Recommendation: The Secretary of Veterans Affairs should ensure that the Office of Enterprise Integration develops a plan—including milestones and roles and responsibilities for OEI, VBA, and VHA—to address identified challenges that have hindered research on the health care outcomes for service-connected conditions of veterans receiving disability compensation. To align VA's efforts with the goals of its 2018-2024 Strategic Plan, VA's development of this plan should be completed and ready for implementation by June 1, 2020. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation. VA stated that the Office of Enterprise Integration (OEI) will coordinate with VBA and the Veterans Health Administration (VHA) to create an operational plan that addresses challenges that have hindered research on health care outcomes for service-connected conditions of veterans receiving disability compensation. As of March 2020, VA anticipates completing this plan by June 2020. We will consider closing the recommendation when that effort is complete.

Recommendation: The Under Secretary for Benefits should develop and implement a periodic analysis of program management data for trends in the individual service-connected conditions being reevaluated as well as data on the outcomes of reevaluations. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA stated in March 2020 that it plans to develop requirements to augment its capacity to analyze reevaluation trends. According to officials, VA has determined the necessary requirements for the data needed to analyze the outcomes of reevaluations. VBA will review 12 months of data to assess trends and make recommendations based on the review. VA plans to complete the trend analysis by the end of June 2020 and will establish a process for periodic analysis of data trends. We will consider closing this recommendation when VA has analyzed multiple data points to assess trends in reevaluations on a periodic basis.

Recommendation: The Under Secretary for Benefits should implement the two recommendations in VBA's May 2018 consistency study to provide training on how to determine when a reevaluation is needed and review reevaluation decisions for accuracy at the lowest-scoring offices and take corrective action as needed. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: In November 2019, VA stated that VBA provided a reminder to all regional offices about the availability of training resources on how to determine when a reevaluation is needed. VA also stated that VBA conducted another consistency study on this issue in August 2019 and plans to use that study's results to guide its review of the lowest-scoring regional offices. This study recommended inspecting claims processed at the two lowest-scoring offices, because they may have high numbers of errors related to reevaluation requirements. VA stated that VBA would devise a statistically valid sample of claims based on the August 2019 study. In April 2020, VA provided information from national accuracy reviews and individual claims processor quality reviews for these two offices. However, these reviews were not specifically designed to assess the quality of decisions on reevaluations, and as such, do not provide generalizable information on all reevaluations decided by these two offices. To help close this recommendation, VA should take steps to focus its review on claims with reevaluations, in order to identify and correct root causes of any deficiencies, such as through additional training or the improvement of training. Using the results of both the 2018 and 2019 studies would allow VBA to more fully assess this issue.

Recommendation: The Under Secretary for Benefits should clarify guidance in its procedures manual regarding the knowledge, skills, and abilities needed to make decisions on whether to reevaluate veterans for changes in their service-connected conditions. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation in principle, acknowledging the importance of having appropriately skilled and trained employees to process reevaluations and other claims. VA stated that it believes the procedures outlined in its manual accurately describe the steps necessary for claims adjudicators to make the decision whether to reevaluate veterans for changes in their service-connected conditions. It further stated that regional office management ensures compliance with the procedures through the quality assurance program, and makes the decisions about which claims processors are best suited to perform the work. Accordingly, as of March 2020, VBA plans to assess the quality of routine future examinations requested by non-raters. Based on the results of this new quality review, VBA will determine if any additional actions are needed. VBA plans to complete this effort by October 2020. We are encouraged by VA's interest in conducting this analysis, and we will consider closing the recommendation when that effort is complete.

Recommendation: The Under Secretary for Benefits should align training requirements with the knowledge, skills, and abilities needed for reviewing claims to decide whether to conduct a reevaluation. (Recommendation 5)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA agreed with this recommendation in principle. As noted in recommendation 4, as of March 2020, VBA plans to assess the quality of routine future examinations requested by non-raters, and determine if any additional actions are needed. VA also stated that if any refresher training is warranted for raters, local quality review team members can provide focused training locally. VBA plans to complete this effort by October 2020. We will consider closing the recommendation when that effort is complete.

Recommendation: The Veterans Health Administration should disseminate guidance for VISNs and VAMCs that more clearly reflects its expectation that mental health providers in specialty care should record mental health treatment plans within veterans' medical records in an easily identifiable way. (Recommendation 1)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VHA concurred with this recommendation and provided an update on its progress in implementing it. In December 2019, VHA reported that it had developed a new memorandum regarding mental health treatment planning that explicitly states the requirement for mental health providers in specialty care to record mental health treatment plans as a separate, easily identifiable document in the medical record. According to this memorandum, these treatment plans are expected to ensure that it is clear what treatment is being provided, that different treatments were considered, and that ongoing assessments are used to determined whether treatment changes are needed for the patient. VHA also reported that the memorandum states that facilities must either use the current treatment planning software or another method to create such a plan. Finally, VHA noted that the memorandum requires VAMCs to attest to full implementation of these requirements. According to VHA, the memorandum was distributed in May 2019 and the implementation process is currently underway across VAMCs. As of March 2020, this recommendation remains open pending further updates from VHA.

Recommendation: The Veterans Health Administration should develop and implement an approach for monitoring treatment plans for veterans with mental health conditions to ensure that such plans include documentation that different evidence-based treatment options were considered. (Recommendation 2)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open
Priority recommendation

Comments: VHA concurred with this recommendation and provided an update on its progress in implementing it. In December 2019, VHA reported that it had developed a new memorandum regarding mental health treatment planning that explicitly states the requirement for mental health providers in specialty care to record mental health treatment plans that include (among other things) an indication that different treatments were considered. VHA stated that the memorandum requires VAMCs to implement ongoing chart reviews to ensure providers were meeting treatment planning expectations. Specifically, VHA stated that the memorandum requires all VAMCs to ensure that each licensed independent provider had 5 treatment plans reviewed biannually to determine whether treatment planning expectations were achieved, including whether different evidence-based treatments were considered. Finally, VHA noted that the memorandum requires VAMCs to attest to full implementation of this process. According to VHA, the memorandum was distributed in May 2019 and the implementation of this process is currently underway across VAMCs. As of March 2020, this recommendation remains open pending further updates from VHA.

Recommendation: To increase its assurance that PTSD and TBI are appropriately considered prior to separating certain servicemembers from the military for misconduct, the Secretary of Defense should direct the Air Force and Navy to address inconsistencies with DOD policy in their policies related to training servicemembers, including officers, on how to identify mild TBI symptoms in the deployed setting.

Agency: Department of Defense
Status: Open

Comments: At the time of report publication DOD indicated it did not concur with this recommendation. However after publication, the department indicated it concurred with the recommendation. As of September 2020, DOD is continuing to take actions to address this recommendation. When actions have been completed, GAO will update the status of the recommendation.

Recommendation: To increase its assurance that PTSD and TBI are appropriately considered prior to separating certain servicemembers from the military for misconduct, the Secretary of Defense should ensure that the military services routinely monitor adherence to policies related to screening certain servicemembers for PTSD and TBI prior to separation for misconduct.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. As of July 2018, the department indicated that it was addressing the recommendation by requiring the military services to submit a report in March 2018 and March 2019 on how they are monitoring adherence to policies related to screening certain servicemembers for PTSD and TBI prior to separation for misconduct. In August 2020, the department indicated it completed a cycle of compliance reporting by the military services in April 2020. DOD stated it would conduct a final compliance reporting cycle in March 2021. GAO maintains that monitoring of compliance on a routine basis (i.e., ongoing) is necessary and will keep the recommendation open until the department indicates that routine monitoring will occur.

Recommendation: To increase its assurance that PTSD and TBI are appropriately considered prior to separating certain servicemembers from the military for misconduct, the Secretary of Defense should ensure that the military services routinely monitor adherence to policies related to training servicemembers, including officers, on how to identify mild TBI symptoms in the deployed setting.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. As of September 2020, the department is continuing to take actions to address this recommendation. When actions have been completed, GAO will update the status of the recommendation.

Recommendation: To increase its assurance that PTSD and TBI are appropriately considered prior to separating certain servicemembers from the military for misconduct, the Secretary of Defense should ensure that the military services routinely monitor adherence to policies related to counseling about VA benefits and services during the process of separating certain servicemembers for misconduct.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. As of July 2018, the department indicated that it was addressing the recommendation by requiring the military services to submit a report in March 2018 and March 2019 on how they are monitoring adherence to policies related to counseling about VA benefits and services during the process of separating certain servicemembers for misconduct. In August 2020, the department indicated it completed a cycle of compliance reporting by the military services in April 2020. DOD stated it would conduct a final compliance reporting cycle in March 2021. GAO maintains that monitoring of compliance on a routine basis (i.e., ongoing) is necessary and will keep the recommendation open until the department indicates that routine monitoring will occur.

Recommendation: The Secretary of Defense should direct the Secretary of the Army to implement processes to review and monitor the Army military treatment facility prescribing practices for medications discouraged under the PTSD guideline and address identified deviations.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and stated that any policy that it may issue related to the monitoring of prescribing practices would be directed toward all of the military services. In May 2018 DOD stated that it planned to (1) conduct a comprehensive review of existing prescribing practices for the treatment of PTSD; (2) develop policy guidance for addressing prescribing practices for the management of PTSD that deviate from the clinical practice guideline; and (3) implement an automated dashboard that will flag medications that the PTSD guideline discourages from use. In its February 26, 2020 response, DOD stated that July 30, 2020 is the estimated completion date for these planned actions. To close this recommendation, DOD needs to implement its planned actions and provide documentation showing that the Department is monitoring medications discouraged from use under the PTSD guideline and addressing identified deviations.

Recommendation: To help DOD obtain reasonable assurance that all active and Reserve component servicemembers to whom the PDHRA requirement applies are provided the opportunity to have their health concerns identified, the Assistant Secretary of Defense for Health Affairs and the military services should take steps to ensure that PDHRA questionnaires are included in DOD's central repository for each of these servicemembers.

Agency: Department of Defense
Status: Open

Comments: In its comments to this report, the Department of Defense (DOD) concurred with this recommendation. On October 2009, DOD's Force Health Protection and Response Office sent a memo to each of the military service Surgeons General emphasizing the need for the post-deployment health reassessment (PDHRA) to be offered to all service members who are eligible to complete the assessment. In 2010, DOD's noted that the services would work with the Armed Forces Health Surveillance Center (AFHSC) repository to ensure PDHRAs are submitted correctly, without transmission errors. DOD's 2011 case records showed that the Air Force and Army had developed data verification processes to ensure that AFHSC received PDHRAs. Further, the Defense Medical Data Center (DMDC) had planed to create a file consisting of the date of deployment for deployed personnel, and that the file would be available to the services in order to match DMDC with data from each of the service-specific systems, in accordance to requirements. In September 2011, although DMDC and the services had agreed to match rosters of deployed service members, there were still inconsistencies in deployment dates. In March 2012, DOD was still verifying data inconsistencies which, until resolved, leads to inaccurate reporting based on errors in the deployment dates. As of September 2019, DOD has not provided information or documentation to address this recommendation.