July 21, 2008 – Introduction
The Office of Inspector General (OIG) conducted an audit to determine if Veterans Benefits Administration (VBA) controls over transition assistance ensured (1) prompt processing of seriously disabled veterans’ compensation claims from Operations Enduring Freedom and Iraqi Freedom (OEF/OIF) and (2) effective outreach to OEF/OIF service members and veterans.
The audit covered VBA transition assistance controls in effect during Fiscal Years (FY) 2006–2008 (through January 2008). The audit included a review of 4,969 compensation claims received at 57 VA Regional Offices (VAROs) from seriously disabled OEF/OIF veterans the Department of Defense (DOD) discharged from military service during FY 2006. The audit also evaluated VBA outreach to service members and veterans during FYs 2006 and 2007.
VBA Emphasis on Seriously Disabled OEF/OIF Veterans. In January 2007, VA’s Under Secretary for Benefits wrote the following to all VBA employees:
There is no higher priority for any VBA employee, whether serving in the field or in headquarters, than ensuring that we are timely meeting the needs of those seriously injured in OEF/OIF. At every level of our organization, we must ensure we have identified and are case-managing all of the seriously injured. We must actively work to stay in touch with them and do all we can to ease their transition.
VBA defines seriously disabled veterans as service members who definitely or possibly will be discharged from military service because of an injury or illness and all veterans with DOD classification codes of very seriously injured, seriously injured, or a special category involving an amputation.
Presidential, Congressional, and Government Accountability Office Concerns. After the September 11, 2001, terrorist attacks, the U.S. led a coalition of military forces from more than 40 countries in two Global War on Terror (GWOT) operations. In October 2001, OEF began in Afghanistan and in March 2003, OIF began in Iraq. During the period of October 2001–December 2007, about 1.7 million U.S. service members supported OEF/OIF operations.
As these service members returned to the U.S., the President, Congress, and the Government Accountability Office (GAO) expressed concerns regarding VBA’s transition assistance. To address these concerns, in March 2007 the President established a Task Force on Returning Global War on Terror Heroes and a Commission on Care for America’s Returning Wounded Soldier. In addition, Congress held five hearings related to VBA’s transition assistance responsibilities during the period August 2005–April 2007. These hearings focused on the effectiveness of the Transition Assistance Program (TAP) for members of the National Guard, cooperation between VA and DOD to meet the needs of returning service members, and timeliness of disability claims processing. Also, GAO issued the report Military and Veterans’ Benefits, Enhanced Services Could Improve Transition Assistance for Reserves and National Guard (Report No. GAO-05-544, May 2005). The report recommended that DOD, in conjunction with the Department of Labor (DOL) and VA, determine what National Guard and Reserve members need to make a smooth transition and to explore options for enhancing their participation in TAP.
VBA Transition Assistance Responsibilities and Controls. Title 10 of the U.S. Code requires VA, DOL, and DOD to administer TAP to meet the needs of service members and veterans transitioning from military service to civilian life. VBA transition assistance responsibilities include promptly processing OEF/OIF veterans’ claims and providing outreach to OEF/OIF service members and veterans.
VBA had several controls over the processing of seriously disabled OEF/OIF veterans’ claims and outreach to OEF/OIF service members and veterans. These controls included a 30-day goal for VARO processing of seriously disabled OEF/OIF veterans’ compensation claims and TAP briefing participation rate goals of 53 percent for FY 2006 and 85 percent for FY 2011.
VBA controls needed strengthening to ensure transition assistance meets the needs of OEF/OIF service members and veterans. Controls over VARO processing of seriously disabled OEF/OIF veterans’ compensation claims needed strengthening to meet VBA’s 30-day claim processing goal. Claim processing delays can cause veterans financial hardship by depriving them of compensation they may need to successfully transition from military service to civilian life. In addition, controls over outreach needed strengthening to ensure VBA informs service members and veterans of available VBA benefits that can ease their transition to civilian life.
Claims Received from Seriously Disabled OEF/OIF Veterans Needed to Be Processed Promptly. To improve claim-processing timeliness, VBA needed to strengthen controls for obtaining DOD data identifying seriously disabled OEF/OIF veterans and monitoring case-managed claims. As shown in Chart 1, VAROs did not process 3,776 (76 percent) of 4,969 seriously disabled veteran compensation claims within VBA’s 30-day goal.
Of the 4,969 claims VAROs processed, 3,776 did not meet VBA’s goal by an average of 114 days and as much as 504 days. Chart 2 shows the processing times for all 4,969 claims VAROs processed.
Obtaining DOD Data.
In June 2005, VBA established procedures with DOD in a Memorandum of Understanding (MOU) to obtain medical information that identified seriously disabled OEF/OIF veterans. In support of the MOU, the Under Secretary of Defense directed the U.S. Army Surgeon General to provide VBA a service member data report every 3 weeks that includes the injury and illness classification codes needed to identify these veterans. However, as of January 2008, VBA had not obtained any of the U.S. Army Surgeon General reports. Senior C&P Service officials stated that VBA had not followed up with DOD to obtain these reports because VBA was waiting to obtain the injury and classification codes from a planned VBA/DOD Veterans Tracking Application (VTA). As of January 2008, VBA was testing the reliability of VTA data and could not provide us with a planned full implementation date.
Monitoring Case-Managed Claims. VBA policy requires VAROs to case manage seriously disabled OEF/OIF veterans’ claims. Case management is intended to ensure VAROs process seriously disabled claims within VBA’s 30-day goal. Case management procedures require VAROs to closely monitor the status of each claim and use telephone calls and letters to inform each veteran of their claim’s status. VAROs only case managed 1,049 (21 percent) of the 4,969 seriously disabled OEF/OIF claims requiring case management. VAROs did not identify the remaining 3,920 (79 percent) claims for case management because VBA did not obtain the necessary information discussed above. Regardless, VBA’s case management had minimal effect on the timeliness of claims received from seriously disabled OEF/OIF veterans. For example, VARO claim processing times did not meet the 30-day goal for 77 percent of the 3,920 claims that were not case managed and a minimally lower 74 percent of the 1,049 claims that were case managed.
To monitor the processing of case-managed claims, VBA’s Office of Field Operations (OFO) and VAROs used an OEF/OIF Registry. However, the OEF/OIF Registry was not an effective monitoring tool because it did not clearly show and summarize claim processing timeliness information such as claim processing days to date. As a result, OFO and VARO officials and case managers could not easily identify, track, and follow-up on claim processing delays.
Outreach to OEF/OIF Service Members and Veterans Needed Improvement. We estimated OEF/OIF service member VBA TAP briefing participation rates of 43 percent in FY 2006 and 47 percent in FY 2007. These participation rates were slightly less than VBA’s FY 2006 goal of 53 percent. (VBA did not have a FY 2007 goal and, as discussed below, did not determine actual participation rates.) In addition, VBA did not deliver initial outreach letters to 65,853 (33 percent) of 198,128 OEF/OIF veterans. Furthermore, VBA did not provide special outreach to an additional 3,274 OEF/OIF veterans who did not have a high school diploma or equivalent. To improve outreach to service members and veterans, DoD is in the best position to collect and monitor service member attendance at VBA TAP briefings. In addition, VBA needed to strengthen procedures for processing initial outreach letters and establish policies and procedures for providing special outreach.
Monitoring TAP Briefing Attendance. DOD and VBA did not determine and monitor TAP briefing attendance for OEF/OIF service members because of difficulties in collecting the data needed to calculate participation rates. To calculate these rates, DOD needs to determine the OEF/OIF service members eligible to attend TAP briefings and the OEF/OIF service members who participate in the briefings. (Hospitalized seriously disabled service members who cannot attend TAP briefings receive an individual briefing at the medical facility providing treatment.) Our estimated participation rates of 43 percent in FY 2006 and 47 percent in FY 2007 indicate that VBA was not achieving the 53 percent TAP participation rate goal. In addition to monitoring TAP briefing attendance, to help increase TAP briefing participation, DOD needed to mandate service members to attend a briefing prior to discharge.
Processing Initial Outreach Letters. Title 38 of the U.S. Code requires VBA to advise discharged veterans, through outreach letters, of available VBA benefits. The 65,853 OEF/OIF veterans did not receive initial outreach letters because C&P Service staff made incorrect ineligibility determinations (36,968 National Guard and Reserve veterans), did not obtain Certificates of Release or Discharge from Active Duty (DD-214s) information from DOD (22,879 veterans), and did not follow-up on letters returned as undeliverable (6,006 veterans).
Providing Special Outreach. Title 38 of the U.S. Code requires VBA to perform special outreach, in person or by telephone, for veterans who do not have a high school diploma or equivalent. C&P Service staff stated that they did not identify and provide the 3,274 OEF/OIF veterans special outreach because it was not required by VBA policies and procedures.
VBA controls needed strengthening to ensure transition assistance meets the needs of OEF/OIF service members and veterans. Controls over VARO processing of seriously disabled OEF/OIF veterans’ compensation claims needed strengthening to reduce claim-processing delays. In addition, controls over outreach needed strengthening to ensure VBA informs service members and veterans of available VBA benefits that can ease their transition to civilian life. VBA implementation of the following recommendations will address the transition control deficiencies identified during the audit and help ensure a smooth transition for the men and women who have made sacrifices in defense of freedom, not only in Iraq and Afghanistan, but also throughout the world.
1. We recommended the Acting Under Secretary for Benefits obtain U.S. Army Surgeon General reports that include the injury and illness classification codes necessary to identify seriously disabled service members until VBA fully implements VTA.
2. We recommended the Acting Under Secretary for Benefits develop improved monitoring mechanisms to ensure VAROs promptly process seriously disabled OEF/OIF veterans’ compensation claims.
3. We recommended the Acting Under Secretary for Benefits pursue an agreement with DOD requiring service members to attend a VBA TAP briefing prior to discharge.
4. We recommended the Acting Under Secretary for Benefits develop a mechanism to obtain the VBA TAP briefing participation data necessary to calculate and monitor annual service member briefing participation rates.
5. We recommended the Acting Under Secretary for Benefits establish policies and procedures that clearly describe minimum benefit eligibility requirements and implement controls for ensuring the accuracy of eligibility determinations.
6. We recommended the Acting Under Secretary for Benefits develop a mechanism to obtain the DD-214 information needed to identify discharged veterans who should receive outreach letters.
7. We recommended the Acting Under Secretary for Benefits establish policies and procedures that require staff to follow-up on initial outreach letters returned as undeliverable.
8. We recommended the Acting Under Secretary for Benefits establish policies and procedures that require staff to provide special outreach to veterans who do not have a high school diploma or equivalent.