VA Disability Benefits:

Improved Planning Practices Would Better Ensure Successful Appeals Reform

GAO-18-352: Published: Mar 22, 2018. Publicly Released: Mar 22, 2018.

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What GAO Found

The Department of Veterans Affairs' (VA) plan for implementing a new disability appeals process while attending to appeals in the current process addresses most, but not all, elements required by the Veterans Appeals Improvement and Modernization Act of 2017 (Act). VA's appeals plan addresses 17 of 22 required elements, partially addresses 4, and does not address 1. For example, not addressed is the required element to include the resources needed by the Veterans Benefits Administration (VBA) and the Board of Veterans' Appeals (Board) to implement the new appeals process and address legacy appeals under the current process. VA needs this information to certify, as specified under the Act, that it has sufficient resources to implement appeals reform and make timely appeals decisions under the new and legacy processes.

VA's appeals plan reflects certain sound planning practices, but it could benefit from including important details in several key planning areas:

Performance measurement: VA's plan reflects steps taken to track performance, but could articulate a more complete and balanced set of goals and measures for monitoring and assessing performance on a range of dimensions of success. Specifically, the plan reports that VA is developing a process to track timeliness of the new and legacy processes. However, contrary to sound planning practices, the plan does not include timeliness goals for all five appeals options available to veterans, does not include goals or measures for additional aspects of performance (such as accuracy or cost), and does not explain how VA will monitor or assess the new process compared to the legacy process. Unless VA clearly articulates a complete and balanced set of goals and measures, it could inadvertently incentivize staff to focus on certain aspects of appeals performance over others or fail to improve overall service to veterans.

Project management: VA's plan includes a master schedule for implementing the new appeals plan. However, this schedule falls short of other sound practices for guiding implementation and establishing accountability, such as articulating interim goals and needed resources for, and interdependencies among, activities. Unless VA augments its master schedule to include all key activities and reflect sound practices, VA may be unable to provide reasonable assurance that it has the essential program management information needed for this complex and important effort.

Risk assessment: VA has taken steps to assess and mitigate some risks related to appeals reform by, for example, pilot testing two of the five appeals options through its Rapid Appeals Modernization Program (RAMP). However, as designed, RAMP does not include key features of a well-developed and documented pilot test. For example, VA has not articulated how it will assess RAMP before proceeding with full implementation. In addition, RAMP is not pilot testing three options and, as a result, VA will not have data on the extent to which veterans will appeal directly to the Board when given the option. Unless VA identifies and mitigates key risks associated with implementing a new process, VA is taking a chance that untested aspects will not perform as desired.

Why GAO Did This Study

VA's disability compensation program pays cash benefits to veterans with disabilities connected to their military service. In recent years, the number of appeals of VA's benefit decisions has been rising. For decisions made on appeal in fiscal year 2017, veterans waited an average of 3 years for resolution by either VBA or the Board, and 7 years for resolution by the Board. The Veterans Appeals Improvement and Modernization Act of 2017 makes changes to VA's current (legacy) appeals process, giving veterans new options to have their claims further reviewed by VBA or appeal directly to the Board. The Act requires VA to submit to Congress and GAO a plan for implementing a new appeals process, and includes a provision for GAO to assess VA's plan.

This report examines the extent to which VA's plan (1) addresses the required elements in the Act, and (2) reflects sound planning practices identified in prior GAO work. GAO reviewed and assessed VA's appeals plan and related documents against sound planning practices, and solicited VA's views on its assessments.

What GAO Recommends

GAO recommends that VA (1) fully address all legally required elements in its appeals plan, (2) articulate how it will monitor and assess the new appeals process as compared to the legacy process, (3) augment its master schedule for implementation, and (4) address risk more fully. VA agreed with GAO's recommendations and outlined its planned actions to address them.

For more information, contact Elizabeth Curda at (202) 512-7215 or curdae@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: VA agreed with this recommendation, stating that both VBA and the Board will use existing resources to implement the new appeals process. VA also stated it plans to take additional steps to determine resource requirements for addressing workloads under both the legacy and new appeals process. For VBA, VA stated that it will continue to rely on RAMP to project resource requirements, while acknowledging the need to augment its analysis of RAMP data by adopting additional strategies to project resource requirements. VA did not describe these strategies, but stated that it will share them with Congress and GAO in the near future. Meanwhile, VA noted that its 2019 budget request includes 605 additional FTEs for VBA to process appeals, but did not indicate how it developed this budget request. For the Board, VA stated that it plans to develop better predictions regarding resource allocations among dockets by leveraging project management and other support within the agency. We will continue to monitor VA's efforts to delineate needed resources, including how it uses the results of pilot tests and prediction analysis.

    Recommendation: The Secretary of Veterans Affairs should address all of the required elements in the Act in VA's appeals plan to Congress--including delineating resources required for all VBA and Board appeals options--using sensitivity analyses and RAMP results, where appropriate and needed. (Recommendation 1)

    Agency Affected: Department of Veterans Affairs

  2. Status: Open

    Priority recommendation

    Comments: VA agreed with this recommendation, stating that it is working to develop a complete and balanced set of measures for the new appeals process, and timeliness goals for all appeals options. Further, VA indicated it will track performance for Board appeal options using an existing process. We are encouraged by VA's proposed actions, which will provide a more complete picture of VA's vision for the new appeals process. However, VA does not detail whether or how the agency will develop a baseline or compare performance of the new appeals process to the legacy process. Until VA develops a baseline and a plan for monitoring and assessing both the new and legacy processes-using a complete and balanced set of goals and measures- VA risks not fully understanding whether the new process is an improvement.

    Recommendation: The Secretary of Veterans Affairs should clearly articulate in VA's appeals plan how VA will monitor and assess the new appeals process compared to the legacy process, including specifying a balanced set of goals and measures--such as timeliness goals for all VBA appeals options and Board dockets, and measures of accuracy, veteran satisfaction, and cost--and related baseline data. (Recommendation 2)

    Agency Affected: Department of Veterans Affairs

  3. Status: Open

    Comments: VA agreed with this recommendation. The agency provided an updated schedule with additional key activities and responsibilities, such as RAMP. Moreover, VA restated its plans to use an agency-wide governance structure to coordinate and track implementation of its new appeals process. We are encouraged by VA's efforts to develop a more detailed implementation schedule. However, the updated schedule VA provided does not include major activities, such as integrated IT system testing, and completion dates for major activities, for example, adding functionality to VA's primary claims processing system. In addition, VA provided an updated calendar for six major IT activities through the end of calendar year 2018. However, we continue to believe that VA will need to develop a longer term schedule that projects when processes will be integrated into new systems and when new systems will be ready to support the new appeals process. The schedule also does not indicate whether activities are interrelated, such that a delay in one activity could affect other activities and thereby affect VA's estimated implementation date. This sound planning practice is especially important because VA stated the agency is concurrently executing many of the activities.

    Recommendation: The Secretary of Veterans Affairs should augment the master schedule for VA's appeals plan to reflect all activities--such as modifications to information technology (IT) systems--as well as assigned responsibilities, interdependencies, start and end dates for key activities for each workgroup, and resources, to establish accountability and reduce overall risk of implementation failures. (Recommendation 3)

    Agency Affected: Department of Veterans Affairs

  4. Status: Open

    Priority recommendation

    Comments: VA agreed with this recommendation and stated that it will assess risks against a balanced set of goals it plans to select. Moreover, using its existing risk management process, VA stated it has identified additional risks and mitigation strategies after submitting its November 2017 plan. For example, VA states that it is addressing the continued low opt-in rate for RAMP, which is testing the new VBA-only options. VA is also acknowledging that delays in the development of IT required to implement the appeals process may prevent the agency from certifying readiness in January 2019. Importantly, VA states that the Board is exploring the development of a pilot program to identify needs and concerns related to full implementation-including all Board appeals options-and to make predictions about timeliness and productivity under the new appeals process. However, VA did not define success criteria for its current pilot test, RAMP, or clearly articulate how the agency will assess results of either RAMP or a new test of Board appeals options before proceeding to full implementation. Implementing our recommendation in a complete and timely manner is important because it would improve VA's ability to identify and mitigate significant risks associated with implementing a new process.

    Recommendation: The Secretary of Veterans Affairs should ensure that the appeals plan more fully addresses risk associated with appeals reform--for example, by assessing risks against a balanced set of goals and measures, articulating success criteria and an assessment plan for RAMP, and testing or conducting sensitivity analyses of all appeals options--prior to fully implementing the new appeals process. (Recommendation 4)

    Agency Affected: Department of Veterans Affairs

 

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