United States Government Accountability Office

GAO Report to Congressional Committees

MILITARY AND 

VETERANS 

DISABILITY SYSTEM 

Pilot Has Achieved 

Some Goals, but 

Further Planning and 

Monitoring Needed 

December 2010 

GAO-11-69 
 United States Government Accountability Office 

Accountability • Integrity • Reliability 

Highlights of GAO-11-69, a report to 

congressional committees 

December 2010 

MILITARY AND VETERANS DISABILITY 

SYSTEM 

Pilot Has Achieved Some Goals, but Further Planning

and Monitoring Needed 

Why GAO Did This Study 

Since 2007, the Departments of 

Defense (DOD) and Veterans Affairs 

(VA) have been testing a new 

disability evaluation system designed 

to integrate their separate processes 

and thereby expedite veterans’ 

benefits for wounded, ill, and injured 

servicemembers. Having piloted the 

integrated disability evaluation 

system (IDES) at 27 military facilities, 

they are now planning for its 

expansion military-wide. 

Part of the National Defense 

Authorization Act for Fiscal Year 

2008 required GAO to report on DOD 

and VA’s implementation of policies 

on disability evaluations. This report 

examines: (1) the results of the 

agencies’ evaluation of the IDES 

pilot, (2) challenges in implementing 

the IDES pilot to date, and (3) 

whether DOD and VA’s plans to 

expand the IDES adequately address 

potential future challenges. GAO 

analyzed data from DOD and VA, 

conducted site visits at 10 military 

facilities, and interviewed DOD and 

VA officials. 

What GAO Recommends 

GAO is making several 

recommendations to improve DOD 

and VA’s planning for expansion of 

the new disability evaluation system, 

including developing a systematic 

monitoring process and ensuring that 

adequate staff is in place. DOD and 

VA generally concurred with GAO’s 

recommendations and provided 

technical comments that GAO 

incorporated into the report as 

appropriate. 

What GAO Found 

In their evaluation of the IDES pilot as of February 2010, DOD and VA 

concluded that it had improved servicemember satisfaction relative to the 

existing “legacy” system and met their established goal of delivering VA 

benefits to active duty and reserve component servicemembers within 295 and 

305 days, respectively, on average. While these results are promising, average 

case processing times have steadily increased since the February 2010 

evaluation. At 296 days for active duty servicemembers, as of August 2010, 

processing time for the IDES is still an improvement over the 540 days that 

DOD and VA estimated the legacy process takes to deliver VA benefits to 

members. However, the full extent of improvement of the IDES over the 

legacy system is unknown because (1) the 540-day estimate was based on a 

small, nonrepresentative sample of cases and (2) limitations in legacy case 

data prevent a comprehensive comparison of timeliness, as well as appeal 

rates. 

Piloting of the IDES has revealed several implementation challenges that have 

contributed to delays in the process, the most significant being insufficient 

staffing by DOD and VA. Staffing shortages were severe at a few pilot sites 

that experienced caseload surges. For example, at one of these sites, due to a 

lack of VA medical staff, it took 140 days on average to complete one of the 

key features of the pilot—the single exam—compared with the agencies’ goal 

to complete this step of the process in 45 days. The single exam posed other 

challenges that contributed to process delays, such as exam summaries that 

did not contain sufficient information for VA to determine the 

servicemember’s benefits and disagreements between DOD and VA medical 

staff about diagnoses for servicemembers’ medical conditions. Cases with 

these problems were returned for further attention, adding time to the 

process. Pilot sites also experienced logistical challenges, such as 

incorporating VA staff at military facilities and housing and managing 

personnel going through the process. 

As DOD and VA prepare to expand the IDES worldwide, they have made 

preparations to address a number of these challenges, but these efforts have 

yet to be tested, and not all challenges have been addressed. To address 

staffing shortages and ensure timely processing, VA is developing a contract 

for additional medical examiners, and DOD and VA are requiring local staff to 

develop written contingency plans for handling surges in caseloads. However, 

the agencies lack strategies for meeting some key challenges, such as ensuring 

enough military physicians to handle anticipated workloads. They also do not 

have a comprehensive monitoring plan for identifying problems as they 

occur—such as staffing shortages and insufficiencies in medical exams—in 

order to take remedial actions as early as possible. 

View GAO-11-69 or key components. 

For more information, contact Daniel Bertoni 

at (202) 512-7215 or bertonid@gao.gov. 
Page i GAO-11-69 

Contents 

Letter 1

Background 3 

Pilot Evaluation Results Are Promising, but the Degree of 

Improvement Achieved Is Unknown 11 

Pilot Sites Experienced Several Challenges 18 

DOD and VA Expansion Plans Address Some Though Not All 

Challenges 34 

Conclusions 39 

Recommendations for Executive Action 41 

Agency Comments and Our Evaluation 42 

Appendix I Objectives, Scope, and Methodology 46 

Appendix II IDES Pilot Processing Times for Reserve Component 

Servicemembers 54 

Appendix III Comments from the Department of Defense 59 

Appendix IV Comments from the Department of Veterans Affairs 62 

Appendix V GAO Contact and Staff Acknowledgments 65 

Tables 

Table 1: Military Treatment Facilities Piloting the IDES 10 

Table 2: Percentage of Legacy Cases with Referral and Appeal 

Dates, by Military Service 50 

Table 3: Percentage of Legacy Cases with Data Used for DOD 

Comparisons, by Military Service 50 

Table 4: Selected Characteristics of IDES Pilot Sites Visited 52 

Table 5: Percentage of Legacy Cases with Data Used for 

Comparison of Time in Active Duty, by Military Service 53 

 DOD and VA Disability Evaluation 
Page ii GAO-11-69 DOD and VA Disability Evaluation 

Figures 

Figure 1: Overview of the Legacy and IDES Processes 7 

Figure 2: Timeliness Goals for the Steps of the IDES Process 9 

Figure 3: Average Case Processing Times and Changes in Active 

Caseload by Location at Least 1 Year After 

Implementation and in August 2010 14 

Figure 4: Active Duty IDES Case Processing Times by Service, as of 

August 29, 2010 15 

Figure 5: Percentage of IDES Active Duty Cases Completed in 295 

Days or Less by Service, as of February 2010 15 

Figure 6: Army Servicemember IDES and Legacy Appeal Rates, as 

of early 2010 17 

Figure 7: Single Exam Processing Time for Active Duty 

Servicemembers at IDES Pilot Sites, as of August 29, 2010 20 

Figure 8: MEB Processing Times for Active Duty Servicemembers 

at IDES Pilot Sites, as of August 29, 2010 22 

Figure 9: Informal PEB Processing Times for Active Duty 

Servicemembers in the IDES Pilot, by Military Service, as 

of August 29, 2010 23 

Figure 10: Average Cases per DOD Board Liaison at IDES 

Pilot Sites 26 

Figure 11: Average Number of Days to Deliver VA Benefits for 

Reserve Component Servicemembers, by Military Service, 

as of August 29, 2010 54 

Figure 12: Percentage of Cases Meeting 305-Day Goal for Delivery 

of VA Benefits to Reserve Component Servicemembers, 

by Military Service, as of February 2010 55 

Figure 13: Average Number of Days to Complete Single Exams for 

Reserve Component Servicemembers, by IDES Pilot Site, 

as of August 29, 2010 56 

Figure 14: Average Number of Days to Complete MEB 

Documentation for Reserve Component Servicemembers, 

by IDES Pilot Site, as of August 29, 2010 57 

Figure 15: Average Number of Days to Complete the Informal PEB 

for Reserve Component Servicemembers, by Military 

Service, as of August 29, 2010 58 
Abbreviations 

DOD Department of Defense 

IDES integrated disability evaluation system 

IT information technology 

MEB medical evaluation board 

NDAA National Defense Authorization Act 

PEB physical evaluation board 

PTSD posttraumatic stress disorder 

VA Department of Veterans Affairs 

VBA Veterans Benefits Administration 

VHA Veterans Health Administration 

VTA Veterans Tracking Application 

WWCTP Office of the Deputy Under Secretary of Defense for 

Wounded Warrior Care & Transition Policy 

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page iii GAO-11-69 DOD and VA Disability Evaluation
 

Page 1 GAO-11-69 

United States Government Accountability Office

Washington, DC 20548 

December 6, 2010 

Congressional Committees 

Over 40,000 servicemembers have been wounded in the wars in Iraq and 

Afghanistan, as of October 2010. After receiving medical treatment, many 

wounded servicemembers must navigate a complex disability evaluation 

system that begins with the Department of Defense (DOD) determining 

whether they are medically fit to continue their military service. If they are 

found unfit, servicemembers continue through the system to obtain a 

determination of their eligibility for military disability benefits. Once 

servicemembers are discharged from the military, they may also be eligible 

to receive disability benefits from the Department of Veterans Affairs 

(VA), but they must first undergo an entirely separate VA disability 

evaluation process. A series of articles in 2007 by The Washington Post

concerning conditions at Walter Reed Army Medical Center, and 

subsequent reports from numerous high-level commissions and review 

groups, highlighted problems with the DOD and VA disability evaluations 

systems.1

 These included long delays, duplication in DOD and VA 

processes, confusion among servicemembers, and distrust of systems 

regarded as adversarial by servicemembers and veterans. 

In response to these concerns, DOD and VA jointly designed a new 

disability evaluation system that integrates DOD and VA processes, with 

the goal of expediting the delivery of benefits to servicemembers. DOD 

and VA began pilot testing the integrated disability evaluation system 

(IDES) in November 2007 at three Washington, D.C., area military 

treatment facilities and, by March 2010, added 24 more facilities to the 

pilot. DOD and VA are now planning to expand the piloted system to 28 

additional facilities, as a first step toward replacing the military’s 

existing—or “legacy”—disability evaluation system with the IDES 

worldwide. 

 

1

These studies include Independent Review Group, Rebuilding the Trust: Report on

Rehabilitative Care and Administrative Processes at Walter Reed Army Medical Center

and National Naval Medical Center (Arlington, Va.: April 2007); Task Force Report to the 

President: Returning Global War on Terror Heroes (April 2007); President’s Commission on 

Care for America’s Returning Wounded Warriors, Serve, Support, Simplify (July 2007); 

Department of the Army, Office of the Inspector General, Report on the Army Physical

Disability Evaluation System (Washington, D.C.: Mar. 6, 2007); GAO, Military Disability

System: Increased Supports for Servicemembers and Better Pilot Planning Could Improve

the Disability Evaluation Process, GAO-08-1137 (Washington, D.C.: Sept. 24, 2008). 

 DOD and VA Disability Evaluation 
 

In January 2008, Congress enacted the National Defense Authorization Act 

for Fiscal Year 2008 (NDAA 2008) requiring DOD and VA, to the extent 

feasible, to jointly develop and implement a comprehensive policy on 

improvements to the care, management, and transition of recovering 

servicemembers, including improvements to the agencies’ disability 

evaluation systems.2

 The NDAA 2008 also required GAO to report on the 

progress DOD and VA have made in developing and implementing the 

comprehensive policy.3

 In agreement with cognizant congressional staff, 

we reviewed DOD and VA’s progress in implementing policies related to 

their disability evaluation systems, focusing on the agencies’ joint pilot of 

the IDES. Specifically, we examined: (1) the results of DOD and VA’s 

evaluation of the pilot, (2) challenges in implementing the piloted system 

to date, and (3) DOD and VA plans to expand the piloted system and 

whether those plans adequately address potential challenges. 

To examine DOD and VA’s evaluation of the IDES pilot, we identified the 

goals that DOD and VA expected the pilot to achieve and reviewed their 

assessment of whether those goals were met. As part of this work, we 

assessed the reliability of two types of data that DOD and VA planned to 

use as the basis of their pilot evaluation—case data from both pilot and 

legacy disability evaluation systems, as well as data from surveys DOD 

conducted to gauge servicemember satisfaction. We obtained the case 

data and survey data as of early 2010, the same cutoff dates that DOD and 

VA used for their pilot evaluation.4

 To identify challenges in implementing 

the piloted system to date, we visited 10 of the 27 military treatment 

 

2

Pub. L. No. 110-181, §1601-1676, 430, 122 Stat. 3. 

3

Pub. L. No. 110-181, § 1615(d), 122 Stat. 3, 447. We previously reported that DOD and VA 

have completed the requirements established in the NDAA 2008 for developing policy to 

improve the medical and physical disability evaluation of recovering servicemembers. 

GAO, Recovering Servicemembers: DOD and VA Have Jointly Developed the Majority of

Required Policies but Challenges Remain, GAO-09-728 (Washington, D.C.: July 8, 2009). 

4

The data we received for the legacy disability evaluation system is as of January 31, 2010. 

The data we received for the IDES pilot is as of February 28, 2010. The survey data we 

received on participants who went through the legacy system and those who went through 

the IDES pilot was as of February 28, 2010. 

Page 2 GAO-11-69 DOD and VA Disability Evaluation
 

facilities participating in the pilot.5 We selected these 10 facilities to obtain 

perspectives from sites in different military services and geographical 

regions and with varying caseloads and organizational structures. For all 

of the research objectives, we conducted interviews with key officials 

involved in the pilot at DOD, VA, and each of the military services. 

Furthermore, we analyzed pilot case data and reviewed reports, guidance, 

plans, and other documents. We also reviewed relevant federal laws and 

regulations. We conducted this performance audit from November 2009 to 

December 2010, in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

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

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. 

The NDAA 2008 also requires us to certify whether we had timely access 

to sufficient information to make informed judgments on the matters 

covered by our report.6

 We were provided sufficient information in a 

timely manner to make informed judgments on the audit objectives 

covered in this report. 

Background 

The DOD Legacy Disability 

Evaluation System 

The military’s legacy disability evaluation process begins at a military 

treatment facility when a physician identifies a condition that may 

interfere with a servicemember’s ability to perform his or her duties.7

 On 

the basis of medical examinations and the servicemember’s medical 

records, a medical evaluation board (MEB) identifies and documents any 

conditions that may limit a servicemember’s ability to serve in the military. 

 

5

The IDES pilot sites we visited were: (1) Bayne Jones Army Community Hospital, Fort 

Polk, Louisiana; (2) David Grant Medical Center, Travis Air Force Base, California; (3) 

Dewitt Army Community Hospital, Fort Belvoir, Virginia; (4) Evans Army Community 

Hospital, Fort Carson, Colorado; (5) Naval Hospital Camp Lejeune, North Carolina; (6) 

Naval Hospital Camp Pendleton, California; (7) Naval Medical Center San Diego, California; 

(8) Walter Reed Army Medical Center, Washington, D.C.; (9) Winn Army Community 

Hospital, Fort Stewart, Georgia; and (10) Vance Air Force Base, Oklahoma. 

6

Pub. L. No. 110-181, § 1615(d)(1), 122 Stat. 3. 

7

A physician is required to identify a condition that may cause the member to fall below 

retention standards after the member has received the maximum benefit of medical care. 

Page 3 GAO-11-69 DOD and VA Disability Evaluation
 

The servicemember’s case is then evaluated by a physical evaluation board 

(PEB) to make a determination of fitness or unfitness for duty. Each of the 

services conducts this process for its servicemembers. The Army has three 

PEBs, which are located at Fort Sam Houston, Texas; Walter Reed Army 

Medical Center in Washington, D.C.; and Fort Lewis, Washington. The 

Navy and Air Force each have one PEB: the Navy’s is located at the 

Washington Navy Yard in Washington, D.C., and the Air Force’s is located 

in San Antonio, Texas. The PEB process begins with an “informal” PEB—

an administrative review of the case file by PEB adjudicators without the 

presence of the servicemember. If the servicemember is found to be unfit 

due to medical conditions incurred in the line of duty, the informal PEB 

assigns the servicemember a combined percentage rating for those unfit 

conditions, and the servicemember is discharged from duty. Disability 

ratings range from 0 (least severe) to 100 percent (most severe) in 

increments of 10 percent. Depending on the overall disability rating and 

number of years of active duty or equivalent service, the servicemember 

found unfit with compensable conditions is entitled to either monthly 

disability retirement benefits or lump sum disability severance pay.8

Servicemembers have opportunities to appeal the results of their disability 

evaluations. If servicemembers are dissatisfied with the informal PEB’s 

decisions, they may request a hearing with a “formal” PEB. If they then 

disagree with the formal PEB’s findings, they can, under certain 

conditions, appeal to the reviewing authority of the PEB.9

As servicemembers navigate DOD’s disability evaluation system, they 

interface with staff who play key roles in supporting them through the 

process. Military physicians involved in the MEB process play a 

fundamental role because they are responsible for documenting in the 

 

8

Servicemembers may receive monthly disability retirement benefits if they have at least 20 

years of active duty or equivalent service, or if they have less than 20 years of active duty or 

equivalent service and a 30 percent or higher disability rating. Servicemembers may receive 

lump sum disability severance if they have fewer than 20 years of active duty or equivalent 

service, and they have a compensable disability rated at 20 percent or lower. 

Servicemembers who separate from the military with a DOD disability rating of 30 percent 

or higher receive health care benefits for life, regardless of their years of military service. 

Servicemembers may also be found to have an unstable disability, in which case they may 

be placed on the Temporary Disability Retired List. 

9

For more detailed descriptions of the disability evaluation system, see GAO, Military

Disability System: Improved Oversight Needed to Ensure Consistent and Timely

Outcomes for Reserve and Active Duty Service Members, GAO-06-362 (Washington, D.C.: 

Mar. 31, 2006) and GAO-08-1137. 

Page 4 GAO-11-69 DOD and VA Disability Evaluation
 

disability evaluation case file the medical conditions that may limit a 

servicemember’s ability to serve in the military. To prepare this 

documentation, military physicians may require that servicemembers 

obtain additional medical evidence from specialty physicians, such as a 

psychiatrist. Throughout the MEB and PEB processes, board liaisons serve 

a key role by explaining the process to servicemembers and constructing 

the case files. The liaisons inform servicemembers of board results and of 

deadlines at key decision points in the process. The military also provides 

legal counsel to advise and represent servicemembers going through the 

disability evaluation process, although servicemembers may retain their 

own representative at their own expense. 

The VA Disability Claims 

Process 

In addition to receiving disability benefits from DOD, veterans with 

service-connected disabilities may receive compensation from VA for lost 

earnings capacity. In contrast to DOD’s disability evaluation system, which 

evaluates only medical conditions affecting servicemembers’ fitness for 

duty, VA evaluates all medical conditions claimed by the veteran, whether 

or not they were previously evaluated by the military services’ medical 

evaluation process. Although a servicemember may file a VA claim while 

still in the military, he or she can only obtain disability compensation from 

VA as a veteran. 

VA’s disability compensation claims process starts when a veteran submits 

a claim to VA’s Veterans Benefits Administration (VBA). The claim lists the 

medical conditions that the veteran believes are service-connected. For 

each claimed condition, VA must determine if credible evidence is 

available to support the veteran’s contention of service connection. A 

service representative assists the veteran in gathering the relevant 

evidence to evaluate the claim, which may include the veteran’s military 

service records and treatment records from VA medical facilities and 

private medical service providers. Also, if necessary for reaching a 

decision on a claim, VBA arranges for the veteran to receive a medical 

examination conducted by clinicians (including physicians, nurse 

practitioners, or physician assistants) certified to perform the exams 

under VA’s Compensation and Pension program. Once a claim has all of 

the necessary evidence, a VA rating specialist evaluates the claim and 

determines whether the claimant is eligible for benefits. If so, the rating 

specialist assigns a percentage rating. If VA finds that a veteran has one or 

more service-connected disabilities with a combined rating of at least 10 

percent, the agency will pay monthly compensation. The veteran can claim 

additional benefits over time, for example, if a service-connected disability 

worsens or surfaces at a later point in time. 

Page 5 GAO-11-69 DOD and VA Disability Evaluation
 

The Integrated Disability 

Evaluation System 

In November 2007, DOD and VA began piloting the IDES, a joint disability 

evaluation system to eliminate duplication in their separate systems and to 

expedite receipt of VA benefits for wounded, ill, and injured 

servicemembers. The IDES merges DOD and VA processes, so that 

servicemembers begin their VA disability claim while they undergo their 

DOD disability evaluation, rather than sequentially, making it possible for 

them to receive VA disability benefits shortly after leaving military service. 

Specifically, the IDES 

• merges DOD and VA’s separate exam processes into a single exam process 

conducted to VA standards. This single exam—which may involve more 

than one medical examination (for example, by different specialists)—in 

conjunction with the servicemembers’ medical records, is used by military 

service PEBs to make a determination of servicemembers’ fitness for 

continued military service, and by VA as evidence of service-connected 

disabilities. The single exam may be performed by medical staff working 

for either VA, DOD, or a private provider contracted with either agency. 

• consolidates DOD and VA’s separate rating phases into one VA rating 

phase. If the informal PEB has determined that a servicemember is unfit 

for duty, VA rating specialists prepare two ratings—one for the conditions 

that DOD determined made a servicemember unfit for duty, which DOD 

uses to provide military disability benefits, and the other for all serviceconnected disabilities, which VA uses to determine VA disability benefits. 

Ratings for the IDES are prepared by rating specialists at VA’s Baltimore 

and Seattle regional offices. 

• provides VA case managers to perform outreach and nonclinical case 

management and explain VA results and processes to servicemembers. 

By consolidating DOD and VA’s separate medical exams and ratings, the 

IDES eliminates several steps from the existing “legacy” systems (see fig. 1). 

Page 6 GAO-11-69 DOD and VA Disability Evaluation
 

Figure 1: Overview of the Legacy and IDES Processes 

Sources: GAO analysis of DOD and VA policies.

1. Service

member

referred

to disability

system.

2. Military

medical

providers

conduct

medical

exam.

7. Veteran

files claim

for benefits

with VA.

8. VA

providers

examine

veteran.

3. Medical

Evaluation

Board (MEB)

identifies

conditions

that may

make

member

unfit for

duty.

4. Physical

Evaluation

Board (PEB)

assesses

service

member’s

fitness for

duty.

5. If found

unfit, PEB

rates the

unfitting

conditions

to determine

benefits.

6. Service

member

discharged

with DOD

benefits if

eligible.

10. Veteran

receives

VA benefits

if eligible.

Legacy process

IDES process

Actions performed by Department of Defense (DOD) Actions performed by Veterans Affairs (VA)

1. Service

member

referred

to disability

system.

2. Medical

providers

conduct

medical

exam to VA

standards.

a

3. Medical

Evaluation

Board (MEB)

identifies

conditions

that may

make

member

unfit for

duty.

4. Physical

Evaluation

Board (PEB)

assesses

service

member’s

fitness for

duty.

5. If found

unfit, VA

rates the

conditions

to determine

both DOD

and VA

benefits.

6. Service

member

receives

both DOD

and VA

benefits

shortly after

discharge.

Actions performed by DOD and VA

9. VA rates

all of 

veteran’s

serviceconnected 

conditions.

Note: Under the legacy system, steps 1, 2, and 3 are not necessarily performed in this order. For 

example, a Navy official told us that under the legacy system, the servicemember is referred into the 

disability evaluation system when the MEB completes the documentation identifying the conditions 

that may make a member unfit for duty. With regard to step 7, servicemembers may file a claim with 

VA while still in the military, but they can only obtain disability compensation from VA as a veteran. 

With regard to step 8, the exams may be conducted by VA clinicians or by private-sector physicians 

contracted with VA. 

a

In the IDES process, the medical exam performed to VA standards can be conducted by VA, DOD, 

or private-sector providers contracted with either agency. 

Page 7 GAO-11-69 DOD and VA Disability Evaluation
 

In designing the IDES, DOD and VA established goals to provide VA 

benefits to active duty servicemembers within 295 days of being referred 

into the system, and to reserve component members within 305 days.10 In 

establishing the 295- and 305-day goals, they also established timeliness 

goals for the specific steps of the IDES process (see fig. 2). 

 

10The Army Reserve, the National Guard, the Air Force Reserve, the Air National Guard, the 

Navy Reserve, and the Marine Corps Reserve constitute DOD’s reserve component. 

Page 8 GAO-11-69 DOD and VA Disability Evaluation
 

Figure 2: Timeliness Goals for the Steps of the IDES Process 

Sources: GAO analysis of DOD and VA policies and guidance.

30

15

30

15

Administrative processing throughout PEB phase

Member may appeal formal PEB decision to military department 

Servicemember referred to the IDES

DOD board liaison meets with servicemember, compiles medical

and personnel records (30 for Reserves)

VA case manager meets member, files VA claim

(30 for Reserves)

VA, DOD, or contracted providers perform medical exam

Servicemember separates from military 

VA issues benefits letter

MEB identifies potentially unfitting conditions

Informal PEB determines fitness for duty

VA completes ratings

10

10

45

35

15

15

45

30

IDES goals

(in days)

Member may appeal fitness decision to formal PEB 

PEB

phase

MEB

phase

295 (305 for Reservesa) 

Member may appeal rating decision to VA

a

DOD guidance allows 40 more days for reserve component members than for active duty members in 

completing the first two steps of the process to provide for employer notification, establish orders for 

active duty, and to compile medical records. However, DOD and VA’s goal for total IDES processing 

time is only 10 days longer for reserve component members than for active duty members. 

Page 9 GAO-11-69 DOD and VA Disability Evaluation
 

DOD and VA first piloted the IDES at 3 Washington, D.C., area military 

treatment facilities, beginning in November 2007 (see table 1). They added 

18 military facilities to the pilot in fiscal year 2009 and 6 in fiscal year 2010. 

DOD and VA stated that expansion to additional sites was intended to 

assess the IDES system in a variety of geographic areas and to test the 

agencies’ capacity to handle additional caseload. According to DOD, the 27 

pilot sites represented almost half of the servicemembers in the military 

services’ disability evaluation systems. 

Table 1: Military Treatment Facilities Piloting the IDES 

Military service Initial pilot sites (3) 

Phase 1 expansion—fiscal 

year 2009 (18) 

Phase 2 expansion—fiscal 

year 2010 (6) 

Air Force (6) Malcolm Grow Medical Center, 

Andrews Air Force Base (MD) 

Elmendorf Air Force Base (AK) 

MacDill Air Force Base (FL) 

Nellis Air Force Base (NV) 

Travis Air Force Base (CA) 

Vance Air Force Base (OK) 

Army (15) Walter Reed Army Medical Center 

(Washington, D.C.) 

Fort Belvoir (VA) 

Fort Carson (CO) 

Fort Drum (NY) 

Fort Meade (MD) 

Fort Polk (LA) 

Fort Richardson (AK) 

Fort Sam Houston (TX) 

Fort Stewart (GA) 

Fort Wainwright (AK) 

Fort Benning (GA) 

Fort Bragg (NC) 

Fort Hood (TX) 

Fort Lewis (WA) 

Fort Riley (KS) 

Navya (6) National Naval Medical Center (MD) Camp Lejeune (NC) 

Camp Pendleton (CA) 

Naval Hospital Bremerton (WA) 

Naval Medical Center San 

Diego (CA) 

Naval Medical Center 

Portsmouth (VA) 

Total number of pilot sites: 27 

Source: DOD. 

Note: Numbers in parentheses indicate numbers of IDES sites. 

a

Navy IDES pilot sites serve both Navy and Marine Corps servicemembers, since the Marine Corps is 

within the Department of the Navy. 

Page 10 GAO-11-69 DOD and VA Disability Evaluation
 

Pilot Evaluation 

Results Are 

Promising, but the 

Degree of 

Improvement 

Achieved Is Unknown 

DOD and VA’s Evaluation 

Shows That the Pilot Is 

Achieving Some of Its 

Goals 

In their planning documents for the IDES pilot, DOD and VA stated that 

they were basing their evaluation of the effectiveness of the IDES pilot on 

whether it has achieved three key goals relative to the legacy process: 

increased servicemember satisfaction, improved case-processing time, and 

a reduction in servicemember appeal rates. In addition, they also 

examined IDES program costs. To determine whether they have achieved 

their goals, the agencies surveyed servicemembers in the IDES pilot and 

legacy systems and are using a data system—called the Veterans Tracking 

Application (VTA)—that enables them to track case processing time and 

appeals. They have been monitoring their progress on these goals through 

weekly reports. 

In August 2010, DOD and VA officials issued an interim report to Congress 

summarizing their evaluation results to date. In this report, the agencies 

concluded that servicemembers who went through the IDES pilot were 

more satisfied than those who went through the legacy system, and that 

the IDES process met the agencies’ goals of delivering VA benefits to 

active duty servicemembers within 295 days and to reserve component 

servicemembers within 305 days. Specifically, they reported that, as of 

February 2010, the IDES process took an average of 274 days to complete 

for active duty servicemembers and 281 days for reserve component 

members who, according to the interim report, comprise 15 percent of 

IDES participants. Furthermore, they concluded that the IDES pilot has 

Page 11 GAO-11-69 DOD and VA Disability Evaluation
 

achieved a faster processing time than the legacy system, which they 

estimated to be 540 days.11

While overall results were promising, data presented in the report had 

some limitations, and the report itself did not include certain analyses. For 

example, DOD officials told us that the 540-day estimate for the legacy 

process was based upon a review of a small and nonrepresentative sample 

of legacy cases during the agencies’ “table top” planning exercise in 

August 2007.12 In addition, although DOD officials told us that they 

planned to compare average processing times of pilot cases with a broader

sample of legacy cases, and to determine whether fewer servicememb

are appealing the findings of informal PEBs and formal PEBs in the pi

compared with the legacy, the interim report did not include these 

comparisons. In addition, in their planning documents for the IDES pilot, 

DOD and VA indicated that they were establishing a goal to deliver VA 

benefits to 80 percent of members in the IDES pilot within the 295- and 

305-day time frames. However, their interim report did not discuss 

whether this goal was met. 

ers 

lot 

 

Our review of DOD and VA’s data and weekly reports generally confirm 

DOD and VA’s findings, as of early 2010. However, while the agencies have 

largely met their overall goal to increase servicemember satisfaction and 

met their timeliness goal as of February 2010, since that time, case 

processing times have been steadily increasing as the caseload has 

increased. In addition, not all of the service branches are achieving the 

same results. 

• Servicemember satisfaction: Our review of the survey data that DOD used 

for the interim report (as of February 2010), as well as a recent weekly 

report, indicate that, on average, servicemembers in the IDES process 

have had higher satisfaction levels than those who went through the 

11DOD and VA also concluded in their interim report that disability ratings in IDES pilot 

cases have been higher than in legacy cases, and more servicemembers in the pilot were 

eligible for monthly disability benefits rather than lump sum severance, compared to the 

legacy, but they noted that these changes were primarily due to the enactment of NDAA 

2008, rather than the IDES pilot. NDAA 2008 required DOD to apply VA’s standards when 

rating disabilities. 

12During the table top exercise, a sample of complete legacy cases was used in a simulation 

exercise to test the relative merits of four pilot options. For further information on the 

table top exercise, see GAO, DOD and VA: Preliminary Observations on Efforts to

Improve Care Management and Disability Evaluations for Servicemembers, GAO-08-514T 

(Washington, D.C.: Feb. 27, 2008). 

Page 12 GAO-11-69 DOD and VA Disability Evaluation
 

legacy process. In addition, a higher percentage of servicemembers who 

went through the IDES process felt that the process was fair compared 

with those who went through the legacy system. However, 

servicemembers in the Air Force who went through the IDES pilot 

indicated less satisfaction with the process than those who went through 

the legacy system, though Air Force members represented a small 

proportion of pilot cases—about 7 percent of those enrolled in the pilot.13

We reviewed the agencies’ survey methodology and generally found their 

survey design and conclusions to be sound (see app. I for further 

information on our review). 

• Average case processing times: The agencies have been meeting their 295-

day and 305-day timeliness goals for much of the past 2 years, but more 

recent weekly reports indicate case processing time has been increasing 

and that they are now missing their goal for active duty members.14 As of 

August 29, 2010, the agencies missed the goal for active duty 

servicemembers by 1 day, while still meeting the 305-day goal for reserve 

component members by 7 days. Processing times have increased as 

caseload has increased, from about 5,750 active cases in February to about 

9,650 cases in August 2010. We reviewed the reliability of the VTA data 

upon which the agencies based their analyses and generally found these 

data to be sufficiently reliable for purposes of these analyses.15

The increases in overall case processing time and caseloads mirror the 

trends at individual sites. For each pilot site, case processing times have 

generally increased as workloads have increased. For example, figure 3 

shows the case processing times 1 year or more after implementation and 

in August 2010 for the first seven pilot sites. 

 

13Weekly monitoring reports from February 2010 (the cutoff date for survey data analyzed 

for DOD and VA’s interim report) and August 2010 show lower satisfaction levels among 

Air Force servicemembers. 

14The weekly monitoring reports present cumulative case processing times, i.e., average 

case processing times for all cases completed as of that given week. 

15Our data reliability assessment included interviews regarding internal controls, electronic 

testing, and a trace-to-file process, where we matched a small number of randomly sampled 

case file dates against the dates that had been entered into the VTA. For the trace-to-file 

process, the overall accuracy rate was 84 percent, and all but one date were 70 percent 

accurate or better and deemed sufficiently reliable for reporting purposes. See appendix I 

for details on our data reliability assessment. 

Page 13 GAO-11-69 DOD and VA Disability Evaluation
 

Figure 3: Average Case Processing Times and Changes in Active Caseload by 

Location at Least 1 Year After Implementation and in August 2010 

a

For the oldest pilot locations—Walter Reed Army Medical Center, Andrews Air Force Base, and 

Bethesda Naval Medical Center—the first average case processing times shown were as of May 31, 

2009, which is more than 1 year after these sites began implementing the pilot in November 2007 

because this was the first month that the agencies reported processing times by location. The first 

processing date for all other sites comes from the weekly report closest to 1 year after each site began 

implementing the pilot. (The implementation dates were: October 1, 2008, for Fort Belvoir and Fort 

Meade; October 31, 2008, for Naval Medical Center San Diego; and November 30, 2008, for Fort 

Stewart). 

b

The end date for the changes in active caseload is August 22, 2010, and differs by 1 week from the 

end date of August 29, 2010, used for the average case processing time because the data used in 

these two analyses are presented in different appendices to the weekly reports that rotate each week. 

Of the four military services, only the Army and Navy were achieving the 

295- and 305-day goals on average, as of February 2010, and only the Army 

was achieving these goals as of August 2010. Because the Army comprises 

a large proportion of cases (approximately 60 percent of IDES pilot cases 

that have completed the whole process), it has lowered the overall average 

processing time to near or below the established goals. Figure 4 shows the 

average case processing times for active duty, by service, as of August 

2010. (See app. II for reserve component.) 

Sources: GAO presentation of weekly report data from DOD and VA.

0 100 200 300 400

San Diego

(Navy)

Bethesda

(Navy)

Fort Stewart

(Army)

Fort Meade

(Army)

Fort Belvoir

(Army)

Walter Reed

(Army)

Andrews

(Air Force)

Processing time (in days)

292

250

355

324

238

257

203

286

236

298

283

258

380

316

About 1 year after implementationa

August 29, 2010b

413 cases

135 cases

144 cases

44 cases

44 cases

23 cases

13 cases

Page 14 GAO-11-69 DOD and VA Disability Evaluation
 

Figure 4: Active Duty IDES Case Processing Times by Service, as of August 29, 2010 

As of February 2010, the agencies also had not met the goal of processing 

80 percent of all pilot cases within targeted time frames. Specifically, 

about 60 percent of active duty pilot cases have been completed within 

295 days, according to our analysis of the agencies’ case data intended for 

their interim report. Further, none of the four military services have 

achieved this goal, although the Army has had the highest rate of cases (66 

percent) meeting the goal, while only 42 percent of Air Force cases were 

processed within the time frame (see fig. 5 for active duty and app. II for 

reserve component). 

Figure 5: Percentage of IDES Active Duty Cases Completed in 295 Days or Less by 

Service, as of February 2010 

Sources: GAO presentation of weekly report data from DOD and VA.

0 50 100 150 200 250 300 350 400

All

Marine Corps

Navy

Army

Air Force

Service goal (295 days)

1 year

339

266

340

334

296

Elapsed time in days

Sources: GAO analysis of pilot case data from DOD and VA.

0 10 20 30 40 50 60 70 80

All

Marine Corps

Navy

Army

Air Force 42%

66%

57%

53%

60%

Percentage of cases meeting goal

Service goal

Page 15 GAO-11-69 DOD and VA Disability Evaluation
 

DOD and VA planned to compare the case processing times of 

servicemembers in the IDES pilot and servicemembers who, between 

fiscal years 2005 and 2009, were enrolled in the legacy system at pilot sites 

prior to pilot implementation, but significant gaps in the legacy case data 

preclude reliable comparisons. DOD compiled the legacy case data from 

each of the military services and the VA, but the military services each had 

slightly different disability evaluation processes, used different data 

systems, and did not track the same information. As a result, information 

needed to conduct a comparison is not available for all services. For 

example, the Navy, Marine Corps, and Air Force legacy data do not have 

information on when the servicemember was referred into the disability 

evaluation system and, as a result, case-processing time for the legacy 

system DOD-wide cannot be known.16 DOD officials said they planned to 

estimate legacy case processing time by approximating the dates that 

servicemembers in the Navy, Marine Corps, and Air Force were referred 

into the disability evaluation process, but their methodology was based on 

a limited number of Army cases (see app. I for further information). In 

addition, for legacy cases across all military services, VA was not able to 

provide data on the date VA benefits were delivered, so total case 

processing time from referral to delivery of VA benefits cannot be 

measured. However, while legacy case data are not sufficiently reliable for 

comparison with the IDES overall, the Army’s legacy data appear to be 

reliable on some key processing dates, making some limited comparisons 

possible. Our analysis of Army legacy data suggests that, under the legacy 

process, active duty Army cases took 369 days to complete the DOD 

legacy process and reach the VA rating phase—though this figure does not 

include time to complete the VA rating and provide the benefits to 

servicemembers—compared with 266 days to deliver VA benefits to 

servicemembers under the pilot, according to the agencies’ August weekly 

report.17 However, Army comparisons cannot be generalized to the other 

services. 

Extent of Improvement 

Over the Legacy System Is 

Unknown Due to Gaps in 

Legacy Data 

 

16DOD officials stated that, under the legacy system, the Navy, Marine Corps, and Air Force 

considered a case to be referred into the disability evaluation system when a physician 

documented the conditions that may render a servicemember unable to perform their 

duties. Under the IDES process, the servicemember is formally referred into the disability 

evaluation system before the documentation is prepared. 

17Reserve component Army cases took 389 days to reach the VA rating phase under the 

legacy process, compared with 285 days to deliver VA benefits under the pilot. Reserve 

component cases made up 48 percent of legacy cases and 23 percent of pilot cases. 

Page 16 GAO-11-69 DOD and VA Disability Evaluation
 

The agencies also planned to compare servicemembers’ appeal rates in the 

pilot and legacy systems, but similar gaps in the legacy data preclude a 

comparison DOD-wide. For example, the legacy data that DOD compiled 

did not contain data on appeals of informal PEB decisions to the formal 

PEB in the Navy and Marines, and consequently the rate of appeals across 

the military in the legacy system is unknown. While the Army’s appeals 

data appear to be more reliable, potentially making some limited 

comparisons possible, the agencies’ method for comparing pilot appeals 

with legacy has limitations. DOD officials told us they are planning to 

compare the proportion of informal PEB decisions that were appealed to a 

formal PEB hearing in the pilot and legacy systems. However, this will not 

take into account that, under the legacy system, a servicemember could 

appeal the informal PEB’s decision for two reasons—because they were 

dissatisfied with the fitness decision or the disability rating the PEB 

assigned, while in the IDES, they can only appeal the informal PEB 

decision to a formal PEB if they are dissatisfied with the fitness decision. 

Under the IDES, servicemembers who disagree with the disability rating 

can appeal to VA for a rating reconsideration. By not including appeals to 

VA for rating reconsiderations, the agencies may overestimate the 

decrease in appeals in the IDES pilot. For example, our analysis of data as 

of early 2010 for the Army indicates that Army members in the pilot 

appealed 7.5 percent of informal PEB decisions. However, when appeals 

to VA are factored in, 13 percent of Army members in the pilot filed an 

appeal, which is the same proportion as in the legacy system (see fig. 6). 

Figure 6: Army Servicemember IDES and Legacy Appeal Rates, as of early 2010 

Sources: GAO analysis of legacy data and pilot case data provided by DOD and VA.

0 5 10 15 20

IDES pilotb

Legacya 12.9%

7.5% 5.6% 13.1%

Percentage of cases with an appeal

Informal PEB appeals

VA rating reconsiderations

a

Legacy data is as of January 2010 on servicemembers who were referred to the disability evaluation 

system between fiscal years 2005 and 2009 at 21 military treatment facilities selected as IDES pilot 

sites. 

b

Pilot case data is as of February 2010 for servicemembers who were referred to the IDES beginning 

November 2007. 

Page 17 GAO-11-69 DOD and VA Disability Evaluation
 

In addition to evaluating the three goals, DOD and VA initially planned a 

cost-benefit analysis of the IDES program but have only completed an 

analysis of costs. According to data provided to us in August 2010, DOD 

projects that costs directly associated with implementing the IDES will be 

$63 million greater per year when compared with the legacy system, after 

full expansion of the IDES.18 In October 2010, VA reported to us total IDES 

cost estimates of approximately $50 million for fiscal year 2011—about 

$33 million for VBA, which provides VA case managers and rating staff to 

the IDES, and $17 million for the Veterans Health Administration (VHA), 

which provides medical staff to perform the single exams.19 These 

analyses did not quantify the value of potential benefits created by the 

pilot, for example time savings from DOD physicians no longer needing to 

perform disability examinations, which allows them to perform other

duties. 

ad 

to 

all, of these challenges as they arose. 

e 

0 

t 

rson and Fort Stewart, in 

particular—experiencing severe shortages. 

 

As DOD and VA tested the IDES at different facilities and added caselo

to the pilot, they encountered several challenges that led to delays in 

certain phases of the process. Among these were insufficient staffing, 

challenges in conducting the single exams, logistical challenges related 

integrating VA staff, as well as housing and managing servicemembers 

going through the IDES. DOD and VA were able to address some, but not 

Pilot Sites 

Experienced Several 

Challenges 

Positions in the IDES Pilot 

DOD and VA have not provided sufficient numbers of staff in many of th

IDES locations, affecting their ability to complete certain phases of the 

IDES process within the goals they established. Officials at most of the 1

pilot sites we visited said they have experienced staffing shortages to a

least some extent, with a few sites—Fort Ca

DOD and VA Did Not 

Sufficiently Staff Many Key 

18As part of their analysis of costs, DOD estimated that costs of servicemembers’ disability 

benefits will increase by approximately $960 million per year. However, they noted that 

these additional costs are due to requirements in the National Defense Authorization Act of 

2008 mandating the use of VA’s rating standards in the disability evaluation system, which 

tend to result in higher benefits than the rating standards that DOD had previously used. 

DOD stated that these increased costs would be realized under the legacy system as well. 

19VHA estimated costs of about $33 million, but anticipates being reimbursed by DOD for 

about half of these costs through a cost-sharing agreement. 

Page 18 GAO-11-69 DOD and VA Disability Evaluation
 

VA or contract examiners: At three pilot sites we visited—Fort Carson, 

Fort Polk, and Fort Stewart—local officials said that a lack of VA or VA 

contractor staff who could perform the required single medical exams led 

to bottlenecks in the process.20 For example, as of August 2010, exams at 

Fort Carson have taken an average of 140 days to complete for active duty

servicemembers, according to the agencies’ data, far from achieving their 

goal to complete single medical exams within 45 days (see fig. 7; s

app. II for processing times for reserve component members). Across all 

pilot sites, exams have taken 68 days to complete for active duty 

servicemembers, on average, with 8 of the 27 pilot sites meeting the 45

goal.

ee also 

-day 

 they had sufficient specialists to 

perform specialty medical exams but did not have enough examiners to 

complete general medical exams. 

 

21 The different sites we visited faced shortages for different types of

examiners. For instance, Fort Carson’s IDES process was particularly

hampered by a lack of mental health specialists; in contrast, VA officials 

serving the Fort Polk pilot site said

20At Fort Stewart, a private-sector provider performs the single exams through a contract 

with VA. At Fort Carson and Fort Polk, the exams are conducted by VA medical staff. A VA 

contractor also conducts single exams at Camp Lejeune (NC), Camp Pendleton (CA), Fort 

Lewis (WA), Naval Hospital Bremerton (WA), and Vance Air Force Base (OK). 

21The 8 pilot sites that met the 45-day goal for completing single exams include 2 Air Force 

sites, 5 Army sites, and 1 Navy site that met the 45-day goal for servicemembers in both the 

Navy and Marine Corps. One additional site (Camp Pendleton) met the 45-day goal for Navy 

members but did not meet it for Marine Corps members. 

Page 19 GAO-11-69 DOD and VA Disability Evaluation
 

Figure 7: Single Exam Processing Time for Active Duty Servicemembers at IDES Pilot Sites, as of August 29, 2010 

Sources: GAO presentation of weekly report data from DOD and VA.

Air Force Navy Marine Corps a

0

30

60

90

120

150

S

Bremerton

an Diego

Portsmouth

Bethesda

Camp Pendleton

Camp Lejeune

Bremerton

Camp Pendleton

San Diego

Portsmouth

Camp Lejeune

Bethesda

Fort Bragg

Fort Riley

Fort Meade

Fort Hood

Fort Benning

Fort Lewis

Fort Polk

Fort Drum

Fort Belvoir

Fort Sam Houston

Walter Reed 

Fort Wainwright

Fort Richardson

Fort Stewart

Fort Carson

Travis

MacDill

Nelli

Vance

s

Andrews

Elmendorf

Service goal

(45 days)

Average for all sites

(68 days)

Elapsed time in days

Army

74

57

33

140

30

42

62

44

a

This figure shows processing times separately for servicemembers in the Navy and Marine Corps at 

the six Navy IDES pilot sites. 

Military physicians: At some of the pilot sites we visited, local DOD 

officials felt there were not enough physicians to quickly complete and 

document their determinations of whether servicemembers’ medical 

conditions may limit their ability to serve in the military. As a result, the 

sites had difficulty achieving the agencies’ goal to complete the MEB 

determinations within 35 days. Across all sites, the MEB determination has 

Page 20 GAO-11-69 DOD and VA Disability Evaluation
 

taken an average of 61 days to complete for active duty servicemembers, 

with 8 of the 27 sites meeting the 35-day goal, as of August 2010.22 A few 

sites we visited were far from achieving the 35-day goal, such as Fort 

Belvoir, where MEB determinations averaged 101 days to complete for 

active duty servicemembers (see fig. 8 and app. II for processing times for 

reserve component members). Only the Army, which has physicians 

dedicated to disability evaluation, has established a caseload target for 

MEB physicians—120 servicemembers per physician, but Army officials 

were not able to provide us with data on the extent to which pilot sites 

met this target. The Navy and Air Force have not established caseload 

targets for their physicians; their MEB determinations are prepared by 

physicians who perform other responsibilities, such as clinical treatment 

or supervision. 

 

22These 8 sites include 2 Air Force sites, 3 Army sites, and 3 Navy sites that met the 35-day 

goal for both servicemembers in the Navy and Marine Corps. 

Page 21 GAO-11-69 DOD and VA Disability Evaluation
 

Figure 8: MEB Processing Times for Active Duty Servicemembers at IDES Pilot Sites, as of August 29, 2010 

Sources: GAO presentation of weekly report data from DOD and VA.

Air Force Navy Marine Corps a

0

20

40

60

80

100

120

Bremerton

Portsmouth

San Diego

Bethesda

Camp Pendleton

Camp Lejeune

Bremerton

Portsmouth

San Diego

Bethesda

Camp Pendleton

Camp Lejeune

Fort Bragg

Fort Wainwright

Fort Benning

Fort Lewi

Fort Hood

Fort Polk

Fort Drum

Fort Riley

s

Fort Sam Houston

Fort Carson

Fort Stewart

Fort Belvoir

Walter Reed 

Fort Meade

Fort Richardson

Elmendorf

Travi

Vance

s

Nellis

Andrews

MacDill

Average

for all sites

(61 days)

Elapsed time in days

Army

106

95

30

109

20

89

Service goal (35 days)

33

14

a

This figure shows processing times separately for servicemembers in the Navy and Marine Corps at 

the six Navy IDES pilot sites. 

DOD PEB adjudicators: Officials with the Air Force and Navy PEBs, who 

determine a servicemember’s fitness for duty, also expressed concerns 

about understaffing, though their concerns are not related to the IDES 

alone since they are currently reviewing cases in both the legacy system 

and the IDES pilot. Air Force PEB officials noted that they had a 

substantial backlog of disability evaluation system cases awaiting a fitness 

decision, though they recently added adjudicators to reduce the backlog. 

Navy PEB officials also expressed concerns that lack of sufficient staff has 

made it difficult to process cases in a timely manner. At the time of our 

Page 22 GAO-11-69 DOD and VA Disability Evaluation
 

review, none of the services were meeting the agencies’ goal for informal 

PEBs to complete their fitness decisions within 15 days, with the Air 

Force, Navy, and Marine Corps far from reaching it (See fig. 9 for 

processing times for active duty servicemembers. See also app. II for 

reserve component processing times). At 23 days, the Army, with 3 PEBs, 

is slightly short of the goal. However, we could not determine case 

processing times at each Army PEB, since the agencies’ weekly monitoring 

report presents data by military services but not by individual PEB. In 

addition, Air Force and Army PEB officials informed us that they had 

prioritized IDES pilot cases over legacy cases at some point in time. As a 

result, DOD’s data for those services may underestimate the amount of 

time the informal PEB would have taken if IDES cases had not received 

priority. 

Figure 9: Informal PEB Processing Times for Active Duty Servicemembers in the 

IDES Pilot, by Military Service, as of August 29, 2010 

Sources: GAO presentation of weekly report data from DOD and VA.

0 20 40 60 80 100

Marine Corps

Navy

Army

Air Force

a

Service goal (15 days)

64

23

83

97

Elapsed time in days

a

The Navy PEB determines fitness decisions for servicemembers in the Marine Corps. 

VA rating staff: Officials at the Baltimore rating office—one of the two VA 

offices that conduct disability ratings for the IDES pilot—expressed 

significant concerns that they were understaffed, in part due to staff 

turnover. DOD and VA data show that, overall, the VA rating offices are 

not meeting the agencies’ goal to complete ratings within 15 days, taking 

39 days on average for active duty servicemembers and 42 days for reserve 

Page 23 GAO-11-69 DOD and VA Disability Evaluation
 

component members.23 We could not determine case processing times at 

each individual VA rating office, since DOD and VA’s weekly monitoring 

reports do not provide processing times for the rating phase by office. The 

weekly reports also do not provide data on caseloads at each office. 

Although the Baltimore office currently has fewer rating staff than Seattle, 

VA officials said that it has prepared ratings for the majority of IDES pilot 

cases, based on the way in which VA has allocated cases between the two 

offices. The Baltimore office handles cases for the Air Force, Navy, 

Marines, and 5 of the 15 Army pilot sites, while the Seattle office conducts 

ratings for the remaining 10 Army pilot sites.24 VA officials said that to 

address staffing shortages in Baltimore, they have assigned staff from 

other VA offices to assist the Baltimore office. 

VA case managers: DOD and VA have set a target for each VA case 

manager to handle no more than 30 cases at a time, but two sites we 

visited—Fort Carson and Fort Stewart—appeared to be far from these 

targets. At Fort Carson, three VA case managers told us they were 

handling about 900 cases when we visited in April 2010, for a caseload 

ratio of roughly 1:300. At the time of our visit in June 2010, Fort Stewart 

had over 750 active cases with two VA case managers, for a caseload ratio 

of approximately 1:375. Although local officials we spoke with at both 

sites told us that the numbers of VA case managers were insufficient, an 

official at VA’s central office told us that VA bases staffing of case 

managers on the number of new (not pending) cases each month, and the 

agencies’ data indicates the average number of new cases per VA case 

manager has been about 25 at each site. The VA official said that the 

reason local case managers felt understaffed was likely due to other 

process inefficiencies. In addition, the official told us VA can reassign staff 

from other VA programs to assist case managers at IDES pilot sites as 

needed. At some of the other pilot sites we visited, local officials also told 

 

23A VA official said that these averages may not include all cases completed as of August 

2010, due to system design issues with the VTA system. In our review of the VTA data as of 

February 2010, we found that in the approximately 1,100 cases that had completed the full 

IDES process up to that date, about 10 percent of the cases were missing the date of the VA 

rating determination. However, the VA official estimated that, as of October 2010, data may 

be missing for about one-third of the 6,000 cases for which the VA rating offices have 

completed ratings. According to the VA official, VTA was updated in September 2010 to 

address these issues. 

24The rating offices are aligned with DOD’s PEBs. The Baltimore rating office rates cases 

adjudicated by the Air Force PEB, Navy PEB, and the Army’s PEB at Walter Reed Army 

Medical Center, Washington, D.C. The Seattle rating office rates cases adjudicated by the 

Army’s PEBs at Fort Sam Houston, TX, and Fort Lewis, WA. 

Page 24 GAO-11-69 DOD and VA Disability Evaluation
 

us they had concerns at times about the numbers of VA case managers 

available to handle the site’s caseload, but VA was able to add staff. VA 

case managers at two Air Force sites we visited—Travis and Vance Air 

Force Bases—indicated that their caseloads were manageable. We were 

unable to independently determine the extent to which VA is meeting its 

caseload target because VA does not collect national data on actual 

caseloads per case manager. 

DOD board liaisons: At most of the sites we visited, local officials 

expressed concerns about insufficient numbers of DOD board liaisons, 

who serve as servicemembers’ DOD case managers. DOD guidance has 

been inconsistent on the caseload target for DOD board liaisons. While 

DOD’s operations manual for the IDES pilot sets a caseload target of at 

most 30 cases per board liaison, guidance on the general disability 

evaluation system sets the target at a maximum of 20 cases per liaison. 

DOD and VA’s documents related to planning for IDES expansion indicate 

that DOD is striving for a 1:20 caseload target in the IDES. However, 19 of 

the 27 pilot sites did not meet the 1:30 caseload target, and 23 did not meet 

the 1:20 target (see fig. 10). 

Page 25 GAO-11-69 DOD and VA Disability Evaluation
 

Page 26 GAO-11-69 DOD and VA Disability Evaluation 

Figure 10: Average Cases per DOD Board Liaison at IDES Pilot Sites 

a

These Navy military treatment facilities also serve members in the Marine Corps. 

Local DOD and VA officials attributed staffing shortages to higher than 

anticipated caseloads and difficulty finding qualified staff in rural areas. At 

several of the pilot sites we visited, officials said that caseloads were 

higher than the initial estimates that they had based staffing levels upon. 

DOD officials said that they had based caseload estimates on a 1-year 

history of caseload at each site. While some sites have added staff as 

caseloads increased, others, such as Fort Polk, located in central 

Sources: GAO presentation of data from the Departments of the Air Force, second quarter, fiscal year 2010; Army, May 2010;

and Navy, October 2010. 

Cases per DOD board liaison

49

152

10 12

86

5

0

40

80

120

160

Air Force Navya Army

20 per

30 per

Goals

Bethesda

S

Bremerton

an Diego

Portsmouth

Camp Pendleton

Camp Lejeune

Fort Benning

Walter Reed

Fort Drum

Fort Riley

Fort Wainwright

Fort Belvoir

Fort Hood

Fort Stewart

Fort Richardson

Fort Sam Houston

Fort Polk

Fort Carson

Fort Bra

Fort Meade

gg

Fort Lewis

Vance

Andrews

MacDill

Elmendorf

Nellis

Travis
 

Louisiana, have had difficulty finding qualified staff, particularly 

physicians, in this rural area.25

Two of the pilot sites we visited—Fort Carson and Fort Stewart—were 

particularly challenged to provide staff in response to surges in caseload, 

which occurred when Army units were preparing to deploy to combat 

zones. Through the Army’s predeployment medical assessment process, 

large numbers of servicemembers were determined to be unable to deploy 

due to a medical condition and were referred to the IDES within a short 

period of time, overwhelming the staff.26 These two sites were unable to 

quickly increase staffing levels, particularly clinicians performing the 

single exam. The VA medical center conducting the single medical exams 

for Fort Carson experienced turnover among its examiners at the same 

time that the caseload surged, while at Fort Stewart, the contractor 

performing the single medical exams had difficulties finding qualified 

physicians in a rural area of Georgia. To address caseload surges, 

examiners were reassigned from other locations to the pilot sites. For 

example, VA officials told us they assigned examiners from other VA 

medical centers to the Fort Carson IDES and established a contract with a 

private-sector provider to complete the exams that VA examiners would 

normally have performed for veterans in the area claiming VA disability 

compensation. At Fort Stewart, the contractor told us that they had 

reassigned examiners from their Atlanta clinic to Fort Stewart. 

 

25VA officials told us that they have recently engaged a contractor to perform exams for 

Fort Polk. 

26In prior work on the Army’s predeployment medical assessment process, GAO 

recommended that the Army develop an enforcement mechanism to ensure that soldiers 

are properly referred to and complete the MEB prior to deployment, move forward with 

plans for an electronic processing system, and provide servicemembers and their families 

with an independent ombudsman. See GAO, Military Personnel: Army Needs to Better

Enforce Requirements and Improve Record Keeping for Soldiers Whose Medical

Conditions May Call for Significant Duty Limitations, GAO-08-546 (Washington, D.C.: 

June 10, 2008). At the time of our review, these recommendations were still in process. 

Page 27 GAO-11-69 DOD and VA Disability Evaluation
 

Insufficiency of Exam 

Summaries and 

Disagreements about 

Medical Diagnoses and 

Ratings Can Prolong Case 

Processing Time 

Issues related to the completeness and clarity of single exam summaries 

were an additional cause of delays in the VA rating phase of the IDES 

process. Officials from VA rating offices said that some exam summaries 

did not contain information necessary to make a rating or fitness decision, 

or were unclear as to the examiners’ diagnoses and conclusions. As a 

result, VA rating office staff must ask the examiner to clarify the summary 

or add information and, in some cases, redo the exam, adding time to the 

process. In addition, VA rating staff told us that it is sometimes unclear 

who they should contact if they identify insufficiencies in an exam 

summary and finding the appropriate person also adds time. However, the 

extent to which insufficient exam summaries caused delays in the IDES 

process is unknown because DOD and VA’s VTA system does not track 

whether an exam summary had to be returned to the examiner or whether 

it was resolved. Due to these limitations, VA officials told us that VA rating 

staff have created logs of outstanding insufficient exams and sent them to 

VA examiners to correct. 

VA officials attributed the problems with exam summaries to several 

factors, including the difficulty of conducting exams for IDES pilot cases, 

which may entail evaluating many complex medical conditions and may 

involve several physicians and specialists. In addition, VA officials 

indicated that, at sites with exam backlogs, such as at Fort Carson, it may 

be difficult for examiners to ensure quality when are trying to complete 

exams quickly. Furthermore, VA staff noted that some errors were 

common, such as missing information for musculoskeletal conditions and 

traumatic brain injury, suggesting that some examiners may not be aware 

of the information required for certain types of medical conditions. 

Finally, while examiners are supposed to receive the servicemember’s 

complete medical records prior to the date of the exam, some VA 

examiners also told us that they did not receive the records in time for the 

exam in some cases, or the records were not well-organized. As a result, 

they lacked key information, such as the servicemember’s medical history 

and results of laboratory tests. According to the agencies’ operations 

manual for the IDES pilot, the DOD board liaison should compile the 

complete medical records within 10 days of an active duty servicemember 

being referred to the IDES, but some DOD officials we spoke with said 

Page 28 GAO-11-69 DOD and VA Disability Evaluation
 

that it is sometimes difficult to obtain all of the records, particularly when 

servicemembers have received treatment from private-sector physicians.27

In addition, while the single exam in the IDES eliminates duplicative exams 

performed by DOD and VA in the legacy system, it raises the potential for 

there to be disagreements about diagnoses of servicemembers’ conditions, 

with implications for their disability ratings, as well as processing times. 

DOD officials we spoke with in our interviews and site visits also said that 

their physicians sometimes disagree with VA medical diagnoses, particularly 

for mental health conditions, and this has extended processing times for 

some cases. In addition, since medical diagnoses are a basis for VA’s 

disability ratings, DOD may subsequently disagree with the ratings VA 

completed for determining DOD disability benefits. The number of cases 

with disagreements about diagnoses and ratings, and the extent to which 

they have increased processing time, are unknown because the VTA system 

does not track when a case has had such disagreements. However, officials 

at 4 of the 10 pilot sites we visited said that military physicians have 

disagreed with VA diagnoses in at least some cases. In addition, PEB 

officials in two of the three military services—the Army and the Navy—said 

that they have sometimes disagreed with the rating VA produced for 

determining DOD disability benefits. 

An example can illustrate the implications of differences in diagnoses. 

Officials at Army pilot sites informed us about cases in which a military 

physician had treated members for a mental condition, such as anxiety or 

depressive disorder. However, when the members went to see the VA 

examiners for their single exam, the examiners diagnosed them with 

posttraumatic stress disorder (PTSD). When such cases were sent to the 

PEB, it returned them to the MEB because it was unclear to the PEB 

which conditions should be the basis of their decision on the 

servicemembers’ fitness for duty. The cases then languished because the 

military physicians experienced difficulties resolving the discrepancy with 

the VA diagnosis. 

To address such processing delays, the Army issued guidance in February 

2010 stating that MEB physicians should review all of the medical records 

(including the results of the single exam) and determine whether to revise 

 

27For reserve component servicemembers, the IDES operations manual states that the DOD 

board liaison should compile the complete medical records within 30 days of their referral 

to the IDES. 

Page 29 GAO-11-69 DOD and VA Disability Evaluation
 

their diagnoses. If after doing so the MEB physician maintains that their 

original diagnosis is accurate, they should write a memorandum 

summarizing the basis of their decision, and the PEB should accept the 

MEB’s diagnosis. Some Army officials we spoke with believe that this 

guidance has been helpful for enabling cases to move forward when there 

are differences in diagnoses. The other services do not have written 

guidance on how to address differences in diagnoses, though Navy 

officials told us that they have provided verbal guidance to their 

physicians, and Air Force officials said they have not had cases with 

significant disagreements about diagnoses. 

In some cases, due to the differences in diagnoses, DOD has also disagreed 

with the rating that VA prepared for DOD disability benefits, particularly in 

cases involving servicemembers with mental health conditions.28 For 

example, Army and Navy officials told us about cases in which the PEB 

found the servicemember unfit due to a mental condition, such as major 

depression, and asked VA to complete a rating for this condition. 

However, VA returned a rating for occupational and social impairment 

caused by PTSD, since the examiner had diagnosed the member with 

PTSD. DOD requires a rating for only the conditions for which the member 

was found unfit for duty because it can only provide disability benefits for 

those conditions. However, according to VA regulations for rating mental 

disorders, VA does not rate each mental health condition individually; 

rather, VA bases its rating on the degree to which the combination of 

symptoms of mental disorders cause occupational and social 

impairment.29 As such, when rating mental health conditions for IDES 

cases, VA officials said that rating specialists would consider both the 

symptoms of mental conditions diagnosed by DOD physicians and those 

identified by the VA examiner. Both Army and Navy PEB officials said

they generally accept VA ratings in these cases, even though the rating

not for the unfitting conditions alone. However, they noted that, if they 

feel the VA rating is in error, there is no guidance on how disagreem

about servicemembers’ ratings should be resolved. Army and Navy 

officials said that they may return the case to VA and informally requ

 that 

 is 

ents 

est 

 

28In our interviews, DOD officials also mentioned cases in which DOD’s PEB disagreed 

about VA’s rating for fibromyalgia and sleep apnea. 

29For example, VA would rate mental health conditions that cause occasional decrease in 

work efficiency at 30 percent, while it would rate conditions that cause deficiencies in most 

areas (such as work, school, family relations, judgment, thinking, or mood) at 70 percent. 

See 38 C.F.R. 4.125-4.130. 

Page 30 GAO-11-69 DOD and VA Disability Evaluation
 

that they reconsider the case, though Navy PEB officials said that they are 

hesitant to do so because it may further delay the case. 

 

DOD and VA officials attributed disagreements about diagnoses to several 

factors. They noted that VA examiners may not have received or reviewed 

the servicemembers’ medical records prior to the exam, and therefore may 

not be aware of the medical conditions for which the members had been 

previously diagnosed and treated. In addition, DOD and VA identify 

conditions for different purposes in the disability evaluation system. While 

DOD identifies conditions that make a servicemember unable to perform 

their duties, VA identifies all service-connected conditions. As such, VA 

examiners are likely to identify a broader set of conditions than DOD’s 

physicians. In addition, local officials we spoke with in some of our site 

visits said that servicemembers may be more willing to disclose all of their 

medical conditions to VA than to DOD because VA could potentially 

compensate them for all of the conditions. Furthermore, VA officials noted 

that servicemembers’ health conditions may have changed between the 

time DOD physicians identified the conditions and VA performed the 

exam. Finally, DOD and VA officials said that differences in opinions about 

diagnoses are common among physicians, particularly in the mental health 

field. For example, they noted that it be can be difficult to distinguish 

PTSD from anxiety, depression, and other mental health conditions.30

Pilot Sites Faced Various 

Logistical Challenges 

Integrating VA Staff 

DOD and VA officials at several pilot sites said that they experienced some 

logistical challenges integrating VA staff at the military facilities. At a few 

sites, it took time for VA staff to receive common access cards needed to 

access the military facilities and to use the facilities’ computer systems. 

During the time that VA staff did not have access cards, they were unable 

to access VA computer systems, such as those for establishing the VA 

claim, requesting exams, and viewing exam results, via DOD’s network. 

In addition, DOD and VA staff noted several difficulties using the agencies’ 

multiple information technology (IT) systems to process cases. While the 

agencies both use the VTA system to manage cases, VA also has IT 

systems for completing certain tasks, and the military services also have 

their own case tracking systems. This causes DOD and VA staff to have to 

enter the same data multiple times into different IT systems. In addition, 

30Some DOD and VA officials also indicated that diagnostic disagreements reflect a greater 

level of scrutiny on behalf of servicemembers. 

Page 31 GAO-11-69 DOD and VA Disability Evaluation
 

some VA staff working on military bases reported that using the military 

services’ computer systems to access VA systems has significantly slowed 

down computer processing speeds. Finally, DOD and VA staff cannot 

directly access each others’ systems, making it more cumbersome for case 

managers to determine the status of servicemembers’ cases. For example, 

without access to VA’s system for managing exams, DOD board liaisons 

cannot readily provide servicemembers with information on when or 

where their exams are scheduled and must contact VA case managers to 

obtain the information. A few sites we visited were able to address some 

IT issues. For example, at Fort Polk, VA officials said they were adding a 

new telecommunications line to provide faster computer processing 

speeds for their staff. 

In addition, VA physicians working at military facilities need to be 

credentialed by DOD before they can begin working on base, which 

involves verification of their education, license, and clinical history. Some 

VA officials said that this process could take 1 month or longer to 

complete.31

Extended Periods in the 

Military Disability 

Evaluation Process Posed 

Housing and Other 

Challenges at Some Pilot 

Sites 

Although many DOD and VA officials we interviewed at central offices and 

pilot sites felt that the IDES process expedited the delivery of VA benefits 

to servicemembers, several also indicated that it may increase the amount 

of time servicemembers are in the military’s disability evaluation process. 

Data on legacy cases are not sufficiently reliable to determine whether this 

is the case military-wide, but Army data appear to be sufficiently reliable 

to allow for some limited analysis. Our analysis of Army pilot and legacy 

data as of early 2010 shows that compared with legacy cases, active duty 

cases in the pilot took on average 39 more days to reach the end of the 

PEB phase—the last step of the DOD disability evaluation process before 

servicemembers begin transitioning from military service or, if found fit, 

back to duty. For reserve component cases in the Army, IDES pilot cases 

took on average 17 more days to reach the end of the PEB phase, 

compared with legacy cases. It was not possible to conduct this analysis 

for the other military services because their legacy data lacked 

information on when servicemembers were referred into the disability 

evaluation system. 

 

31In its comments on a draft of our report, VA informed us that VHA is starting discussions 

with DOD and The Joint Commission (a nonprofit organization that evaluates and accredits 

health care organizations) on streamlining certain processes, including simplifying the 

credentialing process. 

Page 32 GAO-11-69 DOD and VA Disability Evaluation
 

Some DOD officials noted that the increased time that servicemembers are 

in the military’s disability evaluation process means that they must be 

cared for and managed for a longer period. Officials in our site visits and 

interviews said that some pilot sites have had challenges housing 

servicemembers in the IDES, in part due to servicemembers being in the 

process longer. For some servicemembers in the disability evaluation 

system, the military services may move them to temporary medical units 

or, for those needing longer-term medical care or complex case 

management, to special medical units such as a Warrior Transition Unit in 

the Army or Wounded Warrior Regiment in the Marine Corps.32 However, 

these units were full at a few pilot sites we visited, or members in the IDES 

did not meet the criteria for entering the special medical units. Where 

servicemembers remain with their units while going through the disability 

evaluation system, the units cannot replace them with able-bodied 

members. Officials at Fort Carson said that this created a challenge for 

combat units. Because most servicemembers in the IDES did not meet the 

criteria for entering Warrior Transition Units, combat units had to find 

another organizational unit to take charge of members in the IDES so they 

could replace them with soldiers ready and able to deploy to combat 

areas. In addition, officials at Naval Medical Center San Diego and Fort 

Carson said that some members are not gainfully employed by their units 

and, left idle while waiting to complete their disability evaluation process, 

are more likely to engage in negative behavior, potentially resulting in 

their being discharged due to misconduct and a forfeiture of disability 

benefits.33 We were unable to assess the extent or cause of this problem 

because the VTA system that tracks servicemembers in the IDES does not 

capture sufficient detail on reasons for servicemembers dropping out of 

the IDES, or which organizational unit(s) the servicemember was assigned 

to while in the IDES. DOD officials also noted that servicemembers benefit 

from continuing to receive their salaries and benefits while their case 

 

32The Air Force and Navy do not have comparable special medical units, although they have 

temporary medical hold units. For further information on the Army’s Warrior Transition 

Units, see GAO, Army Health Care: Progress Made in Staffing and Monitoring Units that

Provide Outpatient Case Management, but Additional Steps Needed, GAO-09-357 

(Washington, D.C.: Apr. 20, 2009). 

33Officials at Naval Medical Center San Diego were particularly concerned about the length 

of the process for recruits in basic training. Under the legacy system, there had been an 

expedited disability evaluation process for military recruits injured during basic training. At 

IDES pilot sites, recruits went through the longer IDES process. DOD is currently 

developing an expedited IDES process for recruits. 

Page 33 GAO-11-69 DOD and VA Disability Evaluation
 

undergoes scrutiny by two agencies, though some also acknowledged that 

these additional salaries and benefits create costs for DOD. 

DOD and VA 

Expansion Plans 

Address Some 

Though Not All 

Challenges 

DOD and VA Have 

Incorporated Many 

Lessons Learned into Their 

Planning for Worldwide 

Expansion of the IDES but 

Lack Concrete Plans for 

Addressing Some 

Challenges 

DOD and VA plan to expand the IDES to sites worldwide on an ambitious 

timetable—to 113 sites during fiscal year 2011, a pace of about 1 site every 

3 days. Expansion is scheduled to occur in four stages, beginning with 

28 sites in the southeastern and western United States by the end of 

December 2010.34

DOD and VA have many efforts under way to prepare for IDES expansion. 

At each site, local DOD and VA officials are expected to work together to 

prepare for implementation. This includes completing a site assessment 

matrix—a checklist of information DOD and VA officials at each site 

should obtain and preparations they should make. While most pilot sites 

had used a site assessment matrix to prepare for IDES implementation, the 

agencies completed a significant revision of the matrix in August 2010, and 

they now request additional information and documentation to address 

areas where prior IDES sites had experienced challenges. In addition, 

while during the pilot phase local DOD and VA officials were encouraged 

to develop written agreements on IDES procedures, the matrix now 

requests that a written agreement be completed prior to implementing the 

IDES. Finally, senior-level local DOD and VA officials will be expected to 

sign the site assessment matrix to certify that a site is ready for IDES 

implementation. This differs from the pilot phase where, according to 

DOD and VA officials, some sites implemented the IDES without having 

been fully prepared. In addition, in September 2010, the military services 

and VA held preimplementation training conferences for local DOD and 

 

34DOD and VA had originally planned for 34 sites to implement the IDES by the end of 

December 2010. However, the Army postponed implementation at 6 sites. 

Page 34 GAO-11-69 DOD and VA Disability Evaluation
 

VA staff. At the time of our review, the first 28 expansion sites were 

completing their site assessment matrices. 

Through the new site assessment matrix and other initiatives under way, 

DOD and VA are addressing several of the challenges identified in the pilot 

phase. These include ensuring sufficient exam and case management staff, 

being prepared to deal with surges in caseloads, addressing exam 

sufficiency issues, and making adequate logistical arrangements. 

Ensuring sufficient exam resources: The matrix asks whether a site can 

complete single exams within the IDES’ 45-day time frame and within 

DOD’s TRICARE access standards.35 The matrix asks for detailed 

information, such as who will conduct the exams (VA, VA contractor, or 

military providers), where the exams will be conducted, and VA’s 

anticipated overall volume of disability compensation and pension exams 

in the area. In addition to the matrix, VA has several initiatives under way 

to increase resources and expedite exams. VA plans to award a new 

contract under which it can acquire examiners for sites that do not have 

sufficient staff to perform exams, such as sites located where VA does not 

have medical facilities or in rural areas where VA has had difficulty hiring 

staff. VA has also recently changed its exam policy so that exams 

performed by nurse practitioners or physician assistants certified to 

perform disability exams no longer have to be cosigned by a physician, 

which is expected to expedite completion of more exam reports. 

Ensuring sufficient VA rating staff: VA officials said that they have hired 

new staff to replace those that recently left the Baltimore rating office and 

anticipate hiring a small number of additional staff. Based on caseload 

projections, they expect that, once the additional staff are hired, the 

Baltimore office will be close to having sufficient rating staff. Although VA 

officials said that the Baltimore office conducted ratings for a majority of 

cases during the IDES pilot phase, they have projected that the workload 

will be divided almost evenly between the Baltimore and Seattle offices 

once the IDES is fully expanded worldwide. 

Ensuring sufficient DOD PEB adjudicators: Air Force officials informed 

us they added adjudicators for the informal PEB and have since eliminated 

 

35DOD’s TRICARE Prime access standards are based on the minimum time a beneficiary 

should have to wait for an appointment, and the provider’s distance from the beneficiary’s 

residence. For example, the standard for routine care is an appointment within 7 calendar 

days, and a provider not more than 30 minutes’ travel time from the beneficiary’s residence. 

Page 35 GAO-11-69 DOD and VA Disability Evaluation
 

their case backlog. They are currently adding adjudicators for the formal 

PEB. Navy PEB officials also said that they are adding adjudicators 

through activation of reserve component personnel for special work and 

expected that they would be in place by November 2010. 

Ensuring sufficient case management staffing: The site assessment 

matrix also asks whether local facilities will have sufficient trained DOD 

board liaison staff to meet a 1:20 caseload ratio and sufficient VA case 

managers to meet a 1:30 caseload ratio. In addition, according to DOD 

officials, each of the military services is increasing its board liaison 

staffing levels to achieve 1:20 caseload ratios. VA officials said that they 

plan to hire an additional 73 case managers. 

Coping with caseload surges: The matrix asks sites to provide a longer 

and more detailed caseload history—a 2-year, month-by-month history—

as opposed to the 1-year history that DOD based its caseload projections 

on during the pilot phase. In addition, the matrix asks sites to anticipate 

any surges in caseloads, such as those due to seasonal trends. Sites are 

also expected to provide a written contingency plan for dealing with 

caseload surges. In addition, the matrix asks sites to develop a system for 

communicating updates, such as information on expected caseload surges, 

to stakeholders. VA officials also said that the Army has agreed to keep 

them better informed of deployments that could result in caseload surges. 

Further, VA officials noted that they are developing a plan for addressing 

the additional need for examiners during surges, through which VA offices 

with lower demand for disability exams would send examiners to an IDES 

site experiencing a surge in exam workloads. 

Ensuring the sufficiency of single exams: The site assessment matrix 

asks sites whether all staff who will conduct exams are trained to VA 

standards and certified by VA to conduct disability compensation and 

pension exams. In addition, VA has begun the process of revising its exam 

templates, to better ensure that examiners include the information needed 

for a VA disability rating decision and enable them to complete their exam 

reports in less time. Finally, a VA official stated that VA is examining 

whether it can add capabilities to the VTA system that would enable staff 

to identify where problems with exams have occurred and track the 

progress of their resolution. For sites that choose to have military 

physicians perform the single exams, VA officials said that they have 

provided materials to DOD from their national training program, and DOD 

has made these materials accessible on its Web site. To help improve the 

ability of DOD board liaisons to obtain servicemembers’ medical and 

personnel records prior to the exam, DOD officials said that they are 

Page 36 GAO-11-69 DOD and VA Disability Evaluation
 

revising their policies to require reserve component units to provide the 

records when a reserve member is referred to the IDES. 

Ensuring adequate logistics at IDES sites: The site assessment matrix 

asks sites whether they have the logistical arrangements needed to 

implement the IDES, including necessary facilities, IT, and transportation 

for servicemembers to exam locations. For example, the matrix asks 

whether the military treatment facility will address the needs of VA staff 

for access cards, identification badges, and security clearances, and 

whether all VA medical providers will be credentialed and privileged to 

practice at the DOD facility. In terms of IT, the matrix asks whether DOD 

sites will enable VA staff access to VA information systems needed to 

perform their duties. The matrix also asks sites to identify IT contacts 

from both VA and DOD so that they may work together to resolve IT 

problems. Furthermore, DOD and VA are developing a general 

memorandum of agreement on IDES information sharing. This agreement 

is intended to enable DOD and VA staff access to each other’s IT systems, 

for example, to allow DOD staff to track the status of VA exams. DOD 

officials also said that they are developing two new IT solutions. 

According to officials, one system currently being tested would help 

military treatment facilities better manage their cases. Another IT solution, 

still at a preliminary stage of development, would integrate the VTA with 

the services’ case tracking systems so as to reduce multiple data entry. 

However, in some areas, DOD and VA’s efforts to prepare for IDES 

expansion do not fully address some challenges or are not yet complete. 

Ensuring sufficient military physician staffing: While DOD and VA are 

taking steps to address shortages of examiners, case managers, and 

adjudicators, they do not yet have strategies or plans to address potential 

shortages of military physicians for completing MEB determinations. For 

example, the site assessment matrix does not include a question about the 

sufficiency of military providers to handle expected numbers of MEB 

cases at the site, or ask sites to identify strategies for ensuring sufficient 

military physicians if there is a caseload surge or staff turnover. 

Ensuring sufficient housing and organizational oversight for IDES 

participants: Although the site assessment matrix asks sites whether they 

will have sufficient temporary housing available for servicemembers going 

through the IDES, the matrix requires only a yes or no response and does 

not ensure that sites will have conducted a thorough review of their 

housing capacity prior to implementing the IDES. For example, sites are 

not asked about the capacity of their medical hold units or special units 

Page 37 GAO-11-69 DOD and VA Disability Evaluation
 

for wounded servicemembers, or to identify other options if their existing 

units do not have sufficient capacity for their projected IDES caseload. In 

addition, the site assessment matrix does not address whether sites have 

plans for ensuring that IDES participants are gainfully employed or 

sufficiently supported by their organizational units. 

Addressing differences in diagnoses: According to a DOD official, as part 

of its revision of its IDES operations manual, DOD is currently developing 

guidance on how staff should address differences in diagnoses between 

military physicians and VA examiners, and between military PEBs and VA 

disability rating staff. DOD anticipated issuing the new guidance in 

September 2010, but at the time of our review had not yet done so. In 

addition, a VA official stated that VA is developing new procedures for 

identifying cases with potential for multiple mental health diagnoses and 

will ask VA examiners to review the servicemembers’ medical records and 

reconcile differing diagnoses. However, since the new guidance and 

procedures are still being developed, we cannot determine whether they 

will resolve discrepancies or disagreements. Significantly, DOD and VA do 

not have a mechanism for tracking disagreements about diagnoses and 

ratings, and consequently, may not be able to determine whether the 

guidance sufficiently addresses the discrepancies or whether it requires 

further revision. 

DOD and VA Lack a 

Mechanism for Monitoring 

Problems That May 

Emerge with Full 

Implementation 

As DOD and VA move quickly to implement the IDES worldwide, they 

have some mechanisms in place to monitor challenges that may arise in 

the IDES. DOD officials said that they expect to continue holding 

postimplementation “hotwash” meetings, in which they review individual 

sites’ implementation. In addition, DOD and VA will continue to regularly 

collect and report data on caseloads, processing times, and 

servicemember satisfaction. Furthermore, the new site assessment matrix 

asks sites to develop plans for VA and DOD local staff to meet weekly for 

the first 60 to 90 days after implementing the IDES, then no less than 

monthly to address any identified challenges. VA officials also said that 

they will continue to prepare a report on an annual basis on challenges in 

the IDES. To prepare this report, they will obtain input and data from local 

DOD and VA officials. 

However, DOD and VA do not have a system-wide monitoring mechanism 

to help ensure that steps they took to address challenges are sufficient and 

to identify problems in a more timely basis. For example, they do not 

collect data centrally on staffing levels relative to caseload. Consequently, 

despite efforts to acquire additional staff, as local sites experience staffing 

Page 38 GAO-11-69 DOD and VA Disability Evaluation
 

turnover in the future, DOD and VA central offices may not become aware 

that a site is short-staffed until their monitoring reports show lengthy 

processing times. As a result, DOD and VA may be delayed in taking 

corrective action, since it takes time to assess what types of staff are 

needed at a site and to hire or reassign staff. In addition, without 

information on when or how often other problems occur, such as 

insufficient exam summaries or disagreements about diagnoses, DOD and 

VA managers may not be able to target additional training or guidance 

where needed. Furthermore, while DOD and VA report data on processing 

times by phase of the process, military treatment facility, and military 

service, their monitoring reports do not show processing times or 

caseloads for each VA rating office and each of the five PEBs (three Army 

and one each for the Navy and Air Force), limiting their ability to identify 

if specific rating or PEB offices are experiencing challenges. 

DOD and VA also lack mechanisms or forums for systematically sharing 

information on challenges as well as best practices. For example, while 

the site assessment matrix indicates that sites are expected to hold 

periodic meetings to identify local challenges, DOD and VA have not 

established a process for local sites to systematically report those 

challenges to DOD and VA management and for lessons learned to be 

systematically shared system-wide. During the pilot phase, VA surveyed 

pilot sites on a monthly basis about challenges they faced in completing 

single exams. Such a practice has the potential to provide useful feedback 

if extended to other IDES challenges. 

By merging two duplicative disability evaluation systems, the IDES shows 

promise for expediting the delivery of VA benefits to servicemembers 

leaving the military due to a disability. Servicemembers who proceed 

through the process are able to leave the military with greater financial 

security, since they receive disability benefits from both agencies shortly 

after discharge. Further, having both DOD and VA personnel involved in 

reviewing each disability evaluation may result in a more thorough 

scrutiny of cases and informed decisions on behalf of servicemembers. 

Conclusions 

However, piloting of the system at 27 sites has revealed several significant 

challenges that require careful management attention and oversight before 

DOD and VA expand the system military-wide. DOD and VA are currently 

taking steps to address many of these challenges, and the agencies have 

developed a site implementation process that encourages local DOD and 

VA officials to identify and resolve local challenges prior to transitioning 

to the new system. However, given the agencies’ ambitious 

Page 39 GAO-11-69 DOD and VA Disability Evaluation
 

implementation schedule—more than 100 sites in a year—it is unclear 

whether all of these challenges will be fully dealt with before DOD and VA 

deploy the integrated system to additional military facilities. For example, 

it is unclear whether sites will have sufficient military physicians to 

complete key steps of the process in a timely manner. Insufficient staffing 

of any one part of the process is likely to lead to bottlenecks, delaying not 

only servicemembers’ receipt of disability benefits, but also their 

separation from the military and reentry into civilian life. In addition, 

DOD’s preparations of sites for the IDES do not ensure that military 

facilities have adequate capacity or plans for housing and providing 

organizational oversight over servicemembers in the IDES, who potentially 

could remain at the locations for extended periods of time. Furthermore, 

while integrating VA medical exams into DOD’s disability evaluation 

system eliminates duplicative exams, it raises the potential for there to be 

disagreements about diagnoses of servicemembers’ conditions, with 

implications for servicemembers’ disability ratings and their DOD 

disability compensation. While DOD is developing guidance to address 

such disagreements, it is important that the agencies have a thorough 

understanding of how often and why these disagreements occur and 

continually review whether their new guidance adequately addresses this 

issue so as to be able to make improvements where needed. 

Successful implementation of any program requires effective monitoring. 

DOD and VA currently have mechanisms to track numbers of cases 

processed, timeliness, and servicemember satisfaction, but they do not 

routinely monitor factors—such as staffing levels relative to caseload, 

disagreements about diagnoses, and insufficient exam summaries—that 

can delay the process. In addition, they do not monitor timeliness and 

caseloads for some of the key IDES offices, namely each VA rating office 

and each PEB. Ultimately, the success or failure of the IDES will depend 

on DOD and VA’s ability to sufficiently staff local sites, the VA rating 

offices, and the PEBs, and to resolve other challenges not only at the 

initiation of the transition to IDES but also on an ongoing, long-term basis. 

By not monitoring staffing and other risk factors, DOD and VA may not be 

able to ensure that their efforts to address these factors are sufficient or to 

identify problems as they emerge and take immediate steps to address 

them before they become major problems. 

Page 40 GAO-11-69 DOD and VA Disability Evaluation
 

To ensure that the IDES is sufficiently staffed and that military treatment 

facilities are prepared to house personnel in the IDES, we recommend that 

the Secretary of Defense direct the military services to conduct thorough 

assessments prior to each site’s implementation of the IDES of the 

following three issues: 

Recommendations for 

Executive Action 

• the adequacy of staffing of military physicians for completing MEB 

determinations at military treatment facilities; contingency plans should 

be developed to address potential staffing shortfalls, for example, due to 

staff turnover or caseload surges; 

• the availability of housing for servicemembers in the IDES at military 

facilities; alternative housing options should be identified if sites do not 

have adequate capacity; and 

• the capacity of organizational units to absorb servicemembers undergoing 

the disability evaluation; plans should be in place to ensure 

servicemembers are appropriately and constructively engaged. 

To improve their agencies’ ability to resolve differences about diagnoses of 

servicemembers’ conditions, and to determine whether their new guidance 

sufficiently addresses these disagreements, we recommend that the 

Secretaries of Defense and Veterans Affairs take the following two actions: 

• conduct a study to assess the prevalence and causes of such 

disagreements; and 

• establish a mechanism to continuously monitor disagreements about 

diagnoses between military physicians and VA examiners and between 

PEBs and VA rating offices. 

To enable their agencies to take early action on problems at IDES sites 

postimplementation, we recommend that the Secretaries of Defense and 

Veterans Affairs develop a system-wide monitoring mechanism to identify 

challenges as they arise in all DOD and VA facilities and offices involved in 

the IDES. This system could include: 

• continuous collection and analysis of data on DOD and VA staffing levels, 

sufficiency of exam summaries, and diagnostic disagreements; 

• monitoring of available data on caseloads and case processing time by 

individual VA rating office and PEB; and 

Page 41 GAO-11-69 DOD and VA Disability Evaluation
 

• a formal mechanism for agency officials at local DOD and VA facilities to 

communicate challenges and best practices to DOD and VA headquarters 

offices. 

We provided a draft of this report to DOD and VA for review and 

comment. The agencies provided written comments, which are 

reproduced in appendixes III and IV. DOD and VA generally concurred 

with our recommendations. Each agency also provided technical 

comments, which we incorporated as appropriate. 

Agency Comments 

and Our Evaluation 

DOD concurred with our recommendation to ensure that, before the IDES 

is implemented at each new site, a thorough assessment be done of the 

site’s staffing adequacy, the availability of housing for servicemembers in 

the IDES, and the capacity of organizational units to appropriately and 

constructively engage servicemembers in the IDES. However, DOD stated 

that the IDES site assessment matrix addresses plans to ensure that 

servicemembers are gainfully employed while in the IDES. We changed 

our report to more clearly indicate that the site assessment matrix does 

not, in fact, address such plans. We believe that specifically identifying this 

in the matrix could help local DOD officials, including servicemembers’ 

unit commanders, focus on ensuring gainful employment or other support. 

DOD concurred, and VA concurred in principle, with our recommendation 

to study and establish mechanisms to monitor diagnostic differences. VA 

identified a plan to study the prevalence and causes of diagnostic 

differences and determine by July 1, 2011, whether mechanisms are 

needed. DOD stated that it expects, as diagnostic differences are 

monitored and studied, that the agencies will address and resolve many of 

the issues identified in our report. We agree that the planned study could 

yield valuable insights on how to resolve diagnostic differences but 

emphasize that continuous monitoring of such differences over a period of 

time may be needed to assess the extent and nature of such differences, as 

well as the success of any actions to address them. 

Both agencies concurred with our recommendation to develop monitoring 

mechanisms to help them take early actions on problems that may arise at 

IDES sites postimplementation. VA stated that the VTA system currently 

has data that can be monitored by PEB and VA rating site, and DOD said 

its weekly monitoring report could be modified to present these data. Also, 

VHA plans to monitor the IDES exam workload, including numbers of 

exam requests compared with forecasts, exam timeliness, and insufficient 

exams. Implementation is scheduled for December 31, 2010. In terms of 

Page 42 GAO-11-69 DOD and VA Disability Evaluation
 

identifying site implementation problems for quick resolution, DOD stated 

that the military services bring sites’ challenges and best practices to the 

Disability Advisory Council, a DOD body that includes VA representatives, 

which is being re-chartered as part of the Benefits Executive Council, a 

subgroup of the VA-DOD Joint Executive Council. VA and DOD’s plans 

sound promising and consistent with our recommendations provided that 

they allow for ongoing monitoring of site staffing levels and create a 

systematic way for local DOD and VA staff to communicate their 

challenges or best practices, enabling the agencies to identify and address 

problems at an early stage. 

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, the Secretary of Veterans Affairs, 

and other interested parties. The report is also available at no charge on 

the GAO Web site at www.gao.gov. 

If you or your staff members have any questions about this report, please 

contact me at (202) 512-7215 or at bertonid@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Staff members who made key contributions in 

Daniel Bertoni 

this report are listed in appendix V. 

Director, Education, Workforce, 

 and Income Security Issues 

Page 43 GAO-11-69 DOD and VA Disability Evaluation
 

List of Committees 

The Honorable Carl Levin 

Chairman 

The Honorable John McCain 

Ranking Member 

Committee on Armed Services 

United States Senate 

The Honorable Daniel Akaka 

Chairman 

The Honorable Richard Burr 

Ranking Member 

Committee on Veterans’ Affairs 

United States Senate 

The Honorable Daniel Inouye 

Chairman 

The Honorable Thad Cochran 

Ranking Member 

Subcommittee on Defense 

Committee on Appropriations 

United States Senate 

The Honorable Tim Johnson 

Chairman 

The Honorable Kay Bailey Hutchison 

Ranking Member 

Subcommittee on Military Construction, 

 Veterans Affairs, and Related Agencies 

Committee on Appropriations 

United States Senate 

The Honorable Ike Skelton 

Chairman 

The Honorable Howard P. “Buck” McKeon 

Ranking Member 

Committee on Armed Services 

House of Representatives 

Page 44 GAO-11-69 DOD and VA Disability Evaluation
 

The Honorable Bob Filner 

Chairman 

The Honorable Steve Buyer 

Ranking Member 

Committee on Veterans’ Affairs 

House of Representatives 

The Honorable Norman Dicks 

Chairman 

The Honorable C. W. Bill Young 

Ranking Member 

Subcommittee on Defense 

Committee on Appropriations 

House of Representatives 

The Honorable Chet Edwards 

Chairman 

The Honorable Zach Wamp 

Ranking Member 

Subcommittee on Military Construction, 

 Veterans Affairs, and Related Agencies 

Committee on Appropriations 

House of Representatives 

Page 45 GAO-11-69 DOD and VA Disability Evaluation
Appendix I: 

Methodology 

Objectives, Scope, and 

Page 46 GAO-11-69 

Appendix I: Objectives, Scope, and 

Methodology 

In conducting our review of the integrated disability evaluation system 

(IDES) piloted by the Departments of Defense (DOD) and Veterans Affairs 

(VA), our objectives were to examine (1) the results of DOD and VA’s 

evaluation of the IDES pilot, (2) challenges in implementing the piloted 

system to date, and (3) DOD and VA plans to expand the piloted system 

and whether those plans adequately address potential challenges. We 

conducted this performance audit from November 2009 to December 2010, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

To address objective 1, we reviewed DOD and VA policy guidance, reports, 

and analysis plans to determine how the agencies are evaluating the pilot’s 

effectiveness and to obtain information on their results. We also reviewed 

the relevant requirements of the National Defense Authorization Act of 

2008 as it pertains to this review. In addition, we interviewed officials 

responsible for the evaluation at DOD’s Office of the Deputy Under 

Secretary of Defense for Wounded Warrior Care & Transition Policy 

(WWCTP), DOD’s Defense Manpower Data Center, and two organizations 

that DOD has contracted with to perform the evaluation—Booz Allen 

Hamilton and Westat. We then tested the reliability of the data the 

agencies are using for their evaluation—data from surveys of 

servicemembers, IDES case data from the Veterans Tracking Application 

(VTA) system, and legacy case data that DOD’s WWCTP obtained from the 

military services. Finally, we conducted some analyses of IDES and legacy 

case data for the Army to compare the two systems on timeliness and 

appeal rates, using elements of the data that we found to be reliable, but 

these comparisons have limitations and are not generalizable to other 

military services. The sections below describe our data reliability work 

and our analysis of Army data in further detail. 

Review of DOD and 

VA’s Evaluation of the 

IDES Pilot 

Review of Satisfaction 

Survey Data Reliability 

DOD and VA have been surveying servicemembers going through the IDES 

pilot, and a comparison group of veterans who went through the standard 

“legacy” disability evaluation system, to determine whether the IDES pilot 

has improved servicemember satisfaction. The agencies survey all 

servicemembers in the IDES pilot at three points in time—following their 

completion of the medical evaluation board (MEB) of the disability 

evaluation process, completion of the physical evaluation board (PEB), 

 DOD and VA Disability Evaluation 
Appendix I: Objectives, Scope, and 

Methodology 

and during the transition phase. To create a comparison group, the 

agencies sampled veterans who have been through the legacy system at 

current pilot sites. Their sampling methods were designed to ensure that 

the pilot and legacy groups were of comparable size and had similar 

proportions of servicemembers found unfit for duty. DOD and VA are 

analyzing the differences between the pilot and legacy groups’ average 

responses on four “survey composites,” or general categories composed of 

several survey questions: overall experience, fairness, DOD board liaison 

officer customer service, and VA case manager customer service. 

We reviewed the reliability of surveys DOD and VA are using to obtain 

information on satisfaction levels by examining their survey design and 

analysis. To do so, we interviewed officials at DOD’s Defense Manpower 

Data Center and Westat responsible for implementing the survey, as well 

as officials at WWCTP and Booz Allen Hamilton responsible for designing 

the survey and analyzing the survey data. We also reviewed the survey 

instruments, response rates, data analysis plans, analysis results, and 

survey data as of February 28, 2010. We found DOD’s survey 

methodology—and the data derived using that methodology—to be 

reliable for purposes of comparing servicemembers’ satisfaction levels in 

the IDES and legacy disability evaluation systems. 

Pilot and Legacy Case Data 

Reliability Tests 

DOD and VA are collecting data on IDES pilot cases through the VTA and 

are using these data to conduct ongoing monitoring of case processing 

times and appeal rates, with the results presented in weekly reports. VA 

manages VTA, but evaluation of the data is primarily conducted by staff at 

DOD’s WWCTP and Booz Allen Hamilton. 

For their August 2010 interim report to Congress, DOD staff created a data 

set used to compare pilot and legacy processing times and appeal rates. 

This data set included IDES pilot cases as of February 28, 2010, with the 

earliest case started in November 2007. The data set also included data, as 

of January 31, 2010, on legacy cases started between fiscal years 2005 and 

2009 at the first 21 sites operating the IDES pilot, prior to pilot 

implementation. The agencies also matched legacy case data from each of 

the military services with VA data, in order to capture additional 

processing time it took for servicemembers to navigate the VA disability 

claims process. Because the data set was created from February 2010 pilot 

data, it only included about one-third of the IDES pilot cases that were 

completed as of August 29, 2010. The February 2010 data set included 

cases from 17 of the 27 current pilot sites, and 7 of the 17 sites—including 

some of the pilot sites with the largest caseloads such as Fort Carson and 

Page 47 GAO-11-69 DOD and VA Disability Evaluation
Appendix I: Objectives, Scope, and 

Methodology 

Camp Lejeune—had fewer than 20 completed cases each when the data 

set was created. 

To assess whether the data DOD and VA are using for their monitoring and 

evaluation are reliable, we obtained the early 2010 data set that the 

agencies planned to use for their evaluation report to Congress. We 

restricted our reliability assessments to the specific variables that the 

agencies used in their analyses. Following steps detailed below, we found 

that the IDES pilot case data were sufficiently reliable for our analyses, 

but that the legacy case data were incomplete with respect to data 

elements key to measuring case processing time and appeal rates. 

To assess the reliability of the agencies’ IDES pilot data, we interviewed 

VA database managers responsible for VTA, reviewed VTA manuals and 

guidance, conducted electronic tests of the data and, for a small, random 

sample of cases, checked the data against case files. 

• Through our interviews and document reviews, we concluded that the 

agencies have sufficient internal controls to give reasonable assurance 

that the data are complete. 

• Our electronic testing of the data generally found low rates of missing data 

and errors in completed IDES cases. In these tests, we considered a data 

element to be sufficiently reliable for purposes of using in our report if 15 

percent or less of the data were missing or had errors. Using this standard, 

we determined that one data element for IDES cases—the date that 

servicemembers separated from the military—was not reliable, because: 

(1) it was missing in 19 percent of completed cases and (2) in cases where 

the date was present, more than 30 percent appeared to have errors (for 

example, the date was before a step of the process that it should have 

followed). 

• We also conducted a trace-to-file process to determine whether date fields 

in the VTA system were an accurate reflection of the information in the 

IDES case files. Specifically, we compared 12 date fields in the VTA 

against a random sample of paper files for 54 completed cases: 24 from the 

three Army PEBs, 10 from the Air Force PEB, and 20 from the Navy PEB 

(10 Navy cases and 10 Marine Corps).1

 In comparing these dates, we 

 

1

We had originally requested files for 30 Army cases, 10 from each Army PEB. However, 

one PEB had only completed 4 IDES cases at that time, so they provided us with those 4 

cases. 

Page 48 GAO-11-69 DOD and VA Disability Evaluation
Appendix I: Objectives, Scope, and 

Methodology 

allowed for a 10 percent discrepancy in dates—i.e., a difference of 2 to 10 

days, depending on the date and phase of the process2

—to allow for the 

possibility that dates may have been entered into the database after an 

event took place. The trace-to-file process resulted in an overall accuracy 

rate of 84 percent. For five data elements key to DOD and VA’s evaluation 

of the IDES pilot, we found that VTA dates reflected dates in the case files 

85 percent of the time or better. For six key data elements—i.e., the end 

dates of the exam and MEB phases, the start of the PEB phase, the date a 

VA rating request was made, the date of the final disposition, and the date 

servicemembers received VA benefits—the VTA dates matched case file 

dates between 70 to 85 percent of the time. Although we considered these 

dates sufficiently reliable to include in this report, these dates should be 

interpreted with more caution. The separation date was accurate less than 

70 percent of the time and did not meet our standards of reliability. 

To assess the reliability of the legacy data that the agencies planned to 

compare the IDES pilot against, we tested the data electronically, and 

found that data for key dates and appeals indicators had significant gaps 

because the services did not collect the same information for legacy cases 

that were collected for pilot cases (see table 2). For example, only Army 

cases had information on when servicemembers were referred to the MEB 

process. In addition, the legacy data did not include the date on when 

servicemembers received VA benefits—which is necessary for measuring 

the full length of the legacy process. Without sufficient data on the 

beginning (when servicemembers were referred into the system) or end of 

the process (when they received VA benefits), we concluded that the full 

case processing time in the legacy system cannot be known. We also 

concluded that comparisons could not be made between the legacy and 

IDES pilot on appeal rates because only Army and Air Force cases had 

information on whether servicemembers appealed the informal PEB 

decisions. 

 

2

Specifically, we allowed for a 10 percent discrepancy in dates, which fluctuated depending 

on the length of the process phase. For example, for the Final Disposition date in the 

Transition phase, we allowed for a discrepancy of 5 days which is 10 percent of the 45 day 

goal for that stage of the process, rounded up. 

Page 49 GAO-11-69 DOD and VA Disability Evaluation
Appendix I: Objectives, Scope, and 

Methodology 

Table 2: Percentage of Legacy Cases with Referral and Appeal Dates, by Military 

Service 

Key data elements Army Navy Marine Corps Air Force All

Date of referral 100.0% 0.0% 0.0% 0.0% 62.8%

Informal PEB appeal 89.2% 0.0% 0.0% 80.3% 62.4%

Source: GAO analysis of DOD legacy case data. 

GAO’s Review of the 

Agencies’ Comparison of 

Pilot and Legacy Data 

In addition to reviewing the reliability of the IDES pilot and legacy data, 

we reviewed how DOD and VA are using the data for their comparisons of 

the two disability evaluation systems. Through interviews with officials at 

DOD’s WWCTP and Booz Allen Hamilton and documents they provided us, 

we understand that DOD planned to address gaps in the legacy data by: (1) 

approximating the referral dates in Air Force, Marine Corps, and Navy 

cases using Army data and (2) using dates when cases were ready to be 

rated by VA to approximate the end of the process. Specifically, to 

approximate referral dates, they said they would use the average time for 

Army cases between when the servicemember was referred and when the 

MEB documentation identifying the servicemember’s potentially unfitting 

medical conditions (i.e., the narrative summary) was completed, which 

they calculated to be 60 days. For Navy and Marine Corps cases, they then 

subtracted 60 days from the date of the narrative summary to estimate a 

referral date and, for Air Force cases, they did so from the date of the MEB 

decision. However, because only 11 percent of Army legacy cases had a 

narrative summary date, the estimate of 60 days is based on a small 

number of cases (see table 3). To address the lack of data on the date VA 

benefits were delivered, DOD planned to use the date that VA determined 

a case was ready to be rated to approximate the end of the process, 

though this would underestimate the length of time it took to deliver VA 

benefits in the legacy process. 

Table 3: Percentage of Legacy Cases with Data Used for DOD Comparisons, by 

Military Service 

Key data elements Army Navy Marine Corps Air Force All

Narrative summary date 10.5% 99.9% 100.0% 0.0% 35.9%

Date VA ready to rate 88.8% 87.5% 86.7% 87.6% 88.2%

Source: GAO analysis of DOD and VA legacy case data. 

Page 50 GAO-11-69 DOD and VA Disability Evaluation
Appendix I: Objectives, Scope, and 

Methodology 

For objective 1, we presented information on average processing time in 

the IDES, both overall and by military service, using information presented 

by DOD and VA in their weekly monitoring reports. Where information 

was not available in the weekly reports, we conducted our own analysis 

using the early 2010 data set that DOD and VA intended to use for their 

report to Congress. Specifically, we used these data to determine the 

proportion of pilot cases meeting the 295-day goal for active duty 

servicemembers and the 305-day goal for reserve servicemembers. 

In addition, although limitations in the legacy data preclude reliable 

comparisons between the IDES pilot and legacy systems for all the 

military services, the Army legacy data on when servicemembers were 

referred into the IDES were sufficiently complete to make some limited 

comparisons. Specifically, we analyzed Army legacy data to determine 

how long the legacy process took, on average, between when 

servicemembers were referred to the process and when VA was ready to 

conduct the disability rating. We limited our analysis to cases in which a 

VA claim was filed between 2006 and 2009 because data on when VA was 

ready to conduct the rating was missing for a substantial number of cases 

where the VA claim was filed in 2005 and 2010. We compared this legacy 

average with the total pilot case processing time through to delivery of VA 

benefits, but we noted that the legacy average does not account for time 

for VA to complete the rating and deliver the benefits. We also analyzed 

Army data on appeals in order to illustrate the limitations of DOD’s plan to 

compare only appeals to the informal PEB in the pilot and legacy systems 

and not take into account appeals of rating decisions to VA. We conducted 

this analysis using the legacy data and pilot case data as of early 2010, 

since DOD and VA’s weekly reports do not contain information on appeals 

to VA. 

To identify challenges in implementing the IDES during the pilot phase, we 

visited 10 of the 27 military treatment facilities participating in the pilot. At 

the site visits, we interviewed officials involved in implementing the IDES 

from both DOD and VA, including military facility commanders and 

administrators, DOD board liaisons, military physicians involved in MEB 

determinations, DOD legal staff, VA case workers, VA or contract 

examiners, and administrators at VA medical clinics and VA regional 

offices. We selected the 10 facilities to obtain perspectives from sites in 

different military services and geographical regions and that varied in 

terms of disability evaluation caseloads and how their single exams were 

conducted (by DOD, VA, or a VA contractor) (see table 4). 

GAO Analysis of IDES 

Case Data 

Identifying Challenges 

in Implementing the 

IDES at Pilot Sites 

Page 51 GAO-11-69 DOD and VA Disability Evaluation
Appendix I: Objectives, Scope, and 

Methodology 

Table 4: Selected Characteristics of IDES Pilot Sites Visited 

Military treatment facility Military service 

Geographic 

region IDES caseloada

Entity performing 

single exam 

71st Medical Group, Vance Air Force Base Air Force Central 21 VA contractor 

David Grant Medical Center, Travis Air Force 

Base 

Air Force West 112 VA 

Bayne Jones Army Community Hospital, Fort 

Polk 

Army South 518 VA 

Dewitt Army Community Hospital, Fort Belvoir Army East 268 VA 

Evans Army Community Hospital, Fort Carson Army Central 1,341 VA 

Walter Reed Army Medical Center Army East 936 VA 

Winn Army Community Hospital, Fort Stewart Army South 1,209 VA contractor 

Naval Hospital Camp Lejeune Navy South 1,214 VA and VA 

contractor 

Naval Hospital Camp Pendleton Navy West 537 VA contractor 

Naval Medical Center San Diego Navy West 1,447 VA 

Sources: GAO interviews and data from DOD and VA. 

a

Caseload size as of August 22, 2010. 

We also interviewed various offices at DOD and VA involved in 

implementing the IDES pilot. At DOD, this included WWCTP; Office of the 

Assistant Secretary of Defense for Health Affairs; Office of the Assistant 

Secretary of Defense for Reserve Affairs; Air Force Physical Disability 

Division; Army Physical Disability Agency; Navy Physical Evaluation 

Board; Office of the Air Force Surgeon General; Army Medical Command; 

and Navy Bureau of Medicine and Surgery. At VA, we interviewed officials 

in the Veterans Benefits Administration, Veterans Health Administration, 

and VA/DOD Collaboration Service. 

Furthermore, we reviewed relevant documents, including DOD and VA 

policies and guidance and records of “hotwash” meetings, which DOD and 

VA held shortly after implementing the IDES at pilot sites to identify 

implementation successes and challenges. We also reviewed data on 

processing times for the single exams, MEB determinations, informal PEB 

decisions, and VA ratings, as reported in the agencies’ weekly monitoring 

reports. In addition, we reviewed relevant federal laws and regulations. 

To determine whether the IDES process extended the time that 

servicemembers remained in military service, we analyzed the legacy and 

pilot case data from the early 2010 data set, but we identified several 

limitations with the data. As noted earlier, the date servicemembers 

Page 52 GAO-11-69 DOD and VA Disability Evaluation
Appendix I: Objectives, Scope, and 

Methodology 

separated from the military was missing for 19 percent of completed IDES 

pilot cases. Further, as shown in table 5, only Air Force cases contained 

data on the separation date in the legacy data. Also noted earlier, only the 

Army legacy data contained information on when servicemembers were 

referred into the legacy process. As a result, for Army cases, we compared 

the average length of time it took cases to reach a final PEB decision in the 

legacy and pilot, since this date was sufficiently complete in both the 

legacy and pilot data. The PEB decision is the last phase of the disability 

evaluation process before a servicemember either begins to transition 

from military service, or if they are found fit, returns to their unit. 

Table 5: Percentage of Legacy Cases with Data Used for Comparison of Time in 

Active Duty, by Military Service 

Key data elements Army Navy Marine Corps Air Force All

Date of separation 0.0% 0.0% 0.0% 96.5% 7.6%

Date of final disposition 89.2% 99.9% 100.0% 100.0% 93.2%

Source: GAO analysis of DOD and VA legacy case data. 

To identify the agencies’ preparations for worldwide expansion of the 

IDES, we reviewed documents on DOD and VA’s expansion strategy, their 

site assessment matrix, and weekly monitoring reports which, beginning in 

July 2010, tracked key implementation time frames, both nationally and at 

individual military treatment facilities. Our interviews with officials 

involved in the pilot at DOD, VA, and each of the military services also 

provided us with information on the agencies’ expansion plans. We also 

reviewed relevant federal laws and regulations. 

Examining DOD and 

VA’s Plans for 

Expanding the IDES 

We determined the adequacy of the agencies’ planning efforts by assessing 

whether their plans addressed the challenges we had identified in 

objective 2. We also determined whether the plans incorporated internal 

controls described in GAO’s Standards for Internal Control in the Federal 

Government and best practices for program implementation identified in 

academic literature.3

 

3

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00.21.3.1

(Washington, D.C.: November 1999); Dennis P. Slevin and Jeffrey K. Pinto, “Balancing 

Strategy and Tactics in Project Implementation,” Sloan Management Review 33 (fall 1987). 

Page 53 GAO-11-69 DOD and VA Disability Evaluation
Appendix II: ID

Reserve Comp

ES Pilot Processing Times for 

onent Servicemembers 

Page 54 GAO-11-69 

Appendix II: IDES Pilot Processing Times for 

Reserve Component Servicemembers 

The figures below show case processing times in the IDES pilot for reserve 

component servicemembers. Figure 11 shows the average number of days 

it took to complete the process—i.e., to deliver VA benefits to reserve 

component servicemembers, as of August 2010. Figure 12 shows the 

percentage of cases that met the DOD and VA goal to deliver VA benefits 

within 305 days, as of February 2010. Figures 13-15 show the average 

length of time it took, as of August 2010, to complete phases of the IDES 

process—i.e., the single exam, the MEB documentation, and the informal 

PEB decision, respectively—each of which have taken longer, on average, 

than the goals established by DOD and VA. 

Figure 11: Average Number of Days to Deliver VA Benefits for Reserve Component 

Servicemembers, by Military Service, as of August 29, 2010 

Sources: GAO presentation of weekly report data from DOD and VA.

0 50 100 150 200 250 300 350 400

All

Marine Corps

Navy

Army

Air Force

Service goal (305 days)

1 year

376

321

368

Elapsed time in days

285

298

 DOD and VA Disability Evaluation 
Appendix II: IDES Pilot Processing Times for 

Reserve Component Servicemembers 

Figure 12: Percentage of Cases Meeting 305-Day Goal for Delivery of VA Benefits to 

Reserve Component Servicemembers, by Military Service, as of February 2010 

Sources: GAO analysis of pilot case data from DOD and VA.

0 10 20 30 40 50 60 70 80

All

Marine Corps

Navy

Army

Air Force 33%

67%

71%

52%

65%

Percentage of cases meeting goal

Service goal

Page 55 GAO-11-69 DOD and VA Disability Evaluation
Appendix II: IDES Pilot Processing Times for 

Reserve Component Servicemembers 

Figure 13: Average Number of Days to Complete Single Exams for Reserve Component Servicemembers, by IDES Pilot Site, 

as of August 29, 2010 

Air Force Navy Marine Corps a

0

30

60

90

120

150

S

Bremerton

an Diego

Bethesda

Camp Lejeune

Camp Pendleton

Camp Lejeune

S

Bremerton

an Diego

Portsmouth

Bethesda

Camp Pendleton

Fort Bra

Fort Hood

gg

Fort Meade

Fort Riley

Fort Benning

Fort Polk

Fort Lewis

Fort Drum

Fort Belvoir

Fort Sam Houston

Walter Reed 

Fort Richardson

Fort Stewart

Fort Carson

Fort Wainwright

Travis

MacDill

Nellis

Elmendorf

Andrews

Service goal

(45 days)

Average

for all sites

(64 days)

Elapsed time in days

Army

88

36

136

31

26

29

61

64

Sources: GAO presentation of weekly report data from DOD and VA.

a

This figure shows processing times separately for servicemembers in the Navy and Marine Corps at 

the six Navy IDES pilot sites. DOD and VA’s data indicate that, as of August 2010, there had not yet 

been any Marine Corps reserve component servicemembers who completed the single exam in the 

IDES pilot at Naval Medical Center Portsmouth. 

Page 56 GAO-11-69 DOD and VA Disability Evaluation
Appendix II: IDES Pilot Processing Times for 

Reserve Component Servicemembers 

Figure 14: Average Number of Days to Complete MEB Documentation for Reserve Component Servicemembers, by IDES Pilot 

Site, as of August 29, 2010 

Sources: GAO presentation of weekly report data from DOD and VA.

Air Force Navy Marine Corps a

0

50

100

150

200

S

Bremerton

an Diego

Camp Pendleton

Bethesda

Camp Lejeune

S

Bremerton

an Diego

Camp Pendleton

Bethesda

Camp Lejeune

Fort Wainwright

Fort Bra

Fort Drum

gg

Fort Benning

Fort Lewis

Fort Carson

Fort Hood

Fort Stewart

Fort Polk

Fort Sam Houston

Walter Reed 

Fort Belvoir

Fort Meade

Fort Richardson

Nellis

Travis

Elmendorf

Andrews

MacDill

Average for all sites

(76 days)

Elapsed time in days

Army

177

79

51

124

22

111

Service goal (35 days) 28

12

a This figure shows processing times separately for servicemembers in the Navy and Marine Corps at 

the six Navy IDES pilot sites. DOD and VA’s data indicate that, as of August 2010, there had not yet 

been any Marine Corps reserve component servicemembers who completed the MEB phase in the 

IDES pilot at Naval Medical Center Portsmouth. 

Page 57 GAO-11-69 DOD and VA Disability Evaluation
Appendix II: IDES Pilot Processing Times for 

Reserve Component Servicemembers 

Figure 15: Average Number of Days to Complete the Informal PEB for Reserve 

Component Servicemembers, by Military Service, as of August 29, 2010 

Sources: GAO presentation of weekly report data from DOD and VA.

0 20 40 60 80 100

Marine Corps

Navy

Army

Air Force

a

Service goal (15 days)

76

26

80

106

Elapsed time in days

a

The Navy PEB determines fitness decisions for servicemembers in the Marine Corps. 

Page 58 GAO-11-69 DOD and VA Disability Evaluation
Appendix III: Comments from the Department Appendix III: Comments from the of Defense 

Department of Defense 

Page 59 GAO-11-69 DOD and VA Disability Evaluation 
Appendix III: Comments from the Department 

of Defense 

Page 60 GAO-11-69 DOD and VA Disability Evaluation
Appendix III: Comments from the Department 

of Defense 

Page 61 GAO-11-69 DOD and VA Disability Evaluation
Appendix IV: Comments from the Department Appendix IV: Comments from the of Veterans Affairs 

Department of Veterans Affairs 

Page 62 GAO-11-69 DOD and VA Disability Evaluation 
Appendix IV: Comments from the Department 

of Veterans Affairs 

Page 63 GAO-11-69 DOD and VA Disability Evaluation
Appendix IV: Comments from the Department 

of Veterans Affairs 

Page 64 GAO-11-69 DOD and VA Disability Evaluation
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 65 GAO-11-69 

Appendix V: GAO Contact and Staff 

Acknowledgments 

Daniel Bertoni, (202) 512-7215, bertonid@gao.gov

Michele Grgich (Assistant Director), Yunsian Tai (Analyst-in-Charge), 

Jeremy Conley, and Greg Whitney made significant contributions to this 

report. Walter Vance and Vanessa Taylor provided assistance with 

research methodology and data analysis. Bonnie Anderson, Rebecca 

Beale, Mark Bird, Brenda Farrell, Valerie Melvin, Patricia Owens, and 

Randall Williamson provided subject matter expertise. Susan Bernstein 

and Kathleen van Gelder provided writing assistance. James Bennett 

provided graphics assistance. Roger Thomas provided legal counsel. 

 DOD and VA Disability Evaluation 

GAO Contact 

Staff 

Acknowledgments 

(130971) 
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