VA DISABILITY 

BENEFITS

Additional Planning 

Would Enhance 

Efforts to Improve the 

Timeliness of Appeals

Decisions

Report to Congressional Addressees

March 2017

GAO-17-234

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-234, a report to 

congressional addressees

March 2017

VA DISABILITY BENEFITS

Additional Planning Would Enhance Efforts to

Improve the Timeliness of Appeals Decisions

What GAO Found

The Department of Veterans Affairs’ (VA) is taking steps to improve the 

timeliness of its benefit compensation appeals process, in which veterans who 

are dissatisfied with claims decisions by the Veterans Benefits Administration 

(VBA) can appeal first to VBA, and then to the Board of Veterans’ Appeals (the 

Board). VA has taken actions related to increasing staff, reforming the process, 

and updating information technology (IT), which are consistent with relevant 

sound planning practices. However, gaps in planning exist, thereby reducing the 

agency’s ability to ensure that these actions will improve the timeliness of 

disability appeals decisions. 

Increase staff: VA determined that staff resources have not sufficiently kept 

pace with increased pending appeals, and concluded that additional staff are 

needed, particularly at the Board, to improve timeliness and reduce its appeals 

inventory. The Board received approval to hire more staff in fiscal year 2017, and 

expects to need an additional hiring surge beginning in fiscal year 2018. As of 

October 2016, officials estimated that if the agency does not take any action, 

such as increasing staff in 2018, veterans may have to wait an average of 8.5 

years by fiscal year 2026 to have their appeals resolved. 

Consistent with sound workforce planning practices, VA modeled different

options for increasing staff levels to support its conclusion that staff increases in

conjunction with process change would reduce the appeals inventory sooner.

However, contrary to sound practices, VA often used fixed estimates for key

variables in its models—such as staff productivity—rather than a range of

estimates (sensitivity analysis) to understand the effect variation in these key

variables could have on staffing needs. Also, VA’s written workforce plans—

which cover recruiting, hiring and training—did not include detailed steps, time 

frames, and mitigation strategies consistent with sound workforce planning 

practices. For example, while VA has established a center for excellence in 

hiring to focus on recruitment and hiring, the agency has not finalized training or 

telework plans or otherwise mitigated space constraints that it encountered for

hiring staff in fiscal year 2017. Without a timely, detailed workforce plan, VA risks

delays in hiring and preparing staff to help manage workloads as soon as

possible.

Reform process: VA determined that new evidence—which a veteran can 

submit at any point during his or her appeal—inefficiently causes an additional 

round of reviews, and thus delays appeals decisions, and in response it 

proposed legislation (not enacted) to streamline the process. Consistent with 

sound practices for process redesign, VA worked with veterans service 

organizations (VSO) and other key stakeholders in developing the proposal, and 

continued to update VSOs about the development of its implementation plans. 

View GAO-17-234. For more information, 

contact Daniel Bertoni at (202) 512-7215 or 

bertonid@gao.gov. 

Why GAO Did This Study

VA compensates veterans for disabling 

conditions incurred in or aggravated by 

military service. Veterans can appeal 

VBA’s decisions on their compensation 

claims, first to VBA and then to the 

Board, a separate agency within VA. In 

fiscal year 2015, more than 427,000 

appeals were pending and veterans 

waited over 3 years on average for 

decisions. Of this total, about 81,000 

were pending at the Board and the 

average cumulative time veterans 

waited for a decision by the Board in 

2015 was almost 5 years. 

This report examines VA’s approaches 

to address challenges it identified as 

contributing to lengthy appeals 

processing times, and the extent to 

which those approaches are consistent 

with sound planning practices.

GAO focused mainly on the Board, 

which experienced an increase in 

workload of about 20 percent from 

fiscal year 2014 to 2015. GAO 

reviewed VA’s proposed plans and 

actions and compared them to sound 

practices relevant to workforce 

planning and implementing process 

redesign and new information 

technology identified in federal 

guidance, such as internal control 

standards, and prior GAO work. GAO 

also analyzed VA’s data for fiscal years 

2011-2015 (the most recent available) 

on appeals decision timeliness and 

workloads; reviewed relevant federal 

laws, regulations, and planning 

documents; and interviewed VA 

officials and veterans service 

organizations.
Highlights Page 2

VA’s proposed reform is promising, but there are several gaps in its 

implementation plans. In particular, VA plans to fully implement appeals process 

reform at the Board as well as at VBA regional offices across the country while it 

concurrently manages the existing appeals inventory, a hiring surge, and planned 

system changes discussed below. However, VA’s plans run counter to sound 

redesign practices that suggest pilot testing the process changes in a more 

limited fashion before full implementation, in order to manage risks and help 

ensure successful implementation of significant institutional change. VA officials 

told GAO that pilot testing—which would require legislation to implement—will 

prolong a process that is fundamentally broken and delay urgently needed 

repairs. However, without pilot testing VA may experience challenges and 

setbacks on a broader scale, which could undermine planned efficiencies and 

other intended outcomes. In addition, VA has not sufficiently identified how it will 

monitor progress, evaluate efficiency and effectiveness, identify trouble spots, 

and otherwise know whether implementation of its proposed process change is 

on track and meeting expectations. The absence of a robust monitoring plan with 

success criteria is inconsistent with sound planning practices for redesign and 

places the agency at risk of not being able to quickly identify and address 

setbacks. In addition, the timeliness measures that VA currently plans to report to 

Congress and the public lack transparency because they focus on individual 

parts of the agency and pieces of the new process rather than overall appeals 

resolution time from the veterans’ perspective. Without a strategy for assessing 

the proposed new process that includes comprehensive measures, VA, the 

public, and Congress cannot know the extent to which the proposed process 

represents an improvement over the old process.

Update technology: VA determined that the computer system supporting its 

appeals process is outdated, prone to failures, and does not adequately support 

electronic claims processing. VA proposed a new IT system to reduce delays in 

appeals to the Board, and better integrate data from other systems. Consistent 

with sound practices, VA clearly laid out the scope and purpose of IT upgrades, 

and identified risks and strategies to mitigate them. However, the agency’s plan 

lacks details for how and when its new system will be implemented, as 

suggested by sound planning practices for implementing new technology. 

Without a detailed schedule, VA risks not having new systems aligned with 

potential changes in the appeals process when they are implemented.

What GAO Recommends

GAO is making five recommendations

to VA and one matter for 

congressional consideration. VA 

should: apply sensitivity analyses 

when projecting staff needs, develop a 

more timely and detailed workforce 

plan, develop a robust plan for 

monitoring process reform, develop a 

strategy for assessing process reform,

and create a schedule for IT 

improvements that takes into account 

plans for potential process reform. VA 

concurred in principle with the five 

recommendations, but believes it has 

met the intent of those 

recommendations and does not need 

to take additional action. GAO

disagrees and—while recognizing

VA’s ongoing efforts—believes further 

action is needed on all five

recommendations to improve VA’s 

ability to successfully implement 

reforms, as discussed in the report.

VA disagreed with an additional draft 

recommendation that it incorporate 

pilot testing of its proposed appeals 

process into implementation plans and 

pursue necessary legislative authority. 

VA cited its perspective that the 

appeals process is broken and that 

piloting a new process would result in 

further delays to veterans appealing 

their disability decisions. GAO

maintains that the benefits of pilot 

testing—which provides an opportunity 

to resolve implementation challenges 

and make refinements to the process 

on a smaller scale—outweigh the 

potentially negative consequences of 

delaying full implementation. 

Therefore, GAO removed the 

recommendation and added a matter 

for congressional consideration stating 

that Congress should consider 

requiring that appeals process reform 

be subject to a pilot test.
Page i GAO-17-234 VA Disability Benefits

Letter 1

Background 4

VA Has Proposed Increased Staffing, Process Reform, and 

Updated IT to Improve Appeals Timeliness, and Has Taken 

Action for All Three Approaches 9

VA Applied Several Sound Planning Practices in Its Efforts to 

Improve Its Appeals Processing Timeliness, but Fell Short in 

Other Areas 20

Conclusions 35

Matter for Congressional Consideration 36

Recommendations for Executive Action 36

Agency Comments and Our Evaluation 37

Appendix I Comments from the Department of Veterans Affairs 45

Appendix II GAO Contact and Staff Acknowledgments 60

Related GAO and Other Products 61

Table

Table 1: Veteran Affairs’ (VA) Hiring Surge Options—Represented 

in Full Time Equivalents (FTE)—Estimated Impact on 

Pending Appeals Inventory 12

Figures

Figure 1: Current Process for Appeals of Veterans Affairs’ (VA) 

Disability Compensation Benefit Decisions 7

Figure 2: Board of Veterans’ Appeals Decision Times, from the 

Board’s Receipt of the Certified Appeal to Its Decision, 

Fiscal Years 2011-2015 9

Figure 3: Pending Appeals Inventory and Staff (Full-Time 

Equivalents) at the Board of Veterans’ Appeals, Fiscal 

Years 2011-2015 10

Figure 4: Department of Veterans Affairs (VA) Proposed Appeals 

Process and VA’s Estimated Breakdown of Veterans’ 

Use 16

Contents
Page ii GAO-17-234 VA Disability Benefits

Abbreviations

AOJ Agency of Original Jurisdiction

DOD Department of Defense 

DSVA Digital Service at VA

FTE full-time equivalent

IT information technology

NOD Notice of Disagreement

SOC Statement of the Case

SSOC Supplemental Statement of the Case

VA Department of Veterans Affairs

VACOLS Veterans Appeals Control and Locator System

VBA Veterans Benefits Administration

VBMS Veterans Benefits Management System

VLJ Veterans Law Judge

VSO Veterans Service Organization

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Page 1 GAO-17-234 VA Disability Benefits

441 G St. N.W.

Washington, DC 20548

March 23, 2017

Congressional Addressees

In fiscal year 2015, the Department of Veterans Affairs (VA) provided 

about $63.7 billion in disability compensation payments to about 4.1 

million veterans with disabling conditions that were incurred during or 

aggravated by their military service. VA’s Veterans Benefits 

Administration (VBA) determines veterans’ eligibility and payment 

amounts based on medical records and examinations, military service 

records, and other evidence. A veteran dissatisfied with VBA’s initial claim 

decision may appeal at two VA levels—first to VBA, then to the Board of 

Veterans’ Appeals (Board). In recent years, VA has reduced its high 

inventory of initial disability claims to fewer than 100,000, but at the same 

time, appeals inventories have grown. In fiscal year 2015, according to 

VA data, the number of appeals pending at VBA and the Board was more 

than 427,000 and veterans waited over 3 years on average for an 

appeals decision made in that fiscal year by either VBA or the Board. VA 

reported that appeals workloads at the Board almost doubled from 41,000 

in fiscal year 2011 to 81,000 in fiscal year 2015, increasing about 20 

percent from fiscal year 2014 to fiscal year 2015 and the average 

cumulative time veterans waited for an appeals decision by the Board in 

2015 was almost 5 years (1,789 days). GAO has designated VA disability 

compensation and other federal disability programs as a high-risk area, 

due in part to the challenges VA faces in deciding disability benefit claims 

(including appeals) in a timely manner.1

In light of VA’s growing appeals workload, and delays in deciding 

appeals, we conducted this review under the Comptroller General’s 

authority to conduct evaluations of significant current issues on his own 

initiative. In this report, we examined: (1) the key challenges VA identified 

that affect the timeliness of appeals decided by the Board, and what VA is 

doing to address them; and (2) the extent to which VA’s proposed 

approaches to address these challenges are consistent with sound 

planning practices. Our review largely focused on the Board’s role in the 

disability compensation appeals process, given recent increases in its 

 1

GAO, High-Risk Series: Progress on Many High Risk Areas, While Substantial Efforts 

Needed on Others, GAO-17-317 (Washington, D.C.: Feb. 15, 2017).

Letter
Page 2 GAO-17-234 VA Disability Benefits

workloads, and that GAO has not conducted a review of the Board and its 

handling of appeals in over 10 years.2

To examine key timeliness challenges and VA’s efforts to address them, 

we reviewed relevant agency reports, planning documents, budget 

submissions, and federal laws and regulations. We also interviewed VA 

officials representing the Board, VBA, and the Office of Information and 

Technology. From these sources, we identified three approaches that VA 

stressed as important to achieving significant improvements in appeals 

resolution timeliness: (1) increasing staff; (2) streamlining the appeals 

process; and (3) improving information technology (IT) support.

To provide additional perspective on workload challenges, we obtained 

VA administrative data for fiscal years 2011 through 2015 on pending 

appeals inventory, age of appeals determined in each year, number of 

staff, quality measures (such as error rates and the types of errors 

specific to appeals), and the extent to which veterans appeal cases 

repeatedly. We selected a 5-year span for our analysis using data for the 

most recent years available at the time of our request.3 We validated data 

provided by VA by comparing what we received against a data extract we 

collected from the Board’s Veterans Appeals Control and Locator System 

(VACOLS)—which is used by VA to track the status of appeals.4 We 

determined that these data were sufficiently reliable for our purposes. To 

provide further insight on workload challenges, we also interviewed 

representatives of four veterans service organizations (VSO)—the 

 2

While the Board handles appeals of benefit decisions across VA, we chose to focus on 

disability compensation-related appeals because they represent the vast majority of the 

Board’s workload. In fiscal year 2015, about 94 percent of all Board decisions were on 

appeals of VBA decisions on veterans’ disability compensation claims.

3

Within these 5 years, VA changed some of the measures it uses to track and publicly 

report appeals inventories and timeliness. Specifically, in fiscal year 2015, VA stopped 

publicly reporting Appeals Resolution Time data—time from the date the veteran files a 

notice of disagreement until a final decision is made. Instead, VA began tracking and 

reporting Board timeliness based on when the claim was certified by VBA as an appeal 

ready for review by the Board. VA was able to provide us with data from their older 

methods of tracking appeals inventories and timeliness for our data comparison across 

multiple years.

4

In all but two cases, we were able to arrive at figures that were within 5 percent of those 

provided by VA. We could not duplicate VA’s figures for the total time needed to reach a 

final decision on appeals and the end of year claims inventory numbers because they 

were based on point-in-time data that cannot be replicated from the VACOLS data we 

received. In these two cases we worked with VA to obtain explanations as to how it 

calculated these figures and we found its responses to be satisfactory.
Page 3 GAO-17-234 VA Disability Benefits

American Legion, Disabled American Veterans, National Veterans Legal 

Services Program, and Paralyzed Veterans of America—each of which 

has staff members who represent veterans before the Board, and had 

participated in recent VA efforts to improve the appeals process.

To assess the extent to which VA’s approaches to address challenges 

are consistent with sound planning practices, we identified best practices 

and other criteria through a review of relevant literature, such as 

government-wide internal control standards,5 and prior GAO reports.6 We 

specifically selected prior GAO reports where we defined a number of 

desirable characteristics of an effective, results-oriented plan, or 

components of sound planning practices.7 We also reviewed additional 

guidance pertinent to process change and project management.8

Although there is no established set of requirements for all plans, we 

incorporated relevant best practices and criteria into a data collection 

instrument reflecting sound planning practices and used this instrument to 

guide our evaluation of each of VA’s approaches. We further sought out 

and reviewed sources identifying key practices and desirable 

characteristics related to VA’s three key approaches (staffing, process 

reform, and IT upgrades) to improving review processes and workloads 

including strategic planning practices, transformation plans, technology 

upgrades, and human capital improvements (mostly increasing staffing). 

For example, for approaches related to staffing, we referred to reports 

with key principles for effective strategic workforce planning;9 for process 

 5

OMB. Circular A-11 (Washington, D.C.: July 2016).

6

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sep. 10, 2014). 

7

GAO, Combating Terrorism: Evaluation of Selected Characteristics in National Strategies 

Related to Terrorism, GAO-04-408T (Washington, D.C.: Feb. 3, 2004), and Executive 

Guide: Effectively Implementing the Government Performance and Results Act, 

GAO/GGD-96-118 (Washington, D.C.: June 1996).

8

Simon Blackburn, Sarah Ryerson, Leigh Weiss, Sarah Wilson, and Carter Wood, Insights 

into Organization: How Do I Implement Complex Change at Scale? Dallas, TX: McKinsey 

& Company, May 2011, and Project Management Institute, Inc. A Guide to The Project 

Management Body of Knowledge (PMBOK Guide) (Newtown Square, PA.: 2004).

9

GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning. 

GAO-04-39 (Washington, D.C.: Dec. 11, 2003), and GAO, Human Capital: Strategies to 

Help Agencies Meet Their Missions in an Era of Highly Constrained Resources. 

GAO-14-168 (Washington, D.C.: May 7, 2014).
Page 4 GAO-17-234 VA Disability Benefits

reform, we used GAO guidance on business process reengineering10 (or 

redesign); and for IT upgrades, we referred to GAO guidance and reports 

on information technology planning.11 For a list of the sources of sound 

practices and criteria we used to evaluate VA’s approaches, see related 

products at the end of this report.

We also reviewed VA’s analysis assessing the effectiveness of two of the 

proposed approaches (staffing increases and process reform) for 

addressing workload challenges. Specifically, we reviewed data analysis 

spreadsheets and related documentation (such as historical data and 

assumptions), conducted interviews, and observed a demonstration of 

how VA compiled the data for its projections. We did not assess the 

feasibility of the options compared in its analysis.

We conducted this performance audit from February 2016 to March 2017 

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.

VA’s process for deciding veterans’ eligibility for disability compensation 

begins when a veteran submits a claim to VA. The claim is reviewed at 

one of VBA’s 56 regional offices where staff members assist the veteran 

by gathering any additional evidence, such as military and medical 

records, needed to evaluate the claim.12 Based on this evidence, and the 

results of any necessary medical examinations, VBA decides whether the 

veteran is entitled to compensation and, if so, how much. VBA assigns a 

 10GAO, Business Process Reengineering Assessment Guide—Version 3, 

GAO/AIMD-10.1.15 (Washington, D.C.: May 1997). In this report, we refer to 

reengineering as appeals process “redesign.”

11GAO, Information Technology Investment Management: A Framework for Assessing 

and Improving Process Maturity, GAO-04-394G (Washington, D.C.: March 2004).

12VA has a statutory “duty to assist” the veteran by gathering evidence, such as military 

and medical records, needed to make the initial claim decision. This requirement also 

applies to appeals, as well as initial claims.

Background

VA Disability 

Compensation Benefit 

Claims Process
Page 5 GAO-17-234 VA Disability Benefits

rating of 0 to 100 percent disability in increments of 10 percentage points 

depending on the severity of the disability. This rating percentage then 

determines the monthly payment amount the veteran will receive.13

According to VA data, in many cases (74 percent), the veteran submitting 

a claim either is already a beneficiary but is seeking increased 

compensation, or the veteran was denied benefits previously and is 

claiming them again. In fiscal year 2015, VBA decided 1.4 million 

compensation claims and had an inventory of 363,000 claims at the end 

of the fiscal year. As previously noted, in fiscal year 2015, VA paid about 

$63.7 billion in disability compensation to about 4.1 million veterans.

A veteran dissatisfied with VBA’s initial claim decision can generally 

appeal within one year from the date of VBA’s notification letter to the 

veteran. According to the Board, veterans appeal most often because 

they believe VBA: (1) incorrectly denied them compensation for serviceconnected disabilities, or (2) under-rated their service-connected 

disabilities. An appeal begins with the veteran filing a Notice of 

Disagreement (NOD). VBA then re-examines the case and generally 

issues a Statement of the Case (SOC) that represents its decision.

A veteran who is or remains dissatisfied with VBA’s decision can file an 

appeal with the Board.14 In filing that appeal, the veteran could indicate 

whether they would like a Board hearing. VBA prepares the claim file for 

Board review and certifies it as ready for review. If the veteran requests a 

hearing so they can present new evidence or arguments, the Board will 

generally hold a hearing either by video conference or at a local VBA 

 13A veteran with a 30-percent or higher rating receives a larger amount based on the 

number of dependents. Also, VBA provides a larger monthly payment to a veteran who 

lost certain organs or one or more limbs, or who is found in need of aid and attendance. 

Further, a veteran with a rating of at least 60 percent—or a lesser percent, in certain 

circumstances—may be paid a Total Disability Individual Unemployability benefit, 

equivalent to payment for a 100-percent rating, if the veteran is found unable to obtain or 

maintain gainful employment due to service-connected disabilities.

14According to VA officials, in filing that appeal or at any point during the appeals process, 

the veteran may submit new evidence, and VA has a statutory duty to assist the claimant 

in obtaining evidence in support of the appeal throughout the entire appeals process. 

Depending on several factors, the new evidence might not necessitate the issuance of a 

Supplemental Statement of the Case (SSOC). If the appeal was received on or after 

February 2, 2013, VBA would only issue a SSOC if the veteran or their representative 

requests a review in writing, according to VA officials.

VA Appeals Process
Page 6 GAO-17-234 VA Disability Benefits

regional office.15 The Board reports to the Office of the Secretary of 

Veterans Affairs, and is independent of VBA. The Board’s members, also 

known as Veterans Law Judges (VLJ), decide appeals and are supported 

by attorneys and administrative staff. After the appeal is docketed at the 

Board, a VLJ or panel of VLJs reviews the evidence and either (1) grants 

the claimed benefit, (2) denies the benefit, or (3) returns (remands) the 

claim to VBA for additional work on one or more issues pertinent to the 

claim and a new decision. According to VA, the Board remands an appeal 

to VBA in cases where consideration of new evidence, clarification of 

evidence, correction of procedural defect, or any other action it deems is 

essential to achieve a proper decision. If the veteran is unsatisfied with 

the Board’s final decision, the veteran can continue an appeal beyond VA 

to federal court. Such an appeal begins with the U.S. Court of Appeals for 

Veterans Claims, then may go to the U.S. Court of Appeals for the 

Federal Circuit, and finally to the U.S. Supreme Court. See figure 1 for a 

representation of the appeals process for VA disability compensation 

benefit decisions.

 15The vast majority of Board hearings (96 percent in fiscal year 2015) are held by video 

conference or at a regional office, after which the appeal is docketed at the Board. For the 

small percent of hearings that are held in person at the Board’s central office in 

Washington D.C.— 4 percent in fiscal 2015 and 6 percent in fiscal year 2016, according to 

VA—the appeal is docketed prior to the hearing.
Page 7 GAO-17-234 VA Disability Benefits

Figure 1: Current Process for Appeals of Veterans Affairs’ (VA) Disability Compensation Benefit Decisions

a

This timeline does not include time from when VA issues the Statement of the Case to receipt of the 

veteran’s formal request to have their appeal reviewed by the Board and the average remand time, 

which for appeals decided by the Board in fiscal year 2015 took 39 and 255 days respectively. These 

numbers do not add up to the 1,789 days previously noted in part due to averaging and VA pulled the 

fiscal year 2015 data from its system at different times.

b

Under the traditional review option, the veteran may present new evidence and receive a formal 

hearing. In general, the reviewer can change VBA’s original decision based only on new evidence, or 

a clear and unmistakable error in the original decision. Alternatively, the veteran may elect a review 

by a Decision Review Officer, who reviews the record without deference to VBA’s original decision, 

and can revise that decision based on a difference of opinion. If needed, the Decision Review Officer 

may also pursue additional evidence or discuss the appeal informally with the veteran or the veteran’s 

representative.
Page 8 GAO-17-234 VA Disability Benefits

c

An appeal to the Board must be filed within 60 days of the SOC being mailed, or within the 

remainder of the 1-year appeal period from the date of mailing the decision notification.

d

According to VA officials, when new evidence is submitted at any point prior to filing of an appeal to 

the Board, the office that decided the original claim (Agency of Original Jurisdiction or AOJ) is 

required to review the evidence in the first instance, undertake any further development warranted, 

and issue a SSOC addressing the newly submitted evidence, if a SOC was already issued. For new 

evidence submitted by the veteran or his or her representative with or after the appeal is filed with the 

Board, the AOJ is not required to issue a SSOC unless: the appeal is filed with the Board before 

February 2, 2013, or (for appeals filed with the Board on or after February 2, 2013) the veteran or his 

or her representative requests in writing that the AOJ first review such evidence.

e

The vast majority of Board hearings (96 percent in fiscal year 2015) were held by video conference 

or at a regional office, which occur before the appeal is docketed at the Board. Hearings held at the 

Board’s central office in Washington D.C.—4 percent in fiscal year 2015—take place after the appeal 

is docketed.

According to VA officials, the number of appeals filed has increased 

steadily as has the length of time needed for the agency to make a final 

decision. At the end of fiscal year 2015, according to VA data, VA had 

over 427,000 pending appeals, approximately 81,000 of which were at 

the Board. While the percentage of pending appeals awaiting decisions 

from the Board was less than a quarter of all pending appeals, the fiscal 

year 2015 inventory was almost double the 41,000 pending at the end of 

fiscal year 2011. About 20 percent of this growth occurred from fiscal year 

2014 through 2015.16

According to Board data, timeliness has worsened since fiscal year 2011 

as well. From fiscal years 2011 through 2015, the average amount of time 

needed for the Board to make a final decision once the appeal is 

docketed increased from 240 to 270 days. In addition, the proportion of 

cases taking the longest to resolve (from when the Board receives the 

certified appeal to them making a final decision)—over 600 days—

increased from 10 percent in fiscal year 2011 to 14 percent in fiscal year 

2015 (see fig. 2). Given that the median time for the Board to decide an 

appeal was 145 days in fiscal year 2015 (compared to an average of 270 

days), these data suggest that a relatively small number of appeals is 

driving up the Board’s reported average processing times. To illustrate, 

VA officials noted one case where a veteran appealed 27 times over the 

course of 25 years before the original appeal was concluded.17

 16According to our analysis of data from the Board of Veterans’ Appeals, the Board issued 

about 56,000 decisions and also received almost 70,000 appeals in fiscal year 2015.

17According to VA officials, one issue related to this appeal is still pending with the Board; 

therefore, as of February 2017, this appeal had been pending for over 30 years.

Inventories and Timeliness 

of VA Appeals
Page 9 GAO-17-234 VA Disability Benefits

Figure 2: Board of Veterans’ Appeals Decision Times, from the Board’s Receipt of 

the Certified Appeal to Its Decision, Fiscal Years 2011-2015

VA has identified three broad approaches for addressing factors that it 

identified as having contributed to increased appeal inventories and 

reduced timeliness of appeals decisions, and has already taken action on 

all three fronts. Citing staffing levels that have not kept pace with 

workloads, VA secured additional Board staff for fiscal year 2017, and 

analyzed options for another hiring surge in fiscal 2018. Concerned that 

its appeals process contributes to delays in appeals decisions—because 

new evidence may be submitted at any juncture and because VA may be 

continually required to develop or obtain additional evidence—VA 

developed a legislative proposal for streamlining its appeals process, 

including new appeals options designed to accelerate decision-making. 

Finally, VA has put forth plans to modernize its current, outdated, and 

inefficient computer system.

VA has proposed increasing staff at the Board, as well as VBA, to 

manage its increasing inventory of appeals and to address related 

declines in the timeliness of appeals resolutions. VA officials stated that 

there is a direct and proportional correlation between the number of 

employees and the number of final appeals decisions, and that Board 

VA Has Proposed 

Increased Staffing, 

Process Reform, and 

Updated IT to 

Improve Appeals 

Timeliness, and Has 

Taken Action for All 

Three Approaches

VA Proposed Hiring More 

Staff to Address 

Increasing Workloads
Page 10 GAO-17-234 VA Disability Benefits

workloads especially have increased faster than the number of 

employees staffed to the Board. Specifically, officials have concluded that 

staff resources within the Board have not been sufficient to adjudicate the 

increasing number of appeals, ultimately lengthening appeals resolution 

times. According to VA, in fiscal year 2015 increases in staff (VLJs, 

attorneys, and support staff), as represented by full-time equivalents 

(FTEs), allowed the Board to make the highest number of decisions in 

nearly 30 years. However, despite Board staff increasing by 21 percent 

from fiscal years 2011 through 2015, officials said that this increase was

not sufficient to address the growing inventory of pending appeals, which 

doubled during the same time period (see fig. 3).

Figure 3: Pending Appeals Inventory and Staff (Full-Time Equivalents) at the Board of Veterans’ Appeals, Fiscal Years 2011-

2015

Although the increase in Board staff brought about a record number of 

appeals decisions in fiscal year 2015, according to VA data we reviewed, 

each appeal took an average of about 3 months (97 days) longer to reach 

a final decision than in fiscal year 2012.18 Similarly, in fiscal year 2015 

 18VA did not provide data for fiscal year 2011 on appeals resolution time, which was the 

year used in other comparisons throughout this report.
Page 11 GAO-17-234 VA Disability Benefits

one Board FTE produced an average of 86 appeals decisions, down from 

91 completed per FTE in fiscal year 2011. Growing workloads and the 

increased complexity of cases, according to Board officials, have 

contributed to these longer appeal resolution times. More specifically, 

officials said that claims have become more complicated due to not only 

the number and complexity of injuries and illnesses, but also to advances 

in medicine that have improved survival rates from catastrophic injuries,

experienced by today’s veterans. VA officials estimated that if the number 

of FTEs and number of appeals decided per FTE stays steady or 

decreases, appeals resolution times will continue to lengthen. 

Specifically, as of October 2016, VA projected that if nothing else 

changes, and if the number of FTEs hold steady at the fiscal year 2017 

number (922 FTEs for the Board and 1,495 for VBA), the inventory of 

appeals could exceed 1 million in fiscal year 2026, which would mean that 

veterans would wait an average of 8.5 years for a final appeals decision.19

In light of this assessment, VA concluded that increasing the number of 

FTEs at the Board is a key step in mitigating the current and future 

pending inventory of appeals and ultimately improving appeals decision

timeliness. In 2016, VA set a goal to decide the vast majority (90 percent) 

of appeals (including both those reviewed by VBA and the Board) within 1 

year by 2021. As an initial step toward this goal, VA requested and 

received a funding amount that the agency asserted would allow it to fund 

an additional 242 FTEs for the Board in fiscal year 2017 (a 36 percent 

increase over the 680 FTEs funded in fiscal year 2016) for a total of 922 

FTEs. VA also concluded, however, that this increase in staff will not be 

enough to reduce its appeals workload and decrease appeals processing 

time. Therefore, VA estimated the need for a subsequent hiring surge of 

up to 1,458 FTEs beginning in fiscal year 2018 to reduce the current 

pending appeals inventory.20

To understand the need for and implications of a future hiring surge, VA 

modeled different staffing scenarios. Initially, VA compared how 

increasing staff in combination with and without proposed changes to the 

 19This projection combines final decisions made by VBA as well as those made by the 

Board, and includes a number of underlying assumptions that are discussed later in this 

report. Such assumptions include, for example, that the number of initial claims filed 

(increase by 1 percent per year) and appeal rates hold steady at 11 percent, consistent 

with historical averages since 1996.

20According to agency officials, VA plans to continue to update and revise its model, which 

may change its projections.
Page 12 GAO-17-234 VA Disability Benefits

appeals process would achieve inventory reductions, and at what cost. 

VA determined that by combining staff increases with a new process, it 

could clear pending appeals faster and at a lower cost than if it hired 

additional staff under the current process.21 In response to congressional 

inquiries, in September 2016 VA also modeled the cost and impact on 

appeals inventories of four surge options beginning in fiscal year 2018 (in 

addition to planned hiring in fiscal year 2017).22 VA estimated, for 

example, that projected pending appeals in fiscal year 2017 (535,726) 

would be cleared in 10 years under option 2, compared to a 60 percent 

reduction over the same time period if there were no hiring surge. See 

table 1 for a comparison of the four options.

Table 1: Veteran Affairs’ (VA) Hiring Surge Options—Represented in Full Time Equivalents (FTE)—Estimated Impact on 

Pending Appeals Inventory

Option

Additional FTEs across VA 

(beyond those approved for 

fiscal year 2017) 

Estimated impact on projected 

VA pending appeals in fiscal year 

(FY) 2017 (535,726)

Baseline 0 Reduced by about 60 percent in 10 years (FY 2026)

1 244 Reduced by about 76 percent in 10 years (FY 2026)

2 584 Cleared in 10 years (FY 2026)

3 943 Cleared in 8 years (FY 2024)

4 1,458 Cleared in 6 years (FY 2022)

Source: VA data. ׀ GAO-17-234

Note: The estimated impact on the projected pending appeals is based on VA also reforming the 

current appeals process.

VA has proposed changes to its appeals process to address causes of 

delays in resolving appeals. The key challenge VA identified was the 

open-ended nature of its disability appeals process, whereby a veteran 

can submit additional evidence numerous times at any point during the 

VA appeals process, which can cause another cycle of re-adjudication. 

Specifically, when a veteran submits additional pertinent evidence after

VA’s initial decision on their claim, VA is generally required to review the 

 21Based on analysis conducted at that time, VA concluded it could clear pending appeals 

in 5 years at an estimated cost of $700 million over baseline spending for the staff surge 

combined with proposed process changes, compared to 10 years and $2.4 billion over 

baseline for staff surge under the current process.

22Based on its modeling, VA expected that the number of staff would eventually decrease 

after fiscal year 2019 as a result of attrition, commensurate with projections of a declining 

appeals inventory.

VA Proposed Reforming 

Current Appeals Process 

to Address Factors 

Contributing to Delays in 

Resolving Appeals
Page 13 GAO-17-234 VA Disability Benefits

evidence, develop any other needed evidence, and issue another 

decision. This is the case regardless of whether the veteran submits the 

additional evidence to VBA or to the Board and, for appeals pending 

before the Board, the submission of additional evidence may result in a 

remand to VBA for further development. VA reported that in fiscal year 

2015, the Board remanded about 46 percent of appeals to VBA for 

additional development.23 Of those remanded appeals, which may involve 

more than one issue, VA reported that about 60 percent of the reasons 

those appeals were returned to VBA were due to the open record that 

allows veterans to introduce new evidence at any point during the 

appeal.24 VA reported that in fiscal year 2015, it took VBA an additional 

255 days on average to complete remand development and for the 

appeal to be re-docketed at the Board. VA also reported that in fiscal year 

2015 it took the Board an average of 244 additional days to complete its 

subsequent review of the returned remands and decide the appeal. 

According to VA, this re-adjudication can occur multiple times and can 

add years to the time needed to reach a final decision on an appeal.

Board and VSO officials also identified factors within VBA’s initial claim 

process—and outside of the Board’s control—that cause delays in 

veterans receiving final decisions on their appeal. Specifically,

• According to Board and VSO officials, VBA’s decision notification 

letters are unclear and confusing. In particular, the officials stated that 

these letters do not adequately explain why claims were denied and 

do not clearly identify the evidence a veteran needs to provide to fully 

support a claim on appeal. As a result, some veterans may appeal 

unnecessarily, or they may appeal without providing the evidence 

needed to support their claims.

 23According to VA officials, the 46 percent remand rate is based on the Board’s historical 

method for reporting appeals, which counted the disposition of appeals in a given year as 

an allowance, remand, denial, or dismissal. Officials noted that this method did not 

capture every remand because it did not reflect appeals involving multiple issues with 

different dispositions. For example, VA counted an appeal as an allowance if one issue 

was allowed and one remanded. According to VA officials, 29 percent of appeals decided 

in fiscal year 2015 had been remanded to VBA at some point during the appeals process 

for additional development.

24Board officials stated that they track remands by reason and by issue. A remanded case 

may involve multiple issues remanded for multiple reasons. For example, the veteran may 

have appealed VBA’s initial decision on compensation for more than one disabling 

condition, and the Board may have different reasons for remanding each issue. 
Page 14 GAO-17-234 VA Disability Benefits

• VSO officials we interviewed said that some delays are attributable to 

errors in VBA’s initial decisions. They suggested that errors may have 

occurred because VBA rushed some decisions in its initiative to 

reduce its backlog of claims pending more than 125 days. Such errors 

can lead to Board remands and VBA re-work. For example, the Board 

may remand an appeal because VBA failed to meet the “duty to 

assist” responsibilities to a veteran.25 According to the Board, 41 

percent of the reasons for the remands in fiscal year 2015 were due to 

a VBA error.

• Board and VSO officials also cited delays in VBA’s transmittal of 

appeals to the Board as a possible cause for the delays in Board 

decisions. When a veteran files an application with VBA to appeal to 

the Board, VBA prepares the case file for transfer to the Board, 

certifies that the case file is complete and ready for Board review, and 

transmits the file to the Board. According to VA data on appeals 

decisions made by the Board in fiscal year 2015, it took on average 

537 days to process the appeal from receipt to certification. Docketing 

appeals that had been certified to the Board added an average of 222 

days to processing times for appeals decisions made in fiscal year 

2015. VSOs (two of the four we interviewed) told us that they noticed 

these delays occurring as VA’s focus shifted to clearing the 

compensation benefit claims backlog.

To address process-related challenges, VA’s approach has been to 

develop a proposal to streamline the appeals process and to ask the 

Congress to make changes in the laws governing the process. In April 

2016, VA issued a draft summary of a proposed streamlined appeals 

process that reflected collaboration with its stakeholders.26 This summary 

was accompanied by draft legislation for the Congress’ consideration. If 

enacted into law, the draft legislation would make process changes that 

 25According to VA officials, under VA’s new framework, the “duty to assist” requirement 

would not apply following VBA’s initial decision on a claim or supplemental claim, although 

the Board could remand a case to correct duty to assist errors that occurred prior to the 

initial decision being reviewed.

26VA, A New Framework for Veterans Claims and Appeals, April 22, 2016. According to 

VA, it does not plan to produce a final version. 
Page 15 GAO-17-234 VA Disability Benefits

VA identified as needed to streamline the appeals process.27 According to 

VA, key to the proposed process changes would be replacing the current 

appeals process, which begins in VBA, with a process giving a veteran 

four options—two in VBA and two in the Board.28 As presented in VA’s 

framework, these options would be:

• Ask VBA to review its initial decision based on the same evidence. 

Under this option, the veteran would not be able to submit new 

evidence or request a VBA hearing, and would not be subject to VA’s 

“duty to assist” requirement. A VBA official (at a level higher than the 

official who made the initial decision) would review the record 

supporting the initial decision, and issue a new decision.

• The veteran could file a “supplemental claim” with VBA, asking VBA to 

review its initial decision, while providing additional evidence. Under 

this option, the veteran could also request a VBA hearing. Another 

VBA official (at the same level as the original VBA decision-maker) 

would review the revised record, including the additional evidence 

from the veteran, and issue a new decision.

• The veteran could file a Notice of Disagreement directly with the 

Board, bypassing a VBA review. The veteran would have two options 

with the Board:

• Ask the Board to review only the existing record without a hearing 

and then issue a decision.

 27In the 114th Congress, various bills that would have changed the appeals process were 

introduced in the Congress. This included a bill (H.R. 5620) passed by the House of 

Representatives on September 14, 2016. That bill, and other Senate-introduced bills (such 

as S. 3170 and S. 3328), had been pending in the Senate Committee on Veterans’ Affairs 

during the 114th Congress, but were not enacted. At the time our review was complete, 

additional bills that would change the appeals process had been introduced in the 115th

Congress (e.g. H.R. 457, H.R. 611 and S. 152).

28In its appeals process reform proposal, VA refers to appeals in two ways, depending on 

which VA unit reviews the appeal. VA refers to appeals within VBA as “reviews;” and 

considers them extensions of VBA’s initial claims process. Meanwhile, VA generally refers 

to appeals directly to the Board as “appeals,” and considers the Board to be VA’s appeals 

agency. For the purposes of this report, we refer to all formal veterans’ disagreements 

with VBA’s initial decision as “appeals.”
Page 16 GAO-17-234 VA Disability Benefits

• Alternatively, ask the Board to review additional evidence, conduct 

a hearing before issuing its decision, or both.29

See figure 4 for a representation of the options in VA’s proposed 

simplified appeals process.

Figure 4: Department of Veterans Affairs (VA) Proposed Appeals Process and VA’s Estimated Breakdown of Veterans’ Use

VA officials anticipate that the proposed appeals process described 

above will expedite appeals in a number of ways, most notably:

• For those appeals where no additional evidence is submitted, and no 

formal hearing is conducted (indicated as “VBA conducts local higherlevel review” and “Board reviews record without new evidence or a 

hearing” in figure 4), the re-review of the original record could 

expedite a final appeals decision. In addition, VA’s “duty to assist” 

requirements would only apply to VBA for initial and supplemental 

claims. Unlike the current process, in which the Board may remand 

appeals to VBA to consider new evidence, the Board would only 

remand appeals under the new process in cases in which the Board 

found that VBA failed, in its initial or supplemental claim processing, to 

meet VA’s “duty to assist” the veteran. VA estimates that, once the 

 29For the purpose of managing its caseload, the Board would have two dockets (in 

addition to legacy cases): (1) for appeals with additional evidence, which may or may not 

involve a hearing, and (2) for appeals with a review of the existing record without 

additional evidence or a hearing. 
Page 17 GAO-17-234 VA Disability Benefits

new process is fully implemented, remands will steadily decrease and 

eventually occur in as few as 5 percent of appeals.30

• When the veteran appeals directly to the Board, VBA would no longer 

be required to review the record (including any additional evidence), 

prepare statements of its findings (i.e., prepare SOCs or SSOCs), and 

certify appeals as ready for Board review.

VA has estimated that as a result of these process changes—in 

combination with increased FTEs—the Board could complete cases 

faster, deciding many more appeals per FTE in fiscal year 2018 

compared to fiscal year 2015. More specifically, VA estimated that the 

Board could complete an average of 180 appeals decisions per FTE 

without a hearing and 130 with a hearing, compared to the average of 86 

total decisions per FTE in fiscal year 2015. We discuss VA’s estimates in 

more detail later in this report.

While VA’s proposal reflects VA’s intent to expedite appeals resolutions, it 

also contains various protections for veterans that are intended to 

address stakeholders’ concerns about fairness. Notably, such protections 

include the following:

• In contrast to the “one size fits all” process, the proposed reform 

allows the veteran to choose an option that best fits the circumstances 

of a veteran’s claim. As shown in figure 2 above, a veteran could 

choose to have VBA review the initial decision or they could appeal 

directly to the Board. Also, the veteran would have the option to have 

either VBA or the Board review the existing record, without having to 

submit new evidence and/or request a formal hearing. VA expects 

that these options could help the veteran obtain a faster decision from 

VBA or the Board. Per VA’s framework, under the new process, the 

veteran would have up to 1 year from VBA’s initial decision to choose 

an option. Further, if the veteran is unsuccessful in one appeal option, 

the veteran could, within 1 year, choose another option.31 However, 

 30VA estimates this improvement over the 41 percent error rate in fiscal year 2015 will be 

due to a reduction in the number of steps where such errors can occur and improved 

feedback loops between the Board and the VBA office that made the initial decision.

31As previously noted, currently, a veteran generally has 1 year from the date of VBA’s 

notification letter to file a Notice of Disagreement and begin the appeals process. The 

veteran can file an appeal with the Board within 60 days after VBA mails a SOC or within 

the remainder of the 1-year appeal period from the date of mailing the decision 

notification. 
Page 18 GAO-17-234 VA Disability Benefits

according to VA, an appeal for a higher-level review by VBA without 

new evidence cannot directly follow a Board decision.

• VBA would be required to provide more information in letters notifying 

veterans of decisions involving a denial of benefits, which could help 

veterans make more informed decisions on whether to appeal, which 

option to pursue, and what additional evidence (if any) to provide.32

The inclusion of additions to such notifications in VA’s proposed 

legislation addresses stakeholders’ concerns that veterans did not 

have enough information to decide whether they should appeal, or 

what additional evidence they needed to provide, thereby resulting in 

unnecessary appeals or delays in appeals.

• A veteran who is not fully satisfied with the result of any lane would 

have 1 year to seek further review, while preserving an effective date 

for benefits based on the date the veteran filed the original claim with 

VBA. This would help ensure a veteran is not penalized for pursuing 

an appeal to the Board. For example, under VA’s proposal, a veteran 

denied benefits by the Board could choose to have VBA conduct 

another review, by filing a supplemental claim with additional 

evidence. In contrast, under current law, if a veteran appeals to the 

Board and is denied (and does not appeal to a federal court), the 

veteran must generally reopen the claim, or start over, by filing 

another claim with VBA. If the veteran is subsequently granted 

benefits, the benefits would generally be awarded from the date on 

which the new (not original) claim was filed, which could result in the 

veteran not receiving retroactive compensation payments.

VA has plans to modernize its current IT system, which it determined is 

antiquated and a source of delays in processing appeals. VA currently 

uses the Veterans Appeals Control and Locator System (VACOLS) to 

track and manage its appeals workload. VA identified a number of 

reasons why it believes VACOLS should be replaced, including that:

 32Under current law, VBA’s notification must explain the procedures for obtaining a review 

of its decision. Also, if VBA denies benefits to the veteran, its notification must state the 

reasons for its decision, and the evidence it considered. Under VA’s proposal, when VBA 

denies benefits, its notification must include information on: (1) the issues adjudicated, (2) 

the evidence considered, (3) the applicable laws and regulations, (4) findings favorable to 

the veteran, (5) findings as to which element(s) were found not to have been satisfied 

leading to the denial of the claim, (6) how the veteran can access the evidence used in 

making the decision, and (7) the criteria the veteran must satisfy for the claim to be 

granted.

VA Has Plans to 

Modernize Its Outdated 

Appeals IT System
Page 19 GAO-17-234 VA Disability Benefits

• The system is based on outdated technology dating from the 1990s 

that VA determined would be difficult to modify to meet the changing 

needs of VA.

• VA designed VACOLS around a paper-based VA claims process and 

as a result, VACOLS does not adequately support a fully electronic 

environment. According to VA, although VACOLS has been patched 

to some extent to handle paperless appeals, the Board relies on 

paper briefs to help manage its appeals workflow.

• VACOLS’s lack of automation, integration with other VA systems, and 

error checks results in mistakes and lost productivity. According to 

VA, individual employees spend a significant amount of time 

correcting data entry errors that would be avoided if cases were 

automatically transferred to the Board. For instance, they said that 

after cases are transferred to the Board, a team of employees must 

manually review and correct most incoming cases due to issues with 

labeling, mismatched dates, and missing files. Via an internal study, 

VA determined that up to 88 percent of cases transferred to the Board 

had such errors. Additionally, VA notes that data entry errors can 

result in instances where paperless cases are mislabeled as paperbased. These cases will not show up as certified in VACOLS and the 

Board will erroneously wait for a paper case that will never arrive.

• VACOLS is central to appeals processing, thus a system outage 

would halt the processing of appeals across VA, either paper or 

electronic, until VACOLS is repaired, according to VA.

VA expects its VACOLS replacement to improve the efficiency of its 

appeals decisions. Its planned replacement—called Caseflow—is 

intended to address the limitations of VACOLS and better support 

processing appeals in a paperless environment. According to VA, 

Caseflow is being developed in an agile process in which new functions 

are added to the system as they are completed. In fiscal year 2016, VA 

developed two initial deliverables. According to VA, the first is intended to 

automate and introduce consistency to the process of transferring 

appeals to the Board. The second introduced the ability for staff to access 

documentation from the Veterans Benefits Management System 

(VBMS)—VA’s system for processing claims—which VA believes will 

eventually allow users to review appeals more efficiently. As of February 

2017, VA officials also noted the agency is in the process of developing 

additional components, including document review software for VLJs and 

attorneys, and a component to better track appeals that are remanded to 

VBA. According to officials, VA’s longer term plans include a broad 

roadmap for continuously adding improvements to Caseflow. For 
Page 20 GAO-17-234 VA Disability Benefits

instance, VA has plans to build into the system the capability to generate 

performance metrics, using a component called Caseflow Dashboard. VA 

states that the dashboard will be able to draw on various VA data 

systems and provide information on bottlenecks in the appeals process, 

quantify improvements in the appeals process—including those 

attributable to improved IT systems—and track the reasons for and 

number of remands. While Caseflow improvements are being made, VA 

reported it plans to maintain VACOLS as a redundant resource until the 

new system is fully complete, at which point VACOLS will be retired.

VA acted consistently with sound planning practices in determining its 

need for additional staff, but it did not fully consider risks and 

uncertainties in its approach. Sound practices for effective planning 

suggest that agencies should consider alternative solutions to a problem; 

assess the risk of unintended consequences; and use data to analyze the 

problem, including unknowns.33 Consistent with these concepts and more 

specific sound workforce planning practices, VA considered various hiring 

options, such as hiring staff under the current versus VA proposed 

process, and modeling appeals inventories under four hiring surge 

options.34 VA considered a number of factors when comparing the four 

hiring options including historical data on the volume and complexity of 

appeals, estimates of future growth in appeals, and the productivity of 

employees in estimating the number of Board staff needed to meet its 

timeliness goals. For instance, the Board reviewed past data on the 

 33For key characteristics of sound planning of any government project, see GAO-04-408T.

34See GAO-04-39 and GAO-14-168.

VA Applied Several 

Sound Planning 

Practices in Its Efforts 

to Improve Its 

Appeals Processing 

Timeliness, but Fell 

Short in Other Areas

VA Weighed Several 

Factors When Determining 

Its Need for More Staff, 

but Did Not Fully Assess 

Risks or Document Its 

Workforce Plans
Page 21 GAO-17-234 VA Disability Benefits

productivity of new staff—which is generally lower for a period of time 

until individuals acclimate to their jobs—and factored this into the 

modeling assumptions used to project the number of Board staff needed.

More specifically, sound workforce planning practices suggest that 

agencies identify the resources needed to manage the risks of 

implementing new processes and conduct scenario planning to determine 

these needs.35 While VA considered a number of factors when analyzing 

hiring options, it initially made many assumptions using a single set of 

estimates instead of using a sensitivity analysis to consider a range of 

estimates.36 These assumptions could have significant implications for 

how accurately VA identifies needed resources. For example, in its 

scenario analysis VA assumed: (1) that an average of 50 percent of those 

veterans appealing will refile their appeal and go through two of the four 

appeals process options before being satisfied; and (2) that the Board will 

be able to decide 130 appeals per FTE, and do so within 3 years (1,095 

days), for appeals with hearings and decide 180 appeals per FTE within 1 

year for appeals without hearings. Because the Board did not consider 

alternate sets of assumptions, VA does not know the potential effect that 

variations in these key variables could have on staffing needs.

In response to discussions with us on its scenario analyses, VA recently 

conducted further analyses using alternative estimates for key factors, 

although the agency’s analyses fell short of the previously discussed 

sound practices for estimating outcomes based on assumptions. 

Specifically, VA calculated the effect on appeals inventories and 

timeliness if VA decided 20 percent fewer appeals, if VA decided more 

claims and thus had more appeals than expected, and if the breakdown 

of options that veterans selected for their appeals review is different than 

the 50/50 split VA projected. The 20 percent reduction in productivity 

alone could add 2.5 years to VA’s estimate of how long it would take to 

clear the appeals inventory under hiring surge option 4. However, VA ran 

a sensitivity analysis for only one of the four hiring surge options and did 

not analyze the compounded effect of different assumptions together. By 

 35GAO, Cost Estimating and Assessment Guide: Best Practices for Developing and 

managing Capital Program Costs, GAO-09-3SP (Washington D.C.: March 2009). See also 

GAO-04-39.

36Sensitivity analysis, used in scenario planning, is an analysis to determine how sensitive 

outcomes are to changes in the assumptions. The assumptions that deserve the most 

attention should depend on the dominant benefit and cost elements and the areas of 

greatest uncertainty of the program or process being analyzed. See GAO-09-3SP.
Page 22 GAO-17-234 VA Disability Benefits

not comprehensively conducting sensitivity analyses, VA is hampered in 

its ability to anticipate and plan for different contingencies, and risks being 

caught off guard and potentially hiring an inappropriate number of staff. 

Hiring too few staff could result in it taking longer to reduce the inventory 

of pending appeals, while hiring too many staff could result in higher 

expenditures than needed and exacerbate other challenges, such as 

ensuring sufficient office space, training, and other supports for newly 

hired staff, as discussed below. VA has acknowledged that some of its 

assumptions, and thus projections, are based on unknowns and that it will 

need to continuously rerun the models with updated data.

VA also identified strategies and resources needed for recruiting, hiring, 

and training staff in fiscal year 2017; however, aspects of VA’s workforce 

planning fall short of sound workforce planning practices that suggest 

having timely written plans with a systematic approach and detailed 

steps, time frames, and mitigation strategies to help identify where 

resources and investments should be targeted.37 As noted below, VA has 

identified strategies and taken some positive steps related to recruiting, 

hiring, and training staff in fiscal year 2017, although these plans 

sometimes lacked certain details specifically covered in sound workforce 

planning principles in time to inform ongoing efforts.

• Recruitment and Hiring: Consistent with sound workforce planning 

practices, officials have worked to develop a center for excellence in 

hiring to coordinate workforce planning and develop strategies for 

recruiting and hiring staff quickly. However, the center was 

established in the last quarter of fiscal year 2016 to support hiring

beginning early in fiscal year 2017. To date, the Board developed a 

project to recruit recent law school graduates and alumni in fiscal year 

2017, according to Board officials. It also has formed a committee of 

over 90 volunteers to develop recruitment materials, identify 

opportunities, and make contact with law schools; developed a 

PowerPoint presentation for the visits; and conducted a few initial 

presentations at law schools. However, the agency had not yet 

worked out specific goals such as the number of presentations or 

resulting applications, average time taken to recruit, and skills needed 

in recruits, or identified metrics (other than hiring goals) against which 

it would measure the effectiveness of the recruitment efforts.38

 37See GAO-14-168. 

38GAO. Human Capital: A Self-Assessment Checklist for Agency Leaders. 

GAO/OCG-00-14G (Washington, D.C.: September 2000).
Page 23 GAO-17-234 VA Disability Benefits

Also consistent with sound workforce planning practices, Board 

officials told us that they considered lessons learned from a 2013 

hiring surge, although the agency did not provide documentation of 

these lessons learned.39 Having established a goal of hiring 25-52 

new employees per month from October 2016 through April 2017, the 

Board subsequently faced challenges finding space for staff coming 

aboard in fiscal year 2017.40 Specifically, as of October 2016, the 

Board was reconfiguring its office space to accommodate the planned 

242 new FTEs in fiscal year 2017, employing nearly all of its 

conference rooms, and developing a plan for using telework and office 

sharing to accommodate staff until the space is available for them, 

according to officials.

• Training: As of February 2017, VA rolled out training for newly hired 

attorneys in fiscal year 2017, which includes 4 weeks of training and 8 

additional weeks of one-on-one mentoring. VA also stated that its 

Office of Knowledge Management was expanded with additional staff 

resources to ensure training materials were up to date. However, in 

November 2016, officials reported that the Board was still in the 

process of updating various aspects of its training curriculum, such as 

how to support conducting work in a virtual environment, which is 

consistent with the agency’s plans to increase telework as a way to 

manage space restrictions for new staff. In its comments to this report, 

VA did not provide updates on this effort, as of February 2017.

As of October 2016, it was unclear how the Board’s 2017 recruiting, 

hiring, and training efforts will be adjusted to support the agency’s 

proposed hiring surges in 2018 or its proposed process reform. For 

example, the Board has not yet determined how it will meet the space 

needs for any additional growth associated with hiring surges proposed 

for fiscal year 2018, although more detailed planning in advance might 

have better prepared VA for bringing aboard 242 FTEs in fiscal year 

2017. In addition, VA officials stated in February 2017 that draft training 

for the proposed new appeals process had been prepared based on 

statutory language, although these draft documents were not included in 

VA’s comments. Federal strategic planning guidance calls for an agency 

 39According to VA officials, one practice previously identified as successful was using 

human capital experts from the Veteran’s Health Administration with experience in large 

workforce projects. However, the Board stated it was not using these experts for its fiscal 

year 2017 hiring surge.

40As of October 2016, VA hired 43 staff and planned to hire 25 new staff in November and 

December 2016, accounting for holidays when hiring efforts will slow, and about 50 new 

staff in the first few months of 2017. 
Page 24 GAO-17-234 VA Disability Benefits

to have clear plans and goals, and regularly assess its human capital 

approaches through assessments, as well as through data-driven human 

capital management to improve its ability to maximize the value of human 

capital investments while managing related risks.41 Conversely, a lack of 

detailed workforce plans and mitigation strategies prior to proposed hiring 

surges in 2018, as well as potential process reform, further places VA at 

risk of not being ready to accommodate another quick and much larger 

increase in staff, or to train them in accordance with either the legacy or 

proposed reform process.

VA collaborated with key stakeholders in developing its proposed appeals 

process reform framework and related implementation plans, which is 

consistent with sound practices for business process redesign.42 Sound 

redesign practices suggest coordinating with stakeholders in developing 

and implementing plans to obtain and maintain buy-in from start to finish 

and to identify and address disagreements. In developing its proposal, 

Board and VBA officials engaged stakeholders from 11 organizations—

including VSOs that represent veterans in appeals hearings before VBA 

and the Board—in discussions to design a streamlined appeals process.43

Officials we interviewed from three of four VSOs, all of whom participated 

in the discussions, noted that VA’s resulting process proposal addressed 

both the agency’s desire to expedite appeals resolutions and stakeholder 

desires that the new process be fair to veterans. For example, VA 

identified and prioritized key concerns and found areas of consensus with 

VSOs. VA officials stated that they plan to continue to discuss appeals 

process reform (among other topics) at regular meetings with 

stakeholders, during which they will have an opportunity to provide 

feedback on previously unforeseen issues. VA officials said that as 

process reform is implemented, the agency will invite local VSOs to 

 41GAO, Human Capital: A Guide for Assessing Strategic Training and Development 

Efforts in the Federal Government. GAO-04-546G (Washington D.C.: March 2004). See 

also GAO/OCG-00-14G.

42See GAO/AIMD-10.1.15. In this report, we refer to reengineering as appeals process 

“redesign.”

43The organizations were the American Legion, American Veterans, Disabled American 

Veterans, Military Officers Association of America, National Association of County Veteran 

Service Officers, National Association of State Directors of Veterans Affairs, National 

Organization of Veteran Advocates, National Veterans Legal Services Program, Paralyzed 

Veterans of America, Veterans of Foreign Wars, and Vietnam Veterans of America.

VA Collaborated with 

Stakeholders in 

Developing Its Proposed 

Streamlined Appeals

Framework, but Lacks 

Strategies, Such as Pilot 

Testing, to Mitigate Risks
Page 25 GAO-17-234 VA Disability Benefits

training, and share training materials and provide briefings to them and 

other stakeholder groups.

While VA has achieved broad agreement internally and with VSOs on its 

proposed process reform, there are several unaddressed gaps in VA’s 

business case for implementation that introduce the risk of not producing 

the desired results, as follows. 

• To develop a business case for implementing process change, sound 

redesign practices suggest first mapping and analyzing the target 

process to understand the cause and cost of performance 

breakdowns, and assessing potential barriers, costs, and benefits of 

alternative processes. This, in turn, would inform the selection of a 

feasible alternative with a high return on investment, and the 

development of a business case that describes benefits, costs, and 

risks. However, due to IT limitations, VA lacks data to inform and 

confirm its understanding of the root causes of lengthy time frames. 

For example, VA lacks complete historical data on the extent to which 

submission of new evidence and multiple decisions and appeals 

occur, and thus cannot determine the impact of its current, openended process on appeals decision timeliness.44 To shed light on root 

causes, VA analyzed 10 appeals decisions that it found took a long 

time to adjudicate to illustrate extreme examples of cases being rereviewed under VA’s open-ended process—referred to by VA as 

“churning.”45 However, VA cannot know the full extent to which 

churning might be occurring because, according to VA officials, the 

way data are stored made it difficult, if not impossible, to assemble a 

complete historical picture prior to December 2012. To help develop 

baseline data, VA analyzed the average number of decisions per 

appeals phase for several recent fiscal years, and, according to VA 

officials, they are still endeavoring to piece together additional 

historical baselines for performance. 

 44VA officials noted that VACOLS was built to manage workflow, not capture data 

permanently. Over time, as data fields changed or were repurposed, prior information was 

lost or overwritten, and is currently unrecoverable. Since 2012, VA has taken snapshots of 

data, and thus has some capabilities to analyze more recent cases involving multiple 

appeals, submission of new evidence, and multiple decisions on appeals. 

45According to VA officials, VA undertook this analysis in response to a congressional 

inquiry.
Page 26 GAO-17-234 VA Disability Benefits

• Further, although it was appropriate for VA to develop its proposed 

reform in consultation with internal and external experts, the agency 

did not test alternatives using data-driven, cost-effective methods 

suggested by sound redesign practices.46

• Finally, as noted previously, in modeling staff resources needed under 

its proposed process reform, VA relied on assumptions—about the 

percent of veterans who will refile, will appeal to the Board, and will 

submit new evidence—that have direct implications for projections of 

appeals workloads, time frames, and cost. However, VA did not 

perform sufficient sensitivity analyses to help estimate a range of 

potential outcomes—analyses that might help VA understand the 

likelihood that the new process could be more costly and timeconsuming in practice than anticipated, for example, if a higher 

percent of veterans file with the Board, submit new evidence, and 

request hearings than expected.

These gaps notwithstanding, VA made some progress planning for 

potential implementation of proposed process reform in a manner 

generally consistent with sound planning practices for process redesign 

and change management, although some important details are still 

absent.47 According to sound planning practices, implementation is the 

most difficult phase of business process redesign. An agency must 

manage human capital and technical issues as it turns an idea into reality 

and overcomes potential resistance to change. To ensure an orderly 

transition, sound planning practices suggest following a comprehensive 

implementation plan that includes several key activities, such as 

establishing a transition team and developing a comprehensive plan to 

manage implementation.48 Consistent with this, as of October 2016, the 

 46Sound redesign practices suggest using cost-effective methods—such as prototyping, 

modeling and/or computer simulation, or limited pilot-testing—to assess the costs, 

benefits, and feasibility of alternative processes that will inform the selection of a feasible 

process alternative with a high return on investment. These early practices would also 

promote buy-in, and help determine expected performance results.

47In addition to GAO/AIMD-10.1.15, see Insights into Organization and A Guide to the 

Project Management Body of Knowledge (PMBOK) Guide.

48According to sound redesign practices, a comprehensive implementation plan should 

identify tasks, time frames and needed resources, structure the roll-out in an appropriate 

way, assign roles and responsibilities for implementation, provide a means for collecting 

and sharing implementation problems and solutions, and provide for close monitoring 

during implementation.
Page 27 GAO-17-234 VA Disability Benefits

Board and VBA had identified general time frames and offices 

responsible for key implementation efforts. Based on its staff modeling 

efforts, VA also identified how many FTEs it expects it will devote to 

processing cases under the current process versus a new one, should it 

be implemented. Also, per sound planning practices, a comprehensive 

plan should address workforce training and redeployment issues 

(including working closely with employee unions to minimize potential 

adverse effects). Consistent with this, as of October 2016, VA had 

outlined general steps and time frames for training of staff and 

communicating with the unions. 

While VA’s high-level implementation plan included many components 

suggested by sound practices, key details had yet to be addressed. In 

particular, VA’s general timetables and plans to date have not addressed 

in any detail how it will implement a new process while simultaneously 

working to reduce the appeals inventory under the current process.49 For 

example, the agency has not explained how or who will track timeliness of 

appeals of the old compared to the new process, and how decisions will 

be made to ensure the agency is devoting an appropriate share of 

resources to both processes. The lack of a detailed plan for managing 

this transition exposes the agency to risk that veterans whose appeals 

are pending under the old process may experience significant delays 

relative to those under a new process. The Board recognized the need to 

ensure fairness to veterans with appeals pending under the current 

process, and indicated that while legislation is pending that would 

authorize a new process, it will continue to develop plans for managing 

the two processes in parallel.

Sound practices for process redesign and change management also 

suggest having risk mitigation strategies—in particular, pilot testing—to 

ensure moving successfully to full implementation.50 Pilot testing provides 

 49VA’s plan is that when the new process is implemented, pending appeals would 

continue to be processed under the “legacy” or current process. According to VA, only 

appeals of decisions where the notice of decision was provided at least 18 months 

following enactment of appeals reform legislation would follow the new appeals process. 

As of December 2016, VA officials said they were also considering a regulation allowing 

veterans whose appeals are remanded by the Board under the legacy process to opt into 

the new framework. 

50See GAO/AIMD-10.1.15; Insights into Organization, and Michael L. George, David 

Rowlands, Mark Price, and John Maxey; and The Lean Six Sigma Pocket Toolbook: A 

Quick Reference Guide to Nearly 100 Tools for Improving Process Quality, Speed, and 

Complexity. (New York: McGraw-Hill, 2005).
Page 28 GAO-17-234 VA Disability Benefits

agencies opportunities to evaluate the soundness of new processes in 

actual practice on a smaller scale, and to refine performance measures, 

collect and share implementation problems and solutions, correct 

problems with the new design and refine the process prior to full 

implementation, and build capacity among unit managers to lead change. 

Sound redesign and change management practices both suggest that 

pilot tests should be rigorously monitored and evaluated, and that further 

roll-out occur only after the agency’s transition team has taken any 

needed corrective action and determined that the new process is 

achieving previously identified success criteria.51 As noted above, pilot 

testing is not the only method of achieving these risk mitigation goals, but 

sound planning practices suggest pilot testing is an important, often 

necessary approach for ensuring successful implementation when 

undertaking significant institutional change.52

Contrary to sound practices, VA officials stated they do not want to pilot 

proposed appeals reform, even though VA’s proposed reform can be 

considered complex. VA’s reform plans qualify as complex because in 

addition to implementing a new process, the agency must still manage a 

large inventory of appeals under the old process while hiring and training 

a large number of staff and implementing IT improvements.53 Occurring 

 51Sound change management practices suggest that after learning from pilot testing, 

organizations need to decide how to scale up any changes. Factors to consider in 

deciding how to scale up in connection with risk mitigation strategies include whether: the 

organization faces a crisis, there is resistance to change, the resources are available to 

implement change, and implementation requires customization. See Insights into 

Organization.

52As discussed previously, prior to implementation, agencies can mitigate risks associated 

with process change by first assessing potential barriers, costs, and benefits of alternative 

processes to help ensure selection of a feasible process with a high return on investment. 

These early practices would also promote buy-in, and help determine expected 

performance results. After selecting the most promising concept, pilot testing prior to full 

implementation provides an opportunity for testing and refining the new process in actual 

practice, and building support for full implementation. We recognize that some risk 

mitigation strategies would be within VA’s current authority while others—such as 

piloting—would require explicit congressional authorization.

53As noted previously, the Board has already encountered challenges finding space to 

accommodate new staff being hired in fiscal year 2017, despite considering lessons 

learned from a prior hiring surge within the agency. Further, we recently reported that VBA 

encountered complexities—including competing workload priorities and scope 

expansion—that resulted in decisions that delayed implementation of a new claims 

system. See GAO, Veterans Benefits Management System: Ongoing Development and 

Implementation Can Be Improved; Goals are Needed to Promote Increased User 

Satisfaction. GAO-15-582 (Washington, D.C.: September 1, 2015).
Page 29 GAO-17-234 VA Disability Benefits

together, these efforts involve significant change and uncertainty and will 

require management oversight across a broad range of efforts. In 

addition, VA’s proposed process reform and other initiatives affect VBA’s 

regional offices spread across the country, as well as the centrally located 

Board, thereby further increasing complexity of implementation. VA 

officials also stated that the proposed process reform, which has been 

thoroughly vetted with stakeholders, has broad support, and noted their

view that the risk of fully implementing change is outweighed by the cost 

of delay. VA’s rationale for not pilot testing centers on what they describe 

as widespread consensus that the current process is “fundamentally 

broken” and provides “inadequate service to veterans with a high 

percentage of wasted effort.” VA assumed that a pilot test authorized by 

Congress would include a sunset date with a default reversion to the 

current system, which they said would introduce uncertainty into the 

agency’s planning efforts and a reliance on subsequent, time consuming 

legislation before the conclusion of the pilot. VA officials stated that 

piloting with a sunset date would require the agency to expend additional 

resources and time to conduct parallel planning for reverting to the old 

system upon the sunset date. VA stated that pilot testing the new process 

for some veterans would be perceived as inequitable, despite VA having 

previously supported pilot testing a new appeals process.54 VA officials 

concluded that they have not identified any risk that would justify a pilot, 

and indicated that they plan to mitigate risk with a strong implementation 

plan.

While VA has made a compelling case for reforming the appeals process, 

as noted previously, VA’s business case for its proposed reform in some 

instances relies on unproven assumptions and limited analyses of its 

current process that introduces risk in VA’s plans for full implementation. 

Importantly, VA assumes that because the current framework is 

“fundamentally broken,” its proposed new framework will necessarily be a 

better option. However, VA made this decision lacking complete data on 

the root cause of lengthy appeals under the current process, and without 

analyzing barriers, costs and benefits of feasible alternatives using cost 

 54VA previously supported an opt-in pilot program that would have tested a new appeals 

process, in the form of fully developed appeals pilot legislation that was previously 

introduced in Congress. See, e.g., H.R. 800, 114th Cong. (2015). This legislation would 

have given veterans the option to file fully developed appeals. Under this option, veterans 

would have been limited in the new evidence they could present, and the Board, to the 

extent practicable, would have decided such cases within 1 year of the appeal being filed. 

The bill was not enacted and VA withdrew its support for this pilot in favor of its current 

proposal to streamline the appeals process.
Page 30 GAO-17-234 VA Disability Benefits

effective methods, such as computer simulations. VA correctly notes that 

pilot testing prior to full implementation would slow down an overhaul of 

the current system, thus countering the short-term net benefit that the 

agency expects to realize from such an overhaul. However, VA has not 

acknowledged that pilot testing the new process in a more limited fashion 

could greatly increase the probability of long-term success by decreasing 

the chance that a new system will experience unanticipated problems that 

are potentially more widespread and therefore costly to remedy. The 

inclusion of risk mitigation strategies such as pilot testing does not, as VA 

asserts, “imply that the status quo is not in dire need of sweeping reform” 

but rather balances the urgency of the current problem, the technical 

complexity of an overhaul, and the potential for unforeseeable 

complications.

In light of this and the previously discussed inconsistencies in following 

sound planning practices, pushing forward with full implementation 

without testing how process reform unfolds and interacts with other efforts 

in actuality, may lead VA to experience implementation challenges and 

setbacks that could undermine efficiencies and other outcomes resulting 

from planned reforms. In contrast, if VA were to pilot test the proposed 

appeals process reform, implementation problems encountered could be 

identified and resolved prior to full implementation. This could lead to 

smoother implementation and better outcomes overall. Further, resources

that would otherwise be diverted to full implementation of process reform 

across the organization could be focused on its current inventory of 

appeals. VA will also have additional time and managerial capacity to 

recruit and train new staff and develop and implement a communication 

and outreach strategy in time for full implementation of the new process. 

Finally, if risk mitigation strategies demonstrated that process reform 

would be more costly and detrimental to time frames and workloads than 

predicted, a decision to modify or fix the process at that juncture would be 

made with more information and less impact on the agency overall.

Whether VA conducts pilot testing or not, VA has not yet developed a 

plan for closely monitoring implementation or developed a strategy for 

assessing the success of its proposed process reform. Sound planning 

and redesign practices suggest that the transition team develop metrics 

and data gathering procedures, define success criteria, measure 

performance carefully, and take corrective action of any pilot test before 

proceeding to full implementation. Sound practices also suggest the 

agency develop meaningful performance measures—generally a mix of 

outcome, output, and efficiency measures—tied to overall goals of the 

project, and that project goals include a mix of intermediate goals to be 
Page 31 GAO-17-234 VA Disability Benefits

met at various stages during the implementation phase. That way, the 

agency can start to show a return on investment in the early stages of 

implementation.55 To date, VA has identified several broad metrics 

generally reflecting outcomes, output, and efficiency—such as veteran 

survey results, wait times, and inventories—that it plans to use to track 

and assess process improvements. VA also established separate 

timeliness measures for the Board and VBA that it will use in its annual 

performance reports. While these broad metrics and goals are 

appropriate, they fall short of sound practices for monitoring and 

assessing process change in several respects.

First, VA has not developed a dashboard or balanced scorecard, or 

otherwise identified how it will closely monitor progress, evaluate its 

efficiency and effectiveness, and identify trouble spots. For example, 

although VA has stated that it is developing a dashboard to measure 

performance under its proposed appeals process, VA has not yet 

indicated whether, how, and with what frequency it will monitor wait times 

and inventories under the new versus current processes. As a result, it is 

not clear how VA will determine whether veterans with appeals pending

under the current process are receiving equitable treatment and not 

experiencing significant delays relative to those under the new process. It 

is also unclear the extent to which VA will systematically monitor staff 

productivity and IT processing, which may affect its ability to determine 

whether assumptions are being met to help pinpoint corrective action 

(e.g., whether staff need more training, VA’s communication and outreach 

efforts are working as expected, or process reform itself is achieving 

desired results). Further, VA has not established interim goals or criteria 

for success to help determine whether initial implementation is achieving 

intended results.56 Interim goals and criteria could include specific 

timeliness improvements for process steps and outcomes, such as 

average time for VBA or the Board to reach decisions under new appeals 

options. If VA pursues pilot testing, such goals or success criteria will help 

 55For example, sound change management practices suggest tracking near-term 

business performance, and using an integrated set of metrics that span operational 

improvements, health indicators (e.g. staff engagement), and bottom-line results. Metrics 

could include cycle time, quality, pulse checks of staff, and other business outcomes to 

ensure unforeseen consequences are not occurring elsewhere in the organization.

56VA noted that as of February 2017 it had established timeliness goals for three of the 

four options. Because these goals represent average processing times, they are less 

useful for flagging early progress, percent of appeals meeting the goal, and trouble spots. 

Further, the agency did not set a goal for appeals to the Board involving new evidence 

and hearings—an option that will likely require more processing time than the others.
Page 32 GAO-17-234 VA Disability Benefits

determine whether the new process is sufficiently successful to justify full 

implementation.

Second, although streamlining the current open-ended process was 

central to VA’s business case for its proposed process reform, as noted 

previously, VA currently lacks sufficient data to assess the extent to which 

process reform will improve on the open-ended nature of the current 

process. VA officials said that they plan to work to incorporate capabilities 

into Caseflow to piece together historical baselines for performance. VA 

also plans to develop new baseline and historical data on aspects of the

appeals process that affect the timeliness of final decisions so that they 

can be compared to the new process. While these are positive steps, it 

remains to be determined how or whether VA will be able to measure the 

extent to which its proposed process—which would allow the veteran to 

appeal multiple times—is an improvement over “churning” associated with 

the old process.

Lastly, the new timeliness measures that VA plans to report to Congress 

and the public lack transparency on whether overall appeals resolution 

timeliness is improving from the veterans’ perspective. In its fiscal year 

2015 performance report, VA stopped reporting its average appeals 

resolution time measure, which included appeals decisions made by both 

VBA and the Board. VA officials said they considered this measure 

inadequate because neither VBA nor the Board has full control over 

making improvements to performance under this measure. VA officials 

told us the measure does not appropriately provide insight into the 

appeals process because of the variety of appeals paths and wait times 

veterans experience. However, the combined measure would provide a 

basis for comparing timeliness under the old versus new process, and 

would provide historical perspectives on changes in timeliness from the 

point of view of a veteran who may file appeals with both VBA and the 

Board before his or her case is resolved. VA officials stated the agency 

will continue to track this measure internally, but they will not include it in 

VA’s annual performance reports. Instead, they plan to report on VBA and 

Board timeliness separately. VA also stated that it will not use this 

measure to evaluate success of the new process because it considers a 

timeliness measure covering both VBA and the Board to be inappropriate.
Page 33 GAO-17-234 VA Disability Benefits

VA has generally planned the implementation of its Caseflow appeals 

system consistent with sound planning practices. Working with U.S. 

Digital Service at VA (DSVA)57—the group tasked with developing 

Caseflow—VA outlined an approach that has a clear scope and purpose, 

which is to better process appeals in a paperless environment and 

improve automation and productivity. The actions consistent with sound 

IT planning practices include:58

• Setting goals and objectives: VA plans clearly lay out the need for 

replacing VACOLS and set forth how Caseflow will address the 

shortcomings of VA’s current IT system. Its plans also lay out a set of 

broad milestones in terms of the capabilities that will be added to 

Caseflow in the future and the ultimate retirement of VACOLS.

• Identifying and mitigating potential risks: VA planning documents 

identify a number of risks (such as staffing shortfalls and technical 

delays) and strategies to mitigate them. In addition, VA is developing 

Caseflow in an agile process, which officials say will allow VA to 

continually add new capabilities and be responsive to changing 

agency needs. In addition, VA officials told us that rather than replace 

VACOLS at once, the various functions in VACOLS will be 

reproduced and tested in Caseflow iteratively, and each 

corresponding function in VACOLS will be left intact until there is 

reasonable assurance that there will be no impact to VA.

• Measuring performance: VA plans to develop metrics for each new 

component of Caseflow that is implemented. For instance, VA has 

developed metrics for the two components that were developed in 

fiscal year 2016—electronic transfer of cases to the Board and a 

system to electronically access documents from VBMS—which 

specifically assess the performance and effect of those components. 

As mentioned earlier, VA also plans to create a Caseflow dashboard 

that will provide metrics on the effect of IT improvements on 

timeliness of the appeals process.

• Identifying organizational roles and responsibilities: VA entered 

into a memorandum of understanding with DSVA and the Board that 

outlines priorities, and a working relationship for developing Caseflow. 

In addition, the memorandum states that DSVA requires all initiative 

 57DSVA is part of VA’s Office of Information and Technology.

58See GAO-04-394G. 

VA Has Taken Steps 

Consistent With Sound 

Planning Practices while 

Updating Its IT, but Lacks 

Clear Schedules for 

Implementing IT Updates
Page 34 GAO-17-234 VA Disability Benefits

partners within VA to have a single point of contact with the authority 

to make decisions on behalf of their component.

While VA’s plans for replacing VACOLS take steps to mitigate risks, they 

currently do not include consideration of the timing and implications of 

VA’s proposed reform efforts. Federal internal control standards state that 

program managers, in seeking to achieve program objectives, should 

define objectives clearly to enable the identification of risks. This includes 

clearly defining what is to be achieved and the time frames for 

achievement. Additionally, IT investment best practices stress the need 

for oversight regarding a project’s progress towards predefined schedule 

expectations. This oversight also includes systems to make corrections 

regarding schedule and performance slippages. Although VA has laid out 

the broad capabilities it would like to incorporate into Caseflow going 

forward, VA has not developed a schedule for completing Caseflow. 

Specifically, VA could not provide us with firm time frames for when 

different capabilities will be active in Caseflow. As the Caseflow effort 

lacks time frames, VA cannot ensure that the system will be completed in 

time to support the implementation of proposed reforms.

Further, VA’s lack of time frames for developing Caseflow may increase 

the risk of additional costs if the system cannot be developed as quickly 

as anticipated. Sound practices specific to project scheduling state that 

project planning is the basis for controlling and managing project 

performance, including managing the relationship between cost and 

time.59 In a prior GAO report on VBMS development—which was also 

developed in an agile process—we reported that the agency encountered 

some delays with its initial deployment of key functions of VBMS, and that 

its lack of a schedule made it difficult to hold program managers 

accountable for meeting time frames and demonstrating progress.60

In addition, VA has not started planning and determining the changes that 

would be needed for Caseflow if and when appeals reforms are 

implemented. VA staff said that the agile approach they are using allows 

them to quickly respond to changing needs, and VA Office of Information 

 59GAO, Schedule Assessment Guide: Best Practices for Project Schedules. GAO-16-89G 

(Washington, D.C: December 2015).

60We reported that some delays in completing functions of VBMS were due to factors 

such as decisions to enlarge VMBS’ scope over time and to delay plans to establish an 

electronic work queue, so that VBA could fully focus on eliminating its claims backlog 

within established goals. See GAO-15-582.
Page 35 GAO-17-234 VA Disability Benefits

and Technology officials told us that they will not begin planning for such 

changes until reform legislation is passed. As stated earlier, sound IT 

planning practices suggest that implementation plans include specific 

time frames and approaches needed to implement new systems, as well 

as the consideration of potential risks and mitigation strategies. As such, 

and given the absence of a schedule for completing Caseflow, VA further 

risks having an IT system that is not completed in a timely manner or, 

even if in place in time, falls short of meeting VA’s needs.

With an already large inventory of pending appeals—and expectations of 

further growth—VA has taken steps to bolster capacity and improve the 

efficiency and effectiveness of its disability appeals process. Specifically, 

VA hired and proposed hiring more staff, is moving forward with plans to 

upgrade its IT systems, and has proposed bold reforms to streamline its 

appeals process. In planning and executing these approaches, VA took 

several positive steps in line with sound planning practices—such as 

comparing different options for increasing future staffing resources, 

collaborating with external stakeholders to develop a streamlined process 

proposal, and outlining a vision for upgrading outdated IT systems.

Nonetheless, VA’s plans do not account for the significant challenges that 

remain. Above all, its proposal to implement appeals reform at the Board 

and across VBA’s regional offices is ambitious, and as a result, VA may 

be exposing itself to unforeseen risks and setbacks that could slow 

progress toward improving appeals decision timeliness. More specifically, 

VA has proposed implementing process reform while also hiring more 

staff and upgrading its IT, which are challenging efforts in their own right. 

Additionally, VA does not have any plans to pilot test its proposal—a 

sound and often necessary practice for experiencing, evaluating, and 

refining significant institutional change on a smaller scale prior to full 

implementation. At the same time, VA plans for hiring more staff and 

upgrading IT lack key details (for example, on how VA will train and find 

working space for new staff, or a schedule for when and how system 

changes might be integrated with the proposed streamlined process), 

exposing VA to risks of delays, inefficiencies, or other setbacks caused by 

not anticipating needs or a misalignment of efforts. VA also did not 

sufficiently apply sensitivity analysis when projecting staffing needs with 

or without process reform, which could affect the agency’s ability to 

mitigate any potential risks if assumptions are not met. Lastly, VA lacks a 

robust monitoring plan to help assure that unforeseen problems will be 

quickly and effectively addressed, and has not yet developed a strategy 

with appropriate interim goals for process reform, and overall goals for 

Conclusions
Page 36 GAO-17-234 VA Disability Benefits

appeals process timeliness, to gauge whether the agency’s efforts are 

having the desired result and reflect an improvement over prior practices. 

Until VA incorporates these sound planning practices, the agency lacks 

reasonable assurance that its proposed reform will improve the overall 

efficiency of the appeals process and timeliness of disability appeals 

decisions.

To improve VA’s ability to successfully implement appeals process 

reform, Congress should consider requiring that reforms of the VA 

disability appeals process be subject to a pilot test. To aid in the 

development of such a pilot test, Congress could require the Secretary of 

Veterans Affairs to propose options that would allow the agency the 

flexibility to test and refine the new process in a cost-effective and 

efficient manner, while ensuring pre-established interim goals and 

success criteria are being met prior to full implementation.

To further align efforts to address appeals workload and improve 

timeliness of decisions, and reduce the risk that efforts will not go as 

planned, we recommend that the Secretary of Veterans Affairs direct the 

Under Secretary for Benefits; the Chairman, Board of Veterans’ Appeals; 

and the Chief Information Officer, as appropriate, to:

1. Ensure development of a timely, detailed workforce plan for recruiting, 

hiring and training new hires. In particular, this plan should: (1) include 

detailed steps and timetables for updating training curriculum (such as 

preparing decisions in a virtual environment) and ensuring office 

space (such as telework guidance); and (2) incorporate risk mitigation 

strategies that consider how the timing of recruitment and training 

dovetails with uncertain time frames for implementing a new appeals 

process.

2. Develop a schedule for IT updates that explicitly addresses when and 

how any process reform will be integrated into new systems and when 

Caseflow will be ready to support a potential streamlined appeals 

process at its onset.

3. Conduct additional sensitivity analyses based on the assumptions 

used in projection models to more accurately estimate future appeals 

inventories and timeliness. In doing so, consider running additional 

analyses on how these factors, in conjunction with one another, may 

affect the timeliness and cost of deciding pending appeals.

Matter for 

Congressional 

Consideration

Recommendations for 

Executive Action
Page 37 GAO-17-234 VA Disability Benefits

4. Develop a more robust plan for closely monitoring implementation of 

process reform that includes metrics and interim goals to help track 

progress, evaluate efficiency and effectiveness, and identify trouble 

spots.

To better understand whether appeals process reform, in conjunction with 

other efforts, has improved timeliness, we recommend the Secretary of 

Veterans Affairs direct the Under Secretary for Benefits; the Chairman, 

Board of Veterans’ Appeals; and the Chief Information Officer, as 

appropriate to:

5. Develop a strategy for assessing process reform—relative to the 

current process—that ensures transparency in reporting to Congress 

and the public on the extent to which VA is improving veterans’

experiences with its disability appeals process.

We provided a draft of the report to VA for its review. In written 

comments, VA disagreed with one of our recommendations and agreed in 

principle with the other five. We have reproduced VA’s comments in 

appendix I and have incorporated them—as well as technical comments 

provided by VA—into the report, as appropriate. 

In its comments, VA agreed with us that improving the efficiency and 

effectiveness of its appeals process is an ambitious undertaking, and we 

commend VA for the many steps it has taken, including collaborating with 

stakeholders to develop the framework for a new process. We agree that 

obtaining the consensus of internal and external experts—including 

veterans service organizations—demonstrates important progress. We 

disagree, however, that such consensus negates the need for more 

detailed plans and robust risk mitigation strategies. While it is true that VA 

has made noteworthy progress developing an implementation plan to 

guide its efforts, we found the plan lacked important details, such as: how 

VA will monitor for interim success and trouble spots, including whether 

the agency has appropriately distributed resources among the new and 

old processes; how it will mitigate risk of implementation challenges or 

setbacks, and reduce their negative impact; and how it will measure 

whether the new process is improving overall appeals resolution 

timeliness from the veteran’s perspective. 

VA officials also said that VA has extensive experience in organizational 

change management, but it is not clear how some of the practices VA 

used in past transformation efforts are applicable to appeals reform, and 

we are concerned that VA could not provide further information on what 

Agency Comments 

and Our Evaluation
Page 38 GAO-17-234 VA Disability Benefits

these practices include or how they are relevant. We believe 

implementing all of our recommendations will increase the likelihood that 

VA’s efforts to improve the efficiency and effectiveness of its appeals 

process will be successful. For the five recommendations that VA 

concurred with in principle, VA described planned actions to address 

them and stated that it also considered the actions complete and 

requested we close the recommendations. However, we believe VA still 

needs to take actions to address those recommendations, as noted more 

fully below.

VA disagreed with a draft recommendation that it incorporate pilot testing 

of its proposed appeals process into implementation plans and pursue 

necessary legislative authority. In its comments, VA noted that the 

appeals process is broken and that piloting a new process would result in 

further delays to veterans appealing their disability decisions. VA 

disagreed with GAO’s finding that it had proposed the new process 

without analyzing feasible alternatives, noting that the agency designed 

the new process based on the collective experience of internal and 

external experts, and that these experts reached consensus on a new 

design that will be beneficial to veterans, the agency, and taxpayers, 

among others. VA noted that it has carefully assessed risks, identified a 

number of risk mitigation strategies, modeled a number of different 

scenarios, and developed a detailed implementation plan. 

When we reviewed these efforts, however, we found three primary 

shortcomings that need to be addressed. First, VA did not have the data it 

needs to fully understand the extent to which the current process has 

contributed to lengthy appeals time frames, which raises questions about 

whether the proposed process will address the root cause or causes of 

untimely appeals decisions. Specifically, VA lacks historical data on the 

extent to which the introduction of new evidence increases time frames.

Second, VA’s list of potential risks and risk mitigation strategies did not 

always include steps for mitigating the identified risks.61 Third, we found 

that VA’s implementation plans lacked details on how it will carry out key 

aspects of appeals reform, including how it will monitor the timeliness of 

appeals decisions under the old process compared to the new appeals 

 61In particular, regarding the risks that veteran behavior under the new Framework is 

unknown and may vary from VA’s assumptions. For example, VA’s assumptions about 

veterans’ likelihood of appealing directly to the Board might be too high or too low. VA’s 

stated risk mitigation strategy was to use conservative assumptions developed by agency 

and stakeholder experts, and to monitor the actual experience and update models 

accordingly. VA did not identify steps it might take if more veterans request a higher level 

or more reviews than assumed.
Page 39 GAO-17-234 VA Disability Benefits

process, while also hiring additional staff and integrating changes into the 

Caseflow IT system as discussed below. In VA’s comments, it also stated 

that piloting a new appeals process “would raise constitutional issues and 

prompt litigation.” We acknowledge that changing an adjudicatory process 

for determinations of benefits may prompt litigation. However, VA has not 

clearly articulated why pilot testing as a category is unconstitutional or 

why pilot testing poses unique constitutional issues. Further, as noted in 

the report and in VA’s comments, VA previously supported H.R. 800 in 

the 114th Congress, which would have directed VA to conduct an opt-in 

pilot process where a veteran could present a limited amount of new 

evidence and the Board, to the extent practical, would decide cases 

within one year. While GAO did not take a position on that bill, or its 

specific approach to pilot testing, changes of this magnitude in such a 

complex program justify some form of pilot testing to ensure process 

reform is implemented successfully and ultimately achieves VA’s goals. 

As noted in the report, pilot testing is recognized to be a sound planning 

practice and an important, often necessary approach for ensuring 

successful implementation when undertaking significant institutional 

changes.

Until VA pilot tests its appeals reforms, it will lack data to properly plan for 

and overcome the challenges that will likely arise during implementation. 

For example, VA may encounter difficulties making needed process 

changes while simultaneously implementing other logistical requirements, 

such as hiring and training new staff and updating its IT system. By not 

pilot testing, VA is missing a valuable opportunity to refine its 

implementation strategy by first seeing how process reform will unfold on 

a smaller scale. We believe that the potentially negative consequences of

delaying full implementation are far outweighed by the benefits that can 

be realized through piloting. For example, piloting could help avoid delays 

and expenses caused by the need to re-work the process after full scale 

implementation. In light of VA’s disagreement with our draft 

recommendation, we removed the recommendation and now pose a 

matter for congressional consideration. Specifically, to improve VA’s 

ability to successfully implement appeals process reform, Congress 

should consider requiring that reforms of the VA disability appeals 

process be subject to a pilot test. To aid in the development of such a 

pilot test, Congress could require the Secretary of Veterans Affairs to 

propose options that would allow the agency the flexibility to test and 

refine the new process in a cost-effective and efficient manner, while 

ensuring pre-established interim goals and success criteria are being met 

prior to full implementation. 
Page 40 GAO-17-234 VA Disability Benefits

VA concurred in principle with the draft recommendation that it finalize a 

detailed workforce plan that includes steps for training, support, and risk 

mitigation strategies. VA noted that, in addition to currently implementing 

a fiscal year 2017 workforce plan to hire additional staff, as discussed in 

the report, among other efforts it has recently launched new attorney 

training and continues to collaborate across the agency to identify space 

where new staff can be located. We have incorporated these updates into 

our report, as appropriate. In light of these efforts, and because future 

steps, such as developing training materials on the new appeals process, 

are contingent upon appeals reform legislation, VA stated it considers this 

recommendation complete and requested closure. While we recognize 

that VA has made progress and that certain actions, such as training on a 

new process, is contingent upon reform legislation, we disagree that the 

recommendation should be closed. As noted in our report, we found that

VA’s final recruiting, hiring, and training plans lacked important details. 

For example, VA officials were still updating training curriculum that 

supports work conducted in a virtual environment and which is critical for 

managing space restrictions for new staff.

62 Without a detailed workforce 

plan in place, VA cannot assess the success of its human capital 

approach, maximize its investments, or fully mitigate risks. More detailed 

workforce plans would help VA avoid the risks that staff will not be hired 

in time, not be properly trained, or not have the support necessary to 

process appeals. Waiting until legislation is enacted magnifies these 

risks. We believe additional action is needed to meet the intent of this 

recommendation; we also clarified the recommendation language to state 

that VA needs a more detailed plan.

VA concurred in principle with our recommendation that it develop a 

schedule for IT updates that lays out when and how any process reforms 

will be integrated into its Caseflow system. More specifically, VA noted 

that it will rely on the agile process to develop Caseflow—whereby new 

functions are continually added to the system as new user needs or policy 

changes arise—and does not plan to define schedules beyond 6 months. 

Given that Caseflow development related to the new appeals process is 

dependent on the enactment of new legislation, VA stated it considers 

this recommendation to be complete. While it is true that the agile 

process can help mitigate risks and avoid cost overruns and delays, we 

 62In addition, as of December 2016, key aspects of its hiring plan were still underway. For 

example, the Board stated that as part of its mitigation plan for ensuring sufficient space 

for new hires in 2017, it was in the process of reopening negotiations with the union to 

allow attorneys to work remotely, and planned to work with the Office of Administration to 

identify additional opportunities to use space more efficiently.
Page 41 GAO-17-234 VA Disability Benefits

do not believe this approach precludes VA from taking additional steps to 

consider the scope of potential changes required by a new appeals 

process and have a broad plan in place to ensure that all aspects of the 

new process are adequately supported by Caseflow. We believe it is 

especially important for VA to have specific time frames for completing 

Caseflow considering the scope of the changes being proposed. 

Moreover, VA noted that components of Caseflow developed so far will 

not need to be significantly changed because of appeals reform 

legislation being enacted, but VA did not provide documentation to 

support this assertion. In light of these issues, we believe VA has not yet 

met the intent of this recommendation.

VA concurred in principle with our recommendation that it should conduct 

additional sensitivity analyses around the assumptions used in its models. 

VA noted that sensitivity analyses are valuable and that it has focused its 

efforts on risks its staff identified as most likely, such as variations in 

staffing and productivity, and the effect of remands. VA stated it would 

continue to analyze, update, and refine its modeling, and considers this 

recommendation to be complete. While we recognize the logic of focusing 

modeling resources on key variables, VA did not fully examine three of 

the four hiring surge options it proposed. Moreover, VA did not assess the 

compound effect that would result in changing multiple assumptions at 

once. Given the complexity of proposed changes and the number of 

variables beyond VA’s control, we believe that additional analyses are 

needed to identify potential risks that may warrant additional mitigation 

strategies. In addition, if VA goes forward with appeals process reform 

and begins to collect real-time data, these data could improve modeling 

accuracy and serve as a valuable management tool.

VA concurred in principle with our recommendation to develop a more 

robust plan for closely monitoring the implementation of its process 

reform, that includes metrics and interim goals to help VA track progress, 

evaluate efficiency and effectiveness, and pinpoint trouble spots. VA 

agreed that developing such a plan is valuable for monitoring the 

implementation of process reform, and should include metrics and interim 

goals. However, VA stated that it considers this recommendation 

complete, noting that preparing such a detailed plan depends on appeals 

reform legislation being enacted, and that it will incorporate specific goals 

and metrics as it moves towards implementation. While we recognize that 

VA cannot assume to know the exact provisions that may be included in 

future enacted legislation, nor can it predict when appeals reform might 

be enacted, we consider having a more robust monitoring plan to be 

essential to the successful implementation of a new appeals process. 

Moreover, the absence of such a plan raises questions as to how VA will 
Page 42 GAO-17-234 VA Disability Benefits

ensure appropriate resources are devoted to managing appeals under the 

new versus old process, or intended results are achieved as the new 

process is implemented.

VA concurred in principle with our recommendation to develop a strategy 

to transparently report to Congress and the public on veterans’ 

experiences with the new appeals process. VA noted that it is already 

developing timeliness goals for three of the four appeal options in the 

proposed new process, as discussed in our report. VA said it also plans 

to measure success of the new process with results from customer 

satisfaction surveys and is developing a dashboard for internal 

performance monitoring. VA did not agree that measuring overall appeals 

resolution timeliness is an appropriate a measure and believes tracking 

time frames for each of the options separately is more appropriate. While 

we agree that metrics based on the different options could be valuable for 

VA, the Congress, and the public, we disagree that VA’s focus on 

measuring timeliness by option is in the best interest of the veteran.

Because veterans may pursue more than one option under VBA, the 

Board or both, we believe that VA’s approach does not take into account 

the veteran’s perspective of how long it took for them to receive a final 

appeal decision. Metrics from the veterans’ overall perspective would 

complement, not replace, metrics for VBA, the Board, and each option. 

Further, because VA’s approach does not allow VA to compare the new 

process with the old or to determine whether the new process represents 

an improvement over the old process, we believe it does not promote 

transparency in reporting to the Congress and the public. 
Page 43 GAO-17-234 VA Disability Benefits

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Veterans Affairs, the Under Secretary for 

Benefits, the Chairman of the Board of Veterans Appeals, and the VA’s 

Chief Information Officer. In addition, the report is available at no charge 

on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or bertonid@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this

report are listed in appendix II.

Daniel Bertoni

Director

Education, Workforce, and Income Security Issues
Page 44 GAO-17-234 VA Disability Benefits

List of Addressees

The Honorable Johnny Isakson

Chairman

The Honorable Jon Tester

Ranking Member

Committee on Veterans’ Affairs

United States Senate

The Honorable Jerry Moran

Chairman

The Honorable Brian Schatz

Ranking Member

Subcommittee on Military Construction, Veterans Affairs, and Related 

Agencies

Committee on Appropriations

United States Senate

The Honorable Phil Roe

Chairman

The Honorable Tim Walz

Ranking Member

Committee on Veterans’ Affairs

House of Representatives

The Honorable Mike Bost

Chairman

The Honorable Elizabeth Esty

Ranking Member

Subcommittee on Disability Assistance and Memorial Affairs

Committee on Veterans’ Affairs

House of Representatives

The Honorable Robert Menendez

United States Senate

The Honorable Dina Titus

House of Representatives
Page 45 GAO-17-234 VA Disability Benefits

Appendix I: Comments from the Department 

of Veterans Affairs
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Daniel Bertoni, Director, (202) 512-7215 or bertonid@gao.gov

In addition to the contact named above, Michele Grgich (Assistant 

Director), Melissa Jaynes (Analyst-in-Charge), Daniel Concepcion, and 

Greg Whitney made key contributions to this report. Other key 

contributors to this report include James Bennett, Mark Bird, David 

Chrisinger, Clifton Douglas, Alex Galuten, Mitch Karpman, Sheila R. 

McCoy, Claudine Pauselli, Almeta Spencer, Eric Trout, Walter Vance, 

and Tom Williams.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Page 61 GAO-17-234 VA Disability Benefits

For the purpose of evaluating VA’s efforts to improve its appeal 

processing, we identified best practices and other criteria related to 

staffing, process reform, and IT upgrades identified in prior GAO products 

and other publications. These included government-wide internal control 

standards; key principles for effective strategic workforce planning; 

business process reengineering (or redesign) best practices, and 

information technology planning principles. We also reviewed additional 

guidance on project management.

GAO Products

Schedule Assessment Guide: Best Practices for Project Schedules. 

GAO-16-89G. Washington, D.C.: December 2015.

Veterans Benefits Management System: Ongoing Development and 

Implementation Can Be Improved; Goals are Needed to Promote 

Increased User Satisfaction. GAO-15-582. Washington, D.C.: September 

1, 2015.

Standards for Internal Control in the Federal Government. GAO-14-704G. 

Washington, D.C.: September 2014.

Human Capital: Strategies to Help Agencies Meet Their Missions in an 

Era of Highly Constrained Resources. GAO-14-168. Washington, D.C.: 

May 7, 2014.

Managing For Results: Agencies Should More Fully Develop Priority 

Goals under the GPRA Modernization Act. GAO-13-174. Washington, 

D.C.: April 19, 2013.

GAO Cost Estimating and Assessment Guide: Best Practices for 

Developing and Managing Capital Program Costs. GAO-09-3SP. 

Washington D.C.: March 2009.

Human Capital: A Guide for Assessing Strategic Training and 

Development Efforts in the Federal Government. GAO-04-546G. 

Washington, D.C.: March 2004.

Information Technology Investment Management: A Framework for 

Assessing and Improving Process Maturity. GAO-04-394G. Washington, 

D.C.: March 2004.

Related GAO and Other Products
Page 62 GAO-17-234 VA Disability Benefits

Combating Terrorism: Evaluation of Selected Characteristics in National 

Strategies Related to Terrorism. GAO-04-408T. Washington, D.C.: 

February 3, 2004.

Human Capital: Key Principles for Effective Strategic Workforce Planning. 

GAO-04-39. Washington, D.C.: December 11, 2003.

Human Capital: A Self-Assessment Checklist for Agency Leaders. 

GAO/OCG-00-14G. Washington, D.C.: September 2000.

The Results Act: An Evaluator’s Guide to Assessing Agency Annual 

Performance Plans. GAO/GGD-10.1.20. Washington, D.C.: April 1998.

Business Process Reengineering Assessment Guide. 

GAO/AIMD-10.1.15. Washington, D.C.: May 1997.

Executive Guide: Effectively Implementing the Government Performance 

and Results Act. GAO/GGD-96-118. Washington, D.C.: June 1996.

Non-GAO Publications

Blackburn, Simon, Sarah Ryerson, Leigh Weiss, Sarah Wilson, and 

Carter Wood, Insights into Organization: How Do I Implement Complex 

Change at Scale? Dallas, Texas: McKinsey & Company, May 2011.

George, Michael L, David Rowlands, Mark Price, and John Maxey. The 

Lean Six Sigma Pocket Toolbook: A Quick Reference Guide to Nearly 

100 Tools for Improving Process Quality, Speed, and Complexity. New 

York: McGraw-Hill, 2005.

Office of Management and Budget. Circular No. A-11, Preparation, 

Submission, and Execution of the Budget. Washington, D.C.: July 1, 

2016.

Project Management Institute, Inc. A Guide To The Project Management 

Body Of Knowledge (PMBOK Guide) Newtown Square, PA.: 2013. 

(100666)
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