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Submission For The Record of Ms. Diana Rubens, Deputy Under Secretary for Field Operations, Veterans Benefits Administration, U.S. Department of Veterans Affairs

Mr. Chairman and Members of the Subcommittee, thank you for providing me with this opportunity to discuss the Veterans Benefits Administration’s (VBA) efforts to improve performance at challenged regional offices.  I am accompanied today by Mr. Alan Bozeman, Director, Veterans Benefits Management System (VBMS), VBA.

The Subcommittee has indicated special interest in learning about the operations of underperforming Department of Veterans Affairs (VA) regional offices and our efforts to improve performance to ensure higher quality and consistency of disability claims decisions.  We will address these areas and also provide an update on VBA’s implementation of recommendations made by the Office of Inspector General to improve regional office operations.  In addition, we will update the Subcommittee on our progress in developing VBMS and the timeline for its implementation.  

While today’s hearing focuses on challenged regional offices, I would be remiss in not noting the many thousands of exceptionally hard-working and dedicated employees within VBA’s ranks that are committed to serving Veterans every day.  They work in our most productive offices, our challenged offices, and everything in between, doing their level-best to meet the performance standards – both individual and office – that we set.  They are both valued and appreciated members of a workforce with great pride and the will to succeed in any mission.  

Regional Office Performance
Let me begin by stating that we constantly strive to find new ways to improve the performance of our regional offices.  We are pursuing strategic goals established by the Secretary two years ago to transform VBA into a high-performing and innovative, 21st century organization that is people-centric, results-driven, and forward-looking.  One of VA’s highest priority goals is to eliminate the disability claims backlog by 2015 and ensure all Veterans receive a quality decision (98 percent accuracy rate).  VA has defined the claims backlog as any claim pending more than 125 days

VA is attacking the claims backlog through a focused and multi-pronged approach.  At its core, our transformational approach relies on three pillars: changing our culture to one that is centered on accountability to, and advocacy for, our Veterans; improving our business processes through collaboration with stakeholders and industry experts on best practices and ideas; and deploying powerful 21st century IT solutions to simplify and improve claims processing for timely and accurate decisions.  Our strategic initiatives seek to improve the quality and timeliness of benefits delivery; expand accessibility to VA benefits and services; increase Veterans’ satisfaction; and improve VA internal management systems to successfully perform our mission.
The performance of all of our regional offices is evaluated against national and regional office-specific targets that are based on our strategic goals.  These targets are set at the beginning of fiscal year, across all the business lines and for a variety of measures, including quality, timeliness, production, and inventory.  In setting targets, consideration is given to the previous year's performance and current staffing levels.   
VBA's Office of Field Operations and the Area Directors regularly match a facility’s achievements against its performance targets, to include a monthly dashboard review.  Several factors influence performance including workload, workforce experience, and staff turnover.  VBA closely monitors regional office performance, and should negative performance trends develop, Area Directors require improvement plans from regional office directors to correct problem areas.  
Area Directors visit each regional office at least annually to conduct an in-person review of operations.  On-site reviews of regional office operations are also conducted by the VBA’s Compensation and Pension Services.  In addition, monthly Statistical Technical Accuracy Reviews (STAR) provide a consistent and objective review of regional office decision quality.
Regional office directors and individual employees alike are held accountable for performance deficiencies.  If a regional office is not meeting performance targets, improvement plans for the office are put in place and closely monitored.  The regional office director must identify efforts that can be taken locally to improve performance.  If productive capacity is the issue, a regional office will frequently broker work to another regional office.  If the deficiency is a quality issue, there are several options that can implemented, often in a complementary fashion, such as a "Technical Assistance Team" from the Compensation Service; additional training provided by the STAR staff on identified error trends; and  training for local quality reviewers.  Challenged regional offices will also engage an identified high-performing "sister" or "mentor" station to share best practices and identify opportunities for improvement.
Claims processing timeliness is affected by factors ranging from the regional office's workload management to the responsiveness of outside entities.  VBA has established a Workload Management Training Program to train new supervisors in the use of reports that help in timely decisions on workload that can enhance office performance.  
As an improvement plan will involve any or all of the approaches outlined above, the Area Director will also engage in more frequent communication with an underperforming office.  Written and electronic communication, structured telephone calls and site visits are all used to ensure progress toward the improvement plan targets.
If the Director cannot successfully lead the regional office to improvement, subsequent performance action will be taken during performance appraisal periods.  
Resource Allocation Strategy to Optimize Organizational Performance
For a number of years, VBA has been pursuing a strategy to allocate additional resources to regional offices that perform at a higher level. This strategy was intended to increase the VBA organizational performance and capacity to assist regional offices experiencing workload challenges and performance difficulties due to unexpected staffing losses or workload increases.  Resource Centers have been established at thirteen high-performing offices throughout the country, and claims are brokered to these centers for processing.    However, our strategy to recruit and expand operations in locations where we have demonstrated that we can be competitive and achieve high performance levels has been impacted in recent years as a result of the dramatic workload increases and our need to rapidly and significantly increase staffing levels.  In a number of cases, we have had to add resources to regional offices based on the availability of space in existing facilities rather than high performance.  

This fiscal year has been challenging because VBA has been utilizing our Resource Center brokering capacity to readjudicate previously denied claims for newly established Agent Orange presumptive conditions (ischemic heart disease (IHD), Parkinson’s disease (PD) and Hairy Cell (B-Cell) leukemia (HCL)). VA must adjudicate or readjudicate approximately 147,000 claims for IHD, PD, or HCL filed by Nehmer class members (Vietnam Veterans and their survivors) and, when appropriate, provide retroactive benefits.  Due to the complexity of readjudicating these claims, all Nehmer readjudication claims are being processed at VBA’s Resource Centers.  Our Resource Centers are therefore temporarily not available to assist in balancing claims workload across regional offices or support underperforming or challenged regional offices.  There has been some capacity for brokering identified in other regional offices, and Areas have taken advantage of that to continue helping challenged offices this year.  

VA currently has 1,300 employees at Resource Centers around the country devoted to the readjudication of Nehmer claims.  There are approximately another 1,800 VA employees across VA’s 56 regional offices that are adjudicating Agent Orange claims received after October 13, 2009.  All other regional office employees continue to process non-Agent Orange workload.  

Higher Quality and Consistency of Disability Claims Decisions
STAR is the component of VBA’s quality assurance program that focuses on improving regional office claims processing accuracy.  STAR reviews evaluate the quality of the rating decision product that VBA provides for Veterans.  From the Veteran’s perspective, there is an expectation that we understand the claim, evaluate it accurately and fairly, and provide proper compensation under the law.  The purpose of STAR reviews is to ensure that rating decision outcomes meet these expectations.   STAR findings provide statistically valid accuracy results at both the regional office and national level.  STAR error trends are identified and used as training topics to improve performance.

Training continues to be a priority to achieve our performance improvement goals, and is conducted using a variety of methods, including a monthly national Quality Call, where the Compensation Service’s training, policy, and procedures staffs collaborate with the STAR staff to address national error trends identified in STAR assessments.

Regional offices are provided explanations on all error calls, and they are required to take corrective action.  On a quarterly basis, regional offices are required to certify to VBA headquarters the corrective action taken for all errors identified by STAR.  The reported actions are validated during the oversight visits conducted by the site survey teams.  

VBA is committed to using the error trends and accuracy findings to improve overall quality.  VBA uses nationwide error patterns identified by STAR reviews, as well as information from other components of the Quality Assurance Program, to adjust and develop the employee training curricula.  
 
All employees, regardless of training level, must receive 80 hours of instruction annually.  Instructional methods may include Training Performance Support System (TPSS) modules, lectures, or practical application exercises.  For intermediate and journey-level employees, the 80 hours must include 40 Core Technical Training Requirement (CTTR) hours.  These involve standardized training curricula of essential topics and information.  Employees must complete an additional 20 hours of training from a list of standardized topics provided by VBA.  The final 20 hours may be used by regional offices to train on local issues and areas of concern.  This approach ensures that new and experienced employees are grounded in standardized claims processing fundamentals.  

Data from STAR reviews, consistency reviews, special focus reviews, and regional office site visits are used to develop training for our new hires, as well as our intermediate and journey-level employees.  Claims processing personnel are informed in a timely manner of errors, and inconsistency trends, and provided with constructive feedback to include instructions on how to avoid such errors in the future.  The error trends identified in STAR reviews provide us the information we need to assess the effectiveness of our training programs and make necessary adjustments.  This promotes our goal of providing accurate, fair, and consistent claims processing.  Performance support training tools allied to TPSS modules continue to show high and increasing usage, reflecting their utility to the field.  For example, the Medical Electronic Performance Support System provides computerized visual images of the various human body systems.  It was developed with STAR review input to assist with identifying the appropriate rating codes associated with different body systems and to facilitate medical examination requests.  

Last month the Compensation STAR staff completed seven special training programs for select employees from each regional office currently responsible for performing local quality reviews.  This training was designed to help achieve consistency between national and local quality reviews.  Another training session is schedule in June for the remaining regional offices.  Additionally, specialized quality review positions are being created in each regional office to further drive quality improvements.  

Claims Transformation Plan
We are reviewing and reengineering our business processes in collaboration with both internal and external stakeholders, including Veterans Service Organizations and Congress, to constantly improve our claims process using best practices and ideas.  We’re relying heavily on technology and infrastructure by deploying leading-edge, powerful 21st Century IT solutions to create a smart, paperless claims system which simplifies and improves claims processing for timely and accurate decisions the first time.

VBA is working to simplify processes and reduce the burden of paperwork for our Veterans.  Improvements in efficiency and customer service include new policies to promote the use of simple telephone contacts with Veterans to clear up evidence questions and add dependents, reducing requirements for second signatures in medical reports where appropriately trained practitioners are capable of providing health evaluations, and implementing the Fully Developed Claims Initiative to promptly rate claims submitted with all required evidence.

New disability benefits questionnaires are being specifically designed to capture medical information essential for timely and accurate evaluation of disability compensation and pension claims. VA published the first set of these forms in October 2010 and dozens more of these forms are in development for various disabilities.  The content of these disability benefits questionnaires is being built into VA’s own medical information system to guide in-house examinations.  Veterans can provide them to private doctors as an evidence guide that will speed their claims decisions.  The result will be more timely rating decisions, fewer duplicated examinations, a reduced need for VA examinations, less time needed to evaluate examination results by claims processors, and a potential to improve rating accuracy.

Regional office performance will also be significantly improved through the integration of rules-based processing and other calculator tools designed to increase decision accuracy and employee productivity.  We are working on more than a dozen such logic-based calculators with VA’s Office of Information and Technology to equip VA decision-makers with rules-based, online tools that automatically calculate evaluations and certain award actions.  VA recently completed and deployed tools for cases regarding hearing loss and special monthly compensation.  These types of calculators free up time and create efficiencies that allow employees to concentrate on more complex claims that require detailed review and analysis.  

Office of Inspector General
The Office of Inspector General (OIG) established its Benefits Inspection Program in March 2009 as a major initiative to help ensure timely and accurate delivery of Veterans’ benefits and services.  On May 18, 2011, the OIG issued a report, Systemic Issues Reported During Inspections at VA Regional Offices, which identified issues at 16 VA regional offices inspected from April 2009 through September 2010.  OIG found that VARO management teams face multiple challenges in providing benefits and services to Veterans.  As a result of the 16 inspections, OIG made several recommendations to improve VARO operations.  Of those recommendations only four remain open.  

One of OIG’s recommendations was that the Acting Under Secretary for Benefits revise the policy on evaluating residuals of Traumatic Brain Injuries (TBI) and provide training to medical examiners conducting TBI medical examinations to ensure compliance with current examination requirements.  VBA is collaborating with the Veterans Health Administration (VHA) to ensure that all compensation and pension examination providers are trained on TBI examinations.  This initiative is approximately 70 percent complete; all clinicians performing TBI medical examinations will be trained by June 30, 2011.

OIG also recommended that the Acting Under Secretary for Benefits develop a clear and measurable standard for timely completion of competency determinations.  VBA has determined that a 21-day standard is sufficient for timely completion of competency determinations.  This will be measured from the date of expiration of the notification to the Veteran to the date of completion.  Guidance is currently being written for formal distribution.  Notice will also be provided and reinforced to regional offices through regularly scheduled conference calls.

VBA is collaborating with VHA to address the remaining two recommendations covered in the OIG’s report.  Our target for completion of these recommendations is June 30, 2011.  

Veterans Benefits Management System (VBMS)
VBMS is a business transformation initiative supported by technology to improve VBA service delivery.  VBMS is currently in a developmental state with nationwide deployment scheduled to begin in calendar year 2012.  

To improve the efficiency of the claims process, VA is transitioning to a business model that relies less on the acquisition and movement of paper documents for benefits delivery.  Phase 2 of VBMS began in November 2010 at the Providence Regional Office.  The overarching goal of Phase 1 was the development and testing of software, while ensuring integration with existing databases and legacy claims processing systems.  Additionally, Phase 1 focused on identifying and correcting critical defects, optimizing scanning operations and procedures, and developing functionality enhancements for future iterations.  

During the second quarter of fiscal year 2011, claims processors at the Providence Regional Office began using the new software to process a limited number of original claims for disability compensation to validate capabilities within VBMS.  The measure of success, which was achieved for Phase 1, was the capability to enter claims into a paperless system and process the claims to completion.  As of May 18, 2011, 175 claims were established through the VBMS interface and were being processed in a paperless environment.

Phase 2 began in May 2011 at the Salt Lake City Regional Office, building upon the efforts and information gathered in Providence.  The Providence Regional Office will continue using VBMS to process claims and provide recommendations for system improvements.  

Phase 3 is scheduled to begin in November 2011, at a site yet to be determined.  Phase 3 is scheduled for completion in May 2012.  These successive phases  validate and refine system requirements.  The three phases will be followed by a national rollout to all regional offices, which is scheduled to begin in calendar year 2012.  

VBA recognizes that technology is not the sole solution for our claims-processing challenges; however, it is the hallmark of a forward-looking organization.  Combined with a renewed commitment and focus toward increasing advocacy for Veterans, the VBMS strategy combines a business transformation and re-engineering effort with enhanced technologies, giving an overarching vision for improving service delivery to our nation’s Veterans.  

Conclusion
VBA employees in all of our regional offices are dedicated to delivering accurate and timely benefits decisions.  We recognize that there is variance in the overall performance of our regional offices, and we must be both vigilant in identifying shortcomings and aggressive in correcting them.  VBMS and our other claims transformation initiatives are critical to our future success in improving the performance of all of our regional offices.  We will continue to vigorously pursue business process and technology-centered improvements designed to “break the back of the claims backlog” and achieve our goal of processing all claims within 125 days with 98 percent accuracy by 2015.  

Mr. Chairman and Members of the Subcommittee, this concludes my remarks. Thank you again for the opportunity to testify.  I am happy to respond to any questions.