachments to lessen the time that 
employees spend in creating them and to increase consistency and 
quality, some of these paragraphs contain writing deficiencies. 
Because the unclear text is part of the boilerplate language, it 
appears in numerous letters and their attachments that are mailed to 
claimants. VBA began taking steps in the spring of 2001 to clarify the 
boilerplate language in the national compensation and pension 
notification letters. It tested these revised national letters and 
mandated their use by all ROs at the end of 2001, but the extent to 
which these letters are being used by the ROs is unknown. Third, some 
types of writing deficiencies are caused by human errors. These 
include editorial mistakes and boilerplate language not adapted to the 
claimant’s specific situation. Finally, despite its efforts to make 
its letters more understandable, VBA does not systematically evaluate 
the clarity of its letters, identify writing deficiencies, and provide 
timely feedback to help correct such deficiencies. As a result, VBA 
lacks an organized process for continuously improving clarity of its 
letters. 

We are making recommendations in this report to the Secretary of the 
Department of Veterans Affairs to improve the clarity of VBA’s 
letters. These recommendations include simplifying and clarifying the 
wording of the letters in ways that facilitate claimants’ 
comprehension and evaluating letter clarity by obtaining periodic 
input from claimants, their representatives, and staff who write 
letters. VA, in commenting on a draft of this report, agreed with our 
conclusions and concurred with our recommendations, and it detailed 
ongoing efforts and plans, including timeframes, to implement the 
recommendations. 

Background: 

In the early 1990s, VBA learned through focus groups, surveys, and 
other studies that the agency was not communicating adequately with 
claimants. The agency also learned that lack of clarity in its letters 
was taking a toll on its efficiency by generating unnecessary calls to 
its ROs for clarification and creating unnecessary work on claims. To 
satisfy its customers and to increase efficiency, VBA launched its 
Reader-Focused Writing Program in 1995 to create understandable 
communications throughout the agency by focusing on what the reader 
needs to know. To better meet the needs of the reader, Reader-Focused 
Writing seeks to design documents that adhere to certain principles, 
including the following: (1) tell the reader the main message up 
front, (2) use headings and group similar information in short 
sections to help the reader find specific information, (3) use clear 
and concise sentences that avoid jargon, and (4) use correct spelling, 
grammar, and punctuation. VBA has taken a number of steps since 1995 
to implement its Reader-Focused Writing initiative and, as a result, 
was recognized by then President Clinton as a leader in the 
governmentwide movement to use “plain language” in all written 
communications. For instance, a major step in implementing Reader-
Focused Writing involved training nearly all of VBA’s employees in the 
basic principles of Reader-Focused Writing through courses tailored to 
address the needs of particular positions, including VBA’s veterans 
service representatives, who are generally responsible for preparing 
notification and development letters for VBA’s compensation and 
pension program. 

VBA’s compensation and pension program provides monthly cash benefits 
to eligible veterans and their dependents. In fiscal year 2001, 
approximately 2.6 million beneficiaries received a total of $20.2 
billion in disability compensation benefits, and approximately 600,000 
beneficiaries received $3.0 billion in disability pension benefits. 
The rules affecting eligibility and benefit amounts in these programs 
can be complex. VBA pays monthly compensation benefits, based on the 
degree of disability (from 0 to 100 percent), to veterans who have 
service-connected disabilities (injuries or diseases incurred or 
aggravated while on active military duty). The amount of basic 
benefits for veterans with no dependents ranges from $103 to $2,163 
per month, depending on the degree of disability. VBA pays monthly 
pension benefits, based on financial need, to wartime veterans who 
have low incomes and are permanently and totally disabled for reasons 
that are not service connected.[Footnote 3] For both types of 
benefits, additional amounts are paid for dependents as well as for a 
range of special needs. Under certain circumstances, claimants who are 
found to have a service-connected disability or are eligible for 
pension benefits can also qualify for other VA-provided benefits, 
including health care, employment support, and educational assistance. 
For example, disability compensation is a gateway to vocational 
rehabilitation and employment services for some veterans. 

To obtain compensation or pension disability benefits, a claimant 
applies to one of VBA’s 57 ROs. Upon receipt of a substantially 
complete claim, a veterans service representative attempts to obtain 
the evidence required to support the claim, which can involve creating 
and mailing a development letter requesting the necessary information 
from the claimant or someone else. If appropriate, an RO rating 
specialist subsequently analyzes the evidence obtained, evaluates the 
claimed conditions to determine whether they are service connected, 
and assigns a rating for the degree to which each claimed service-
connected condition is disabling. To assign the rating, the rating 
specialist uses the Schedule for Rating Disabilities. This schedule 
contains medical criteria and disability ratings associated with the 
level(s) of severity for each condition. 

To record the reasoning underpinning the decision, the rating 
specialist prepares a rating decision document. This document is 
supposed to explain, for each claimed condition, VBA’s decision; the 
evidence considered in reaching the decision; the evidence for and 
against the claim; and the rationale for the decision, based on the 
facts and applicable legal requirements. Once a decision on benefit 
eligibility is reached, a veterans service representative creates a 
cover letter notifying the claimant of the decision and attaches the 
rating decision document and necessary forms (e.g., a form describing 
a claimant’s appeal rights). The letter package is then mailed to the 
claimant. A copy of the letter and its attachments is also mailed to 
the veterans service organization representing the claimant, if the 
claimant has named one. If the claimant disagrees with the decision, 
he or she can request a review by an RO decision review officer, who 
will attempt to resolve the disagreement. If the claimant continues to 
disagree with the decision, he or she may appeal the decision to VA’s 
Board of Veterans’ Appeals and subsequently to the Court of Appeals 
for Veterans Claims, which is independent of VA. Finally, either the 
claimant or VA may appeal a decision of the Court of Appeals for 
Veterans Claims to the Court of Appeals for the Federal Circuit. 

Legal, regulatory, and policy requirements govern the standards for 
notification and development letters prepared in the ROs. Notification 
letters should clearly state (1) the decision made; (2) the date the 
decision is to be effective, the monthly rates payable to the 
claimant, and any amounts to be withheld from the benefits; (3) the 
reasons for the decision; (4) a claimant’s right to appeal the 
decision, including procedures and time limits; and (5) any additional 
benefits to which the claimant may be entitled. Standards for 
development letters follow the tenets of the VCAA, which was signed 
into law on November 9, 2000. According to the act, development 
letters are to advise claimants of any information needed to 
substantiate their claims—-including the information that claimants 
are to submit in support of their claims, as well as that which VBA is 
to obtain on the claimants’ behalf. In addition, VBA policy requires 
that these letters inform the claimant of the consequences for not 
submitting the requested information within a specified time limit. 

To create a letter, veterans service representatives select from a 
national database certain boilerplate paragraphs that they can tailor 
to a particular claimant by inserting an unlimited amount of free 
text. Some ROs have adapted letters from the national database and 
created their own local letter databases. Additionally, individual 
letter writers in the ROs have created their own sets of letters by 
modifying the national and local letters. 

VBA’s ROs, which create the notification and development letters, face 
a complex operating environment. According to the VA Claims Processing 
Task Force, which was established by the Secretary in 2001 and which 
reviewed VBA’s claims processing problems, VBA’s inventory of pending 
claims nearly doubled, from about 350,000 to nearly 670,000 cases, 
between 1989 and August 2001.[Footnote 4] Of the pending cases in 
August 2001, nearly 420,000 involved a disability rating.[Footnote 5] 
VBA wants to reduce this backlog of pending claims involving a 
disability rating to 250,000 cases by September 2003. Over the past 
decade, the average amount of staff time that it takes for VBA to 
process a compensation claim has more than doubled. The task force 
attributes VBA’s growing backlogs and increased processing time to a 
number of factors. For example, veterans are filing increasingly 
complex claims, with more disabilities per case than in the past and 
with disabilities that are more difficult to evaluate, such as 
illnesses related to service in the Gulf War. In addition, a number of 
legislative and regulatory changes, such as VBA’s duty to assist 
claimants in gathering evidence to support their claims, have added to 
the complexity of processing claims. Moreover, VBA has recently hired 
a significant number of veterans service representatives and rating 
specialists to fill vacancies left by a recent wave of retirements. At 
the end of fiscal year 2001, about one quarter of veterans service 
representatives and rating specialists had less than one year of 
experience in their jobs. According to VBA, these new hires require 
intensive training and on-the-job experience to achieve proficiency. 
[Footnote 6] 

In Many VBA Letters, Certain Key Aspects Were Clear but Others Were Not 

In its letters, VBA clearly explained some, but not all, of the key 
aspects that claimants needed to understand. In most of its 
notification letters, VBA clearly stated the decision concerning 
claimants’ entitlement to benefits, claimants’ responsibilities, their 
right to appeal, how they could contact VBA for more information, and 
other benefits for which they might be eligible. However, other key 
aspects that claimants needed to understand were unclear in 
compensation letters. These included pertinent financial information 
and the reason for VBA’s decision regarding whether or not to award 
benefits. Further, about 43 percent of development letters did not 
clearly explain the actions that claimants should take to support 
their claims. Beyond the lack of clarity in these key aspects of the 
letters, various writing deficiencies, such as sequencing and 
formatting problems, reduced the overall clarity of VBA’s letters. 
Unclear notification and development letters confuse and frustrate 
veterans. As a result, they are more likely to contact VBA to discuss 
or appeal the decision, adding to VBA’s workload, or they may not 
pursue benefits to which they are entitled. 

Some Notification Letters Did Not Clearly Communicate the Reason for 
VBA’s Decision or Financial Information: 

Many of VBA’s notification letters were understandable in certain key 
aspects. However, significant percentages of VBA’s notification 
letters were difficult to understand in other key areas (see table 1). 

Table 1: Percentages of VBA’s Notification Letters That Were Unclear, 
by Type: 

Key aspects of VBA’s notification letters: Decision concerning the 
claimant’s entitlement to benefits; 
Percentages of letters that were unclear: 
Compensation: 5%; 
Pension: 15%. 

Key aspects of VBA’s notification letters: Reason for the decision; 
Percentages of letters that were unclear: 
Compensation: 29%; 
Pension: 10%. 

Key aspects of VBA’s notification letters: Financial information 
concerning the claimant’s benefit;
Percentages of letters that were unclear: 
Compensation: 52%[A,B]; 
Pension: 7%[B]. 

Key aspects of VBA’s notification letters: Claimant’s responsibilities 
and appeal rights and 4 ways to contact VBA for more information; 
Percentages of letters that were unclear: 
Compensation: 4%; 
Pension: 6%. 

Key aspects of VBA’s notification letters: Other benefits available to 
the claimant; 
Percentages of letters that were unclear: 
Compensation: 0%[B]; 
Pension: N/A[C]. 

[A] The 95 percent confidence interval around this estimate ranges 
from 37 to 67 percent. 

[B] The percentage was based on only those letters in the sample that 
contained the applicable information. 

[C] The sample of pension letters that we reviewed included almost no 
letters that contained the applicable information. 

Legend: N/A = not applicable. 

Source: GAO’s review of a national sample of letters. 

[End of table] 

Decision Concerning Entitlement: 

The vast majority of letters-—95 percent of compensation letters and 
85 percent of pension letters-—clearly conveyed, in general, the 
decision concerning the claimant’s entitlement to benefits. In 
comparison, VBA estimates that about 70 and 80 percent of their 
customers, respectively, believe that VBA’s compensation and pension 
letters explained the decision in a way that the reader could 
understand.[Footnote 7] The letter in figure 1 provides an example of 
a compensation decision covering nine separate conditions that was 
particularly clear and easy to read, primarily because of the use of 
simple lay language. 

Although the great majority of VBA’s pension letters clearly stated 
the decision concerning the claimant’s entitlement to benefits, 15 
percent of the pension letters in our sample did not. Among the 
letters that we reviewed that were unclear, in most cases, the 
statement of the decision in the letter was inconsistent with that in 
the attached rating decision document. Figure 2 illustrates such a 
case. In this instance, the notification letter stated that VBA denied 
the claim for pension. However, the rating decision document stated 
that entitlement to pension was granted. Neither the notification 
letter nor the rating decision document explained how the claimant 
could be entitled to a pension and at the same time be denied it. 

Figure 1: Compensation Letter That Clearly Stated the Decision: 

[Refer to PDF for image: letter illustration] 

What Did We Decide? 

1. Service connection for carpal tunnel syndrome, bilateral wrists is 
denied. 

2. Service connection for residuals of right eye injury is denied. 

3. Service connection for shin splints is denied. 

4. Service connection for low back pain is denied. 

5. Service connection for headaches is denied. 

6. Service connection for leg cramps is denied. 

7. Service connection for left ankle condition is denied. 

8. Service connection for exposure to asbestos as a result of asbestos 
exposure is denied. 

9. Service connection for right shoulder pain is denied. 

Commentary: 

The letter set forth VBA’s decision to deny the claim on nine separate 
conditions. It was written in lay language (e.g., “left ankle condition”
or “right shoulder pain”) and contained no editorial mistakes. 

[End of figure] 

Figure 2: Pension Letter That Did Not Clearly State the Decision 

[Refer to PDF for image: letter illustration] 

Why We Denied Your Claim: 

A. We cannot approve your claim for pension because your yearly family 
income is $37,879.00. This amount exceeds the limit set by law of 
$18,405.00 for a veteran with a wife with the aid and attendance 
allowance. 

B. We have enclosed a copy of our Rating Decision for your review. It 
provides a detailed explanation about our decision, including the 
evidence considered and the reasons and basis for our decision. 

C. Decision: 

1. Entitlement to pension is granted. 

2. Entitlement to special monthly pension based on the need for aid 
and attendance is established effective June 14, 2001. 

Commentary: 

A. The letter set forth the decision on the claim for pension. The 
claim was denied because of income that exceeded specified limits. 

B. The letter referred the claimant to the attached rating decision 
document for an explanation of the decision. 

C. To the lay reader, the statement of the decision in the attached 
rating decision document seems to contradict VBA’s decision as stated 
in the letter. The rating decision document stated that the claimant 
was entitled to pension and to another “special monthly pension.” 

[End of figure] 

Reason for the Decision: 

Seventy-one percent of VBA’s compensation letters and 90 percent of 
its pension letters clearly stated, in general, the reason for the 
decision. In comparison, VBA estimates that 74 and 81 percent of its 
customers, respectively, believe that VBA’s compensation and pension 
letters clearly explained all of the reasons for the decision. 
[Footnote 8] Figure 3 illustrates a rating decision document from our 
sample that used nontechnical language to explain how the facts of the 
case led to the decision. Despite the presence of technical language 
in the recitation of the facts of the case and in the criteria used to 
assign the degree of disability, this rating document provided a 
brief, generally plain English summary of the reasons for the decision 
that a layperson could understand. 

Although the reason for VBA’s decision in most of these compensation 
and pension letters was generally clear, nearly one-fifth of the 
compensation letters included rating decision documents that contained 
editorial mistakes or redundancies. Editorial mistakes included 
typographical errors, run-on sentences, and sentence fragments, making 
the documents more challenging to read. In addition, redundancies made 
the rating documents unnecessarily lengthy. For example, a legal 
requirement—such as the VCAA provisions—-was listed for each of the 
multiple conditions, rather than being stated once for all claimed 
conditions. Similarly, the rating documents sometimes repeated 
language for each claimed condition that described the RO’s attempts 
to obtain information from the claimant and the claimant’s failure to 
respond to these attempts, when stating it once would have sufficed. 
In one rating document, essentially the same paragraph—-including the 
sentence fragments embedded in it—was repeated 7 times throughout a 13-
page document. 

Figure 3: Rating Decision Document That Clearly Summarized, Despite 
Medical Terminology, the Reasons for the Decision: 

[Refer to PDF for image: form illustration] 

A. VA examination notes no objective findings of loss of range of 
motion and the veteran had flexion of 140 degrees and full extension. 
The patella was hypermobile and there was a small prepateller 
effusion. There was no laxity of the knee and no tenderness. 
Subjectively the veteran does state his left knee is intermittently 
painful and gets stiff. He notices his knees are symptomatic going up 
and down stairs with discomfort and stiffness. He has had to limit 
such physical activities such as running. Patellofemoral syndrome was 
diagnosed. 

B. An evaluation of 10 percent is assigned under diagnostic code 5257 
from September 5, 2000. An evaluation of 10 percent is granted if the 
record shows recurrent subluxation or lateral instability of the knee 
which is slight. A higher evaluation of 20 percent is not warranted 
unless there is evidence of moderate subluxation or lateral 
instability of the knee. 

C. Although the VA examiner did not give any objective findings of any 
limitation of motion and flexion and extension were normal, the 
veteran still is experiencing pain in left knee. The veteran does 
state that his knee is intermittently painful and gets stiff. He also 
notices that he has pain when going up and down stairs. He has limited 
his physical activities such as running and avoids walking any long 
distances. Because of the functional limitations due to knee pain, a 
10 percent evaluation is assigned. 

Commentary: 

A. The facts of the case were written with medical terminology that 
would be difficult for a layperson to understand. 

B. Similarly, the medical criteria used to assign the degree of 
disability were written with medical terms. 

C. In spite of the medical terms used in describing the facts and the 
criteria, the document provided a simple, brief summary, written in 
lay language, of the reasons for the decision. 

[End of figure] 

While notification letters, in general, clearly stated the reason for 
VBA’s decision concerning the claimant’s entitlement to benefits, 29 
percent of the compensation letters did not. Among the letters that 
were unclear, many had legal and medical terminology in the rating 
decision document that would be difficult for a layperson to 
understand. For example, one rating decision document used highly 
technical medical language in attempting to establish the reasons for 
a decision about inflammation of tendons in the wrist (De 
Quervain’s Syndrome), as follows: 

The evaluation of Post operative residuals, De Quervain’s Syndrome, 
right wrist is increased to 40 percent disabling effective April 19, 
2001. An evaluation of 40 percent is assigned under diagnostic code 
5214 from April 19, 2001. An evaluation of 40 percent is granted for 
any position of ankylosis other than: palmar flexion, ulnar or radial 
deviation, or favorable ankylosis in 20 to 30 degrees of dorsiflexion. 
A higher evaluation of 50 percent is not warranted unless evidence 
demonstrates unfavorable ankylosis of the wrist in any degree of 
palmar flexion, or with ulnar or radial deviation. [Claimant name] 
experiences limitation of dorsiflexion to 10 degrees, which warrants 
assignment of the 40 percent evaluation. She does not, however, 
experience unfavorable ankylosis in palmer [sic] flexion, or with 
ulnar or radial deviation, which warrants the 50 percent evaluation. 

Another rating decision document used the legalistic language 
illustrated below in trying to explain why a case did not warrant a 
higher evaluation than would be allowed by the rating schedule. In 
this paragraph, technical jargon such as “schedular evaluation,” 
“extra-schedular evaluation,” and “increased evaluation,” as well as 
such legalistic language as “to render impractical the application of 
the regular schedular standards,” would be difficult for a lay reader 
to understand. 

In exceptional cases where the schedular evaluations are found to be 
inadequate, an extra-schedular evaluation may be approved, provided 
that case presents such an exceptional or unusual disability picture, 
with such related factors as marked interference with employment or 
frequent periods of hospitalizations, as to render impractical the 
application of the regular schedular standards. The veteran has not 
submitted evidence tending to show this case presents such an 
exceptional or unusual disability picture as to warrant an extra-
schedular increased evaluation, and the veteran has made no assertion 
to that effect. Accordingly, referral for an extra-schedular increased 
evaluation is not warranted in this case. 

Likewise, VBA officials in the agency’s central office and in the ROs, 
as well as claimant representatives, told us that rating decision 
documents are difficult for claimants to understand because of the 
highly technical language. Officials in one RO, for example, told us 
that the RO received, on average, between 8 and 15 calls per day from 
claimants about letters and rating decisions. Several calls typically 
involved claimants’ asking for clarification of language in the rating 
decision, particularly about how VBA had reviewed the evidence and 
reached the decision, as well as what other evidence the claimant 
could submit to better substantiate the claim. 

Financial Information: 

Forty-eight percent of compensation letters and 93 percent of pension 
letters that contained financial information clearly conveyed, in 
general, such information. Figure 4 provides an example of a 
compensation letter with clear financial information. In this letter, 
the explanation of the payment start date was consistent with the 
actual date given in the table, and the letter clearly stated the 
reasons cited for the benefit. 

However, in 52 percent of VBA’s compensation letters that contained 
financial information concerning the claimant’s benefit, this 
information was unclear. Among the letters that did not clearly 
explain the financial information, 30 percent or more had one or more 
of the following deficiencies: 

* The way that financial information was communicated could make 
claimants think that they would receive a larger payment than they 
would actually receive. When notifying claimants of a decision that 
would result in a retroactive change in benefits, several letters gave 
the new gross monthly entitlement amount, less any withholding amounts 
(see figure 5). These letters did not explain to claimants that to 
calculate their net retroactive benefits, they must deduct from the 
gross amount the benefits that they had already received at the 
preexisting rate. Veterans’ representatives in the two regions that we 
visited told us that presenting the gross benefit amount without any 
explanation confused claimants, causing them to think that they would 
receive a larger retroactive payment than they would actually receive. 
However, several RO and central office officials with whom we spoke 
had not found problems with this method of communicating the benefit 
amount to claimants. 

* Inconsistencies, contradictions, and incomplete information in VBA’s 
compensation letters resulted in unclear statements of the date that 
the claimant was first eligible for payment. Figure 6 provides an 
excerpt from a typical example. In this letter, the general 
explanation of the payment start date was not applicable to the 
particular case. As a result, the payment start date that one would 
expect from reading this general explanation was inconsistent with the 
actual date given in the letter. 

* The explanations of how the benefit amount was computed were 
incomplete or contradictory, contained convoluted language, or were 
simply missing. For example, in one letter, the monthly rate of 
payment of benefits was projected to decrease over the next three 
years without any explanation for the decrease. 

Figure 4: Compensation Letter That Clearly Stated Financial 
Information about the Claimant’s Benefits: 

[Refer to PDF for image: letter illustration] 

A. When Can You Expect Payment? 
Your payment begins the first day of the month following your 
effective date. Generally, your effective date is the date we receive 
your claim. 

B. We made a decision on your claim for service connected disability 
benefits received on January 31, 2001. 

What Is Your Check Amount And Payment Start Date? 

Your monthly check amount is shown below: 

Monthly Check Amount: $427.00; 
C. Payment Start Date: February 1, 2001; 
D. Reason for Change: compensation is granted. 

D. We are paying you as a single veteran with no dependents. 

Commentary: 

A. Payment was to begin the first day of the month following the 
“effective date.” The effective date was generally the date that VBA 
received the claim. 

B. This claim was received on January 31, 2001. 

C. The actual payment start date was established as February 1, 2001, 
as the claimant would expect. 

D. The reasons cited for the benefit were clearly stated in lay 
language and contained no editorial mistakes. Additionally, the 
reasons cited presented no contradictions. 

[End of figure] 

Figure 5: Compensation Letter Illustrating VBA’s Policy of 
Communicating the Gross Benefit Amount: 

[Refer to PDF for image: letter illustration] 

What Is Your Check Amount And Payment Start Date? 

Your monthly check amount is shown below: 

C. Total Amount Granted: $893.00; 
D. Amount Withheld: $180.00; 
E. Monthly Check Amount: $713.00; 
A. Payment Start Date: February 1, 2001; 
Reason for Change: Withheld due to retirement pay. 

B. What Did We Decide? 
We increased your service connected disability rating for the 
following condition(s): 

Medical Condition you Claimed: Cervical strain with degenerative joint 
disease and history of herniated nucleus pulposus, postoperative; 
New percent assigned: 20%; 
Old percent assigned: 10%. 

Commentary: 

A. “Payment Start Date” was February 1, 2001, 4½ months prior to the 
date of the letter, which was June 13, 2001. 

B. VBA assigned the claimant an increased degree of disability (from 
10 to 20 percent) for one condition. 

C. As a result, the claimant’s benefits were increased retroactively 
to the payment start date to reflect the difference between the amount 
the veteran had been receiving and the newly established amount. “
Total Amount Granted” referred to the newly awarded gross monthly 
entitlement amount. 

D. The “Amount Withheld” referred to special withholdings, such as 
military retirement pay, deducted from the monthly entitlement amount. 

E. VBA subtracted the amount withheld from the total amount granted to 
obtain the “Monthly Check Amount.” Contrary to what the heading says, 
the “Monthly Check Amount” did not reflect the net monthly amount the 
claimant would have actually received. To calculate that amount, the 
claimant must have deducted from the “Monthly Check Amount” the 
previous monthly benefit payments that he or she had already received 
for the 4½ months prior to the date of the letter. 

[End of figure] 

Figure 6: Compensation Letter in Which the Date the Claimant Was First 
Eligible for Benefits Was Unclear: 

[Refer to PDF for image: letter illustration] 

A. When Can You Expect Payment? 
Your payment begins the first day of the month following your 
effective date. Generally, your effective date is the date we receive 
your claim. 

B. We made a decision on your claim for service connected disability 
benefits received on October 2, 2000. 

C. What Is Your Check Amount And Payment Start Date? 

Your monthly check amount is shown below: 

Monthly Check Amount: $517.00; 
Payment Start Date: June 1, 2000; 
Reason for Change: grant of service connected compensation. 

D. Decision: 
1. Service connection for right knee condition is granted with an 
evaluation of 10 percent effective May 22, 2000. 

Commentary: 

A. Payment was to begin the first day of the month following the 
“effective date.” The reader was told only that the effective date was 
generally the date that VBA received the claim. 

B. This claim was received on October 2, 2000. The claimant would 
therefore conclude that payment would begin November 1, 2000. 

C. However, the payment start date was established as June 1, 2000, 
with no further explanation in the letter. 

D. The rating decision document, to which the reader would typically 
turn only after having read the multipage letter, showed that, in this 
case, the effective date—May 22, 2000—was not the date that VBA 
received the claim. The effective date, instead, was the date that VBA 
granted service connection for a claimed condition. 

[End of figure] 

Responsibilities, Appeal Rights, and Contact Information: 

Nearly all of VBA’s letters—96 percent of compensation letters and 94 
percent of pension letters—clearly explained, in general, a claimant’s 
responsibilities and right to appeal VBA’s decision and how to contact 
VBA. Claimant responsibilities include, for example, reporting changes 
in income or dependents that could affect benefits. VBA’s letters 
generally used simple, lay language to explain the rights, 
responsibilities, and contact information, as illustrated in figure 7. 

While the letters were generally clear in explaining claimant rights 
and responsibilities and VBA contact information, nearly 30 percent of 
pension letters and 17 percent of compensation letters did not provide 
a deadline for filing an appeal of VBA’s decision, as required by VBA 
policy.[Footnote 9] However, a form describing appeal rights-—
including the deadline for filing an appeal—was attached to nearly all 
notification letters. In those notification letters that mentioned a 
deadline for appealing, the deadline always complied with the 
statutory requirement that an appeal be filed within one year of the 
date of the notification letter. 

Other Benefits Available: 

VBA’s compensation letters that mentioned other benefits for which the 
claimant might be eligible clearly explained, in general, these other 
benefits, using lay terms. These benefits include, for example, 
medical, educational, or vocational rehabilitation benefits. The 
letter in figure 7 (see the paragraphs labeled “C”) illustrates VBA’s 
use of lay terminology in explaining the benefits for which the 
claimant could be eligible. 

Figure 7: Notification Letter That Clearly Stated the Claimant’s 
Rights and Responsibilities, Contact Information, and Other Benefits 
for Which the Claimant Could Be Eligible: 

A. How Do You Start Direct Deposit? 

Your money may be deposited directly into your checking or savings 
account. This is the safest and most reliable way to get your money. 
For more information about Direct Deposit, please call us toll free by 
dialing 1-877-838-2778. 

B. Are Your Dependents Included In This? 

Your payment includes an additional amount for your spouse, and your 
children. Let us know right away if there is any change in the status 
of your dependents. 

C. If You Need Medical Care: 

You can receive free medical care for any service-connected 
disability. You can apply for treatment at the nearest VA medical 
center. Take a copy of this letter with you. 

Are You Entitled To Additional Benefits? 

You may be eligible for Department of Veterans Affairs (VA) vocational 
rehabilitation. The enclosed VA Form 28-8890 explains this benefit. To 
apply, complete VA Form 28-1900, and return it to this office. 

D. Do You Have Questions Or Need Assistance? 

If you have any further questions, call us toll-free by dialing 1-800-
827-1000. Our TTD number for the hearing impaired is 1-800-829-4833. 
If you call, please have this letter with you. 

E. What You Should Do If You Disagree With Our Decision. 

If you do not agree with our decision, you should write and tell us 
why.You have one year from the date of this letter to appeal the 
decision. The enclosed VA Form 4107, “Notice of Procedural and 
Appellate Rights,” explains your right to appeal. 

Commentary: 

A. This sentence clearly set forth contact information about directly 
depositing the benefit amount. 

B. This sentence clearly reminded the claimant of his or her 
responsibility to report changes in the status of dependents. 

C. These two paragraphs clearly explained that the claimant might be 
eligible for medical and vocational rehabilitation benefits and how to 
apply for these benefits. 

D. This paragraph clearly explained how claimants could contact VBA 
for more information. 

E. The final paragraph briefly highlighted the actions that claimants 
could take if they disagreed with the decision, stating the one-year 
deadline for appealing the decision and referring the claimant to an 
attached form that details procedures for appealing. 

[End of figure] 

Many Development Letters Did Not Clearly Explain Actions That the 
Claimant Should Take: 

About 43 percent of VBA’s development letters did not clearly explain 
the actions that the claimant should take to support the claim. These 
letters were generally clear, however, in explaining VBA’s actions in 
attempting to obtain information to support the claim. (See table 2.) 

Table 2: Percentages of VBA’s Development Letters That Were Unclear: 

Key aspects of VBA’s development: Actions that claimant should take to 
a support the claim; 
Percentages of letters that were unclear: 43%[A]. 

Key aspects of VBA’s development: Actions that VBA would take or had 
taken in attempting to obtain information to support the claim; 
Percentages of letters that were unclear: 13%[B]. 

Source: GAO’s review of a national sample of letters. 

[A] The 95 percent confidence interval around this estimate ranges 
from 30 to 56 percent. 

[B] The percentage is based on only those letters in the sample that 
contained the applicable information. 

[End of table] 

Actions That Claimant Should Take: 

Fifty-seven percent of VBA’s development letters, in general, clearly 
explained the actions that the claimant should take to support the 
claim. For example, one easily understandable letter that we reviewed 
grouped the actions that the claimant should take under a single 
heading, using simple, lay language to describe these actions. 
Attachments to the letter listed the more detailed information needed 
from the claimant. The letter also clarified and simplified the 
description of the evidence needed to establish that a disability was 
connected to military service (see figure 8). 

Figure 8: Development Letter That Clearly Set Forth What VBA Needed 
from the Claimant: 

[Refer to PDF for image: letter illustration] 

A. What You Should Do: 

1. It is extremely important to identify all evidence of any post-
service treatment for the conditions shown above. Also, send us a 
statement that provides a detailed history about the claimed 
condition(s). Include all information from the date of the onset of 
the condition(s) to the present. 

The statement should include: 

* a description of the symptoms and the level of severity; 
* when the symptoms were experienced and how long they lasted; 
* whether medication was taken for the symptoms (either prescription 
or over the counter). 

2. Your service medical records do not show treatment for a left ankle 
condition or PTSD. Send evidence showing inservice occurrence or 
aggravation of your claimed disease or injury. See the Secondary 
Evidence attachment. 

3. Complete the enclosed Stressor Detail forms using the PTSD 
Attachment as a guide. 

4. If you had private treatment that has not already been submitted 
and you would like as to request the records, complete, sign, and 
return the enclosed VA Form 21-4142, Authorization and Consent to 
Release Information to the Department of Veterans Affairs (VA). 

5. For any statement submitted in support at the claim, use the 
enclosed VA form 21-4 Statement in Support of Claim. If the form is 
not used, the statement must conclude with the following 
certification: "I hereby certify that the information I have given is 
true and to the best of my knowledge and belief. Please Show Veteran's 
Full Name And Va File Number On All Correspondence Or Evidence 
Submitted. 

B. What VA WILL DO: 

* Let you know what information we need to process your claim. 
* Obtain evidence kept by the VA and any other federal government 
agency.
* Request private treatment records, if you complete a release form.
* Obtain medical records from a VA facility, if you give us the 
location and dates of treatment.
* Request statements from persons who have knowledge of the claimed 
condition(s), if you provide complete names and mailing addresses. 

In reviewing applications and making decisions on claims for service 
connection, we consider all of the following to determine if it tends 
to prove or support the claim: 

* All the information of record; 
* Any medical evidence; 
* Statements from the claimant; 
* Statements from persons who have knowledge of the claimed 
condition(s). 

C. The information and evidence of record should show that the 
claimant has a current disability, or persistent or recurrent symptoms 
of disability. In addition, the evidence considered should show that 
the disability or symptoms may be associated with the claimant's 
active military service. 

Commentary: 

A. The first major section of the letter, following the introduction, 
focused the reader's attention directly on a clear, crisp checklist of 
claimant responsibilities. 

B. The second section of the letter grouped the actions that VBA would 
take on behalf of the claimant. 

C. The description of the evidence needed to establish that a 
disability was connected to military service was stated clearly and 
simply, using lay language. 

[End of figure] 

However, 43 percent of VBA’s development letters did not clearly 
explain the actions that claimants should take to support their 
claims. Among the letters that were unclear, half or more had one or 
more of the following deficiencies: not grouping similar ideas, using 
convoluted language, and raising unanswered questions. Table 3 
describes each of these writing deficiencies. In addition, in about 11 
percent of development letters, a description of the consequences for 
claimants’ not responding in a timely manner to VBA’s request for 
information was either incomplete or missing. A claimant who does not 
realize the significance of VBA’s request might delay in providing the 
needed information. Moreover, about one-third of development letters 
did not ask the claimants to put their full name and VBA file number 
on the information that they submitted to the agency.[Footnote 10] If 
claimants do not appropriately identify the documents that they 
submit, these documents can be misfiled or lost, lengthening the time 
that it takes to process the claim and increasing claimant frustration. 

Table 3: Writing Deficiencies That Obscured Development Letters’ 
Explanation of Actions That Claimants Should Take 

Specific writing deficiency: Similar ideas not grouped together; 
Description of the writing deficiency: Actions that the claimant 
should take were frequently spread throughout the letter under 
multiple headings rather than grouped together under a single heading. 
Therefore, the reader could not go to a single section of the letter 
to determine what he or she should do to comply with VBA’s request for 
information. 

Specific writing deficiency: Convoluted language used; 
Description of the writing deficiency: Language describing the actions 
that the claimant should take was sometimes legalistic and awkward and 
thus difficult for a layperson to understand. 

Specific writing deficiency: Unanswered questions raised; 
Description of the writing deficiency: Passages describing actions 
that the claimant should take often raised questions that were not 
answered. For example, in the four paragraphs that typically described 
the evidence necessary to establish a disability’s connection to 
military service, cumbersome sentence structure and legalistic wording 
frequently made the paragraphs’ content hard to grasp. This left the 
reader confused as to the specific evidence needed to substantiate the 
claim. 

In addition, the letters typically gave the claimant two very 
different deadlines for submitting the needed information. The letter 
asked the claimant to send the requested information within 60 days 
from the date of the letter, but it also said that the evidence could 
still be received within one year from the date of the letter. The 
differing deadlines raised unanswered questions for a lay reader about 
the differences in the consequences for not complying with each of the 
two deadlines. 

[End of table] 

Officials with whom we spoke in VBA’s central office and ROs also told 
us that poor structure and use of legalistic language, among other 
factors, made development letters difficult to read. For example, 
officials in several ROs reported that development letters were 
unnecessarily long and complicated, causing confusion among veterans. 
Some RO and central office officials with whom we spoke suggested 
simplifying and clarifying the letters by placing the details in an 
attachment. 

Actions That VBA Would Take or Had Taken: 

Eighty-seven percent of VBA’s development letters clearly explained, 
in general, the actions that VBA would take or had taken in attempting 
to obtain information on behalf of the claimant to support the claim. 
The exemplary development letter in figure 8 clearly explained VBA’s 
actions. For example, this letter grouped under a single heading, 
without redundancy, the actions that VBA would take and explained 
these actions in simple lay terms. However, while the majority of 
development letters generally clearly explained VBA’s actions, many 
letters mentioned VBA’s actions throughout the letter-—sometimes 
mentioning the same actions repeatedly-—making this aspect of the 
development letters difficult to comprehend. 

Variety of Writing Deficiencies Reduced Overall Clarity of VBA’s 
Letters and Their Attachments: 

Beyond the lack of clarity of certain key aspects of VBA’s 
notification and development letters, a variety of writing 
deficiencies made letters and their attachments generally harder to 
understand. In many letters, the ordering of ideas made it more 
difficult to grasp information quickly, and in some instances, there 
were almost as many headings as sentences. Moreover, certain standard 
forms attached to VBA’s letters contained writing deficiencies similar 
to those that we found in the letters that we reviewed. 

In many letters, the sequence of ideas was out of order, and 
information of greatest importance to the claimants was often not 
discussed first. This ordering generally made letters more difficult 
to understand. For example, two-thirds of VBA’s development letters 
did not state specific actions that claimants should take to support 
their claims until at least the second page of the letter.[Footnote 
11] In 14 percent of the letters, VBA did not provide this information 
until the third or fourth page.[Footnote 12] The specific request for 
information from the claimant was generally preceded by information 
about provisions of the VCAA, including a description of the act, VBA’
s duty to notify the claimant about needed information, and VBA’s duty 
to assist the claimant in obtaining evidence. Also preceding the 
request for information was a multiparagraph description of the 
evidence needed to establish that a disability was connected to 
military service. 

RO officials with whom we spoke noted problems with the ordering of 
information in VBA letters. Officials in one RO said that one of the 
most frequent complaints received on that RO’s hot line involved 
claimants’ having to go through two or three pages of information 
before locating what they were being asked to do. Officials in another 
RO questioned whether claimants would actually take the time to read 
through the entire letter to find out exactly what was being requested 
of them. We did find some VBA letters that ordered ideas in a more 
logical manner. These letters were easier to understand, because VBA 
placed first an explanation of what the agency needed from the 
claimant, as shown in figure 8. 

In addition to overall problems with sequencing, some letters 
categorized information under too many headings. Sometimes only a 
single sentence appeared below the heading. In one instance, a one-
page letter contained 10 sentences that were broken down under 5 
separate headings. On the other hand, most letters contained headings 
in boldface that were, in general, useful for breaking information 
down and enabling the reader to find particular topics quickly. Figure 
7, for instance, illustrates VBA’s use of headings to group 
information about specific topics, such as ways to contact VBA and 
other benefits for which the claimant might be eligible. 

Finally, some VBA standard forms attached to the letters that we 
reviewed contained writing deficiencies similar to those that we 
encountered in our review of VBA’s letters. For example, some of the 
forms contained convoluted language and technical jargon that made 
them difficult to understand. To illustrate, figure 9—VA’s Form 21-
8760, which provides additional information for veterans with military 
service-related permanent and total disability—contained technical 
jargon, lengthy sentences, convoluted language, and typographical 
errors that hindered clarity. 

On the other hand, some forms were relatively easy to understand—for 
example, the form explaining appeal rights that is shown in figure 10. 

Figure 9: Letter Attachment with Technical Jargon and Lengthy 
Sentences That Made It Difficult to Understand: 

[Refer to PDF for image: letter illustration] 

A. Specially Adapted Housing: 

Veterans who have a service-connected disability entitling them to 
compensation for permanent and total disability due to: 

(1) the loss, or loss of use of both lower extremities, such as to 
preclude locomotion without the aid of braces, crutches, canes, or a 
wheelchair, or; 

(2) disability which includes (a) blindness in both eyes, having only 
light perception, plus (b) loss or loss of use of one lower extremity, 
or; 

(3) the loss or loss of use of one lower extremity together with 
residuals of organic disease or injury or the loss or loss of use of 
one lower and one upper extremity which so affect the functions of 
balance or propulsion as to preclude locomotion without resort to 
braces, crutches, canes or a wheelchair; 

may be entitled to a VA grant of not more than 50 percents, or up to a 
maximum of 38,000, to pay part of the cost of building, buying or 
remodeling a specially adapted house or to pay indebtedness on such 
homes already acquired. Apply to the nearest VA office. 

B. Special Home Adaptation Grant: 

Veterans who have a service-connected disability entitling them to 
compensation due to: (1) blindness in both eyes with 5/200 visual 
acuity or less, or; 

(2) the anatomical loss or loss of use of both hands may be entitled 
to a VA grant of not more than $6,500 to pay the cost of remodeling a 
house in which they reside. Apply to the nearest VA office. 

C. Job Counseling And Employment Services: 

A job and job training counseling service program, employment 
placement service program, and job training placement service program 
are available to a spouse of any veteran who has a total disability 
permanent in nature resulting from a service-connected disability or 
the spouse of a veteran who dies while disability so evaluated was in 
existence. 

Commentary: 

A and B. These sections used technical jargon (e.g., “residuals of 
organic disease;” “as to preclude locomotion without resort to;” ”
anatomical loss or loss of use of both hands”) that would be difficult 
for a layperson to understand. Further, the structure of both sections—
using single lengthy sentences connected by the word “or” to list a 
series of alternatives—hindered clarity. Finally, typographical errors 
(e.g., “50 percents” and lack of a dollar sign preceding “38,000”) 
also reduced clarity. 

C. This lengthy sentence contained convoluted language. 

[End of figure] 

Figure 10: Form That Was Clear and Easy to Read: 

[Refer to PDF for image: form illustration] 

A. An appeal is your formal request that the Board review the evidence 
in your VA file and review the law that applies to your appeal. The 
Board can either agree with our decision or Yes. You can send us more 
evidence to support a claim change it. The Board can also send your 
file back to us for more processing before the Board makes its 
decision. 

B. How do I start my appeal? To begin your appeal, write us a letter 
telling us you disagree with our decision. This letter is called your 
“Notice of Disagreement.” If we denied more than one claim for a 
benefit (for example, if you claimed compensation for three 
disabilities and we denied two of them), please tell us in your letter 
which claims you are appealing. Send your Notice of Disagreement to 
the address at the top of our letter. 

C. How long do I have to start my appeal? You have one year to appeal 
our decision. Your letter saying that you disagree with our decision 
must be postmarked (or received by us) within one year from the date 
of our letter denying you the benefit. In most cases, you can’t appeal 
a decision after this one-year period has ended. 

D. What happens if I don’t start my appeal on time? If you don’t start 
your appeal on time, our decision will become final. Once our decision 
is final, you can’t get the VA benefit we denied unless you either: 

* show that we were clearly wrong to deny the benefit or; 
* send us new evidence that relates to the reason we denied your claim. 

E. Can I get someone to help me with my appeal to the Board? Yes. You 
can have a veteran’s service organization representative, an attorney-
at-law, or an “agent” help you with your appeal. But you’re not 
required to have someone represent you. It’s your choice. 

* Representatives who work for accredited veterans’ service 
organizations know how to prepare and present claims and will 
represent you.You can find a listing of these organizations on the 
Internet at: [hyperlink, http://www.va.gov/vso]. 

* A private attorney or an “agent” can also represent you. Your local 
bar association may be able to refer you to an attorney with 
experience in veterans’ law. An agent is a person who isn’t a lawyer, 
but who VA recognizes as being knowledgeable about veterans’ law. 
Contact us if you’d like to know if there is a VA accredited agent in 
your area. 

F. Can I Give VA Additional Evidence? 
Yes. You can send us more evidence to support a claim whether or not 
you appeal to the Board. If you want to appeal, though, don’t forget 
the one-year time limit! 

Commentary: 

A. Short sentences and lay language described what is essentially a 
legal process. 

B. Potentially confusing technical terms were kept to a minimum. 
However, where they were used (e.g., “Notice of Disagreement”), they 
were clearly defined. 

C. Emphasis was used to make critical distinctions-—in this case, 
between the claimant’s letter disagreeing with VBA’s decision and 
VBA’s letter denying benefits. 

D. Questions used as headings anticipated a reader’s questions and 
emphasized important points, such as the consequences of not appealing 
on time. 

E. In a series of alternatives, clarity was achieved with short 
sentences. 

F. The reader was reminded of important procedural deadlines that the 
claimant was responsible for meeting. 

[End of figure] 

Clarity in VBA’s standard forms is important, because these forms 
serve critical purposes. For example, they provide claimants with 
detailed information about other benefits for which the claimants 
might be eligible. The forms also request specific information-—such 
as claimant income and net worth-—that is needed to support the claim. 

Negative Consequences May Occur for Both Claimants and VBA if Letters 
Are Unclear: 

Unclear letters confuse claimants and make them anxious, according to 
VBA. Such letters also cause frustration and can affect the benefits 
that a claimant receives. For example, if claimants do not understand 
VBA’s development letters, they may not provide VBA with the 
information needed to support their claims, claimant representatives 
told us. As a result, VBA may delay processing the claimant’s 
application or may deny benefits because of inadequate evidence. 
Moreover, if claimants do not understand the reasoning that VBA used 
to reach its decision, they may not question an incorrect decision and 
may therefore not receive the appropriate level of benefits. 

Unclear letters can also have an adverse effect on VBA, requiring that 
staff resources be diverted to rework claims or respond to additional 
inquiries rather than to process claims and reduce VBA’s backlog. 
According to VBA’s 2000 national customer satisfaction survey, if 
notification letters and rating decision documents do not explain the 
decision in a way that claimants can understand, claimants are more 
likely to contact VBA to discuss or appeal the decision, adding to VBA’
s already heavy workload (see figure 11). Survey respondents who 
understood VBA’s explanation of its decision in the notification 
letter were less likely to appeal the decision or contact VBA to 
discuss it than respondents who did not understand the explanation. 
This was true regardless of whether the decision granted or denied 
benefits. Of respondents who had been denied benefits, 34 percent of 
those who did not understand the explanation of the decision appealed, 
compared with 23 percent of those who understood the explanation. Even 
when benefits were granted, 30 percent of those who did not understand 
the explanation appealed, compared with 12 percent of the respondents 
who understood.[Footnote 13] Survey results were similar for 
respondents who contacted VBA to discuss the decision: significantly 
more respondents who did not understand the explanation of the 
decision contacted VBA, regardless of whether they were granted or 
denied benefits, than did those who understood the explanation. 

VBA officials agree that processing appeals and responding to 
claimants diverts employees from processing pending cases. These 
officials conclude that any reductions in appeals or in the number of 
claimants who contact VBA to discuss decisions would improve VBA’s 
productivity. 

Figure 11: Respondents to the Customer Satisfaction Survey Who 
Appealed or Contacted VBA to Discuss a Decision on a Compensation or 
Pension Claim: 

[Refer to PDF for mage: vertical bar graph] 

Filed appeals: 
Denied: 
Understood: 23%; 
Did not understand: 34%; 
Granted: 
Understood: 12%; 
Did not understand: 30%. 

Contacted VBA to discuss the decision: 
Denied: 
Understood: 22%; 
Did not understand: 34%; 
Granted: 
Understood: 26%; 
Did not understand: 46%. 

Note: These data reflect only the types of notification letters that 
we reviewed as part of this study. See appendix II for a description 
of possible data limitations. 

Source: Department of Veterans Affairs, Veterans Benefits 
Administration, “Effect of Clarity of Decision Letter on Percent Who 
Appealed or Who Contacted VA to Discuss the Letter by Whether Their 
Claim was Granted or Denied,” Survey of Veterans’ Satisfaction with 
the VA Compensation and Pension Claims Process: 2000 Summary Report 
(Washington, D.C.: 2001). 

[End of figure] 

Multiple Factors Contribute to Deficiencies; Some Initiatives Are 
Under Way, but an Evaluation System Is Needed: 

Four key factors contribute to deficiencies in VBA’s letters and their 
attachments: 

* Attempting to achieve more than one objective and, in doing so, 
compromising clarity for the reader. 

* Using boilerplate paragraphs that contain redundancies and writing 
deficiencies, such as technical terminology that is difficult for a 
layperson to understand. 

* Through human error, making editorial mistakes and not adapting 
boilerplate language to the claimant’s specific situation. 

* Not systematically evaluating letter clarity, not identifying 
writing deficiencies, and not providing timely feedback to help 
correct such deficiencies. 

VBA has initiatives underway to address some of these problems (see 
table 4). 

Table 4: Status of VBA Initiatives That Can Improve Clarity of Letters 
and Attachments: 

Letters: 

Initiative: Revisions of national compensation and pension program 
letters; 
Description: To make letters more reader friendly, VBA revised the 
paragraphs that are stored in a national database and used by ROs to 
compose letters; 
Status: Begun in spring 2001, revisions of national compensation and 
pension notification letters and new Strong Prompts technology were 
tested with some ROs and made available for RO use at the end of 2001. 
Use of these revised national notification letters was then mandated 
for all ROs. VBA has plans extending into 2003 to revise other types 
of national compensation and pension program letters. For example, VBA 
officials plan to clarify the national development letter and 
incorporate the revised language into the national database of 
paragraphs in the summer of 2002 at the earliest. 

Initiative: Strong Prompts; 
Description: VBA created a software application that provides a 
mechanism for selecting and inserting paragraphs from the national 
database of revised paragraphs; 
Status: Begun in spring 2001, revisions of national compensation and 
pension notification letters and new Strong Prompts technology were 
tested with some ROs and made available for RO use at the end of 2001. 
Use of these revised national notification letters was then mandated 
for all ROs. VBA has plans extending into 2003 to revise other types 
of national compensation and pension program letters. For example, VBA 
officials plan to clarify the national development letter and 
incorporate the revised language into the national database of 
paragraphs in the summer of 2002 at the earliest. 

Rating Decision Documents: 

Initiative: Improvement of rating decision document quality: Training 
and guidance materials; 
Description: VBA provided training and guidance materials for rating 
specialists that, in part, were intended to encourage them to 
eliminate redundancy and incorporate into the rating document a brief 
layperson’s summary of the success in enhancing clarity of the rating 
document; 
Status: The initiative, begun in 2000, was subject to a range of 
implementation problems that limited the initiative’s. These problems 
included not mandating that ROs reasons for the decision. provide a 
layperson’s summary, not emphasizing clarity sufficiently in training, 
and increasing workload pressures in ROs. Although training has ended, 
related written guidance was distributed in May 2001. 

Initiative: Improvement of rating decision document quality: Review of 
rating decision documents prepared for recently discharged claimants; 
Description: VBA reviewed rating decision documents to determine their 
sufficiency for notifying claimants of the reason for the decision, 
among other objectives. This review was to consider, in part, ways to 
prepare a rating document that explained the decision clearly for all 
readers—-especially laypersons-—and was free of professional jargon 
while meeting legal requirements; 
Status: The results of the review, which began at the end of 2001, are 
currently being assessed. 

Initiative: Revisions of rating schedule; 
Description: VBA updated the terminology and medical conditions in the 
Schedule for Rating Disabilities. While improving clarity was not a 
focus of this initiative, the initiative did involve removing 
ambiguity and, with more recent regulations, explaining some medical 
terms in lay language when this could be done briefly. Some medical 
terms and concepts would require lengthy explanations, which VBA 
believes would be better left to claimants’ medical providers; 
Status: VBA has completed more than two-thirds of this initiative and 
estimates that it will not be finalized for another 2 years. 

Initiative: Simplification of legal terms; 
Description: VBA aimed to simplify and clarify legalistic language 
embedded in a computer application used to create rating decision 
documents; 
Status: This initiative focused only on a few less complex types of 
rating decisions, such as whether to award benefits for specially 
adapted housing. The initiative was temporarily suspended to redirect 
agency resources toward reducing the backlog of pending cases. A task 
force is currently assessing how to resume this process of simplifying 
language. 

Forms: 

Initiative: Revision of standard forms; 
Description: VBA revised standard forms to make them more reader 
friendly; 
Status: VBA revised the claimant’s appeal rights form and is currently 
assessing how to go about rewriting the rest of its standard forms. 

[End of table] 

VBA’s Attempt to Achieve Multiple Objectives May Compromise Clarity; 
VBA Has Some Initiatives Planned and Under Way to Improve Clarity: 

In many of its rating decision documents and development letters, VBA 
attempts to achieve more than one objective. In doing so, however, VBA 
may compromise clarity for the reader. The rating decision document is 
intended to serve two purposes. Its first purpose is to provide 
veterans with a readily understandable explanation of the decision 
regarding their claims for benefits. Its second purpose is to document 
the precise legal and medical reason for the decision, which is 
especially important if the claimant appeals the decision. If a 
claimant appeals a decision, the Board of Veterans’ Appeals and the 
Court of Appeals for Veterans Claims use the rating decision document 
as a basis for their review. Because the rating decision document is 
used in this legal process, regulation and court precedents require 
that rating decision documents include certain key pieces of 
information that can involve highly technical language. 

For example, the rating decision documents must lay out the medical 
criteria justifying the degree of disability assigned to a claim, as 
well as the medical criteria for the next higher degree of disability. 
The criteria are taken from VA’s Schedule for Rating Disabilities, 
which sometimes uses technical medical terminology. Additionally, 
rating decision documents must include an evaluation of all relevant 
evidence and how this evidence supports a particular decision on the 
claim. Because the documents must discuss the evidence with reference 
to the medical criteria justifying the degree of disability, this 
discussion is typically written with terminology similar to that found 
in the criteria. Table 5 illustrates the similarity of technical 
language in the Schedule for Rating Disabilities for heart diseases to 
the language in a rating decision document that we reviewed in our 
sample of letters. 

Table 5: Similarity of Technical Language in Medical Criteria from the 
Schedule for Rating Disabilities and a Rating Decision Document 

Illustration of medical criteria for heart diseases, excerpted from 
the Schedule for Rating Disabilities (38 CFR 4.104, July 1, 2001): 
[For 30 percent degree of disability:] “Workload of greater than 5 
METs but not greater than 7 METs results in dyspnea, fatigue, angina, 
dizziness, or syncope, or; evidence of cardiac hypertrophy or 
dilatation on electro-cardiogram, echocardiogram, or X-ray.” 
Excerpt from a typical rating decision document taken from our sample: 
“An evaluation of 30 percent is assigned if there is workload greater 
than 5 METs but not greater than 7 METs resulting in dyspnea, fatigue, 
angina, dizziness, or syncope; or evidence of cardiac hypertrophy or 
dilatation on electrocardiogram, echocardiogram, or X-ray. 

Illustration of medical criteria for heart diseases, excerpted from 
the Schedule for Rating Disabilities (38 CFR 4.104, July 1, 2001): 
[Note:] “One MET (metabolic equivalent) is the energy cost of standing 
quietly at rest and represents an oxygen uptake of 3.5 milliliters per 
kilogram of body weight per minute.” 
Excerpt from a typical rating decision document taken from our sample: 
“One MET (metabolic equivalent) is the energy cost of standing quietly 
at rest and represents an oxygen uptake of 3.5 milliliters per 
kilogram of body weight per minute.” 

[End of table] 

Some central office officials assert that the ability of rating 
specialists to explain medical conditions in lay terms is necessarily 
limited because the specialists lack in-depth medical training and 
physicians are not available in all regional offices to assist them. 
As a result, in preparing rating decision documents, rating 
specialists tend to repeat the language used in regulations and 
medical reports. Because the reports of VA physicians’ medical 
examinations of claimants are now available in electronic form, 
employees can now copy wording from these reports directly into the 
rating document. 

While rating decision documents may be used as legal documents by the 
Board of Veterans’ Appeals and the Court of Appeals for Veterans 
Claims, they are also used to meet the needs of a vastly different 
audience-—the claimant, who is typically a lay reader. VBA regulations 
state that claimants are entitled to notice of a VBA decision that 
affects their benefits, including a clear statement of the reason, or 
reasons, for the decision. The rating decision document is currently 
the primary means of complying with the regulations and communicating 
the reasons for the decision to the claimant. However, as our review 
of letters and their attached rating decision documents showed, the 
reasons for the decision were often unclear to lay readers. These 
documents did not provide a lay summary explanation of the reasons for 
the decision. 

Acknowledging that its rating decision documents need improvement, VBA 
is working to assure that these documents provide the claimant with a 
clear explanation of the reasoning used to reach the decision, while 
documenting for the record the legal and medical reasons for the 
decision. For example, one aim of VBA’s initiative to improve the 
quality of the rating decision document was to train rating 
specialists to briefly summarize the reasons for the decision in terms 
that a layperson could easily understand. However, this initiative had 
limited success, owing to a range of implementation problems explained 
in table 4. In a related initiative, the review of rating decision 
documents prepared for recently discharged claimants, VBA has 
reemphasized the importance of preparing high-quality rating decision 
documents. In this initiative, VBA is considering how it can explain 
the decision clearly for all readers, especially laypersons, while 
meeting legal requirements. The results of this review, which was 
begun at the end of 2001, are currently being assessed. In addition, 
recent revisions of the Schedule for Rating Disabilities include 
efforts to explain some medical terms in lay language, but only when 
such explanations can be written relatively briefly. Lengthier 
explanations are left for the claimants’ medical providers. Some of 
these revisions of the schedule have yet to be published, so it is too 
early to know the extent to which they will affect readability of the 
rating documents. 

With the development letters, like the rating decision documents, VBA 
attempts to serve two purposes and, in doing so, may compromise 
clarity for the claimant. VBA sends development letters to claimants 
to request specific information necessary to reach decisions on their 
claims. At the same time, VBA uses the letter to meet its legal 
obligations under VCAA. VCAA requires, among other things, that VBA 
notify claimants of any information that is necessary to substantiate 
the claim. VCAA also requires VBA to distinguish between the 
information that the claimant is to supply and the information that 
VBA is to obtain on the claimant’s behalf. Our review of a sample of 
development letters showed that in attempting to comply with its legal 
duties, VBA obscured its explanation of the specific information 
needed from the claimant to support the claim. 

VBA acknowledges that improvements are needed to clarify the current 
development letter, but improvement efforts are not yet under way. 
Currently, VBA is focusing its energies on revising its national 
compensation and pension program letters. As part of this effort, VBA 
officials plan to clarify the national development letter’s language 
and incorporate the revised language into the national database of 
paragraphs in the summer of 2002, at the earliest. 

Some Standardized Paragraphs and Forms Contain Deficiencies; VBA 
Is Working on Resolutions: 

VBA’s central office, as well as some ROs, have developed boilerplate 
paragraphs for letters and the rating decision attachments to lessen 
the time that employees spend in creating them and to improve their 
quality and consistency. VBA has also developed a variety of standard 
forms to provide detailed information to claimants regarding other 
types of benefits and to obtain various types of information from 
claimants. Employees in ROs who write letters may choose to attach 
these forms to the letters, as appropriate. 

Some boilerplate paragraphs and standard forms, however, contain 
writing deficiencies that reduce clarity, such as convoluted language 
and highly technical terminology. Because the unclear text is part of 
the standard boilerplate language, it is replicated in numerous 
letters and attachments that are mailed to claimants. Moreover, 
boilerplate paragraphs lack critical information such as, in some 
notification letters, the deadline for filing an appeal of VBA’s 
decision and, in some development letters, the consequences for not 
responding in a timely manner to VBA’s request for information. 

VBA has begun to take steps to deal with boilerplate language 
problems. First, in the spring of 2001, VBA began to simplify and 
clarify boilerplate language in its national compensation and pension 
notification letters. However, the extent to which these letters are 
being used by the ROs is unknown. Second, as part of its Reader-
Focused Writing effort, VBA attempted to simplify legal terms embedded 
in the computer application used to create a rating decision document. 
VBA did not attempt, however, to simplify the legalistic language used 
for the more complicated rating issues involved in deciding disability 
compensation and pension claims. Although the initiative was 
temporarily suspended, a task force is currently considering how to 
resume efforts to simplify the language. The agency also recognizes 
the need for rewriting its standard forms according to reader-focused 
principles. It has rewritten the form that describes a claimant’s 
right to appeal a decision and is currently considering how to go 
about rewriting the rest of its standard forms. 

Boilerplate language contributes to the redundancy that we found in 
rating decision documents. The computer application that VBA employees 
use in creating rating decision documents automatically inserts 
boilerplate text concerning the legal principle applicable to the 
decision for each claimed condition.[Footnote 14] This boilerplate 
text is automatically inserted for each condition, even if the reason 
for the decision for each condition is the same. In the same way, a 
rating specialist, when preparing a rating decision document, may 
insert the same boilerplate text for each claimed condition. 

As part of its previously described initiative to improve the quality 
of rating decision documents, VBA has attempted to reduce some of the 
redundancy in them. Guidance materials issued nationwide as part of 
this initiative instructed ROs, when preparing rating decision 
documents, to consider grouping the reasons for the decision for each 
claimed condition when the reasons were the same. VBA’s guidance 
materials note, however, that grouping the reasons for the decision is 
a cumbersome task. These materials state that VBA might seek computer 
enhancements to make it easier for employees to reduce redundancy. To 
date, however, VBA has not made any computer enhancements that would 
ease the task of eliminating redundancy. 

Human Error Contributes to Some Writing Deficiencies; VBA’s Efforts to 
Improve Letters May Reduce the Need for Human Intervention: 

During the process of drafting a letter to a claimant or a rating 
decision document, editorial mistakes and other writing deficiencies 
can result from human error. Human error can occur when employees 
modify existing text or insert original text, which they may do for a 
variety of reasons. For example, boilerplate paragraphs may not be 
appropriate for every claimant’s particular situation and may 
therefore have to be revised. In addition, an employee will need to 
insert original text, such as medical conditions, dates, dollar 
amounts, or other facts that are specific to the claimant. Also, 
because they believe that some boilerplate paragraphs used to create 
letters or rating decision documents contain writing deficiencies, 
employees with whom we spoke in some ROs edit these paragraphs by 
inserting original text, or they cut and paste from what they perceive 
to be clearer existing text developed by other RO employees. Officials 
in one RO told us that this process of modifying existing text and 
inserting original text could result in editorial mistakes. Types of 
editorial mistakes in the letters that we reviewed included 
typographical errors, run-on sentences, and sentence fragments. 

Workload pressures and an inexperienced new workforce can exacerbate 
writing deficiencies related to human error. ROs are under pressure to 
reduce VBA’s large backlog of pending claims. Additionally, according 
to VBA officials, a significant portion of VBA’s veterans service 
representatives and rating specialists are newly hired and need 
intensive training and on-the-job experience to become fully 
proficient at creating and modifying letters and rating decision 
documents. For example, rating specialists require about 2 years to 
become fully productive. The combined effect of many new hires and a 
heavy workload can increase the potential for human error that can 
contribute to writing deficiencies. 

Writing deficiencies can also occur when a letter writer does not 
check the relevance of the boilerplate language. It is ultimately the 
responsibility of the employee to read the letter or rating document 
that he or she has created and to revise or replace any text if it 
does not apply to the claimant’s particular situation. However, 
according to some RO officials, because of time pressures, employees 
do not take the time necessary to review letters for writing 
deficiencies. The inconsistencies and incomplete information that we 
found in some key aspects of the letters we reviewed—such as the 
statement of VBA’s decision and the financial information concerning a 
claimant’s benefits—suggest that the letters had not been reviewed 
thoroughly for overall clarity. 

VBA’s efforts to revise its national compensation and pension 
notification letters may help to reduce the need for human 
intervention in letter writing. For example, VBA has designed its 
revised national compensation and pension notification letters to 
cover about 80 percent of possible claimant situations that a letter 
might have to address. As a result, the need for a veterans service 
representative to modify boilerplate paragraphs in letters that are 
inappropriate for a claimant’s particular situation should decrease. 
However, some human intervention will probably always be required, 
even with the revised national notification letters, because these 
letters cannot be written to cover all possible claimant situations. 

In addition, VBA has developed the new Strong Prompts software 
application, intended to make it easier for the veterans service 
representative in the field to create a letter. With this application, 
a series of automated commands guides a veterans service 
representative in the process of creating a notification letter using 
the revised boilerplate paragraphs. These commands prompt the veterans 
service representative to select particular paragraphs or to insert 
specific information. VBA officials expect that use of the new 
software application will reduce the time needed to create a letter. 
If this productivity enhancement is achieved, it could eventually help 
to reduce workload pressures that contribute to mistakes. 

Further, during the process of testing the revised national 
compensation and pension notification letters with the ROs, VBA 
received feedback from the ROs about how to improve the letters. The 
agency used this feedback to improve the national letters as 
appropriate. Thus, some of the writing deficiencies that veterans 
service representatives identified in the previous national 
notification letters may have been eliminated through the testing 
process, potentially reducing the perceived need for veterans service 
representatives to modify the boilerplate paragraphs. However, simply 
using the revised national letters will not eliminate human error. In 
fact, RO officials warn that errors can result from excessive 
dependence on automated tools for preparing letters without close 
review of how the letters apply to claimants’ specific situations. 

VBA Lacks Systematic Monitoring and Feedback to Identify and Correct 
Writing Deficiencies: 

VBA recognizes the importance of evaluating the clarity of its 
letters. For example, the agency’s blueprint for its Reader-Focused 
Writing Program acknowledged that ongoing evaluation of program 
effectiveness should be an essential element of this initiative. 
[Footnote 15] Moreover, the agency has some systems in place to assess 
the clarity of its letters. However, these systems are not adequate 
for helping VBA continuously monitor and improve the clarity of its 
letters throughout the compensation and pension program. Consequently, 
VBA will continue to miss opportunities to systematically evaluate 
clarity, identify writing deficiencies, and provide timely feedback to 
the responsible organizational component to help correct such 
deficiencies. 

VBA has a customer satisfaction survey that addresses some aspects of 
letter quality, but this survey is not designed to be a tool for 
continuously improving clarity of VBA’s letters. The annual Survey of 
Veterans’ Satisfaction with the VA Compensation and Pension Claims 
Process measures various aspects of customer satisfaction for a random 
sample of persons whose claims are pending or were recently decided. 
[Footnote 16] Three questions on the survey measure the extent to 
which notification letters clearly explain the agency’s decision and 
the subsequent appeal process. While responses to these questions 
provide broad information on overall customer satisfaction with 
clarity of notification letters and their attachments, they do not 
allow VBA to identify the root causes of specific problems with 
clarity in its notification letters. Without this information, VBA may 
not be able to develop effective solutions. 

In addition to its customer service survey, the agency’s Systematic 
Technical Accuracy Review Program includes a limited review of 
letters. However, this system is intended primarily to assess overall 
claims accuracy, not letter clarity. To assess accuracy of VBA claims, 
reviewers evaluate a monthly sample of completed cases, including 
letters created as part of the cases. The reviewers use formal 
guidelines that address such accuracy issues as whether all claims 
issues were addressed; correctness of the decision, effective dates, 
and payment rates; and whether the basis of each decision was 
explained and all applicable evidence was discussed. Reviewers also 
follow guidelines for assessing accuracy and completeness of letters 
notifying claimants about the agency’s decision. Although the 
guidelines were not designed to assess letter clarity in a 
comprehensive fashion, they do address some dimensions of letter 
clarity such as conciseness, logical sequencing, and consistency. They 
do not, however, cover other important elements of clarity, such as 
the absence of technical jargon, convoluted language, or redundancy. 
Moreover, the system is not designed to obtain the opinions of 
claimants, their representatives, or VBA employees who process claims 
with regard to specific letter clarity problems. Yet, given the 
deficiencies that we encountered in our letter review and the 
complaints about clarity that we heard from RO officials and claimant 
representatives, such information is essential for identifying writing 
deficiencies. 

While VBA does not have a programwide mechanism for systematically 
evaluating letter clarity, each RO is required to assess at least 
annually various aspects of claims processing, including the quality 
of its locally generated letters. On the basis of this assessment, 
each RO is to diagnose potential problems and identify solutions. Our 
interviews with RO officials indicated that there is variation in 
whether and how the ROs evaluate letter clarity. For example, 
officials at two ROs told us that they review a sample of a day’s 
outgoing letters every three months to assess writing deficiencies. 
Additionally, one of these ROs reviewed its letters for clarity 
semiannually with focus groups of veterans and their representatives, 
although workload pressures resulted in recent reductions in this 
effort. On the basis of claimant input obtained in this way, this RO 
has made immediate improvements to its letters. Officials whom we 
interviewed at another RO survey a sample of 10 claimants every week 
to assess letter clarity, among other service issues, and invite 
comments. In contrast to the emphasis placed by these ROs on 
evaluating letter clarity, at another RO where we conducted 
interviews, the annual assessment of letter quality does not focus on 
clarity but rather on accuracy. 

VBA acknowledges the importance of evaluation. Prior to establishing 
its Reader-Focused Writing Program, VBA used focus groups of veterans 
and employees and a variety of ad hoc studies to assess the clarity of 
the letters that it sent to claimants. However, its compensation and 
pension program has more recently focused its efforts on revising its 
national letters rather than on evaluating the clarity of the letters 
that the ROs are generating. Without systematically evaluating the 
clarity of its letters, VBA will not know if its revised national 
letters or other efforts are improving letter clarity. 

Conclusions: 

Given the environment in which VBA is operating—including large claims 
backlogs, the inexperience of a significant portion of the workforce, 
and complex laws and regulations—writing clear letters can be a 
daunting task. Veterans and their families, as well as VBA itself, 
benefit when the agency effectively conveys the information that it 
intends to communicate. Veterans are entitled to compensation and 
other benefits for their military service-related conditions and, in 
some instances, to pensions for conditions not directly related to 
their military service. If veterans submit a claim for benefits, it is 
reasonable for them to expect that they will be able to understand 
what VBA decided and why. 

To fulfill these expectations, it is imperative that VBA clearly 
convey in its development letters what claimants must provide to 
support their claims. Doing so at the outset could improve the chances 
of VBA’s making the appropriate decision based on complete 
information, thus avoiding the processing delays that could result 
from subsequent information requests. It is also important that VBA 
provide claimants with a clear explanation of the reasoning that the 
agency used to reach its decision. Unclear reasoning can confuse and 
frustrate claimants and take a toll on VBA’s efficiency if scarce 
staff resources must be diverted to rework claims. While explaining 
the reasoning is challenging, VBA acknowledges that improvements are 
needed and is working to clarify the rating decision documents. Some 
of the letters that we read demonstrate that VBA can prepare rating 
decision documents that clearly state the reasons for the decision in 
language that a layperson can understand. 

VBA has taken some steps to address the root causes of writing 
deficiencies. In addition, its reader-focused initiative has been in 
the vanguard of the plain-language movement in the federal government. 
However, without a systematic mechanism for evaluating the clarity of 
its letters, VBA lacks a means to position itself to continuously 
improve letter clarity. As a result, VBA will continue to miss 
opportunities to identify writing deficiencies in letters, diagnose 
their causes, and provide timely feedback to guide corrective actions. 
Moreover, the agency will not have a way to assess whether its 
initiatives are being implemented consistently and are having the 
intended effect of improving letter clarity. Until VBA systematically 
evaluates letter clarity, the agency cannot comprehensively measure 
its performance in communicating clearly with claimants, assess its 
progress in improving letter clarity, or hold itself accountable for 
making such improvements. VBA already uses its Systematic Technical 
Accuracy Review Program to partially assess the clarity of its 
letters. It could develop this into a more comprehensive review to 
supplement its accuracy rate computation or choose other ways to 
assess clarity. In deciding how to proceed, VBA would need to balance 
the costs of evaluating clarity against the benefits to claimants, and 
to VBA itself, of reducing the need to rework claims. 

We recognize that VBA is trying to address other high-priority issues, 
namely, reducing the backlog and shortening lengthy processing times, 
a long-standing problem. These issues are extremely important and 
deserve the immediate attention that they are getting. However, 
communicating clearly with claimants is an integral part of the 
solution and needs to be addressed. The Secretary of the Department of 
Veterans Affairs estimates that VBA’s pending workload will be under 
control by September 2003. At that time, VBA needs to start holding 
itself accountable for communicating clearly to claimants. In the 
meantime, to position itself to do this, the agency needs to develop a 
systematic mechanism that will enable it, on an ongoing basis, to 
assess the effectiveness of initiatives to improve letter clarity. 

Recommendations: 

As VBA proceeds with its initiatives to improve the clarity of its 
letters, we recommend that the Secretary of the Department of Veterans 
Affairs direct the Undersecretary for Benefits to take the following 
steps to enhance the effectiveness of these efforts: 

1. Eliminate writing deficiencies in the national development letter 
to clarify the actions that the claimant should take to substantiate a 
claim. Once the letter is rewritten, before mandating its use by the 
ROs, test its clarity with claimants, their representatives, and 
employees who process claims in the ROs. 

2. In continuing VBA’s efforts to improve rating decision documents, 
write succinctly, clearly, and in lay terms the reasons for its 
decisions to grant or deny benefits. 

3. Expand the Systematic Technical Accuracy Review Program or choose 
other ways to systematically evaluate whether letters (including their 
attachments) are clear to the claimant. The evaluation method should 
include obtaining periodic input on letter clarity from claimants, 
their representatives, and employees who process claims. Use the 
results of this evaluation to continuously improve letters by 
identifying writing deficiencies and providing timely feedback to 
enable the responsible entity (e.g., central office or ROs, as 
appropriate) to take corrective actions. In September 2003, when VBA 
projects that its large inventory of backlogged claims will be 
reduced, the agency should formally measure letter clarity and hold 
itself accountable for improved clarity. 

Agency Comments and Our Response: 

The Department of Veterans Affairs provided written comments on a 
draft of this report. These comments are reprinted in appendix I. The 
agency agreed with our conclusions and concurred with our 
recommendations, noting that, in seeking to enhance quality of service 
to veterans, improving the quality of its communications is a critical 
element. The agency also detailed steps that it is planning or has 
under way, including timeframes, to implement the recommendations. 

As agreed with your office, we will make no further distribution of 
this report until 10 days after its issue date, unless you publicly 
release the contents earlier. At that time, we will send copies of 
this report to the Honorable Anthony J. Principi, Secretary of the 
Department of Veterans Affairs; appropriate congressional committees; 
and other interested parties. We will make copies available to others 
on request. The report will also be available on GAO’s home page at 
[hyperlink, http://www.gao.gov]. 

If you or your staff have any questions regarding this report, please 
call me at (202) 512-7101 or Shelia Drake, assistant director, at 
(202) 512-7172. Staff acknowledgments are listed in appendix III. 

Sincerely yours, 

Signed by: 

Cynthia A. Bascetta: 
Director, Education, Workforce, and Income Security Issues 

[End of section] 

Appendix I: Comments from the Veterans Benefits Administration: 

The Secretary of Veterans Affairs: 
Washington: 

April 10, 2002: 

Ms. Cynthia A. Bascetta: 
Director Education, Workforce, and Income Security Issues: 
U. S. General Accounting Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Bascetta: 

The Department of Veterans Affairs (VA) has reviewed your draft 
report, Veterans Benefits Administration: Clarity of Letters to 
Claimants Needs to Be Improved (GAO-02-395) and agrees with your 
conclusions and concurs with your recommendations. In the Department's 
efforts to enhance the overall quality of service to our Nation's 
veterans, improving the quality of VA's communications is a critical 
element. As GAO pointedly concludes, making VA's letters more readily 
understandable can be a significant factor in achieving the Veterans 
Benefits Administration's (VBA) goal of reducing the serious problem 
of claims processing backlogs. 

The enclosure details actions underway and plans to implement GAO's 
recommendations. Thank you for the opportunity to comment on your 
draft report. 

Sincerely yours, 

Signed by: 

Anthony J. Principi: 

Enclosure: 

Department Of Veterans Affairs Comments To GAO Draft Report, Veterans 
Benefits Administration: Clarity of Letters to Claimants Needs to Be 
Improved (GAO-02-395): 

As VBA proceeds with its initiatives to improve the clarity of its 
letters, GAO recommends that I direct the Under Secretary for Benefits 
to take the following steps to enhance the effectiveness of these 
efforts: 

1. Eliminate writing deficiencies in the national development letter 
to clarify the actions that the claimant should take to substantiate a 
claim. Once the letter is rewritten, before mandating its use by the 
ROs, test its clarity with claimants, their representatives, and 
employees who process claims in the ROs. 

Concur - The development/substantiation letter created to address the 
duty to assist requirements established by the Veterans Claims 
Assistance Act of 2000 (Public Law 106-475) must be rewritten. Members 
of the Compensation and Pension (C&P) Service will draft a rewrite of 
the letter. To ensure clarity, VBA proposes to contract with Kleimann 
Communications Group to protocol test the letter at 3 sites with a 
total of 18 veterans. VBA has used the Kleimann Communication Group 
for its Reader Focused Writing initiative and still has an open 
contract with them. VBA plans to have that contract modified to add 
this task. 

Based on comments received during the protocol testing, C&P will 
revise the letter as needed. VBA will send the revised letter to some 
regional office users and veterans' service organization (VSO) 
representatives for review and comment. Based on comments received 
from regional office users and VSOs, VBA will revise the letter 
further, as needed. 

VBA will send the finalized letter to regional offices in the form of 
a template or sample letter for their use, pending programming in 
national personal computer generated letters (PCGL). VBA anticipates 
the sample letter can be drafted, tested, revised, and finalized by 
August 1, 2002. 

Once the letter has been finalized, C&P Service staff members will 
build the specifications and share them with VA's Hines data 
processing center for PCGL programming. After C&P Service staff 
members have tested and certified the letter, it will go to pre-
production according to schedule. The letter will be deployed 
initially to beta sites for testing prior to national deployment. At 
this time, VA cannot project when the programmed letter will be 
deployed as a part of national PCGL. The timeline is dependent on 
VBA's technology upgrade from Windows 95 to Windows 2000 which we 
currently anticipate to be effective by May 30, 2003 for the desktops. 

2. In continuing VBA's efforts to improve rating decision documents, 
write succinctly, clearly, and in lay terms the reasons for its 
decisions to grant or deny benefits. 

Concur - VBA is aware that rating decision documents produced in its 
regional offices may be improved with respect to their clarity. 
Statutory requirements for rating decision content can sometimes 
result in language that is either fraught with medical terminology or 
legalese, both of which may be confusing to a layperson. 

In an effort to improve the content and the clarity of rating 
decisions, VA has formed a task force to review the content of rating 
decisions and the process through which they are prepared. The task 
force consists of three employees from VBA's C&P Service, along with 
three representatives from the Office of General Counsel and three 
representatives from the Board of Veterans' Appeals. The task force 
has identified ways to improve the content and clarity of rating 
decisions. Members of the task force believe this may be accomplished 
by being more precise in the formulation and communication of 
organizational expectations to VBA's decision makers and by developing 
and using information technology (IT) more prudently. 

Well written, legally sufficient ratings should explain the decision 
without undue details, and be in terms understandable to a layperson. 
This is the goal of VBA. Neither the interests of veterans nor VBA are 
served when Rating Veterans Service Representatives write 
unnecessarily long rating decisions that are unclear to veterans and 
their advocates. 

VBA has approved the task force's recommendations. Within the next 2 
months, VBA will develop and issue new guidelines and training 
materials. Shortly after issuing them, VBA will hold a nationwide 
satellite broadcast to discuss the guidelines and to share directly 
with decision makers VBA's organizational expectations. 

3. Expand the Systematic Technical Accuracy Review (STAR) program or 
choose other ways to systematically evaluate whether letters 
(including their attachments) are clear to the claimant. The 
evaluation method should include obtaining periodic input on letter 
clarity from claimants, their representatives, and employees who 
process claims. Use the results of this evaluation to continuously 
improve letters by identifying writing deficiencies and providing 
timely feedback to enable the responsible entity (e.g. central office 
or regional offices, as appropriate) to take corrective actions. In 
September 2003, when VBA projects that its large inventory of 
backlogged claims will be reduced, the agency should formally measure 
letter clarity and hold itself accountable for improved clarity. 

Concur - STAR reviews will include assessment of letter clarity. The 
issue of clarity alone will not be included as an error category, but 
will be a documented comment category. Recently, VBA modified the STAR 
database to capture comments in several key areas, including 
notification. These comments provide case specific feedback to VBA's 
regional offices. Additionally, summary reports will provide essential 
data for trend analysis. An individual with extensive experience in 
the area of written communication has been added to VBA's quality 
review team and will be assigned the lead for ensuring continuing 
assessment and feedback concerning letter clarity. VA agrees that 
September 2003 would be the appropriate time to formally measure 
letter clarity. 

[End of section] 

Appendix II: Scope and Methodology: 

To assess letter clarity, we analyzed a random sample of each of three 
types of letters (including the letter attachments) generated by the 
Veterans Benefits Administration’s (VBA) compensation and pension 
program: (1) letters notifying claimants of original and reopened 
compensation decisions, (2) letters notifying claimants of original 
and reopened pension decisions, and (3) compensation and pension 
development letters sent to claimants.[Footnote 17] We selected these 
types of letters because they reach a large number of people, have the 
potential for affecting VBA’s productivity if they are unclear, and 
are relatively complex. Moreover, the compensation and pension 
notification letters convey important information about claimants’ 
eligibility for benefits and about changes in their benefit amounts 
that can significantly affect their future income. The types of 
letters that we selected account for about 36 percent of notification 
and development letters sent by VBA’s compensation and pension 
program.[Footnote 18] 

We selected each of our three samples of letters from a national 
sample of cases that VBA collects for its Systematic Technical 
Analysis Review Program. VBA draws this sample each month from the 
cases involving a disability rating that are completed in each of VBA’
s nine service delivery networks during the month.[Footnote 19] After 
we had accounted for missing cases and letters, our three samples 
comprised the following: 

* Ninety-seven compensation letters selected from VBA’s sample of 
cases that were closed in June 2001. 

* Seventy-two pension letters comprising VBA’s entire sample of 
pension cases that were closed in both June and July 2001. (VBA’s 
sample of cases closed in June 2001 was not large enough to yield an 
adequate number of letters.) 

* Seventy-three development letters drawn from our sampled 
compensation and pension cases that were closed in June 2001, as 
described above, and written in 2001. Because the Veterans Claims 
Assistance Act (VCAA) was signed into law on November 9, 2000, letters 
written in 2001 were more likely to reflect the law’s requirements 
than were letters written before 2001. The development letters that we 
selected were those substantive development letters that were first 
sent to claimants after they had filed a claim for benefits. Thus, our 
development letter sample did not include the letters sent 
subsequently to claimants or others to request particular items, such 
as a signature on a form, that were missing from the claim files. 

Because we followed a probability procedure based on random 
selections, our sample is only one of a large number of samples that 
we might have drawn. Since each sample could have provided different 
estimates, we express our confidence in the precision of our 
particular sample’s results as 95 percent confidence intervals (for 
example, +/- 7 percentage points). These are the intervals that would 
contain the actual population values for 95 percent of the samples 
that we could have drawn. This means that there is a 95 percent 
likelihood that each of the confidence intervals in this report will 
include the true values in the study population. Unless otherwise 
noted, all percentage estimates from the letter review have sampling 
errors (confidence intervals) whose upper and lower bounds are not 
more than 10 percentage points higher or lower than the estimated 
percentage. 

We used VBA’s legal and policy requirements for its notification and 
development letters as the basis for identifying the aspects of a 
letter that should be clearly conveyed to claimants. For the 
notification letters, these were: 

1. VBA’s decision concerning the claimant’s entitlement to benefits, 

2. the reason for VBA’s decision, 

3. the financial information concerning the amount of benefits to 
which the claimant is entitled, 

4. the claimant’s responsibilities and appeal rights and ways to 
contact VBA for more information, and, 

5. other benefits that might be available to the claimant. 

Moreover, we based our assessment of VBA’s development letters on the 
premise that they would clearly explain: 

1. the actions that the claimant should take to support the claim and, 

2. the actions that VBA would take or had taken in attempting to 
obtain information to support the claim. 

To review our samples of letters, we developed a set of decision rules 
in consultation with writing consultants and incorporated these rules 
into a data collection instrument to assess letter clarity.[Footnote 
20] For each aspect of a letter, our decision rules defined specific 
types of writing deficiencies—-for example, jargon, contradictory or 
incomplete information, or convoluted language—-that reduced 
understandability. The consultants used their professional opinion to 
judge whether the decision rules were a valid measure of letter 
clarity. To verify that these rules could be reliably applied to 
assess letter clarity, the consultants and our GAO team used the rules 
to review examples of VBA letters and identify writing problems. We 
then verified that the results of our reviews were consistent among 
all reviewers. Similarly, throughout the process of assessing the 
sampled letters for clarity, we used a systematic method of review to 
help assure that we were consistently applying the decision rules. 

In general, we used a two-staged process to assess whether VBA’s 
letters were clear. First, we determined what, if any, writing 
deficiencies were present for a key aspect of the letter. Second, we 
determined whether the writing deficiencies—if such existed—made the 
letter unclear for that aspect. An aspect of a letter could have 
multiple writing deficiencies, but unless the deficiencies were 
sufficient to make the meaning unclear to the reader, we would judge 
that aspect of the letter to be clear. 

As part of our methodology, to identify questions that were pertinent 
to this study, we reviewed the questionnaire used by VBA to survey its 
customers in its 2000 Survey of Veterans’ Satisfaction with the VA 
[Veterans Administration] Compensation and Pension Claims Process. For 
the relevant questions, VBA’s Surveys and Research staff provided us 
with special data results based on the 2000 survey. This survey data 
may have some limitations, however. The response rate to the VBA 2000 
survey was 62 percent. Because VBA did not conduct a nonresponse 
follow-up analysis to determine whether there was a difference between 
those individuals who responded to the survey and those who did not, 
the survey results may reflect an unknown level of bias. VBA believes 
that the sampling errors of estimates from their 2000 national 
customer service survey that are cited in this report do not exceed 
3.4 percentage points. 

To assess the underlying factors contributing to writing deficiencies 
in VBA’s letters and any initiatives to correct these deficiencies, we 
interviewed officials at VBA’s central office and at seven regional 
offices (RO), as well as claimant representatives. We selected the 
seven ROs because they reflected a range in the understandability of 
the ROs’ letters from the claimants’ perspective, according to VBA’s 
customer satisfaction survey, and because of their geographic 
dispersion. Moreover, we discussed writing deficiencies in VBA’s 
letters during interviews with claimant representatives on VCAA 
implementation, as part of another GAO study. 

We also reviewed VBA laws, regulations, and policies on notification 
and development letters and VBA documentation on initiatives to 
improve letter clarity. We conducted our work between March 2001 and 
March 2002 in accordance with generally accepted government auditing 
standards. 

[End of section] 

Appendix III: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Cynthia A. Bascetta, (202) 512-7101: 
Shelia Drake, (202) 512-7172: 

GAO Acknowledgments: 

In addition to those named above, Barbara Bordelon, Patrick diBattista, 
Tamara Harris, John Smale, James Wright, and Paul Wright made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] We estimated the number of notification and development letters 
because these numbers are not tracked. We based our estimate on the 
assumption that most benefit decisions would generate, at a minimum, 
one notification and one development letter. While some decisions 
might not require a development letter and others could result in 
multiple notification letters, development letters, or both, generally 
VBA will generate at least one notification letter and one development 
letter for each decision. These estimates do not reflect letters 
generated for certain types of activities, such as appeals or special 
reviews. Neither do the estimates reflect the letters sent to 
claimants to explain cost-of-living adjustments in their benefits or 
acknowledging receipt of their claims. 

[2] When a claimant submits an initial claim to VBA for compensation 
or pension benefits, that claim is designated as an “original” claim. 
Once the original claim is decided, subsequent claims are called “
reopened” claims. For example, claimants may submit reopened claims to 
request an increase in benefits or reconsideration of a previous 
denial. 

[3] To be eligible for pension benefits, in addition to having low 
income and permanent and total disability, veterans must have 90 days 
or more of active military service, at least one day of which was 
during a period of war. Under the law, VA recognizes certain war 
periods. For example, the war period for the Vietnam War is generally 
considered to be August 5, 1964, through May 7, 1975. The war period 
for the Gulf War is considered to have begun August 2, 1990, and is 
not yet recognized as having ended. Under the Veterans Education and 
Benefits Expansion Act of 2001, enacted on December 27, 2001, veterans 
who are 65 years or older do not have to be permanently and totally 
disabled to become eligible for pension benefits, as long as they meet 
the other requirements for income and military service. 

[4] Department of Veterans Affairs, Claims Processing Task Force, 
Report to the Secretary of Veterans Affairs (Washington, D.C.: 2001), 
p. 9. 

[5] Cases that do not involve a disability rating include such cases 
as adjustments to benefits resulting from income and dependency 
changes. Comparable data on the number of pending cases involving a 
disability rating in 1989 are unavailable. 

[6] For further information on VBA’s training program, see U.S. 
General Accounting Office, Veterans’ Benefits: Training for Claims 
Processors Needs Evaluation, [hyperlink, 
http://www.gao.gov/products/GAO-01-601] (Washington, D.C.: May 31, 
2001). 

[7] Data were provided by Surveys and Research staff, VBA Data 
Management Office (from data presented in Department of Veterans 
Affairs, Veterans Benefits Administration, Survey of Veterans’ 
Satisfaction with the VA Compensation and Pension Claims Process: 2000 
Summary Report [Washington, D.C.: 2001]). See appendix II for a 
description of possible data limitations. Veterans responding to the 
customer satisfaction survey would have evaluated letters written 
prior to spring 2001, when VBA launched its initiative to improve the 
quality of its compensation and pension program letters. In contrast, 
the samples of letters that we reviewed were likely to have included 
some letters that had been rewritten under the initiative. 

[8] See footnote 7. 

[9] The 95 percent confidence interval for the pension estimate ranges 
from 19 to 41 percent. 

[10] The 95 percent confidence interval for this estimate ranges from 
21 to 45 percent. 

[11] The 95 percent confidence interval for this estimate ranges from 
53 to 79 percent. 

[12] The 95 percent confidence interval for this estimate ranges from 
7 to 25 percent. 

[13] VBA grouped under “denied” those respondents whose entire claim 
was denied. VBA grouped under “granted” all respondents who replied 
that they had been awarded benefits, even if benefits were less than 
respondents had expected. 

[14] VBA is currently using two different versions of a computer 
application to create rating decision documents—the older Rating Board 
Automation (RBA) and a newer version, called RBA 2000. Both versions 
created substantial redundancy in some of the rating decision 
documents that we reviewed. 

[15] Department of Veterans Affairs, Undersecretary for Benefits, 
Reader-Focused Writing. Task Force on Simplified Communications 
(Washington, D.C.: 1995). 

[16] Department of Veterans Affairs, Veterans Benefits Administration 
Survey of Veterans’ Satisfaction with the VA Compensation and Pension 
Claims Process: 2000 Summary Report (Washington, D.C.: 2001). 

[17] Our selected compensation and pension categories do not include 
letters notifying survivors of benefits following the death of the 
claimant, such as death pensions. 

[18] As mentioned earlier, the estimates of the number of VBA’s 
compensation and pension letters do not reflect letters generated for 
certain types of activities, such as appeals or special reviews. 
Neither do they reflect the letters sent to claimants explaining cost-
of-living adjustments in their benefits or acknowledging receipt of 
their claims. 

[19] In addition to original and reopened compensation and pension 
cases, cases involving a disability rating include appeals. Cases that 
do not involve a disability rating include adjustments to benefits due 
to income and dependency changes. 

[20] Additionally, the writing consultants assessed the clarity of 
VBA’s standard forms that were commonly attached to the sampled 
letters. 

[End of section] 

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