Reclaiming the Process: Examining the VBA Claims Transformation Plan as a Means to Effectively Serve Our Veterans
June 19, 2012
MANAR, DEPUTY DIRECTOR
NATIONAL VETERANS SERVICE
VETERANS OF FOREIGN WARS OF THE UNITED STATES
ON VETERANS’ AFFAIRS
STATES HOUSE OF REPRESENTATIVES
the Process: Examining the VBA Claims
Transformation Plan as a Means to Effectively Serve Our Veterans
WASHINGTON, DC June
MR. CHAIRMAN AND MEMBERS OF THIS
On behalf of the more than 2 million
members of the Veterans of Foreign Wars of the United States (VFW) and our
Auxiliaries, I would like to thank you for the opportunity to testify today on
the VBA claims transformation plan within the Veterans Benefits Administration
Over the last 20 years we have
watched VBA struggle to determine how it would modernize its claims processing
systems. “Struggle to determine” because
VBA has lacked a coherent vision of what a 21st Century claims
processing system should be. Lewis
Carol, author of Alice in Wonderland, is often quoted as saying: “If you don’t
know where you’re going, any road will get you there.” To the despair of many of us, VBA started
down many roads, only to find that nearly all got them precisely nowhere.
In our view, VBA is still struggling
to find its vision. Without a clear
vision, an ultimate goal, it advances in fits and starts, making some progress,
but often at the cost of wasted time, money and the energy of its people.
In the last year Allison Hickey,
Under Secretary for Benefits, has worked hard to bring that vision into
focus. Just a year ago this month she
called 50 people to a Strategic Planning and Implementation Workshop. Through two grueling, 12- hour days she
worked with them to define where VBA should be by 2015. By the end of the workshop they had taken the
vision from its murky, ethereal shape and had developed the outline of goals
and the start of a plan.
They started the process of paring
away the programs and pilots that weren’t working. They sought to identify those things that
were working but not delivering sufficient value to continue. Then they began to examine which of the
remaining initiatives would help them get to their goals, and figure out what
was required to further the process.
In all of this there was a
recognition that VBA could not overhaul its claims processing systems without
first overhauling its computer and software infrastructure.
How best to describe the computer
systems used by VBA to process claims?
Imagine a house first built in the late 1970’s. The house was an old design but because the
plans and materials were already out of date, the price to build it was
considered reasonable. The house was
modest at first, and because it was new, its owners thought that it would serve
them for many years to come.
Over the next 40 years many rooms
were added to the house. The rooms had
funny names, such as BIRLS, COVERS, RBA 2000, BDN and MAPD, to name a few. Each room was added at
different times. Some doors failed to
open onto hallways. Some had central air
conditioning while others had none. In
some rooms the plumbing worked fine while there were chronic problems in
others. Visitors to this house often had
to go back outside and enter through a different door just to get to another
room. As a consequence of poor planning
and design, the house was not very efficient and it was difficult to live in.
This analogy describes the computer
systems VA uses today. While it is true
that many changes and improvements have been made, the basic foundation on
which all these systems are built is inadequate to support a functional claims
system. It is slow, inefficient,
requires repetitive input and it is difficult to update and repair.
VBMS is VBA’s attempt to build a
foundation for a new house. It’s not
just designed to sustain the software programs VBA envisions for the immediate
future, it is intended to be sufficiently flexible to allow the addition of
programs not yet contemplated.
It is important to understand that
VBMS is the foundation. VBMS is designed
to facilitate the creation of efficiencies. As such, we do not anticipate that
the rollout of VBMS over the next year will initially result in significant
improvements in claims processing timeliness or quality. In fact, if history is any guide, the
deployment of VBMS will actually slow claims processing during the first 6
months as software problems are identified and fixes installed.
We do anticipate some efficiencies
from the start. For instance,
information concerning individual veterans, now scattered in multiple locations
requiring separate input, will be stored in one location. Whenever that information is required, VBMS
is designed to retrieve that centrally stored data.
For instance, right now a Veterans Service
Representative (VSR) must enter a veteran’s address in several different
programs to ensure that the address is current.
Systems do not automatically update. Similarly, a veteran’s Power of
Attorney (POA) must be entered in different programs to allow access by
veterans representatives. With VBMS, a
VSR need update the system in one place only and other programs will draw from
that central data point to find the most current address or POA.
There has been some discussion of
late that the deployment of VBMS may be delayed. There is a fine line between rolling out a
new program too soon and delaying rollout too long while seeking to fix all the
problems. VBA’s initial plans for rapid
development and deployment of VBMS were, in our view, unrealistic from the
start. It is our understanding that
development and testing of VBMS was to be conducted in rapid succession:
collect the business requirements in Baltimore for a few months, deploy the
first version to Providence for 6 months, update and deploy the second version
to Salt Lake City for 6 months then roll it out to the other regional
offices. To date VBMS is in four
regional offices and, we are told, fewer than 800 cases have been processed to
We believe that rolling out VBMS
prematurely, before it is fully stressed to identify the majority of issues and
problems it contains, is a bad business practice, bad for veterans and bad for
morale of an already demoralized VA workforce.
Examples are replete in the history of VBA claims processing of what
happens when a new software program is deployed before it is ready for prime
BIRLS has been a useful tool to aid
claims processors for many decades. It
contains, among other things, data on veterans’ military service. In an effort to clean up and verify the data
contained in this program, VBA undertook a project in the1980’s called BIRLS
Redesign. This program was rolled out to
the field without adequate testing. As a
result, tens of thousands of records had to be corrected or updated by hand,
costing VBA thousands of man-hours of lost productivity.
In the 1990’s VBA developed a
program called RBA to assist rating specialists in the completion of rating
decisions. In 2000, VBA updated the program
and deployed it to the field without sufficient beta testing. As a consequence, creation of rating
decisions slowed to a crawl while thousands of VA’s most critical decision
makers spent months identifying software bugs and struggled with “workarounds”
while computer programmers fixed problems.
While it is counterproductive to
delay release of a computer program until all the bugs are identified, these
two examples are ample evidence of what happens when a new program is
inadequately tested and released too soon.
We encourage this Committee to
continue its oversight of VBA and VBMS while recognizing that it may be
necessary to accept modest delays in deployment of this major initiative in
order to avert the negative effects of rolling out a program with defects
simply to meet a deadline.
VBMS is just one of many initiatives
underway in VBA. A list of
Transformation Initiatives on VA’s website offers a fascinating, though dated, summary of the dozens of
ideas tried, adopted or discarded in a quest to find the most efficient way to
develop and decide claims in a timely manner.
Simplified Notification Letters
(SNL) is an initiative thoroughly embraced by VBA leadership. An examination of what this initiative does
to veterans is illustrative of the mindset of VBA in the last year.
The veteran service organizations
first became aware of this project in June 2011 when our service officers in
Atlanta notified us of its existence.
Initially called Disability Evaluation Narrative Text Tool (DENTT) and
later Rating Redesign, a team working in the Atlanta and St. Paul regional
offices designed a process which could best be described as “Back to the
Future”. Instead of creating a time
machine in a DeLorean, this team reached back to a simpler pre-VCAA, pre-veterans
court era when ratings were simply conclusions with no discussion of the
evidence considered nor the reasons and bases as to why the decisions were
Instead, this initiative, now called
SNL, required the rating specialist to include a set of codes at the end of the
rating. The codes, in turn, were used by
VSR’s to select standard paragraphs for inclusion in the decision notice
letters to veterans. While these standard
paragraphs were better written and more understandable than those previously
used by VA, they were generic and did not include the minimum information
needed by a veteran to decide whether the decision was likely to be
correct. With only general information
provided by VA, veterans are faced with the choice of blindly accepting the
decision or filing a Notice of Disagreement in order to obtain the reasons for the decision.
In September 2011, the VFW conducted
an on-site review in Atlanta of rating decisions made under this
initiative. After reviewing 60 ratings
and accompanying notice letters we concluded that the quality of the rating
decisions was worse than that reported by VA through its STAR quality review
program, and that veterans were not receiving adequate notice to satisfy legal
and judicial requirements. Local management
bragged that production was increased by 40 percent when cases were rated under
Over the ensuing months we continued
to complain about the inadequate notice being provided to veterans. To be fair, Under Secretary of Benefits Hickey
listened to our concerns and changes have been made in the SNL program in an
attempt to address the problems we noted.
Under the most recent changes,
rating specialists were given additional instructions on providing sufficient
details and discussion to explain their decisions. Restrictions on how much “free text”
narrative they could insert in a rating were removed. At the time these changes were implemented in
late February, 2012, we concluded that if field personnel followed the
instructions it would be possible to create barely adequate decisions and
Since May 2012, the VFW has
conducted a review of SNL ratings and letters from several regional
offices. Fifty three (53) percent of the
cases reviewed contained errors in either the rating, decision letter or
both. There were only a few examples of
where claimants were provided what we view as legally adequate notice.
VBA’s apparent inability to compel
compliance by rating and authorization personnel with the most recent written
directives concerning the SNL program force us to renew our opposition to this
initiative. While we understand VBA’s
desire to increase production, we believe that this increased output is being
done at the expense of veteran’s legal right to know why decisions have been
made in their cases. No two veterans,
nor their disabilities, are alike.
Canned generic paragraphs are not sufficient to tell them why their
claims were decided in a particular way.
VBA should suspend the SNL program until they can ensure that veterans
receive adequate notice as required by law.
Mr. Chairman, this concludes my
testimony, and I look forward to any questions you and the Committee may have
concerning these issues or other programs or pilots the VA is conducting to improve
the claims process.
Information Required by Rule XI2(g)(4) of the
House of Representatives
Pursuant to Rule XI2(g)(4) of the House of
Representatives, VFW has not received any federal grants in Fiscal Year 2012,
nor has it received any federal grants in the two previous Fiscal Years.
Benefits Identification and Records Locator System
Control of Veterans Records System
Rating Board Automation 2000 was an updated version of the original Rating
Board Automation program
Benefits Delivery Network
Modern Awards Processing - Development
Notice of Disagreement is the first step in the appeal process. Upon receipt, VA is required to review the
decision, determine if additional development is required, and a new decision
is warranted, If no change is warranted,
a Statement of the Case, which provides the reasons and bases, as well
as applicable citations of law and regulations supporting the decision, is issued to the appellant. 38 CFR 19.26; 20.201.
A regulations and Federal court
decisions make it clear that VA must provide claimants the reasons and bases
for the decisions it makes. “Every
claimant has the right to written notice of the decision made on his or her claim…” 38 CFR 3.103(a). “Claimants and their representatives are
entitled to notice of any decision made by VA affecting the payment of
benefits… Such notice shall clearly set
forth the decision made, any applicable effective date, the reasons for the decision…” 38 CFR 3.103(b). See also Gilbert v. Derwinski, 1 Vet.App.
49, 56-57 (1990) and Bolton v. Brown, 8 Vet.App. 185, 191 (1995).
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