Mr. Chairman and Members of the Subcommittee:

I appreciate this opportunity to express the views of the 2.5 million members of The American Legion on the current state of training at the Veterans Benefits Administration (VBA) of the Department of Veterans Affairs (VA).  Training is one of the most important aspects of any plan for improvement in the VA at this time, especially in light of the fact that nearly half the VA workforce has less than three years of experience on the job.  If VA is to achieve Secretary Shinseki’s stated goal of “no claims pending longer than 125 days and an accuracy rate of 98%” then training is going to be one of the most important tools to achieve that promise.  If accuracy is to increase, and The American Legion strongly believes that this component is essential to any reform of VA, then the training must improve to bolster the workforce that has grown so dramatically in recent years.

The American Legion has examined this problem through direct, first hand action in the Regional Offices (ROs), as a component of our Quality Review visits of those Regional Offices.  Furthermore, the studies of the Government Accountability Office (GAO) in August of this year, and others, have provided further insight that identifies some of the problems faced by VA’s training system as currently implemented.

In our Quality Review visits, as in our System Worth Saving visits of the healthcare system, The American Legion has encountered one of the greatest problems facing VA today -- inconsistency.  Simply put, regardless of the intentions of Central Office, how programs are implemented varies widely from region to region.  Each individual RO functions more like a semi-autonomous fiefdom, and little consistency is apparent among the ROs as a whole.

This need for better oversight was confirmed not only by our in-person site visits, but also in the findings of a GAO report entitled “Veterans’ Disability Benefits: Expanded Oversight Would Improve Training for Experienced Claims Processors” published just last month.  That testimony paints a picture of a “one size fits all” training program that fails to meet the needs of more experienced processors.  If a reason were to be assigned to why the program is not meeting the needs for this group of claims processors, The American Legion would suggest that these needs are actually being met in offices where training is a priority, and seriously addressed by those responsible to make the training work.  In other offices, where the training is planned by individuals seeking merely to “check a box,” then the training suffers and is poorly tailored to the needs of the employees.  Again, this all stems from inconsistent implementation within ROs that vary in quality far too much from region to region.

Training is seldom viewed as a priority. All too often it falls far behind the driving goal behind the majority of VA operations—the endless march towards reaching production requirements.  VA is so driven by the need to churn out numbers by a dysfunctional work credit system, that the time needed for training is simply not available.  When faced with the choices of not meeting production numbers and not adequately meeting the training hour requirements, time and time again we see that the individual offices choose to ensure that production numbers do not drop.  The vast majority of VA employees interviewed by The American Legion over the past decade in Quality Review visits have continually reinforced the frustration that meeting production numbers is the single greatest factor in determining how they are able to do their jobs.

Clearly, if VA is to adequately bring on line their new and inexperienced workforce in a manner that will enable them to process claims without common errors, then training to eliminate those errors must be an essential component of that plan.  These simple, procedural errors keep claims bouncing around the system through the appeals and remand process; they must change this attitude to reflect a commitment to appropriate and targeted training.  Furthermore, they must ensure that regardless of how strongly this new commitment is expressed by Central Office, that implementation is enforced in the Regional Offices.  VA must strive to improve consistency and oversight to make sure that their aims are being implemented equally from coast to coast.

GAO indicated that claims processors may not be getting the training they need, even when they do receive training.  Common complaints included too little training on some topics, too much on other topics. Specific topics such as Special Monthly Compensation (SMC) where not enough training was received and Records Management as a topic on which they received far too much training were identified.  The American Legion has found in our Quality Review visits that often times the training is repetitive, dealing with the same topics year in and year out, with little helpful additions.  Simply put, the training they are receiving does not match the target areas that are actually needed.  But how is VA to identify what areas are really needed by their employees?

The American Legion has previously testified that there is a mechanism already existing and waiting to be harnessed to just this end.  Annually, VA conducts their internal STAR review to identify accuracy issues with individual work and identify problems that need to be addressed by employees when they process claims incorrectly.  Furthermore, every day the Board of Veterans Appeals (BVA), the Court of Appeals for Veterans Claims (CAVC) and the Appeals Management Center (AMC) return hundreds of cases to lower jurisdictions after identifying errors in the lower level of processing.  This could even be said for Decision Review Officer (DRO) examination of appeals, a process wherein the most experienced claims workers in the ROs may review a veteran’s claim when that veteran elects to appeal the decision made on the original claim.  These decisions are made by better trained and more experienced personnel, and can be a great tool in identifying common errors.

VA could collect the aggregate data from STAR review, remands, and overturned decisions of the higher authorities, compile them into analytical reports, identifying common errors and trends would become apparent; training programs could be implemented specifically targeting the areas of greatest need. 

For example, American Legion sampling of cases in Quality Review visits indicates VA is having a problem rating mental health claims consistently. This could be identified and turned into a training program to increase consistency in these ratings.  If VA is churning out improper exams, or exams that inadequately address the proper provisions for repetitive movement or other factors, then remedial training on these exams would be necessary.

This could even be targeted to the regional level.  Consistency across regions does not have to mean the exact same training in each office.  However, each office has a robust plan that is targeting their individual deficiencies and working to raise their accuracy rate.  There is a gold mine of data on the common errors available, and VA would be foolish to ignore this valuable research tool to develop their training plans on both a national and regional level.

Finally, it would be premature to discuss whether or not the current 80-85 hours of required training is meeting the needs of the employees, when it is being inconsistently implemented among the regional offices.  You cannot determine if 80, or 85, or 45 hours is the “right” amount of training until you can determine that it is consistently implemented as the right kind of training.

This falls victim to the same fallacy that drives VA’s production goals.  By evaluating success or failure solely on the ability to meet a numerical benchmark, you fail to evaluate whether the quality component is being met.  VA needs a better mechanism.  Simply punching a card for 80 hours of the same, lackluster and undirected training no better serves the veterans of America than processing 4 claims a day with little regard to whether or not they are done properly.  Again, the quality of the training must be of equal import to the quantity of training.

It is essential to develop real benchmarks that illustrate not only where VA is complying with the minimum number of hours of training required, but also that this training is addressing the deficiencies in knowledge and expertise so that it raises the skill level of the workforce.

In summation, VA must implement a training program that is universally consistent regardless of region, is targeted to areas of need identified by common errors denoted in collected data from VA’s various internal mechanism for identifying mistakes and inaccuracy, and finally evaluates the worth of the training not with mere numerical benchmarks, but also accurately assesses and affirms that the overall knowledge base of the employees is growing and that they are becoming more proficient and adept at their jobs.

As previously stated, this is one of the most inexperienced workforces that VA has ever fielded.  Congress has admirably provided VA with the resources to grow their workforce to meet the needs of a caseload volume that exceeds a million new cases a year.  Patience must exist to some extent as new employees come up to speed.  However, these new employees, nearly a full half of VA’s workforce, could not underline the need for effective and robust training more clearly.

VA is building the core of their 21st Century operational structure in this workforce and through other infrastructure means such as their computer technology.  The time to address these training issues is now, at the ground floor level, not years down the road when the aggregate effects of years of lackluster training and poorly targeted and implemented plans have done their damage.

The American Legion stands ready to answer any questions of this Subcommittee and thanks you again for this opportunity to provide testimony on behalf of our members.