Chairman Hall, Ranking Member Lamborn and Members of the Subcommittee:

Thank you for the opportunity to share the perspective of the American Federation of Government Employees (AFGE) and the National Veterans Affairs Council (VA Council), the exclusive representatives of Compensation and Pension Service (C&P) employees of the Veterans Benefits Administration (VBA), regarding the critical need to overhaul the current work credit and work management systems.

The work credit system is the essential building block for managing work and evaluating performance. This system must be developed on the basis of valid empirical data; VBA must, with no preconceptions, identify how much an employee can reasonably be expected to do with an acceptable level of accuracy, and use that data to project the number of employees it needs to process its inventory.

The studies that form the basis of work credit systems are widely used in industry to increase productivity and known by terms such as “business efficiency” or “time and motion” studies.  AFGE and the VA Council are aware of only one extremely limited attempt by VBA to conduct a study along these lines but it failed to produce any useful findings. Management placed a software program on a sampling of employees' computers in an undetermined number of ROs, with no explanation of how they selected the sample. The data was collected by a program appearing on the screen every few hours to ask what the employee was doing. The program did not differentiate between employees working on a single claim and multiple claims, thereby leading VBA to continue to create flawed work credit and work management systems based on incomplete data retrieved.

A study of VBA’s work credit and work management systems was mandated by P.L.110-389, but we fear that when completed by the contractor, this long overdue study will not produce adequate data. It is very troubling that once again, VBA did not solicit input from employee representatives.

The performance standards that comprise the work management system are only as good as the underlying work credit system. Pursuant to an agreement between VBA and AFGE and the VA Council, national performance standards to boost VSR productivity were put in place in 1997, and were later revised in 2003, again in 2005, and most recently this spring. 

AFGE and the VA Council have long taken the position that VBA is contractually barred from raising local production standards above the national standards. VBA’s insistence on allowing ROs to set their own local standards has led to harmful inconsistencies and low morale. For example, a RVSR assigned to the Seattle Regional Office may be required to produce 5.25 weighted cases per day, where a RVSR assigned to the Winston Salem Regional Office may be required to produce 4.0 weighted cases. Consequently, RVSRs in Seattle have to complete 6 single weighted action cases, while RVSRs in Winston-Salem only have to complete 4 cases, to meet the local standard.

The underlying problem is that production standards for VSRs and RVSRs appear to be based more on politics and bonuses rather than on the goal of processing today’s complex claims in an accurate and complete manner.  VBA managers, many of whom have not adjudicated a claim for many years (or never), define performance largely in terms of inventory and days pending completion of a decision. Our members working on the front lines report that when they meet RO production goals, they have been “rewarded” with arbitrary increases in production standards for the following year.

VBA has not adjusted individual employee production standards to reflect the increasing sophistication of our claimants, the complexity of claims and continued changes stipulated by regulation. Employees are subjected to arbitrary and unreasonable production standards that lead to inefficient and incomplete claims development. As a result, issues are missed, evidence is ignored, and decisions are rushed. All of this results in poor service to our claimants and is contrary to the VA’s mission.

The current standards discourage complete and accurate claims development by denying employees credit for completing work on essential tasks. The following are some of the many examples of essential work that VSRs and RVSRs perform for which they receive zero credit:  (We can provide more examples at your request)

1. VSRs receive zero credit for Triage and Public Contact work because the new VSR Performance Standards only allow credit based on 5 criteria (instead of 60);
2. RVSRs get zero credit for additional development directed or completion of VA examination requests, even though both may require multiple hours of production time to complete;
3. Under the previous standards, VSR would receive full credit for all tasks (“End Products (EP)”). Under the current VSR standards, employees can receive zero credit for work completed. For example, a VSR on the Post-determination team receives a rating to promulgate a reopened claim (EP 020), and the veteran requests to add a dependent (EP 130). In addition, VBA proposes to reduce the rating of one of the veteran’s service-connected disabilities (EP 600). The employee would only receive credit for the 020, while completing the other actions for zero work credit.
4. VSRs get zero credit for any supplemental development, i.e. all aspects of the claim following initial development actions at the time the claim is established. The only other credit is applied at the time the claim is established as Ready for Decision. For example, RVSRs may send the case back to “cut” (request) the correct exam. (This is occurring more frequently because VSRs are being asked to write opinion exams and perform other complex work without adequate training, thus causing more requests for the wrong exams). In this case, the VSR is forced to remove any prior credit taken, and must complete the directed development with zero credit given.
5. In order to provide medical release forms to all treating physicians, VSRs may spend up to an hour – with zero credit – duplicating individual release forms, because veterans often erroneously list all their providers on a single form.
6. VSRs and RVSRs get zero credit for the mandatory work of reviewing the claims folder, which may take as long as two to four hours to complete.

Other Concerns

The current work credit system fails to adequately measure the work of VBA personnel who have been assigned collateral duties (in addition to adjudication duties), e.g. Homeless Veteran Coordinator and Seriously Disabled Veteran Coordinator.  These employees are especially impacted by management's continual change in priorities to meet new Central Office mandates.

Similarly, employees assigned to outreach duties during the work day do not receive adjustments in their work credit for time away from production.

New VSRs and RVSRs still undergoing training are held to unrealistic standards and penalized for having to correct prior work, regardless of how much time this takes away from production. Corrections are not considered in the evaluation of performance.

Summary

The current work credit system has created a tremendously stressful, demoralizing, assembly-line work environment that is hurting VBA retention of experienced employees and contributing to attrition among new hires. The current system also takes a heavy toll on training, resulting in the termination of many employees within the first year. The ultimate harm falls upon the veterans, who are deprived of a full, fair, and timely consideration of their claims, and a growing backlog.

Therefore, AFGE and the VA Council urge the Subcommittee to mandate a scientific time-motion study of the resources and skills required to do the current mix of increasingly complex claims. Both VSOs and employee representatives should have formalized, ongoing roles in the design, implementation and updating of the new work credit and work management systems, as well as staffing decisions based on these measures. Thank you.