Inspection of the
 

VA Regional Office
 

Des Moines, Iowa
 

OFFICE OF AUDITS AND EVALUATIONS

May 11, 2011 

11-00511-164 
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 Analyses of Operations 

STAR Systematic Technical Accuracy Review 

TBI Traumatic Brain Injury 

VACOLS Veterans Appeals Control and Locator System 

VARO VA 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, Des Moines, Iowa 

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 

Of the VAROs we have inspected since 

April 2009, the Des Moines VARO has 

exhibited one of the best accuracy rates for 

disability claims processing. The VARO 

correctly processed herbicide exposurerelated disability claims and established 

correct dates of claim in the electronic 

record. VARO performance was generally 

effective in processing post-traumatic stress 

disorder claims, correcting errors identified 

by the Veterans Benefits Administration’s 

Systematic Technical Accuracy Review 

program, and ensuring Systematic Analyses 

of Operations were timely and complete. 

However, VARO management lacked 

effective controls and accuracy in 

processing temporary 100 percent disability 

evaluations and traumatic brain injury 

claims. Overall, staff did not accurately 

process 11 (11 percent) of the 99 disability 

claims we reviewed. Controls also need 

strengthening to ensure timely processing of 

Notices of Disagreement for appealed 

claims, proper mail handling, and accuracy 

of final competency determinations. 

What We Recommended 

We recommended VARO management 

implement controls to ensure staff establish 

suspense diaries for the temporary 

100 percent disability reevaluations and 

follow up as appropriate. We also 

recommended management provide 

refresher training on proper procedures for 

processing traumatic brain injury claims and 

ensure staff return inadequate medical 

examination reports to the appropriate 

hospitals for correction. 

Additionally, we recommended VARO 

management strengthen controls to ensure 

timely establishment of Notices of 

Disagreement in the Veterans Appeals 

Control and Locator System. We also 

recommended management provide clear 

guidance on proper mail processing and 

ensure that staff obtain training on 

evaluating evidence required to make 

accurate competency determinations. 

Agency Comments 

The VARO Director concurred with our 

recommendations. Management’s planned 

actions are responsive and we will follow up 

as required on all actions. 

(original signed by:) 

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...........................................................................................................8
 

5. Eligibility Determinations.....................................................................................................10
 

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

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

Appendix C Inspection Summary..........................................................................................17 

Appendix D OIG Contact and Staff Acknowledgments........................................................18 

Appendix E Report Distribution ...........................................................................................19 

ii 
Inspection of the VA Regional Office, Des Moines, Iowa 

Objective
 

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 January 2011, the OIG conducted an inspection of the Des Moines 

VARO. The inspection focused on five protocol areas examining ten 

operational activities. The five protocol areas were disability claims 

processing, data integrity, management controls, workload management, and 

eligibility determinations. 

We reviewed 69 (16 percent) of 433 disability claims related to posttraumatic stress disorder (PTSD), traumatic brain injury (TBI), and herbicide 

exposure that the VARO completed from July through September 2010. In 

addition, we reviewed 30 (18 percent) of 165 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 Des Moines VARO and the scope of our 

inspection. Appendix B provides the Des Moines 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, Des Moines, Iowa 

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 

Of the VAROs we have inspected since April 2009, the Des Moines VARO 

has exhibited one of the best accuracy rates for disability claims processing. 

However, the VARO still needs to improve the accuracy of processing 

temporary 100 percent disability evaluations and TBI-related disability 

claims. VARO staff incorrectly processed 11 (11 percent) of the total 

99 disability claims reviewed. We advised VARO management regarding 

the inaccuracies noted during our inspection and they initiated corrective 

measures to address them. The table below reflects the errors affecting, and 

those with the potential to affect, veterans’ benefits processed at the Des 

Moines 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 8 3 5 

PTSD 30 1 0 1 

TBI 9 2 1 1 

Herbicide 

Exposure-Related 

Claims 

30 0 0 0 

Total 99 11 4 7 

VA Office of Inspector General 2 
Inspection of the VA Regional Office, Des Moines, Iowa 

Temporary 

100 Percent 

Disability 

Evaluations 

VARO staff incorrectly processed 8 (27 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 needing surgery or specific 

treatment. At the end of a mandated period of convalescence or cessation of 

treatment, VARO staff must request a follow-up medical examination to help 

determine whether to continue the veteran’s 100 percent disability benefits. 

Based on analysis of available medical evidence, 3 of the 8 processing 

inaccuracies identified affected veterans’ benefits and involved 

overpayments totaling $415,648. The most significant overpayment 

occurred when VARO staff did not schedule a medical reexamination in 

October 2004 as required. Our review of VA treatment records revealed 

medical evidence that the veteran’s condition had improved and he was no 

longer entitled to receive temporary 100 percent disability benefits. As a 

result, the veteran was overpaid $201,431 over a period of 5 years and 

10 months. 

The remaining five inaccuracies had the potential to affect veterans’ benefits. 

In four of these cases, VSC staff did not establish or improperly cancelled 

reminder notifications in the electronic record. These notifications ensure 

staff are alerted when future reexaminations must be scheduled. In the 

remaining case, VSC staff did not schedule a required reexamination to 

assess the veteran’s disability. We could not determine if these five 

temporary 100 percent disability evaluations would have continued because 

the veterans’ claims folders did not contain the medical examination reports 

needed to reevaluate each case. 

The delays in scheduling the reexaminations ranged from 1 year and 

2 months to 6 years and 4 months. An average of 2 years and 11 months 

elapsed from the time staff should have scheduled these medical 

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

took corrective actions to obtain the necessary medical evidence. 

For temporary 100 percent disability evaluations, including confirmed and 

continued evaluations where rating decisions do not change veterans’ 

payment amounts, VSC staff must input suspense diaries in VBA’s 

electronic system. A diary is a processing command that establishes a date 

when VSC staff must schedule a reexamination. As the diary matures, the 

electronic system generates a reminder notification alerting VSC staff to 

schedule a reexamination. 

The most common processing errors occurred when VARO staff did not 

properly establish suspense diaries for future VA reexaminations. VSC 

management stated, and we verified, the VARO did not have a procedure in 

place requiring VSC staff to review confirmed and continued rating 

VA Office of Inspector General 3 
Inspection of the VA Regional Office, Des Moines, Iowa 

PTSD Claims 

TBI Claims 

Herbicide 

Exposure- Related 

Claims 

Recommendations 

decisions mandating future reexaminations. Because staff did not schedule 

reexaminations as required, veterans did not always receive correct benefit 

payments. 

VARO staff incorrectly processed 1 (3 percent) of 30 PTSD claims. In this 

case, the Rating Veterans Service Representative (RVSR) prematurely 

granted service connection for PTSD using an inadequate medical 

examination report instead of returning the report to the hospital for 

correction as required. We did not consider the frequency of errors 

significant, so we made no recommendations for improvement in this area. 

The Department of Defense and VBA commonly define a TBI as 

traumatically induced structural injury or 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. 

VARO staff incorrectly processed two (22 percent) of nine TBI claims we 

reviewed. In both cases, RVSRs incorrectly evaluated TBI residual 

disabilities by using veterans’ subjective complaints instead of the VA 

examiners’ medical opinions. As a result, VA overpaid one veteran 

$2,985 over a period of 1 year and 3 months. In the other case, this 

inaccuracy did not affect the veteran’s current 50 percent disability 

evaluation, but has the potential to affect future evaluations for additional 

benefits. 

VARO management stated these errors were due to a lack of understanding 

of TBI evaluation procedures and staff’s reluctance to seek clarification in 

cases where examination results were incomplete or inadequate. VARO staff 

indicated the process of returning inadequate medical examinations was time 

consuming. This led to the two RVSRs using their own interpretation of 

medical examination results to decide TBI claims instead of those provided 

by medical professionals. As a result, veterans did not always receive 

accurate benefits payments. 

In accordance with VBA policy, VARO staff correctly processed all 

30 herbicide exposure-related disability claims we reviewed. We made no 

recommendations for improvement in this area. 

1.	 We recommend the Des Moines VA Regional Office Director implement 

controls to ensure staff establish suspense diaries for temporary 

100 percent disability reevaluations. 

2.	 We recommend the Des Moines VA Regional Office Director ensure 

Rating Veteran Service Representatives receive refresher training on the 

proper evaluation of disabilities related to traumatic brain injuries. 

VA Office of Inspector General 4 
Inspection of the VA Regional Office, Des Moines, Iowa 

Management 

Comments 

OIG Response 

3. We recommend the Des Moines VA Regional Office Director develop 

and implement a plan to ensure VARO staff return inadequate medical 

examination reports to the appropriate VA medical facilities for 

correction. 

The VARO Director concurred with our recommendations related to 

improving disability claims processing. The Director informed us that 

RVSRs received refresher training on properly rating TBI injuries, 

requesting TBI medical examinations, and identifying and returning 

inadequate VA medical examinations for correction. This training occurred 

during March 2011. In addition, the Director designated a VA Medical 

Center Liaison to manage the return of Compensation and Pension medical 

examinations identified as inadequate. 

The VARO Director’s comments and planned actions are responsive to our 

recommendations for improving disability claims processing. We will 

follow up as required on all actions. 

A draft of this inspection report included an additional recommendation that 

the VA Regional Office Director review the remaining temporary 

100 percent disability evaluations identified but not included in our 

inspection sample to determine if reevaluations are required and take 

appropriate action. We have removed the recommendation, from this 

individual VARO inspection report, since 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). 

The Acting Under Secretary for Benefits agreed to review all temporary 100 

percent disability evaluations and ensure each evaluation has a future exam 

date entered in the electronic record. The Acting Under Secretary explained 

that VBA’s national review plan entails use of three medical diagnostic 

codes to comprise a sample for testing whether future examination dates are 

established in the electronic record. Those diagnostic codes relate to NonHodgkin’s Lymphoma, Malignant Neoplasms of the Genitourinary System, 

and Post-traumatic Stress Disorder. Further, the Acting Under Secretary 

stated, “the remainder of the cases will be identified through a batch process, 

and VBA will establish the appropriate future diary controls electronically.” 

While the Acting Under Secretary for Benefits’ national review plan differs 

from the approach we previously recommended in a draft of this VARO 

inspection report, we believe the intent is the same. Removing the 

recommendation from our draft inspection report allows VBA time to 

implement its national plan for reviewing all temporary 100 percent 

disability evaluations to correct processing errors, with a target completion 

date of September 30, 2011, as the Acting Under Secretary for Benefits 

VA Office of Inspector General 5 
Inspection of the VA Regional Office, Des Moines, Iowa 

Effective Dates 

Dates of Claim 

Notices of 

Disagreement 

previously indicated. We nonetheless are requesting that VBA’s Office of 

Field Operations provide a copy of both VBA’s national review plan for 

sample testing using the diagnostic codes specified above, as well as a 

documented explanation of its batch process for identifying the remaining 

cases and establishing appropriate future diary controls electronically. Such 

information will enable us to monitor implementation progress and gauge 

effectiveness of VBA’s national review plan approach as we move forward 

in conducting our individual VARO inspections. Based on the magnitude of 

errors and associated financial risks we have identified in temporary 100 

percent disability evaluation processing to date, we have an ongoing 

responsibility to exercise continued oversight in this area. 

2. Data Integrity 

We reviewed claims folders to determine if the VARO was following VBA 

policy on establishing effective dates in the electronic record. Generally, an 

effective date indicates when entitlement to a specific benefit arose. VARO 

staff followed VBA policy and correctly established effective dates for all 

99 disability claims we reviewed. As such, we made no recommendation for 

improvement in this area. 

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

policy on establishing dates of claim in electronic record. VBA generally 

uses the 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. VARO staff 

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

30 claims reviewed. As such, we made no recommendation for improvement 

in this area. 

We reviewed claims folders to determine if the VARO was timely recording 

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 veterans’ appeals 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. 

VA Office of Inspector General 6 
Inspection of the VA Regional Office, Des Moines, Iowa 

Finding 2
 

Recommendation 

Management 

Comments 

OIG Response 

Controls Over Recording Notices of Disagreement 

Need Strengthening 

The VSC did not have controls in place to ensure staff recorded NODs in 

VACOLS within VBA’s 7-day standard. The VSC had not trained all 

Claims Assistants on the proper use of VACOLS to timely record incoming 

appeals-related mail. Untimely recording of NODs in VACOLS affects data 

integrity and misrepresents VARO performance. 

The VARO exceeded VBA’s 7-day standard for 5 (17 percent) of the 

30 NODs we reviewed. It took staff an average of 17 days to record these 

5 NODs in VACOLS. These delays ranged from 11 to 34 days. As of 

December 31, 2010, VBA performance reports showed the average time for 

the Des Moines VARO to complete an NOD was 283 days, 44 days worse 

than the national average of 239 days. 

Prior to September 2010, the Appeals Team had two Claim Assistants 

assigned to process NODs. However, in September 2010 one Claim 

Assistant transferred to another office, leaving the team with one trained 

employee. Because of the vacancy, the VSC was unable to record NODs 

timely. To compensate for the personnel shortage, other Appeals Team 

employees volunteered to help the Claim Assistant record NODs in 

VACOLS. Claim Assistants assigned to other teams could not help because 

they were not familiar with how to use VACOLS or process NODs. 

Data integrity issues such as untimely recording of NODs in VACOLS make 

it difficult for VARO and senior VBA leadership to accurately measure and 

monitor VARO performance. Further, VBA’s National Call Centers rely 

upon accurate VACOLS information to provide quality customer service to 

veterans. Unnecessary delays in controlling NODs affect national 

performance measures for NOD inventory and timely appeals completion. 

4.	 We recommend the Des Moines VA Regional Office Director develop a 

plan to train all Claim Assistants on the proper procedures for processing 

appeals-related mail and timely entering Notices of Disagreement in the 

Veterans Appeals Control and Locator System. 

The VARO Director concurred with our recommendation. The Director 

informed us all Claims Assistants received training on the proper procedures 

for processing appeals-related mail in January and April 2011. 

Management’s comments and actions are responsive to the recommendation 

and we will follow up as required on all actions. 

VA Office of Inspector General 7 
Inspection of the VA Regional Office, Des Moines, Iowa 

Systematic 

Technical 

Accuracy 

Review 

Systematic 

Analyses of 

Operations 

Mail Room 

Operations 

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 that veterans and 

other beneficiaries receive accurate and consistent compensation and pension 

benefits. VBA policy requires that VAROs take corrective action on errors 

that STAR staff identify. In general, VARO staff followed VBA policy 

regarding the correction of STAR errors. 

VARO staff did not correct 1 (4 percent) of 23 errors identified by VBA’s 

STAR program staff. In this instance, VARO staff erroneously reported to 

STAR that they had completed the corrective action identified by STAR 

program staff. We did not consider the error rate significant, so we made no 

recommendation 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 a VSC 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 an annual SAO schedule 

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

The Des Moines VARO management generally followed VBA policy by 

ensuring SAOs were timely and complete. Our analysis revealed VARO 

staff did not timely complete 1 (8 percent) of 12 required SAOs according to 

their annual schedule. Specifically, VSC management delayed completing 

the Quality of Developmental Activity SAO by 64 days. Management did 

not submit to the VARO Director a request for an extension to complete this 

SAO until two months after the initial deadline passed. We did not consider 

the error rate significant, so we made no recommendation for improvement 

in this area. 

4. Workload Management 

We assessed controls over mailroom operations to ensure VARO 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 Des Moines VARO assigns responsibility for 

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

Services Division. Because VARO mailroom staff processed, date stamped, 

and delivered all VSC mail to the Triage Team daily as required, we made no 

recommendation for improvement in this area. 

VA Office of Inspector General 8 
Inspection of the VA Regional Office, Des Moines, Iowa 

Triage Mail 

Processing 

Procedures 

Finding 3
 

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

staff reviewed, controlled, and processed all claims-related mail. VBA 

policy indicates that oversight to ensure staff use available plans and systems 

is the most important part of workload management. It also states that 

effective mail management is crucial to the success and control of workflow 

within the VSC. 

VBA policy requires that staff use the Control of Veterans Records System 

(COVERS), an electronic tracking system, to track claims folders and search 

mail. VBA defines search mail as active claims-related mail waiting to be 

associated with a veteran’s claim folder. 

VSC Mail Procedures Need Strengthening 

The Triage Team did not always control and process active claims-related 

mail according to VBA policy. This occurred because management did not 

provide clear guidance to ensure staff processed and controlled mail 

properly. As a result, staff unnecessarily delayed processing veterans’ 

claims. 

For 7 (23 percent) of 30 pieces of active claims-related mail reviewed, staff 

did not properly use COVERS to ensure timely processing and adequate 

control of mail. For example, staff delayed processing one claim by 

135 days because they did not place the mail on search in COVERS upon 

receipt at the VARO. VSC staff were unaware of this claim until we 

identified it during our inspection. Additionally, VSC staff did not remove 

32 electronic notifications in COVERS when staff associated claims-related 

mail with veterans’ claims folders. 

In an attempt to improve mail processing VSC management removed the 

previously designated search mail point, thereby changing procedures for 

processing search mail. However, management did not modify the Mail Plan 

to designate the new location for storing and controlling search mail or 

provide instructions on how staff should implement the new procedures. A 

VSC supervisor stated this change confused staff. In some instances, staff 

temporarily stored search mail at their workstations or other locations 

because they were not sure where else to put it. 

Additionally, the Mail Plan provided conflicting guidance to staff regarding 

responsibility for deleting electronic notifications in COVERS when no 

longer needed. In one section of the plan, management indicated every 

employee had the responsibility to delete electronic notifications once they 

obtained the search mail. In another section, management gave employees 

the option to print the electronic notification and provide it to supervisors to 

remove the electronic notifications from COVERS. VSC management 

VA Office of Inspector General 9 
Inspection of the VA Regional Office, Des Moines, Iowa 

Recommendation 

Management 

Comments 

OIG Response 

Competency 

Determinations 

agreed the search mail procedures were not clear and that oversight of this 

process needed improvement. 

5.	 We recommend the Des Moines VA Regional Office Director amend the 

Mail Plan to provide clear, updated guidance and delineation of 

responsibilities for controlling search mail and deleting electronic 

notifications in the Control of Veterans Records System. 

The VARO Director concurred with our recommendation and revised the 

Mail Management Plan in February 2011. Management ensured the Mail 

Plan provided proper guidance and delineation of responsibilities for 

controlling search mail and deleting electronic notifications in the Control of 

Veterans Records System. 

Management’s comments and actions are responsive to the recommendation 

and we will follow up as required on all actions. 

5. Eligibility Determinations 

We reviewed competency determinations completed by the VSC Decision 

Team to ensure staff completed them accurately and timely. Delays in 

making these determinations ultimately affect the Fiduciary Unit’s ability to 

be timely in appointing fiduciaries. 

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 that assists in managing funds 

for an incompetent beneficiary. 

VBA policy requires staff to obtain clear and convincing medical evidence 

that a beneficiary is incapable of managing his or her affairs prior to making 

a final competency decision. The policy allows the beneficiary a 65-day due 

process period to submit the evidence showing an ability to manage funds 

and other personal affairs. At the end of the due process period, VARO staff 

must take immediate action to determine if the beneficiary is competent. 

In the absence of a definition of “immediate”, we allowed 14 calendar days 

after the due process period to determine if VARO staff timely completed a 

competency decision. We considered this a reasonable period to control, 

prioritize, and finalize these types of cases. Our analysis revealed VARO 

staff timely processed all 11 competency determinations we reviewed. 

Therefore, we made no recommendation for improving timeliness in 

processing competency determinations. 

VA Office of Inspector General 10 
Inspection of the VA Regional Office, Des Moines, Iowa 

Finding 4
 

Recommendation 

Management 

Comments 

OIG Response 

VARO Staff Need to Improve Accuracy in Processing 

Competency Determinations 

VARO staff did not always accurately process competency determinations. 

These errors occurred because VSC staff misinterpreted VBA policy and did 

not obtain medical evidence to support court determinations of veterans’ 

incompetency as required. As a result, veterans were determined to be 

incompetent and denied the ability to manage their funds independently even 

though such decisions may have been unwarranted. 

VBA policy states that when a court finds a veteran incompetent, the VARO 

must obtain additional medical evidence to support the court’s incompetency 

determination. VBA policy requires review of all medical evidence related 

to incompetency prior to making a final competency determination. Judicial 

findings of a court with respect to the competency of a veteran are not 

binding upon VBA decisions. They are compelling evidence, but not the 

only deciding factor. 

Our analysis revealed 2 (18 percent) of 11 competency determinations we 

reviewed contained processing inaccuracies. In both cases, VARO staff 

determined the veterans were incompetent based solely upon court decrees of 

incompetency. Instead, VARO staff should have requested medical evidence 

before making these determinations and assigning fiduciaries to manage the 

veterans’ affairs. VARO management agreed with our assessment that the 

decisions in both cases were premature and initiated corrective actions to 

obtain the required medical evidence to determine if the veterans were 

incompetent. 

6.	 We recommend the Des Moines VA Regional Office Director ensure 

Rating Veterans Service Representatives receive refresher training on 

evaluating evidence required to make accurate competency 

determinations. 

The VARO Director concurred with our recommendation and informed us 

that on April 20, 2011, Rating Veterans Service Representatives received 

training on evaluating evidence to make accurate competency 

determinations. 

Management’s comments and actions are responsive to the recommendation 

and we will follow up as required on all actions. 

VA Office of Inspector General 11 
Inspection of the VA Regional Office, Des Moines, Iowa 

Appendix A 

Organization 

Resources 

Workload 

Scope 

VARO Profile and Scope of Inspection 

The Des Moines VARO is responsible for delivering non-medical VA 

benefits and services to veterans and their families in Iowa. The VARO 

fulfills these responsibilities by administering compensation and pension 

benefits, vocational rehabilitation and employment assistance, and outreach 

activities. 

As of January 2011, the Des Moines VARO had a staffing level of 131 fulltime employees. Of these, the VSC had 105 employees (80 percent) 

assigned. 

As of December 2010, the VARO reported 4,780 pending compensation 

claims. The average time to complete these claims was 174 days—1 day 

better than the national target of 175 days. As reported by STAR, accuracy 

of compensation rating-related issues was 90.4 percent, or .4 percent above 

the 90 percent target set by VBA. 

We reviewed selected management controls, claims processing, and 

administrative activities to evaluate compliance with VBA policies regarding 

delivery of benefits and non-medical services to veterans and other 

beneficiaries. We interviewed managers and employees and reviewed 

veterans’ claims folders. 

Our review included 69 (16 percent) of 433 disability claims related to 

PTSD, TBI, and herbicide exposure that the VARO completed from July to 

September 2010. For temporary 100 percent disability evaluations, we 

selected 30 (18 percent) of 165 existing claims from VBA’s Corporate 

Database. We provided the VARO with the 135 claims remaining from the 

universe of 165 to assist in implementing our first report recommendation. 

These claims represented instances in which staff granted temporary 

100 percent disability determinations for at least 18 months. 

We reviewed 23 errors identified by VBA’s STAR program during the 

period of July to September 2010. VBA measures the accuracy of 

compensation and pension claims processing through its STAR program. 

STAR measurements include a review of work associated with claims 

requiring rating decisions. STAR staff review original claims, reopened 

claims, and claims for increased evaluations. Further, they review appellate 

issues that involve a myriad of veterans’ disabilities claims. 

Our process differs from STAR as we review specific types of disability 

claims such as PTSD, TBI, and herbicide exposure that require rating 

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

involving temporary 100 percent disability claims. 

VA Office of Inspector General 12 
Inspection of the VA Regional Office, Des Moines, Iowa 

We selected for review dates of claim and NODs 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. 

VA Office of Inspector General 13 
Inspection of the VA Regional Office, Des Moines, Iowa 

Appendix B VARO Director’s Comments 

Department of Memorandum Veterans Affairs 

Date: April 15, 2011 

From: Director, VA Regional Office Des Moines 

Subj: Inspection of the VA Regional Office, Des Moines, Iowa 

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

1.	 Attached are the Des Moines VARO’s comments on the OIG Draft 

Report: Inspection of the VA Regional Office, Des Moines, Iowa. 

2.	 Questions may be referred to Gregory Reed, Acting Director at 515-323­

7503. 

(original signed by:) 

Gregory C. Reed 

Attachment 

VA Office of Inspector General 14 
Inspection of the VA Regional Office, Des Moines, Iowa 

Des Moines VA Regional Office
 

Response to the OIG
 

Benefits Inspection Division
 

Draft Report of the Des Moines Regional Office
 

Recommendation 1 - We recommend the Des Moines VA Regional Office Director review the 

remaining 135 temporary 100 percent disability evaluations identified but not included in our 

inspection sample to determine if reevaluations are required and take appropriate action. 

Non-Concur with recommendation 

Response: We do not believe this recommendation is necessary or appropriate. 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. 

Recommendation 2 - We recommend the Des Moines VA Regional Office Director implement 

controls to ensure staff establish suspense diaries for temporary 100 percent disability 

reevaluations. 

Concur with recommendation 

Response: 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. 

Recommendation 3 - We recommend the Des Moines VA Regional Office Director ensure 

Rating Veterans Service Representatives receive refresher training on the proper evaluation of 

disabilities related to traumatic brain injuries. 

Concur with recommendation 

Response: Rating Veterans Service Representatives received refresher training on Rating TBI 

Injuries (LMS 1209939) and TBI Exam Requests (LMS 1209934) on March 16, 2011. 

Recommendation 4 - We recommend the Des Moines VA Regional Office Director develop 

and implement a plan to ensure VARO staff return inadequate medical examination reports to 

the appropriate VA medical facilities for correction. 

Concur with recommendation 

Response: Training on TBI Exam Requests was delivered on March 16, 2011 and was intended 

to improve the staff’s ability to identify and return inadequate VA examinations. In addition, the 

Des Moines Service Center has a designated VA Medical Center Liaison who is responsible for 

managing the return of C&P exams deemed insufficient by Veterans Service Representatives, 

Rating Veterans Service Representatives, and Decision Review Officers. 

VA Office of Inspector General 15 
Inspection of the VA Regional Office, Des Moines, Iowa 

Recommendation 5 - We recommend the Des Moines VA Regional Office Director develop a 

plan to train all Claim Assistants on the proper procedures for processing appeals-related mail 

and timely entering Notices of Disagreement in the Veterans Appeals Control and Locator 

System. 

Concur with recommendation 

Response: Training on the proper procedures for processing appeals-related mail and timely 

entering Notices of Disagreement in the Veterans Appeals Control and Locator System was held 

on January 5, 2011 with Claims Assistants assigned to the Appeals Team. Training for all 

Claims Assistants was held on April 6, 2011. Claims Assistants have been instructed to bring 

any new NOD pending establishment greater than seven days to the supervisor’s attention to 

determine the cause for the discrepancy. 

Recommendation 6 - We recommend the Des Moines VA Regional Office Director amend the 

Mail Plan to provide clear, updated guidance and delineation of responsibilities for controlling 

search mail and deleting electronic notifications in the Control of Veterans Records System. 

Concur with recommendation 

Response: The Mail Management Plan was revised effective Feb 1, 2011 to provide proper 

guidance and delineation of responsibilities for controlling search mail and deleting electronic 

notifications in COVERS. 

Recommendation 7 - We recommend the Des Moines VA Regional Office Director ensure 

Rating Veterans Service Representatives receive refresher training on evaluating evidence 

required to make accurate competency determinations. 

Concur with recommendation 

Response: Refresher training for Rating Veterans Service Representatives on evaluating 

evidence to make accurate competency determinations is scheduled for April 20, 2011. 

VA Office of Inspector General 16 
Inspection of the VA Regional Office, Des Moines, Iowa 

Appendix C Inspection Summary
 

10 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 CFR 3.103(b)) (38 CFR 3.105(e)) (38 CFR 3.327) 

(M21-1MR 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 claims for service connection for all residual disabilities 

related to in-service TBI were properly processed. (Fast Letters 08-34 and 

08-36, Training Letter 09-01) 

X 

4. Herbicide 

Exposure-Related 

Claims 

Determine whether VARO staff properly processed claims for service 

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

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

Data Integrity 

5. Date of Claim Determine whether VARO staff properly recorded dates of claim in the 

electronic records. (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 Analyses 

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) (Fast Letter 09­

08) 

X 

CFR=Code of Federal Regulations, M=Manual, MR=Manual Re-write 

VA Office of Inspector General 17 
Inspection of the VA Regional Office, Des Moines, Iowa 

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	 Brent Arronte, Director 

Kristine Abramo 

Daphne Brantley 

Robert Campbell 

Madeline Cantu 

Danny Clay 

Lee Giesbrecht 

Mark Ward 

VA Office of Inspector General 18 
Inspection of the VA Regional Office, Des Moines, Iowa 

Appendix E Report Distribution 

VA Distribution 

Office of the Secretary 

Veterans Benefits Administration 

Assistant Secretaries 

Office of General Counsel 

Veterans Benefits Administration’s Central Area Director 

VA Regional Office Des Moines 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: Charles Grassley, Tom Harkin 

U.S.	 House of Representatives: Leonard Boswell, Bruce L. Braley, Steve 

King, David Loebsack, Tom Latham 

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 19