Ronald R. Aument
Mr. Chairman and members of the Subcommittee, it is my pleasure to be here to discuss the Veterans Benefits Administration’s (VBA) response to the Institute for Defense Analyses’ (IDA) Analysis of Differences in Disability Compensation in the Department of Veterans Affairs. I am pleased to be accompanied by Mr. Bradley G. Mayes, VBA’s Director of the Compensation and Pension Service. Today I will discuss the various initiatives underway within VBA that support the recommendations put forth by IDA to improve the quality and consistency of the disability claims processing.
In December 2004, media reports identified differences in average disability compensation payments across states. In response, the Secretary of VA requested the Office of Inspector General (OIG) to conduct a review of disability payments. OIG examined benefit payment data for the six states with the lowest average payments and the six with the highest average payments to determine the factors that contributed to the differences. OIG’s report concluded that the factors, to include demographics, were complicated and intertwined, and recommended that VA pursue a scientific study to further understand the influences on disability compensation payments.
In May 2005, the Department of Veterans Affairs contracted with the Institute for Defense Analyses to better understand the potential causes of the differences in disability payments. The IDA study was structured to determine if a significant correlation to one or more variables could be identified that contribute to the variance.
Findings from IDA Study
IDA identified several major factors that individually contribute to the observed variation in average compensation. These factors include:
- Distribution of veterans with ratings of 100%;
- Types of disabilities (including PTSD and other mental disabilities);
- County of residence;
- Median family income;
- Percent of the population with physical or mental disability;
- Population density;
- Representation by power of attorney; and
- Period of service.
Other key drivers include application rates, which influence the percentage of the veteran population receiving disability benefits, and the percentage of beneficiaries that are military retirees.
It is important to understand that the average payments being compared in the IDA study cover all veterans currently receiving VA disability compensation benefits, and that the decisions that awarded these benefits have been made over a period of more than fifty years. The average payment for compensation recipients is therefore not necessarily reflective of the experience of veterans currently applying for disability compensation benefits. In order to assess differences in VA benefits currently being awarded to recently separated veterans, VA also looks at average payments to veterans who are added to VA's disability compensation rolls during the year.
Based on the study results, IDA made six recommendations aimed at critical aspects of the adjudication process they found most likely to affect the consistency of claims determinations. The recommendations are:
- Standardize initial and on-going training for rating specialists
- Standardize the hospital evaluation reporting process
- Increase oversight and review of rating decisions
- Consider consolidating all or selected parts of the rating process into one location
- Develop and implement metrics to monitor consistency in adjudication results
- Improve and expand data capture and retention
VBA Response to IDA Recommendations
I will respond to each recommendation in turn and discuss how VBA is working to achieve the intended outcomes of that recommendation.
Standardize initial and on-going training for rating specialists
Critical to improving claims accuracy and consistency is ensuring that our employees receive the essential guidance, materials, and tools to meet the ever-changing and increasingly complex demands of their decision-making responsibilities. To that end, VBA has deployed new training tools and centralized training programs that support accurate and consistent decision-making.
New hires receive comprehensive training and a consistent foundation in claims processing principles through a national centralized training program called "Challenge." After the initial centralized training, employees follow a national standardized training curriculum (full lesson plans, handouts, student guides, instructor guides, and slides for classroom instruction) available to all regional offices. Standardized computer-based tools have been developed for training decision-makers (71 courses completed and an additional 5 in development). Training letters and satellite broadcasts on the proper approach to rating complex issues are provided to the field stations. In addition, a mandatory cycle of training for all Veterans Service Center employees has been developed consisting of an 80-hour annual curriculum.
VBA already has in place a skills-certification process for veteran service representatives, and we are developing a skills-certification process for rating specialists. Additionally, we have increased our Systematic Technical Accuracy Review (STAR) staff and tasked it with more oversight visits of our regional offices and greater responsibilities for training our decision makers.
Standardize the hospital evaluation reporting process
VA has made significant progress in our efforts to standardize the medical evaluation process. VA’s Compensation and Pension Examination Program (CPEP) continues to improve the examination process through the use of templates, quality reports, and examiner certification.
To date CPEP has developed 58 computerized examination templates based on associated worksheets that cover a variety of body systems and disabilities. The templates guide the examiner through specific examination types to ensure pertinent information is obtained and included in the examination report. The templates have been deployed to all VA medical care sites where Compensation and Pension Service (C&P) examinations are conducted.
A critical component of the C&P examination process is the examination request generated by VBA and submitted to the Veterans Health Administration (VHA). Examination requests must properly identify the specific examinations to be conducted and provide accurate explanations for any medical opinions that are required. To ensure the quality of these requests, CPEP staff review a sampling of examination requests from all regional offices on a monthly basis.
The compensation and pension disability examination is often a key component of the VBA disability determination process. To ensure the quality of these reports, CPEP conducts a monthly review of a sampling of completed exams generated by the Veterans Health Administration (VHA) medical facilities. VHA instituted a performance measure on the quality of C&P examinations in 2004. CPEP quality reviews are used to calculate this performance metric. Contract examinations are subject to internal quality reviews that parallel the CPEP process.
In FY 2008, through CPEP, VHA will implement an examiner certification program for all examiners performing compensation and pension disability examinations. The examiners themselves are expected to undergo specified computerized training modules relevant to C&P examinations and be certified to perform these disability examinations.
Our CPEP initiatives are instrumental to achieving our quality goals. VBA and VHA continue to work together to develop and refine tools that will ensure even greater consistency in the hospital disability evaluation reporting process.
Increase oversight and review of rating decisions
To ensure accurate benefit decisions, VBA has established an aggressive and comprehensive program of quality assurance and oversight to assess compliance with VBA claims processing policy and procedures and assure consistent application.
The Systematic Technical Accuracy Review (STAR) program includes review of work in three areas: rating accuracy, authorization accuracy, and fiduciary program accuracy. Overall station accuracy averages for these three areas are included in each regional office director’s performance standards and the station’s performance measures. STAR results are readily available to facilitate analysis and to allow for the delivery of targeted training at the regional office level. C & P Service conducts satellite broadcast training sessions based on an analysis of national STAR error trends. Over the last four years, our quality has risen significantly from 81 percent to 89 percent.
Site surveys of regional offices address compliance with procedures, both from a management perspective in the operation of the service center and from a program administration perspective, with particular emphasis on current consistency issues. Training is provided, when appropriate, to address gaps identified as part of the site survey.
Consider consolidating all or part of the rating process into one location
The consolidation of specialized processing operations for certain types of claims has been implemented to provide better and more consistent decisions. Three Pension Maintenance Centers were established to consolidate the complex and labor-intensive work involved in ensuring the continued eligibility and appropriateness of benefit amounts for pension recipients. We are exploring centralization of all pension adjudications in these Centers.
In November 2001, a Tiger Team was established at the Cleveland Regional Office to adjudicate the claims of veterans age 70 and older. VBA also established an Appeals Management Center to consolidate expertise in processing remands from the Board of Veterans' Appeals. In a similar manner, a centralized Casualty Assistance Unit was established to process all in-service death claims. VBA also established two Development Centers in Phoenix and Roanoke to assist regional offices in obtaining the required evidence and preparing cases for decision, and centralized the processing of all radiation claims to the Jackson Regional Office.
The Benefits Delivery at Discharge (BDD) Program provides servicemembers with briefings on VA benefits, assistance with completing applications, and a disability examination before leaving service. The goal of this program is to deliver benefits within 60 days following discharge. VBA has consolidated the rating aspects of our BDD program to two rating sites, which will bring greater consistency of decisions on claims filed by newly separated veterans.
We continue to look for ways to achieve additional organizational efficiencies through the consolidation of other aspects of our claims processing, including death benefits, fiduciary activities, and telephone service.
Develop and implement metrics to monitor consistency in adjudication results
In addition to conducting quality reviews, C & P Service’s STAR staff are beginning to conduct analyses to identify unusual patterns of variance in claims adjudication by diagnostic code, and then review selected disabilities to assess the level of decision consistency among and between regional offices. These studies are used to identify where additional guidance and training are needed to improve consistency and accuracy, as well as to drive procedural or regulatory changes.
Improve and expand data collection and retention
VBA’s data management systems have been substantially improved in recent years with such programs as the VETSNET suite of applications and the establishment of our data warehouse. VETSNET and the analytical tools in our data warehouse provide our employees and managers with more robust data, which better support information management and analysis.
Mr. Chairman, this concludes my testimony. I would be pleased to answer any questions you or other members of the Committee may have.