Inspection of the
 

VA Regional Office
 

Chicago, Illinois
 

OFFICE OF AUDITS AND EVALUATIONS

June 2, 2011 

11-00521-183 
ACRONYMS AND ABBREVIATIONS
 

COVERS Control of Veterans Records System 

NOD Notice of Disagreement 

OIG Office of Inspector General 

PTSD Post-Traumatic Stress Disorder 

RVSR Rating Veterans Service Representative 

SAO Systematic Analysis of Operations 

STAR Systematic Technical Accuracy Review 

TBI Traumatic Brain Injury 

VACOLS Veterans Appeals Control and Locator System 

VARO Veterans Affairs Regional Office 

VBA Veterans Benefits Administration 

VSC Veterans Service Center 

To Report Suspected Wrongdoing in VA Programs and Operations:
 

Telephone: 1-800-488-8244
 

E-Mail: vaoighotline@va.gov
 

(Hotline Information: http://www.va.gov/oig/contacts/hotline.asp)
 
Report Highlights: Inspection of the
 

VA Regional Office, Chicago, Illinois
 

Why We Did This Review 

The Benefits Inspection Division conducts 

onsite inspections at VA Regional Offices 

(VAROs) to review disability compensation 

claims processing and Veterans Service 

Center operations. 

What We Found 

Chicago VARO staff correctly processed 

post-traumatic stress disorder disability 

claims, properly established the correct dates 

of claim in the electronic record, and 

ensured staff corrected errors identified by 

the Veterans Benefits Administration’s 

Systematic Technical Accuracy Review 

Program. The VARO’s performance was 

generally effective in processing herbicide 

exposure-related claims and final 

competency determinations. 

VARO management lacked effective 

controls to ensure accurate processing of 

temporary 100 percent disability evaluations 

and traumatic brain injury claims, as well as 

action items related to disability claims 

processing. Overall, VARO staff did not 

accurately process 21 (20 percent) of the 

103 disability claims reviewed and they 

were not timely recording Notices of 

Disagreement for appealed claims. Further, 

they did not complete Systematic Analyses 

of Operations and manage mail effectively. 

What We Recommended 

We recommended Chicago VARO 

management implement controls to ensure 

the Veterans Service Center staff establishes 

suspense diaries to request medical 

reexaminations for temporary 100 percent 

disability reevaluations and follow policy 

for completing related action items. 

Management should also develop and 

implement plans to monitor the 

effectiveness of training and improve 

accuracy and oversight of traumatic brain 

injury claims. 

Further, we recommended management 

implement a plan to ensure timely 

establishment of Notices of Disagreement in 

the Veterans Appeals Control and 

Locator System. Management also needs to 

implement a plan to ensure timely and 

complete Systematic Analyses of Operations 

and oversight of search mail. 

Agency Comments 

The Chicago VARO Director concurred 

with all recommendations. Management’s 

planned actions are responsive and we will 

follow up as required on all actions. 

BELINDA J. FINN
 

Assistant Inspector General
 

for Audits and Evaluations
 

i 
TABLE OF CONTENTS
 

Introduction......................................................................................................................................1
 

Results and Recommendations ........................................................................................................2
 

1. Disability Claims Processing ..................................................................................................2
 

2. Data Integrity ..........................................................................................................................6
 

3. Management Controls .............................................................................................................8
 

4. Workload Management...........................................................................................................9
 

5. Eligibility Determinations.....................................................................................................11
 

Appendix A VARO Profile and Scope of Inspection ............................................................12 

Appendix B VARO Director’s Comments............................................................................14 

Appendix C Inspection Summary..........................................................................................18 

Appendix D OIG Contact and Staff Acknowledgments........................................................19 

Appendix E Report Distribution ...........................................................................................20 

ii 
Inspection of the VA Regional Office, Chicago, Illinois 

Objectives
 

Scope of
 

Inspection
 

INTRODUCTION 

The Benefits Inspection Program is part of the Office of Inspector General’s 

(OIG) efforts to ensure our Nation’s veterans receive timely and accurate 

benefits and services. The Benefits Inspection Division contributes to 

improved management of benefits processing activities and veterans’ 

services by conducting onsite inspections at VA Regional Offices (VAROs). 

These independent inspections provide recurring oversight focused on 

disability compensation claims processing and performance of Veterans 

Service Center (VSC) operations. The objectives of the inspections are to: 

	 Evaluate how well VAROs are accomplishing their mission of providing 

veterans with access to high-quality benefits and services. 

	 Determine if management controls ensure compliance with VA 

regulations and policies; assist management in achieving program goals; 

and minimize the risk of fraud, waste, and other abuses. 

	 Identify and report systemic trends in VARO operations. 

In addition to this standard coverage, inspections may examine issues or 

allegations referred by VA employees, members of Congress, or other 

stakeholders. 

In March 2011, the OIG conducted an inspection of the Chicago VARO. 

The inspection focused on 5 protocol areas examining 10 operational 

activities. The five protocol areas were disability claims processing, data 

integrity, management controls, workload management, and eligibility 

determinations. 

We reviewed 73 (18 percent) of 397 disability claims related to 

post-traumatic stress disorder (PTSD), traumatic brain injury (TBI), and 

herbicide exposure that the VARO completed from October through 

December 2010. In addition, we reviewed 30 (6 percent) of 469 rating 

decisions where VARO staff granted temporary 100 percent disability 

evaluations for at least 18 months, generally the longest period a temporary 

100 percent disability evaluation may be assigned under VA policy without 

review. 

Appendix A provides details on the VARO and the scope of our inspection. 

Appendix B provides the VARO Director’s comments on a draft of this 

report. Appendix C provides criteria we used to evaluate each operational 

activity and a summary of our inspection results. 

VA Office of Inspector General 1 
Inspection of the VA Regional Office, Chicago, Illinois 

RESULTS AND RECOMMENDATIONS 

1. Disability Claims Processing 

The OIG inspection team focused on disability claims processing related to 

temporary 100 percent disability evaluations, PTSD, TBI, and herbicide 

exposure. We evaluated claims processing accuracy and its impact on 

veterans’ benefits. 

Finding 1	 VARO Staff Need To Improve Disability Claims 

Processing Accuracy 

The Chicago VARO needs to improve the accuracy of disability claims 

processing. VARO staff incorrectly processed 21 (20 percent) of the total 

103 disability claims we reviewed. VARO management agreed with our 

findings and initiated action to correct the inaccuracies identified. 

The following table reflects the errors affecting, and those with the potential 

to affect, veterans’ benefits processed at the Chicago VARO. 

Table Disability Claims Processing Results 

Type Reviewed 

Claims Incorrectly Processed 

Total Affecting 

Veterans’ 

Benefits 

Potential To 

Affect Veterans’ 

Benefits 

Temporary 

100 Percent Disability 

Evaluations 

30 13 5 8 

PTSD 30 0 0 0 

TBI 13 7 1 6 

Herbicide 

Exposure-Related 

Disabilities 

30 1 0 1 

Total 103 21 6 15 

Temporary 

100 Percent 

Disability 

Evaluations 

Source: VA OIG Analysis March 2011 

VARO staff incorrectly processed 13 (43 percent) of 30 temporary 

100 percent disability evaluations we reviewed. Veterans Benefits 

Administration (VBA) policy requires a temporary 100 percent disability 

evaluation for a service-connected disability following surgery or when 

specific treatment is needed. At the end of a mandated period of 

convalescence or treatment, VARO staff must request a follow-up medical 

VA Office of Inspector General 2 
Inspection of the VA Regional Office, Chicago, Illinois 

examination to help determine whether to continue the veteran’s 100 percent 

disability benefits. 

For temporary 100 percent disability evaluations, including those where 

rating decisions do not change a veteran’s payment amount (confirmed and 

continued evaluations), VSC staff must input suspense diaries in VBA’s 

electronic system. A suspense diary is a processing command that 

establishes a date when VSC staff must schedule a medical reexamination. 

As a suspense diary matures, the electronic system generates a reminder 

notification to alert VSC staff to schedule the reexamination. 

Based on analysis of available medical evidence, 5 of the 13 processing 

inaccuracies affected veterans’ benefits—3 involved overpayments totaling 

$40,275 and 2 involved underpayments totaling $12,414. Details on the 

most significant overpayment and underpayment follow. 

	 A Rating Veterans Service Representative (RVSR) incorrectly granted 

special monthly compensation for a veteran’s service-connected active 

prostate cancer and multiple residual disabilities determined to be due to 

the prostate cancer. In accordance with VBA policy, RVSRs should not 

separately evaluate complications of prostate cancer when the disease is 

active. As a result, VA overpaid the veteran $17,799 over a period of 

4 years and 10 months. 

	 An RVSR did not grant a veteran special monthly compensation as 

required for loss of use of a creative organ. As a result, VA underpaid 

the veteran $10,110 over a period of 9 years and 8 months. 

The remaining eight inaccuracies had the potential to affect veterans’ 

benefits. Following are summaries of those inaccuracies. 

	 In six cases, VSC staff did not input suspense diaries or establish local 

controls to schedule follow-up medical reexaminations needed to 

determine whether the temporary 100 percent disability evaluations 

should continue. 

	 In one case, an RVSR correctly continued the 100 percent disability 

evaluation without requiring a future reexamination. In making this 

decision, the RVSR did not consider entitlement to the additional benefit 

of Dependents’ Educational Assistance as required by VBA policy. 

	 In one case, an RVSR incorrectly requested a future reexamination for a 

veteran with an incurable disease. In making this decision, the RVSR did 

not consider entitlement to the additional benefit of Dependents’ 

Educational Assistance as required by VBA policy. 

VA Office of Inspector General 3 
Inspection of the VA Regional Office, Chicago, Illinois 

PTSD Claims 

TBI Claims 

An average of 4 years elapsed from the time staff should have scheduled 

medical reexaminations until the date of our inspection—the date staff 

ultimately ordered the medical reexaminations to obtain the necessary 

medical evidence. The delays ranged from 1 year and 2 months to 11 years 

and 1 month. 

The most frequent error noted in 7 of the 13 temporary 100 percent disability 

evaluations occurred when VARO staff did not properly establish suspense 

diaries for future VA medical reexaminations. Four of the seven errors 

involved rating decisions where medical reexaminations were required 

within 60 days of VSC staff finalizing the decisions. VBA policy requires 

VAROs establish local procedures to maintain control of claims requiring 

medical reexaminations within 60 days of final processing actions. VSC 

staff stated they were unaware of any local policy regarding control of these 

types of medical reexaminations. As such, VARO staff did not always 

schedule medical reexaminations as required. 

Additionally, VARO staff did not follow VBA policy or the VSC workload 

management plan guidance on 810 work items. The 810 work item is a 

system-generated reminder notification to take future actions on a claim. 

VSC staff are responsible for reviewing the 810 work items and taking the 

follow-up actions needed. For temporary 100 percent disability evaluations, 

the 810 work items provide notification to review the claims to determine the 

need to schedule medical reexaminations. We found 198 pending 810 work 

items; the oldest had been pending since August 2010. VSC’s workload 

management plan requires weekly review of work items. However, VSC 

staff indicated management promoted the person responsible for the weekly 

review and did not reassign the duty. As a result, VSC staff did not schedule 

medical reexaminations timely. 

We provided the VARO with 439 temporary 100 percent disability claims 

remaining from the universe of 469 reviewed. We make no recommendation 

for the VARO to review these claims as the Acting Under Secretary for 

Benefits has already concurred with a corresponding recommendation in our 

national report, Veterans Benefits Administration: Audit of 100 Percent 

Disability Evaluations, (Report Number 09-03359-71, January 24, 2011). 

VARO staff correctly processed all 30 PTSD claims we reviewed. 

Therefore, we made no recommendations for improvement in this area. 

The Department of Defense and VBA commonly define a TBI as a 

traumatically induced structural injury or a physiological disruption of brain 

function caused by an external force. The major residual disabilities of TBI 

fall into three main categories—physical, cognitive, and behavioral. VBA 

policy requires staff to evaluate these residual disabilities. 

VA Office of Inspector General 4 
Inspection of the VA Regional Office, Chicago, Illinois 

Herbicide 

Exposure-Related 

Claims 

VARO staff incorrectly processed 7 (54 percent) of 13 TBI claims. One of 

the errors affected a veteran’s benefits and six had the potential to affect 

veterans’ benefits. Following are summaries of these inaccuracies. 

	 In the one case that affected a veteran’s benefits, an RVSR incorrectly 

continued a grant of service connection for a residual TBI-related 

disability without evidence of an in-service event or injury. The service 

treatment records did not show treatment, diagnosis, or complaints of 

TBI. Further, the VA medical examination did not link residuals of TBI 

to the veteran’s military service. As a result, VA overpaid the veteran 

$23,144 over a period of 2 years. 

	 In six cases that had the potential to affect veterans’ benefits, RVSRs and 

Decision Review Officers prematurely evaluated residual TBI-related 

disabilities using inadequate medical examinations. According to VBA 

policy, when a medical examination does not address all required 

elements, VSC staff should return it to the clinic or healthcare facility as 

insufficient for rating purposes. Neither VARO staff nor we can 

ascertain all of the residual disabilities related to TBI without an adequate 

or complete medical examination. 

Generally, errors associated with TBI claims processing occurred because 

VARO staff incorrectly interpreted VBA policy and used VA medical 

examinations that were inadequate for decision-making purposes. Prior to 

our inspection, three of the seven inaccuracies received second reviews by 

Decision Review Officers and VSC staff completed a local quality review on 

one of the seven inaccuracies without identifying any errors. Although 

VARO staff received training on how to evaluate TBI disability claims, 

interviews with VSC supervisors, RVSRs, and Decision Review Officers 

indicated that TBI regulations and policies were difficult to understand. As a 

result, veterans did not always receive correct benefit payments. 

VARO training staff provided refresher TBI training in response to the errors 

we identified during our site inspection. Interviews with VSC staff indicated 

this new training corrected problems with previous guidance regarding VBA 

policy for processing TBI claims; however, management would benefit from 

monitoring the training provided to ensure that it is effective and adequate. 

VARO staff incorrectly processed 1 (3 percent) of 30 herbicide 

exposure-related claims. In this case, an RVSR incorrectly denied service 

connection for a diabetes-related complication diagnosed in both private and 

VA medical examinations. Because we found only one inaccuracy, we 

determined the VARO generally followed VBA policy for herbicide 

exposure-related claims. Therefore, we made no recommendations for 

improvement in this area. 

VA Office of Inspector General 5 
Inspection of the VA Regional Office, Chicago, Illinois 

Recommendations 

Management 

Comments 

OIG Response 

Dates of Claim 

1.	 We recommend the Chicago VA Regional Office Director establish 

mechanisms to ensure staff control claims requiring medical 

reexaminations within 60 days of final processing action, as required. 

2.	 We recommend the Chicago VA Regional Office Director review all 

pending 810 work items to determine if medical reexaminations are 

required and take appropriate action. 

3.	 We recommend the Chicago VA Regional Office Director implement 

oversight to ensure staff follow Veterans Benefits Administration 

guidance and the local workload management plan for reviewing 

810 work items. 

4.	 We recommend the Chicago VA Regional Office Director develop and 

implement a plan to monitor the effectiveness and adequacy of training 

provided in March 2011, on proper processing of disabilities related to 

traumatic brain injuries. 

5.	 We recommend the Chicago VA Regional Office Director develop and 

implement a plan to improve accuracy and oversight of traumatic brain 

injury claims processing. 

The VARO Director concurred with our recommendations. In response to 

recommendation 1, the Director stated the VARO would follow the 

Compensation and Pension Service guidance provided in May 2011 to 

ensure staff control claims requiring medical reexaminations. In response to 

recommendations 2 and 3, the VSC revised its workload management plan to 

ensure rating staff review pending work items on a monthly basis and take 

appropriate action as needed. In response to recommendations 4 and 5, the 

Director stated the VARO provided training on all aspects of TBI ratings 

and, effective May 2011, all TBI ratings require a second review by a 

Decision Review Officer. The Decision Review Officers will provide 

feedback to management and VSC staff will receive targeted training based 

on errors noted. At the end of the fiscal year, management will reevaluate 

the need to continue the second review of all TBI ratings. 

Management’s actions are responsive to the recommendations. We will 

follow up as required on all actions. 

2. Data Integrity 

We analyzed claims folders to determine if the VARO is following VBA 

policy to establish correct dates of claim in the electronic record. In addition 

to establishing the time frame for benefits entitlement, VBA generally uses a 

date of claim to indicate when a document arrives at a VA facility. VBA 

relies on accurate dates of claim to establish and track key performance 

measures, including the average days to complete a claim. 

VA Office of Inspector General 6 
Inspection of the VA Regional Office, Chicago, Illinois 

Notices of 

Disagreement 

Finding 2 

Recommendation 

VARO staff established correct dates of claim in the electronic record for all 

30 claims we reviewed. As a result, we determined the VARO is following 

VBA policy and we made no recommendations for improvement in this area. 

We analyzed claims folders to determine if the VARO is following VBA 

policy to timely record Notices of Disagreement (NODs) in the Veterans 

Appeals Control and Locator System (VACOLS). An NOD is a written 

communication from a claimant expressing dissatisfaction or disagreement 

with a benefits decision and a desire to contest the decision. An NOD is the 

first step in the appeals process. VACOLS is a computer application that 

allows VARO staff to control and track a veteran’s appeal and manage the 

pending appeals workload. VBA policy states staff must create a VACOLS 

record within 7 days of receiving an NOD. Accurate and timely recording of 

NODs is required to ensure appeals move through the appellate process 

expeditiously. 

Controls Over Recording Notices of Disagreement 

Need Strengthening 

The VARO Appeals Team did not consistently record NODs in VACOLS 

within VBA’s 7-day standard. VARO staff did not meet the 7-day standard 

for 7 (23 percent) of the 30 NODs we reviewed. Staff took an average of 

21 days to record these seven disagreements in VACOLS. The most 

untimely action occurred when staff did not create a record for 36 days. 

Although the Appeals Team was aware of the 7-day standard, delays 

occurred because the workload management plan and local procedures did 

not incorporate provisions to ensure prompt control of NODs in VACOLS. 

VARO staff’s untimely recording of NODs in VACOLS affects data 

integrity and misrepresents VARO performance. 

As of February 2011, the VARO averaged 73 days to establish NODs, 

66 days over VBA’s 7-day standard. NODs at the VARO have been pending 

completion an average of 326 days, 68 days over the national average of 

258 days. 

Data integrity issues make it difficult for VARO and senior VBA leadership 

to accurately measure and monitor VARO performance. Further, VBA’s 

National Call Centers rely upon VACOLS information to provide accurate 

customer service to veterans. Unnecessary delays in controlling NODs affect 

national performance measures for NOD inventory and timeliness. 

6.	 We recommend the Chicago VA Regional Office Director develop and 

implement a plan to ensure staff record Notices of Disagreement in the 

Veterans Appeals Control and Locator System within 7 days as required 

by Veterans Benefits Administration policy. 

VA Office of Inspector General 7 
Inspection of the VA Regional Office, Chicago, Illinois 

Management 

Comments 

OIG Response 

Systematic 

Technical 

Accuracy 

Review 

Systematic 

Analysis of 

Operations 

Finding 3 

The VARO Director concurred with our recommendation. The Director 

stated the existing workload management plan dictates Appeals Team 

Veteran Service Representatives will enter NODs into VACOLS. However, 

effective April 2011, when the volume of incoming NODs would become 

too large for the Veteran Service Representatives to complete, Claims 

Assistants would help enter the NODs into the system. Management will 

continue to monitor the incoming NOD volume and assign staff as needed to 

timely complete NOD entry. 

Management’s actions are responsive to the recommendation. We will 

follow up as required on all actions. 

3. Management Controls 

We assessed management controls to determine if VARO management 

adhered to VBA policy regarding correction of errors identified by VBA’s 

Systematic Technical Accuracy Review (STAR) staff. The STAR program 

is VBA’s multifaceted quality assurance program to ensure veterans and 

other beneficiaries receive accurate and consistent compensation and pension 

benefits. VBA policy requires the VARO take corrective action on errors 

identified by STAR. 

VARO staff adhered to VBA policies by taking corrective action on all 

17 errors identified by STAR from October through December 2010. 

Therefore, we made no recommendations for improvement in this area. 

We assessed whether VARO management had controls in place to ensure 

complete and timely submission of Systematic Analyses of Operations 

(SAOs). An SAO is a formal analysis of an organizational element or 

operational function. SAOs provide an organized means of reviewing VSC 

operations to identify existing or potential problems and propose corrective 

actions. VARO management must publish annual SAO schedules 

designating the staff required to complete the SAOs by specific dates. 

Improved Oversight Is Needed To Ensure Timely 

Completion of SAOs 

Seven (58 percent) of the 12 SAOs were not completed timely per the annual 

schedule, were incomplete (missing required elements), or were not done at 

all. The VSC Manager is responsible for completing the 12 annual SAOs as 

part of ongoing analysis of VSC operations. VARO management did not 

provide adequate oversight to ensure VSC staff completed the SAOs in 

accordance with VBA policy. As a result, VARO management may not have 

adequately identified existing and potential problems for corrective actions to 

improve VSC operations. 

VA Office of Inspector General 8 
Inspection of the VA Regional Office, Chicago, Illinois 

Recommendation 

Management 

Comments 

OIG Response 

Mailroom 

Operations 

Triage Mail 

Processing 

Procedures 

At the time of our inspection, 3 (25 percent) of the 12 SAOs were partially 

completed, 2 (17 percent) were not started, 1 (8 percent) was not timely, and 

1 (8 percent) was both partially completed and not timely. VSC management 

indicated supervisors complete the same SAO every year and use the 

previous year’s SAO as a model rather than following VBA’s policy to 

complete the current SAO. In turn, VARO staff responsible for SAO 

tracking stated that VSC managers also did not review VBA’s policy when 

analyzing completed SAOs. The VSC Manager identified a lack of SAO 

oversight by previous management in FY 2010 and is currently developing a 

plan to improve this area. 

One of the SAOs that VARO staff did not complete involved medical 

examinations. If VARO managers had ensured proper completion of this 

required SAO, they might have identified deficiencies in the quality of TBI 

examinations similar to what we found during our inspection. 

7.	 We recommend the Chicago VA Regional Office Director develop and 

implement a plan to ensure staff complete Systematic Analyses of 

Operations timely and address all required elements. 

The VARO Director concurred with our recommendation. The Director 

stated management updated the SAO schedule. Management reviews SAOs 

to ensure all required elements are addressed and monitors the schedule to 

ensure they are timely completed. 

Management’s actions are responsive to the recommendation. We will 

follow up as required on all actions. 

4. Workload Management 

We assessed controls over VARO mailroom operations to ensure staff timely 

and accurately processed incoming mail. VBA policy states staff will open, 

date-stamp, and route all mail to the appropriate locations within 4–6 hours 

of receipt at the VARO. The Chicago VARO assigns responsibility for 

mailroom activities, including processing of incoming mail, to the Support 

Services Division. Mailroom staff were timely and accurate in processing, 

date-stamping, and delivering VSC mail to the Triage Team control point 

daily. As a result, we determined the VARO Support Services mailroom is 

following VBA policy and made no recommendation for improvement in 

this area. 

We assessed the VSC’s Triage Team mail processing procedures to ensure 

staff reviewed, controlled, and processed all claims-related mail in 

accordance with VBA policy. VARO staff are required to use VBA’s 

tracking system, Control of Veterans Records System (COVERS), to 

electronically track veterans’ claims folders and control search mail. VBA 

VA Office of Inspector General 9 
Inspection of the VA Regional Office, Chicago, Illinois 

Finding 4 

Recommendation 

Management 

Comments 

OIG Response 

defines search mail as active claims-related mail waiting to be associated 

with veterans’ claims folders. Conversely, drop mail requires no processing 

action upon receipt. VBA policy allows the use of a storage area, known as 

the Military File, to hold mail temporarily when staff are not able to identify 

associated claims folders in the system. 

Triage Team Mail Management Procedures Need 

Strengthening 

The Triage Team staff did not properly manage 12 (14 percent) of 83 pieces 

of mail we reviewed. The most significant error occurred when staff did not 

control search mail through COVERS for 8 (27 percent) of 30 pieces of mail 

reviewed. At the time of our inspection, approximately 1,200 pieces of 

search mail were pending. The most egregious error occurred when the 

VARO received service treatment records on July 28, 2010, and placed them 

in the search mail holding area with another veteran’s COVERS information 

attached. The service treatment records were for a veteran who submitted a 

claim for benefits on May 25, 2010. At the time of our inspection in 

March 2011, the VARO had not made a decision on the veteran’s claim and 

had no search mail control in COVERS for the service treatment records. 

The above errors occurred because of a lack of supervisory oversight to 

ensure timely and accurate movement of mail throughout the VSC. Triage 

Team employees complete reviews of search mail; however, supervisors did 

not provide adequate oversight to ensure search mail was properly marked in 

COVERS. In addition, the station’s workload management plan does not 

thoroughly define search mail procedures. The VSC Manager acknowledged 

weaknesses associated with search mail processing. 

Untimely association of mail with veterans’ claims folders can cause delays 

in processing benefits claims. As a result, beneficiaries may not receive 

accurate and timely benefits payments. 

8.	 We recommend the Chicago VA Regional Office Director develop and 

implement a plan to ensure management oversight and control of search 

mail. 

The VARO Director concurred with our recommendation. The Director 

stated, as part of its integration into the Lean Team model, the VSC updated 

its workload management plan to require the teams review search mail 

weekly. 

Management’s actions are responsive to the recommendation. We will 

follow up as required on all actions. 

VA Office of Inspector General 10 
Inspection of the VA Regional Office, Chicago, Illinois 

Competency 

Determinations 

5. Eligibility Determinations 

VA must consider beneficiary competency in every case involving a mental 

health condition that is totally disabling or when evidence raises questions as 

to a beneficiary’s mental capacity to manage his or her affairs. The 

Fiduciary Unit supports implementation of competency determinations by 

appointing a fiduciary, which is a third party who assists in managing funds 

for an incompetent beneficiary. We reviewed competency determinations 

made at the VARO to ensure staff completed them accurately and timely. 

Delays in making these determinations ultimately affect the Fiduciary Unit’s 

ability to appoint fiduciaries timely. 

VARO staff unnecessarily delayed making final decisions in 1 (9 percent) of 

the 11 competency determinations completed from October through 

December 2010. Because we found only one delay, we determined the 

VARO generally followed VBA policy regarding competency 

determinations and made no recommendation for improvement in this area. 

VA Office of Inspector General 11 
Inspection of the VA Regional Office, Chicago, Illinois 

Appendix A VARO Profile and Scope of Inspection 

Organization The Chicago VARO is responsible for delivering nonmedical VA benefits 

and services to veterans and their families. The VARO fulfills these 

responsibilities by administering compensation and pension benefits, 

vocational rehabilitation and employment assistance, and outreach activities. 

Resources As of January 28, 2011, the Chicago VARO had a staffing level of 

227 employees. Of these, the VSC had 184 employees (81 percent) 

assigned. 

Workload As of February 28, 2011, the VARO reported 14,766 pending compensation 

claims. The average time to complete claims was 228.9 days—53.9 days 

longer than the national target of 175 days. As reported by STAR staff, the 

accuracy of compensation rating-related decisions was 79.6 percent, which 

was 10.4 percent below the 90 percent VBA target. The accuracy of 

compensation authorization-related processing was 93.9 percent, which was 

2.1 percent below the national target of 96 percent. 

Scope We reviewed selected management controls, benefits claims processing, and 

administrative activities to evaluate compliance with VBA policies regarding 

benefits delivery and nonmedical services provided to veterans and other 

beneficiaries. We interviewed managers and employees and reviewed 

veterans’ claims folders. 

Our review included 73 (18 percent) of 397 claims related to PTSD, TBI, and 

herbicide exposure-related disabilities that the VARO completed from 

October through December 2010. For temporary 100 percent disability 

evaluations, we selected 30 (6 percent) of 469 existing claims from VBA’s 

Corporate Database. We provided the VARO with the 439 claims remaining 

from our universe of 469. These claims represented all instances in which 

VARO staff granted temporary 100 percent disability determinations for at 

least 18 months. 

We also reviewed 11 competency determinations completed by the Chicago 

VARO during the 3-month period from October through December 2010. 

We reviewed 17 errors identified by VBA’s STAR program during the same 

time period. VBA measures the accuracy of compensation and pension 

claims processing through its STAR program. STAR’s measurements 

include a review of work associated with claims that require rating decisions. 

STAR staff review original claims, reopened claims, and claims for 

increased evaluation. Further, they review appellate issues that involve a 

myriad of veterans’ disability claims. 

Our process differs from STAR as we review specific types of claims issues 

such as PTSD, TBI, and herbicide exposure-related disabilities that require 

VA Office of Inspector General 12 
Inspection of the VA Regional Office, Chicago, Illinois 

rating decisions. In addition, we review rating decisions and awards 

processing involving temporary 100 percent disability evaluations. 

For our review, we selected dates of claims, NODs, and mail pending at the 

VARO during the time of our inspection. We completed our review in 

accordance with the Council of the Inspectors General on Integrity and 

Efficiency’s Quality Standards for Inspections. We planned and performed 

the review to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our review objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our review objectives. 

VA Office of Inspector General 13 
Inspection of the VA Regional Office, Chicago, Illinois 

Appendix B VARO Director’s Comments 

Department of Memorandum Veterans Affairs 

Date: May 18, 2011 

From: Director, VA Regional Office Chicago, Illinois (328) 

Subj: Inspection of the VARO Chicago, Illinois 

To: Assistant Inspector General for Audits and Evaluations (52) 

Attached are the Chicago VARO’s comments on the OIG Draft Report: Inspection of 1. 

VARO Chicago.
 

Questions may be referred to Mary Hainey, Management Analyst, at telephone number
 2. 

(312) 980-4203. 

(original signed by:) 

DUANE A. HONEYCUTT 

Attachment 

VA Office of Inspector General 14 
Inspection of the VA Regional Office, Chicago, Illinois 

Department of Veterans Affairs

Regional Office
 

2122 W. Taylor Street
 

Chicago, IL 60612
 

RE: VA Office of Inspector General 

Office of Audits and Evaluations 

Inspection of the VA Regional Office Chicago, Illinois 

Recommendations Response from Chicago VA Regional Office (328) 

RECOMMENDATION #1: We recommend the Chicago VA Regional Office Director 

establish mechanisms to ensure staff control claims requiring medical reexaminations within 

60 days of final processing action, as required. 

Response: Concur. We agree that the electronic system should automatically populate future 

exam dates. In response to OIG Report, Audit of 100 Percent Evaluations, dated 

January 24, 2011, VBA developed a national plan to review 100 percent evaluation cases, which 

was accepted by OIG. Therefore, the Regional Office will follow the national review plan. 

On May 11, 2011, Compensation and Pension Service provided interim guidance to the Field 

that provided the four basic scenarios where Future Exam Diary control is either being cancelled 

unexpectedly or not being set at all during the VETSNET Award generation process. This 

interim guidance will be utilized where appropriate. 

RECOMMENDATION #2: We recommend the Chicago VA Regional Office Director review 

all pending 810 work items to determine if medical reexaminations are required and take 

appropriate action. 

Response: Concur. We agree that additional attention is required to accurately control and 

process the 800-series work items for medical reexaminations. As part of our integration into 

the Lean Team model, we have amended our workload management plan specifically for 

800-series work items. Effective immediately, RVSRs will review the pending reevaluation 

work items on a monthly basis and take appropriate action to complete or clear the work item. 

RECOMMENDATION #3: We recommend the Chicago VA Regional Office Director 

implement oversight to ensure staff follows Veterans Benefits Administration guidance and the 

local workload management plans for reviewing 810 work items. 

Response: Concur. We agree that additional attention is required to accurately control and 

process the 810 work items. As part of our integration into the Lean Team model, we have 

VA Office of Inspector General 15 
Inspection of the VA Regional Office, Chicago, Illinois 

amended our workload management plan specifically for 810 work items. Effective 

immediately, VSRs will review the pending work items on a monthly basis and take appropriate 

action to complete or clear the work item. 

RECOMMENDATION #4: We recommend the Chicago VA Regional Office Director 

develop and implement a plan to monitor the effectiveness and adequacy of training provided in 

March 2011, on proper processing of disabilities related to traumatic brain injuries. 

Response: Concur. The Chicago RO conducted training on rating traumatic brain injuries (TBI) 

on March 17, 2011. This training, conducted by a DRO on the Quality Review Team, covered 

all aspects of TBI ratings, particularly including the VA examination requirements. The newly 

implemented 100% DRO review (discussed in the following paragraph) will allow us to monitor 

the effectiveness of this training. 

RECOMMENDATION #5: We recommend the Chicago VA Regional Office Director 

develop and implement a plan to improve accuracy and oversight of traumatic brain injury 

claims processing. 

Response: Concur. Effective May 6, 2011, all TBI ratings require a DRO second signature 

review until September 30, 2011, at which point the need for 100% review will be re-evaluated. 

Coaches will keep track of errors noted, and targeted training will be provided. DROs will 

provide feedback each month to the Appeals coach, who will disseminate the data and training 

needs to the leadership team. 

RECOMMENDATION #6: We recommend the Chicago VA Regional Office Director 

develop and implement a plan to ensure staff record Notices of Disagreement in the Veterans 

Appeals Control and Locator System within 7 days as required by Veterans Benefits 

Administration policy. 

Response: Concur. The existing Workload Management Plan dictates that VSRs on the 

Appeals Team will review and record Notices of Disagreement (NODs) into VACOLS. 

Effective April 1, 2011, in situations when the incoming NOD volume is too high for the VSRs 

to complete input within 7 days, the Appeals Claims Assistants will assist in entering NODs into 

VACOLS. The Appeals Coach will monitor the incoming NOD volume to ensure there are 

sufficient personnel to complete this action in the required timeframe. 

RECOMMENDATION #7: We recommend the Chicago VA Regional Office Director 

develop and implement a plan to ensure staff complete Systematic Analyses of Operations 

timely and address all required elements. 

Response: Concur. The SAO schedule has been updated and is being monitored for timely 

completion of SAOs. SAOs are being closely reviewed to ensure they contain all required 

elements. 

RECOMMENDATION #8: We recommend the Chicago VA Regional Office Director 

develop and implement a plan to ensure management oversight and control of search mail. 

VA Office of Inspector General 16 
Inspection of the VA Regional Office, Chicago, Illinois 

Response: Concur. As part of our integration into the Lean Team model, we have updated our 

existing Workload Management Plan. Effective April 4, 2011 (Lean Teams 1-2), and 

May 2, 2011 (Lean Teams 3-5), each individual Lean Team will maintain control of their own 

search mail. Search mail will be reviewed on a weekly basis to ensure that it is being properly 

consolidated with the claims folder and the appropriate development, rating, or promulgation 

action taken on the mail. 

VA Office of Inspector General 17 
Inspection of the VA Regional Office, Chicago, Illinois 

Appendix C Inspection Summary
 

Ten Operational 

Activities Inspected Criteria 

Reasonable 

Assurance of 

Compliance 

Yes No 

Claims Processing 

1. Temporary 

100 Percent 

Disability 

Evaluations 

Determine whether VARO staff properly reviewed temporary 100 percent 

disability evaluations. (38 Code of Federal Regulations (CFR) 3.103(b)) 

(38 CFR 3.105(e)) (38 CFR 3.327) (Manual (M) 21-1 Manual Rewrite (MR) 

Part IV, Subpart ii, Chapter 2, Section J) (M21-1MR Part III, Subpart iv, 

Chapter 3, Section C.17.e) 

X 

2. Post-Traumatic 

Stress Disorder 

Determine whether VARO staff properly processed claims for PTSD. 

(38 CFR 3.304(f)) X 

3. Traumatic Brain 

Injury 

Determine whether VARO staff properly processed service connection for 

all residual disabilities related to in-service TBI. (Fast Letter (FL) 08-34 and 

FL 08-36, Training Letter 09-01) 

X 

4. Herbicide Exposure Determine whether VARO staff properly processed claims for service 

connection for disabilities related to herbicide exposure. (38 CFR 3.309) 

(FL 02-33) (M21-1MR Part IV, Subpart ii, Chapter 2, Section C.10) X 

Data Integrity 

5. Dates of Claim Determine whether VARO staff properly recorded the correct dates of 

claim in the electronic record. (M21-1MR, Part III, Subpart ii, Chapter 1, 

Section C) 

X 

6. Notices of 

Disagreement 

Determine whether VARO staff properly entered NODs into VACOLS. 

(M21-1MR Part I, Chapter 5) X 

Management Controls 

7. Systematic 

Technical Accuracy 

Review 

Determine whether VARO staff properly corrected STAR errors in 

accordance with VBA policy. (M21-4, Chapter 3, Subchapter II, 3.03) X 

8. Systematic Analysis 

of Operations 

Determine whether VARO staff properly performed formal analyses of 

their operations through completion of SAOs. (M21-4, Chapter 5) X 

Workload Management 

9. Mail Handling 

Procedures 

Determine whether VARO staff properly followed VBA mail handling 

procedures. (M23-1) (M21-4, Chapter 4) (M21-1MR Part III, Subpart ii, 

Chapters 1 and 4) 

X 

Eligibility Determinations 

10. Competency 

Determinations 

Determine whether VAROs properly assessed beneficiaries’ mental capacity 

to handle VA benefit payments. (M21-1MR Part III, Subpart v, Chapter 9, 

Section A) (M21-1MR Part III, Subpart v, Chapter 9, Section B) (FL 09-08) 

X 

VA Office of Inspector General 18 
Inspection of the VA Regional Office, Chicago, Illinois 

Appendix D OIG Contact and Staff Acknowledgments 

OIG Contact For more information about this report, please contact the 

Office of Inspector General at (202) 461-4720. 

Acknowledgments	 Dawn Provost, Director 

Bridget Bertino 

Madeline Cantu 

Lee Giesbrecht 

Brian Jeanseau 

David Pina 

Dana Sullivan 

Brandi Traylor 

VA Office of Inspector General 19 
Inspection of the VA Regional Office, Chicago, Illinois 

Appendix E Report Distribution 

VA Distribution 

Office of the Secretary 

Veterans Benefits Administration 

Assistant Secretaries 

Office of General Counsel 

Veterans Benefits Administration Central Area Director 

VA Regional Office Chicago Director 

Non-VA Distribution 

House Committee on Veterans’ Affairs 

House Appropriations Subcommittee on Military Construction, Veterans 

Affairs, and Related Agencies 

House Committee on Oversight and Government Reform 

Senate Committee on Veterans’ Affairs 

Senate Appropriations Subcommittee on Military Construction, Veterans 

Affairs, and Related Agencies 

Senate Committee on Homeland Security and Governmental Affairs 

National Veterans Service Organizations 

Government Accountability Office 

Office of Management and Budget 

U.S. Senate: Richard Durbin, Mark Kirk
 

U.S. House of Representatives: Judy Biggert; Jerry Costello; Danny Davis;
 

Robert Dold; Luis Gutierrez; Randy Hultgren; Jesse Jackson, Jr.;
 

Timothy Johnson; Adam Kinzinger; Daniel Lipinski; Donald Manzullo;
 

Mike Quigley; Peter Roskam; Bobby Rush; Janice Schakowsky;
 

Robert Schilling; Aaron Schock; John Shimkus; Joe Walsh.
 

This report will be available in the near future on the OIG’s Web site at 

http://www.va.gov/oig/publications/reports-list.asp. This report will remain 

on the OIG Web site for at least 2 fiscal years. 

VA Office of Inspector General 20