VA DISABILITY 

BENEFITS

Improved Planning 

Practices Would

Better Ensure 

Successful Appeals 

Reform

Report to Congressional Committees

March 2018

GAO-18-352

United States Government Accountability Office
United States Government Accountability Office

 

Highlights of GAO-18-352, a report to 

congressional committees

March 2018

VA DISABILITY BENEFITS

Improved Planning Practices Would Better Ensure 

Successful Appeals Reform

What GAO Found

The Department of Veterans Affairs’ (VA) plan for implementing a new disability 

appeals process while attending to appeals in the current process addresses 

most, but not all, elements required by the Veterans Appeals Improvement and 

Modernization Act of 2017 (Act). VA’s appeals plan addresses 17 of 22 required 

elements, partially addresses 4, and does not address 1. For example, not 

addressed is the required element to include the resources needed by the 

Veterans Benefits Administration (VBA) and the Board of Veterans’ Appeals 

(Board) to implement the new appeals process and address legacy appeals 

under the current process. VA needs this information to certify, as specified 

under the Act, that it has sufficient resources to implement appeals reform and 

make timely appeals decisions under the new and legacy processes. 

VA’s appeals plan reflects certain sound planning practices, but it could benefit 

from including important details in several key planning areas: 

Performance measurement: VA’s plan reflects steps taken to track 

performance, but could articulate a more complete and balanced set of goals 

and measures for monitoring and assessing performance on a range of 

dimensions of success. Specifically, the plan reports that VA is developing a 

process to track timeliness of the new and legacy processes. However, contrary 

to sound planning practices, the plan does not include timeliness goals for all five 

appeals options available to veterans, does not include goals or measures for 

additional aspects of performance (such as accuracy or cost), and does not 

explain how VA will monitor or assess the new process compared to the legacy 

process. Unless VA clearly articulates a complete and balanced set of goals and 

measures, it could inadvertently incentivize staff to focus on certain aspects of 

appeals performance over others or fail to improve overall service to veterans.

Project management: VA’s plan includes a master schedule for implementing

the new appeals plan. However, this schedule falls short of other sound practices

for guiding implementation and establishing accountability, such as articulating 

interim goals and needed resources for, and interdependencies among, 

activities. Unless VA augments its master schedule to include all key activities 

and reflect sound practices, VA may be unable to provide reasonable assurance 

that it has the essential program management information needed for this 

complex and important effort. 

Risk assessment: VA has taken steps to assess and mitigate some risks 

related to appeals reform by, for example, pilot testing two of the five appeals 

options through its Rapid Appeals Modernization Program (RAMP). However, as 

designed, RAMP does not include key features of a well-developed and 

documented pilot test. For example, VA has not articulated how it will assess 

RAMP before proceeding with full implementation. In addition, RAMP is not pilot 

testing three options and, as a result, VA will not have data on the extent to 

which veterans will appeal directly to the Board when given the option. Unless 

VA identifies and mitigates key risks associated with implementing a new 

process, VA is taking a chance that untested aspects will not perform as desired. View GAO-18-352. For more information, 

contact Elizabeth Curda at (202) 512-7215 or 

curdae@gao.gov.

Why GAO Did This Study

VA’s disability compensation program 

pays cash benefits to veterans with

disabilities connected to their military 

service. In recent years, the number of 

appeals of VA’s benefit decisions has 

been rising. For decisions made on 

appeal in fiscal year 2017, veterans 

waited an average of 3 years for 

resolution by either VBA or the Board, 

and 7 years for resolution by the 

Board. The Veterans Appeals 

Improvement and Modernization Act of 

2017 makes changes to VA’s current 

(legacy) appeals process, giving 

veterans new options to have their 

claims further reviewed by VBA or 

appeal directly to the Board. The Act 

requires VA to submit to Congress and 

GAO a plan for implementing a new 

appeals process, and includes a 

provision for GAO to assess VA’s plan.

This report examines the extent to 

which VA’s plan (1) addresses the 

required elements in the Act, and (2) 

reflects sound planning practices 

identified in prior GAO work. GAO

reviewed and assessed VA’s appeals 

plan and related documents against 

sound planning practices, and solicited

VA’s views on its assessments. 

What GAO Recommends

GAO recommends that VA (1) fully 

address all legally required elements in 

its appeals plan, (2) articulate how it 

will monitor and assess the new 

appeals process as compared to the 

legacy process, (3) augment its master 

schedule for implementation, and (4)

address risk more fully. VA agreed with 

GAO’s recommendations and outlined 

its planned actions to address them. 
Page i GAO-18-352 VA Disability Benefits

Letter 1

Background 4

VA’s Plan Addresses Most of the Act’s Required Elements for the 

New and Legacy Disability Appeals Processes 7

VA’s Appeals Plan Reflects Certain Sound Planning Practices, but 

Could Improve on Others 11

Conclusions 24

Recommendations for Executive Action 26

Agency Comments and Our Evaluation 26

Appendix I Our Assessment of VA’s Appeals Plan Against Required 

Elements in the Act 31

Appendix II Comments from the Department of Veterans Affairs 35

Appendix III GAO Contact and Staff Acknowledgments 65

Tables

Table 1: The Department of Veterans Affairs’ (VA) Appeals Plan 

Partially Addresses or Does Not Address 5 of 22 Required 

Elements of the Veterans Appeals Improvement and 

Modernization Act of 2017 8

Table 2: Summary of GAO’s Assessment of VA’s Appeals Plan 

Against the Required Elements in the Veterans Appeals 

Improvement and Modernization Act of 2017 (Act) 32

Contents
Page ii GAO-18-352 VA Disability Benefits

Abbreviations

Act Veterans Appeals Improvement and Modernization 

Act of 2017

Board Board of Veterans’ Appeals

DRO Decision Review Officer

IT information technology

PMI Project Management Institute 

RAMP Rapid Appeals Modernization Program

VA Department of Veterans Affairs

VBA Veterans Benefits Administration

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Page 1 GAO-18-352 VA Disability Benefits

441 G St. N.W.

Washington, DC 20548

March 22, 2018

Congressional Committees

The Department of Veterans Affairs (VA) provides cash benefits to 

veterans for disabling conditions incurred in or aggravated by military 

service, paying an estimated $67 billion to about 4.3 million veterans in 

fiscal year 2016.1 If veterans are dissatisfied with VA’s initial decision they 

can appeal—first to the Veterans Benefits Administration (VBA) and then, 

if not satisfied there, to the Board of Veterans’ Appeals (Board), a 

separate agency within VA. In recent years, the number of appeals of 

VA’s benefit decisions has been rising. For appeals resolved in fiscal year 

2017, veterans waited an average of 3 years from the date they initiated 

their appeal to resolution by either VBA or the Board—and a cumulative 

average of 7 years for appeals resolved by the Board.2 Due in part to the 

challenges VA faces managing large workloads and deciding disability 

claims and appeals in a timely manner, GAO in 2003 designated VA 

disability compensation and other federal disability programs as one of 

the government’s highest management risks.3

In a March 2017 report, we examined VA’s approaches to address 

challenges it identified as contributing to lengthy appeals processing 

times—including VA efforts to hire staff, propose reform legislation to 

Congress in April 2016, and upgrade its information technology (IT)

systems—and the extent to which those approaches were consistent with 

sound planning practices.4 We made five recommendations to improve 

VA’s ability to implement its proposed appeals process reform while 

addressing a growing appeals workload. VA agreed in principle with our 

five recommendations, which remain open as of March 2018. We 

recommended, in essence, that VA develop: (1) a detailed workforce 

plan, (2) a complete schedule of IT updates, (3) better estimates of future 

workloads and timeliness, (4) a robust plan for monitoring appeals reform, 

 

1

VA Fiscal Year 2018 Congressional Budget Justification.

2

VA, Comprehensive Plan for Processing of Legacy Appeals and Implementing the 

Modernized Appeals System (Washington, D.C.: Nov. 22, 2017). 

3

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). 

4

GAO, VA Disability Benefits: Additional Planning Would Enhance Efforts to Improve the 

Timeliness of Appeals Decisions, GAO-17-234 (Washington, D.C.: March 23, 2017).

Letter
Page 2 GAO-18-352 VA Disability Benefits

and (5) a strategy for assessing whether the new process improves 

veterans’ experiences over the current process.5 We also suggested that 

Congress require VA to pilot test appeals reform.

Enacted on August 23, 2017, the Veterans Appeals Improvement and 

Modernization Act of 2017 (Act) will make changes to VA’s appeals 

process.6 Specifically, the Act replaces the current appeals process with 

one that gives veterans various options to have their claim reviewed 

further by VBA or to bypass VBA and appeal directly to the Board. The 

Act also requires VA to submit a comprehensive plan for implementing 

the new appeals process and processing legacy appeals (appeals that 

remain pending in the current process prior to fully implementing appeals 

reform) to the appropriate committees of Congress and GAO.7 The Act 

delineates the required elements of this plan, and required VA to submit 

its plan within 90 days of enactment. VA submitted its plan on November 

22, 2017. The Act also includes a provision for GAO to assess VA’s 

appeals plan, including whether the plan comports with sound planning 

practices and/or contains gaps.

This report examines the extent to which VA’s appeals plan (1) addresses 

the required elements in the Act; and (2) reflects sound planning practices 

identified in prior GAO work.8

To assess the extent to which VA’s plan addresses the required elements 

in the Act, we identified the required elements under section 3(a) and (b) 

of the Act; compared VA’s appeals plan and supplemental materials VA 

provided at our request to those elements; and made a preliminary 

determination as to whether VA’s plan addressed, partially addressed, or 

did not address each element. We then shared the results of this review 

 

5

While agreeing in principle, VA stated in its written comments that all five 

recommendations should be closed because its efforts to date already addressed the 

recommendations, or further progress was contingent upon passage of appeals reform 

legislation. We disagreed and maintained that VA needed to take further action on all 

recommendations.

6

Pub. L. No. 115-55, § 2, 131 Stat. 1105, 1105.

7

The Act defines “appropriate committees of Congress” to be the Committee on Veterans’ 

Affairs and the Committee on Appropriations of the Senate, and the Committee on 

Veterans’ Affairs and the Committee on Appropriations of the House of Representatives. 

8

We discussed our work and proposed recommendations in a January 2018 testimony.

See GAO, VA Disability Benefits: Opportunities Exist to Better Ensure Successful Appeals 

Reform, GAO-18-349T (Washington, D.C.: Jan. 30, 2018).
Page 3 GAO-18-352 VA Disability Benefits

with VA officials, and considered their comments in arriving at our 

assessment.9

To address the extent to which VA’s plan reflects sound planning 

practices, we compared the appeals plan and supplemental materials 

against relevant sound planning practices and other criteria identified in 

our prior work.10 

For both assessments, our analyses focused on the information and 

elements VA presented in its appeals plan and in supplemental materials 

rather than auditing the underlying information. We shared our findings 

related to both assessments with VA. Specifically, in advance of a 

January 30, 2018 hearing based on our ongoing work, we provided VA a 

draft of our testimony statement for review and comment.11 At a January 

17, 2018 meeting, VA officials provided us with comments on our 

findings, including our findings of how VA’s plan compared to sound 

practices, which we have incorporated in this report, as appropriate. 

We conducted this performance audit from October 2017 to March 2018 

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.

 

9

We developed a checklist and decision rules to determine whether VA’s appeals plan 

addressed, partially addressed, or did not address each required element, or all of the 

sub-parts of each required element, of the Act. Using these tools, an analyst reviewed 

VA’s plan against each required element and documented a judgment about whether that 

element was addressed in VA’s appeals plan. An attorney reviewed the analyst’s 

assessment and documented agreement or disagreement with the initial assessment. 

Where the attorney and analyst did not agree, a second attorney reviewed and made a 

final decision. We sent our preliminary assessment to officials at VA for comment and 

verification, which we considered in arriving at the assessment in this report. 

10See GAO-17-234. Specifically, that report identified best practices and other criteria 

through a review of relevant literature, such as federal internal control standards and prior 

GAO reports in which we defined a number of desirable characteristics of an effective, 

results-oriented plan, or components of sound planning practices. For a list of the sources 

of sound practices and criteria used to evaluate VA’s approaches, see the Related GAO 

and Other Products section of GAO-17-234 (page 61).

11For our published statement, see GAO-18-349T. 
Page 4 GAO-18-352 VA Disability Benefits

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

begins when a veteran submits a claim to VA. The veteran submits his or 

her claim to one of VBA’s 56 regional offices, where staff members assist 

the veteran by gathering additional evidence, such as military and 

medical records, that is needed to evaluate the claim. Based on this 

evidence, VBA decides whether the veteran is entitled to compensation 

and, if so, how much.

A veteran dissatisfied with the initial claim decision can generally appeal 

within 1 year from the date of the notification letter sent by VBA. Under 

the current appeals process (now referred to by VA as the legacy 

process), an appeal begins with the veteran filing a Notice of 

Disagreement. VBA then re-examines the case and generally issues a 

Statement of the Case that represents its decision.12

A veteran dissatisfied with VBA’s decision can file an appeal with the 

Board. In filing that appeal, the veteran can indicate whether a Board 

hearing is desired. Before the Board reviews the appeal, VBA prepares 

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

hearing to present new evidence or arguments, the Board will hold a 

hearing by videoconference or at a local VBA regional office. The Board’s 

members, also known as Veterans Law Judges, review the evidence and 

either issue a decision to grant or deny the veteran’s appeal or refer (or 

remand) the appeal back to VBA for further work.

The 2017 Act made changes to VA’s legacy appeals process that will 

generally take effect no earlier than February 2019, which is 

 

12According to VA officials, the veteran can elect either a traditional VBA review or a VBA 

review by a Decision Review Officer (DRO). Under the traditional review option, the 

veteran may present new evidence and receive a formal hearing. In general, the review 

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 DRO, 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 DRO may also pursue 

additional evidence or discuss the appeal informally with the veteran or the veteran’s 

representative.

Background

VA’s Disability 

Compensation Claims 

Process

New Appeals Process
Page 5 GAO-18-352 VA Disability Benefits

approximately 18 months from the date of enactment.13 According to its 

appeals plan, VA intends to implement the Act by replacing the current 

appeals process with a process offering veterans who are dissatisfied 

with VBA’s decision on their claim one of five options: two of those 

options afford the veteran an opportunity for an additional review of VBA’s 

decision within VBA, and the other three options afford them the 

opportunity to bypass additional VBA review and appeal directly to the 

Board.14

• Under the new appeals process, the two VBA options will be:

1. Request higher-level review: The veteran asks VBA to review its 

initial decision based on the same evidence but with a higher-level 

official reviewing and issuing a new decision.

2. File supplemental claim: The veteran provides additional 

evidence and files a supplemental claim with VBA for a new 

decision on the claim.

• The three Board options will be:

3. Request Board review of existing record: The veteran appeals 

to the Board and asks it to review only the existing record without 

a hearing.

4. Request Board review of additional evidence, without a 

hearing.

5. Request Board review of additional evidence, with a hearing.

The Act also requires VA to submit to the appropriate committees of 

Congress and GAO, within 90 days of the date of enactment, a 

comprehensive plan for (1) processing appeals under the legacy process 

 

13Under the Act, the legal changes to VA’s appeals process will generally take effect on or 

after the later of (1) 540 days (approximately 18 months) after enactment, and (2) 30 days 

after the Secretary of Veterans Affairs submits to the appropriate committees of Congress 

(i) a certification that VA has the resources, personnel, office space, procedures, and IT 

required to carry out the new appeals system and to timely address appeals under the 

new appeals system as well as pending legacy appeals, and (ii) a summary of the 

expected performance outcomes used in making the certification with respect to legacy 

claims and a comparison of these expected outcomes with actual program performance 

with respect to the appeals under the legacy system (before the new system is 

implemented). Pub. L. No. 115-55, § 2, 131 Stat. 1105, 1105.

14Veterans who are dissatisfied with VBA’s decision on their appeal may file another 

appeal to the Board using one of these three options, according to VA officials. 

VA’s Appeals Plan
Page 6 GAO-18-352 VA Disability Benefits

until there are no more to process, (2) implementing the new appeals 

process, (3) processing of claims under the new appeals process in a 

timely manner, and (4) monitoring implementation of the new appeals 

process. In addition to these four broad elements, the Act lists 18 

elements required to be included in the plan that relate to, among other 

things:

• staffing, IT, and other resources required to implement the plan;

• estimated timelines for hiring and training VA employees; and

• a description of risks associated with each element of the plan.15

The Act also includes a provision for GAO to assess the plan within 90 

days after VA submits it.16

The Act also requires VA to provide progress reports to the appropriate 

committees of Congress and GAO at least once every 90 days (starting 

after VA submits its plan), until the date the Act’s legal changes to the 

appeals process generally go into effect and then at least once every 180 

days after this date for 7 years.

The Act also authorized VA to carry out a program to test any 

assumptions relied upon in developing its comprehensive plan and test 

the feasibility and advisability of any facet of the new appeals process. In 

its appeals plan, VA reported its decision to pilot test two of the five new 

options by allowing veterans with pending appeals in the legacy process 

(known as legacy appeals) to elect the VBA higher-level review or VBA 

supplemental claim options beginning in November 2017. This program, 

which VA refers to as RAMP, is intended to reduce legacy appeals by 

providing veterans with a chance for early resolution of their claims within 

VBA while the Board focuses on reducing its inventory of legacy appeals, 

according to VA. Participation in RAMP is voluntary, but veterans must 

withdraw their pending legacy appeal to participate, according to VA. 

Veterans dissatisfied with their RAMP decisions must wait until VA fully 

implements the new appeals process (in February 2019 at the earliest) 

before pursuing an appeal with the Board under the new process, 

according to VA officials.

 

15Pub. L. No. 115-55, § 3(a) and (b), 131 Stat. 1105, 1116.

16VA submitted its plan to GAO on November 22, 2017. 

Rapid Appeals 

Modernization Program 

(RAMP)
Page 7 GAO-18-352 VA Disability Benefits

VA’s appeals plan addresses 17 of the Act’s 22 required elements, 

partially addresses 4 related to monitoring implementation and workforce 

planning, and does not address 1 element related to identifying total 

resources. For example, VA’s appeals plan addresses the required 

elements related to, among others, identifying legal authorities for hiring 

and removing employees, estimating timelines for hiring and training 

employees, and outlining the outreach VA expects to conduct. For the 

elements in the Act that VA’s appeals plan partially addresses or does not 

address, see table 1. For a detailed list of the 22 required elements in the 

Act, see appendix I.

VA’s Plan Addresses 

Most of the Act’s 

Required Elements 

for the New and 

Legacy Disability 

Appeals Processes
Page 8 GAO-18-352 VA Disability Benefits

Table 1: The Department of Veterans Affairs’ (VA) Appeals Plan Partially Addresses or Does Not Address 5 of 22 

Required Elements of the Veterans Appeals Improvement and Modernization Act of 2017

Required element in the Act What VA provides Our assessment

VA’s preliminary comments 

and our responsea

Section 3(a)(4)

A comprehensive plan for 

monitoring the implementation 

of the new appeals system, 

including metrics and goals— 

(A) to track the progress of 

implementation;

(B) to evaluate the efficiency 

and effectiveness of the 

implementation; and

(C) to identify potential issues 

relating to the implementation.

VA’s plan states that the 

agency convened an 

enterprise-wide governance 

workgroup to oversee 

implementation and develop 

metrics and track timeliness of 

appeals in the legacy system 

and the new process.

The plan also references VA’s 

intended use of certain 

metrics, such as average 

processing time for Veterans 

Benefits Administration (VBA) 

options.

Partially addressed: VA’s 

appeals plan does not contain 

sufficient details about metrics 

for tracking the progress of 

implementation 

(subparagraph (A)) or the 

metrics and goals for 

identifying potential issues 

related to implementation 

(subparagraph (C)).

VA officials stated that they 

disagree with our assessment 

and that their appeals plan 

addresses this required 

element. Their comments 

generally restated what is 

contained in VA’s plan, except 

they added that the agency is 

developing more detailed 

project plans and schedules.

We continue to believe VA’s 

plan partially addresses this 

required element.

Section 3(b)(1)

Delineation of the total 

resource requirements of the 

Veterans Benefits 

Administration and the Board 

of Veterans’ Appeals, 

disaggregated by resources 

required to implement and 

administer the new appeals 

system and resources 

required to address the 

appeals of decisions on 

legacy claims.

VA’s plan states that the 

agency will use existing 

resources devoted to its 

workforce, information 

technology (IT) systems, and 

performance tracking, among 

other areas, to implement 

parts of the new appeals 

process. VA’s plan indicates it 

will collect and use data from 

its Rapid Appeals 

Modernization Program 

(RAMP)—for example, on the 

(1) percentage of veterans 

who opt-in to this program, (2) 

veterans’ choices within the 

new VBA options, and (3) VA 

employees’ productivity—to 

inform future funding requests 

through the annual 

appropriations process. In its 

plan, VA states that it will 

efficiently allocate resources 

to the new appeals process 

and allocate all remaining 

resources to address legacy 

appeals.

Not addressed: VA’s appeals 

plan does not include a 

delineation of the total 

resources required by VBA 

and the Board of Veterans’ 

Appeals (Board) to implement 

the new system while 

addressing pending legacy 

appeals. 

VA officials stated that they 

disagree with our assessment 

and that this element is 

addressed in their plan. Their 

comments generally restated 

what is contained in VA’s plan.

We continue to believe VA’s 

plan does not address this 

required element.
Page 9 GAO-18-352 VA Disability Benefits

Required element in the Act What VA provides Our assessment

VA’s preliminary comments 

and our responsea

Section 3(b)(2)

Delineation of the personnel 

requirements of the 

Administration and the Board, 

including staffing levels during 

the— 

(A) period in which the 

Administration and the Board

are concurrently processing— 

(i) appeals of decisions on 

legacy claims; and

(ii) appeals of decisions on 

non-legacy claims under the 

new appeals system; and

(B) the period during which 

the Administration and the 

Board are no longer 

processing any appeals of 

decisions on legacy claims.

VA’s plan states the number 

of personnel required by VBA 

and the Board for concurrently 

processing legacy and new 

appeals in fiscal year 2018 

(1,495 and 1,050 full-time 

equivalents, respectively).

The plan also references 

using data from RAMP and 

the new system—once fully 

implemented—to inform its 

personnel needs for when VA 

is no longer processing legacy 

appeals.b Further, VA’s 

statements suggest the 

agency will wait for RAMP 

results and budget outcomes 

to estimate future personnel 

requirements, rather than 

develop estimates based on a 

range of assumptions.

Partially addressed: VA’s 

appeals plan does not provide 

an estimate of personnel 

required for either VBA or the 

Board for the period when the 

agency would no longer be 

processing legacy appeals 

(subparagraph (B)). 

VA officials stated that they 

disagree with our assessment 

and that their appeals plan 

addresses this required 

element.

Their comments generally 

restated what is contained in 

VA’s plan.

We continue to believe VA’s 

plan partially addresses this 

required element.

Section 3(b)(12)

Projections for the productivity 

of individual employees at the 

Administration and the Board 

in carrying out tasks relating 

to the processing of appeals 

of decisions on legacy claims 

and appeals under the new 

appeals system, taking into 

account the experience level 

of new employees and the 

enhanced notice requirements 

under section 5104(b) of title 

38, United States Code, as 

amended by section 2(e).

For VBA, VA provided 

information on productivity 

projections for processing 

legacy appeals in fiscal year 

2018 that are not in the plan. 

Also, VA’s plan states VA 

would use data from RAMP 

and the new process—once 

fully implemented—to develop 

productivity information for the 

new process.

For the Board, VA’s plan 

provides productivity 

projections for processing 

legacy appeals in fiscal year 

2018 and projects that 

productivity will be higher 

under the new process. 

Partially addressed: VA’s 

appeals plan does not contain 

projected productivity 

information for VBA 

processing of appeals under 

the new process.

VA officials stated that they 

disagree with our assessment 

and that their appeals plan 

addresses this required 

element. In their comments, VA 

officials provided additional 

information on productivity 

projections that are not in the 

plan. For VBA, VA provided 

projections for the legacy 

process for fiscal year 2018. For 

the Board, VA restated that 

productivity will be 79 appeals 

per full-time equivalent for fiscal 

year 2018 and projects that 

productivity will be higher than 

79 in the new appeals process.

We continue to believe VA’s 

plan partially addresses this 

required element due to the 

absence of projected 

productivity information for VBA 

processing appeals under the 

new process, which VA 

anticipates will be implemented 

in fiscal year 2019.
Page 10 GAO-18-352 VA Disability Benefits

Required element in the Act What VA provides Our assessment

VA’s preliminary comments 

and our responsea

Section 3(b)(17)

Delineation of the key goals 

and milestones for reducing 

the number of pending 

appeals that are not 

processed under the new 

appeals system, including the 

expected number of appeals, 

remands, and hearing 

requests at the Administration 

and the Board each year, 

beginning with the one year 

period beginning on the date 

of the enactment of this Act, 

until there are no longer any 

appeals pending before the 

Administration or the Board 

for a decision on a legacy 

claim.

VA’s plan states that the rate 

at which the legacy appeals 

inventory can be resolved 

depends on numerous factors, 

such as future funding and the 

rate that veterans opt into 

RAMP. VA’s plan indicates 

that the agency would collect 

information from RAMP and 

as the Board begins deciding 

appeals in the new process to 

develop accurate goals and 

milestones for reducing the 

number of pending legacy 

appeals at VBA and the 

Board. For the Board, VA 

provided aggregated 

information on appeals and 

remands that were not in the 

plan.

Partially addressed: VA’s 

appeals plan does not contain 

milestones for reducing legacy 

appeals. The plan also does 

not describe the expected 

number of appeals, remands, 

and hearing requests at VBA, 

or the expected number of 

hearing requests at the Board 

each year. Further, the followup information VA provided for 

VBA and the Board does not 

extend beyond fiscal year 

2019, yet VA indicates that 

the Board will be processing 

legacy appeals for several 

years.

VA officials stated that they 

disagree with our assessment 

and that this element is 

addressed in their plan. For the 

Board, VA also provided 

updated information that 

contained aggregated appeals 

and remands expected in fiscal 

years 2018 and 2019.

We continue to believe VA’s 

plan partially addresses this 

required element due to the 

absence of (1) milestones for 

reducing legacy appeals; (2) 

expected number of appeals, 

remands, and hearing requests 

at VBA, or the expected number 

of hearing requests at the Board 

each year; and (3) key goals 

and milestones beyond fiscal 

year 2019.

Source: GAO analysis of VA’s November 2017 appeals plan and supporting documents VA provided on or before January 18, 2018, the Veterans Appeals Improvement and Modernization Act of 2017, 

and VA input. | GAO-18-352

Note: We identified 22 required elements for VA’s comprehensive plan under section 3(a) and (b) of 

the Act. Specifically, subsection (a) contains 4 elements, and subsection (b) requires the appeals plan 

to address 18 elements. Although this table shows the required elements that VA’s plan partially 

addresses or does not address, VA’s appeals plan addressed most (17 of 22) of the required 

elements in the Act. In determining that VA’s plan addresses these requirements, we assessed the 

plan and its elements as presented, rather than auditing the underlying information.

a

VA provided its preliminary comments to us on January 11, 2018. Subsequently, in discussing our 

assessment at a January 2018 House Committee on Veterans’ Affairs hearing, the Deputy Secretary 

of Veterans Affairs stated that the agency agreed with our assessment and will work with us to 

address the requirements.

b

RAMP involves VA inviting certain veterans with pending appeals—starting with those appeals 

pending the longest—among other eligibility criteria to participate in the higher-level review or 

supplemental claims options with VBA, which are two of the five options that will be available under 

the new appeals process to all veterans.

When we provided VA with our preliminary assessment, VA officials said 

they disagreed and that their appeals plan addresses all 22 of the 

required elements. In general, they said that data are not available, and 

VA cannot yet forecast the information required by the Act until aspects of 

the new appeals process are tested or implemented. However, in 

discussing our assessment at a January 2018 House Committee on 

Veterans’ Affairs hearing, the Deputy Secretary of Veterans Affairs stated 
Page 11 GAO-18-352 VA Disability Benefits

that the agency agreed with our assessment and will work with us to 

address these gaps in VA’s appeals plan.17

Until VA’s appeals plan has complete information on all 22 of the required 

elements, Congress does not have the information it needs to fully 

conduct oversight of the plan and the agency’s efforts to implement and 

administer the new process while addressing legacy appeals. VA also 

needs information on resources, among other areas, to certify that the 

agency is prepared to carry out timely processing of appeals under the 

new and legacy appeals process.18 Further, as discussed below, 

addressing required elements through a more comprehensive plan and 

underlying analysis is consistent with sound planning practices and would 

better position VA to implement the new appeals process while attending 

to legacy appeals. For example, such an appeals plan would provide for 

carefully monitoring the new and legacy appeals processes against 

balanced goals and metrics, and clearly articulates resources, milestones 

and other information needed for effective program management.

VA’s appeals plan reflects certain sound planning practices, such as

convening a working group on performance tracking; however, the plan 

could benefit from including important details related to three key planning 

areas:

1. articulating a balanced set of goals and related measures to monitor 

and assess the performance of the new appeals process, in 

conjunction with the legacy process; 

2. developing a high-quality and reliable implementation schedule to 

manage key steps and activities of the project; and

3. assessing key risks in a comprehensive manner, including respective 

mitigation strategies, articulating clear criteria and an assessment 

plan for RAMP, and more fully testing or analyzing all appeals options. 

 

17Appeals Reform: Will VA’s Implementation Effectively Serve Veterans?, hearing before 

the Veterans’ Affairs Committee, House of Representatives, 115th Congress, January 30, 

2018.

18VA’s plan states that the agency intends to begin full implementation in February 2019.

VA’s Appeals Plan 

Reflects Certain 

Sound Planning 

Practices, but Could 

Improve on Others
Page 12 GAO-18-352 VA Disability Benefits

VA’s appeals plan reflects steps taken to track performance, but it could 

improve its planning practices related to monitoring and assessing 

performance on a range of key dimensions of success. Sound planning 

practices suggest that agencies develop overall goals tied to meaningful 

and balanced performance measures. These measures include a mix of 

outcome, output, and efficiency measures to ensure that an 

organization’s priorities—as well as government-wide priorities such as 

quality, timeliness, and cost of service—are addressed.19

VA’s appeals plan reports that the agency convened a working group to 

design a process for tracking timeliness of both the legacy appeals and 

appeals within the new process. In supporting documentation that we 

requested, VA officials stated they are also determining the best way to 

measure veterans’ satisfaction with the new appeals process. VA’s 

appeals plan and supporting documentation also identify timeliness goals 

for the two VBA-only options and one of the three Board options. 

Nevertheless, its appeals plan does not articulate a set of goals and 

measures that cover all aspects of its new appeals process, such as 

accuracy of decisions and cost. The plan also does not provide details on 

the metrics the agency will develop, how it will assess if the new appeals 

process is an improvement over the legacy appeals process, and how it 

will monitor the allocation of resources between legacy and new appeals 

claims. More specifically:

• VA’s reported timeliness measures are incomplete: VA’s appeals 

plan outlines timeliness goals for the two VBA options (average 

processing time of 125 days) and for the Board option that does not 

include new evidence or a hearing (average processing time of 365 

days).20 However, VA’s plan does not establish timeliness goals for 

the other two Board options: Board review of additional evidence 

without a hearing and Board review of additional evidence with a 

 

19See GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 

Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). In addition, the 

Act requires VA’s plan to contain goals and related measures that can be used to manage 

and assess implementation of VA’s new appeals process, and key goals and milestones 

for reducing the number of pending appeals under the legacy process.

20In supporting documentation, VA indicated that it will measure average veteran wait 

times in the new appeals system as one indicator of success. For example, an average 

processing time of 365 days will be the timeliness goal for the option in which the Board 

reviews the existing record without a hearing. VA indicated it would develop measures and 

determine appropriate resource allocation for the other options in the future.

VA’s Appeals Plan 

Indicates Steps to Assess 

Process Changes, but 

Should Also Include Goals 

and Measures to Provide 

Full Picture of Success
Page 13 GAO-18-352 VA Disability Benefits

hearing. In commenting on our findings, while VA officials indicated 

they expect the new process to be more efficient than the legacy 

process (and, therefore, more timely), they also said data to inform 

goal setting for all Board options will not be available until VA fully 

implements these options. Establishing timeliness goals for all options 

would provide a more complete picture of VA’s vision for the new 

appeals process, and help VA to develop concrete, objective, and 

observable performance measures to show progress in achieving that 

vision, as well as inform resource estimates.

• VA’s reported measures lack adequate balance: Other than 

including certain timeliness goals, VA’s appeals plan does not 

articulate additional aspects of performance important for managing 

appeals, such as accuracy of decisions, veteran satisfaction with the 

process, or cost. We previously reported that VA officials said they 

wanted to also use veteran survey results, wait times, and inventories 

as sources of information to measure progress under the new appeals 

process.21 Further, VA’s fiscal year 2018 annual performance plan 

includes an overall customer satisfaction score for veterans’ 

benefits.22 However, these and other potential measures of success 

are not specified in VA’s appeals plan for monitoring the new appeals 

process as compared with legacy appeals. By not articulating a set of 

comprehensive and balanced goals and measures in its appeals plan, 

VA could be inadvertently creating skewed incentives by focusing on 

one area of program performance to the detriment of other areas 

(e.g., processing claims quickly but inaccurately).

In commenting on our findings, VA officials recognized the need to 

develop additional goals and measures. They indicated, for example, 

that they are developing and testing whether the existing quality 

assurance goal—92 percent accuracy—is appropriate for the new 

process. According to VA officials, once they have developed these 

other goals and measures, VA will communicate this information as 

part of the required progress reports to the appropriate committees of 

Congress and GAO. Moreover, at a January 2018 House Committee 

on Veterans’ Affairs hearing, the Deputy Secretary of Veterans Affairs 

acknowledged that their performance goals and measures are not yet 

complete and indicated that the agency will address these gaps in 

measuring performance.

 

21GAO-17-234. 

22Specifically, VA’s Voice of the Veteran Customer Satisfaction Survey tracks veterans’ 

and their beneficiaries’ overall satisfaction on a 1,000-point scale. 
Page 14 GAO-18-352 VA Disability Benefits

• VA’s plan does not reflect how it will establish baseline data:

VA’s approach for evaluating the efficiency and effectiveness of the 

implementation of the new appeals process falls short of sound 

practices for using baseline data to assess performance. Our prior 

work has demonstrated that by developing and tracking a 

performance baseline for all measures, including those that 

demonstrate the effectiveness of a program, agencies can better 

evaluate progress made and whether or not goals are being 

achieved.23 However, VA’s appeals plan did not provide important

details about what aspects of the new appeals process’ performance 

will be compared to what aspects of the legacy process’ performance.

In particular, section 5 of the Act lists a number of metrics VA is 

required to report periodically, including some that could be used as 

baseline measures.24 For example, VA is required to periodically 

publish on its website the average time that elapsed between the filing 

of an initial claim and the final resolution of the claim, for legacy 

appeals as well as appeals under the new system, which is consistent 

with our prior recommendation.25 However, VA’s appeals plan does 

not explain how or when the agency would collect and use these or 

other data about the legacy and new processes’ performance—such 

as accuracy, veteran satisfaction, and cost—to assess their relative 

performance.

As we had previously reported, VA’s business case for reform in some 

instances relied on unproven assumptions and limited analyses of its 

legacy process to identify root causes of performance problems.26

Specifically, VA determined that the open-ended nature of its legacy 

appeals process, whereby a veteran can submit additional evidence 

 

23Baseline and trend data can also be used to inform and refine performance goals, 

according to our prior work. See GAO, Agency Performance Plans: Examples of Practices 

That Can Improve Usefulness to Decisionmakers, GAO/GGD/AIMD-99-69 (Washington, 

D.C.: Feb. 26, 1999). 

24Pub. L. No. 115-55, § 5, 131 Stat. 1105, 1123.

25We previously recommended that VA develop a strategy for assessing process reform—

relative to the current process—that ensures transparency on the extent to which VA is 

improving veterans’ experiences with its disability appeals process. This includes 

measuring the average time to reach final resolution of veterans’ appeals and reflects the 

fact that veterans may file multiple appeals under the new appeals process before 

achieving resolution of their claims. GAO-17-234. 

26See GAO-17-234. 
Page 15 GAO-18-352 VA Disability Benefits

numerous times at any point, can cause additional cycles of readjudication, a process VA refers to as “churning.” 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. Without fully 

articulating a plan for collecting and using baseline and trend data, VA 

cannot determine the extent to which the new appeals process, which 

also allows for multiple appeal opportunities, will achieve final 

resolution of veterans’ appeals sooner, on average, than the legacy 

process.

In commenting on our assessment, VA indicated that it is working 

toward capturing the metrics listed in section 5 of the Act. VA officials 

also noted that reporting on the new appeals process will require IT 

system functionality that currently does not exist, but stated that 

efforts are underway to add this functionality.

• VA’s plan does not explain how the agency will monitor 

processing of legacy versus new appeals: In addition, VA’s 

appeals plan does not fully articulate how the agency will monitor 

whether resources are being appropriately devoted to both the new 

and legacy appeals process and how it will track both sets of 

workloads.27 An appeals plan that does not specifically articulate how 

VA will manage the two processes in parallel exposes the agency to 

risk that veterans with appeals in the legacy process may experience 

significant delays or otherwise poor results relative to those in the new 

appeals process or vice versa. In commenting on our findings, VA 

officials noted that VA was not required under section 3 of the Act to 

provide a description of its plans to capture metrics listed in section 5. 

Even if not required by the Act, developing an approach for carefully 

monitoring the management of new and legacy appeals would help 

VA track progress being made and achievement of goals.

Until VA establishes complete and balanced goals and measures, 

identifies baseline data, and develops a plan for monitoring and 

assessing both the new and legacy processes, VA runs the risk of 

promoting skewed behaviors, or not fully understanding whether the new 

process is an improvement or whether veterans with appeals in the 

legacy process are experiencing poor results.

 

27As noted earlier, we also determined that VA’s appeals plan does not contain sufficient 

details about metrics and goals to identify potential issues related to implementing the new 

appeals system, and therefore only partially addresses the required element at section 

3(a)(4) of the Act.
Page 16 GAO-18-352 VA Disability Benefits

VA’s appeals plan reflects certain aspects of sound planning practices 

related to managing the implementation of process change; however, 

other key components are not addressed. Sound planning practices for 

implementing process change suggest establishing a transition team.28

Consistent with such practices, VA’s appeals plan states that the agency 

convened an agency-wide governance structure to coordinate 

implementation of its new appeals process; it is comprised of senior-level 

employees with authority to make necessary decisions to keep the project 

on track. VA’s appeals plan also includes a copy of a master schedule. In 

its plan, VA asserts that the master schedule reflects timelines, interim 

goals and milestones, reporting requirements, and established deadlines, 

and that it will be used to guide implementation. VA’s appeals plan also 

reports that VA is consulting with project management professionals, who 

are using the master schedule, among other tools, to monitor 

implementation. In addition, VA made progress addressing some of the 

issues we previously identified by developing steps and timetables for 

updating training in anticipation of implementing the new appeals 

process.29

However, VA’s master schedule for implementing reform is missing 

elements of a high-quality and reliable implementation schedule for key 

activities. We have previously reported that having a well-planned 

schedule is a fundamental management tool. Generally recognized sound 

practices from the Project Management Institute (PMI) and GAO call for 

organizations to employ an integrated and reliable master schedule that 

defines when work activities will occur, who will complete the work, how 

long they will take, how they are related to one another, and the 

constraints affecting the start and completion of work elements, as well as 

whether resources will be available when they are needed.30 Such a 

project management schedule not only provides a road map for 

systematic project execution, but also provides the means by which to 

 

28GAO, 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.” 

29See GAO-17-234. 

30Project Management Institute, Inc., A Guide to the Project Management Body of 

Knowledge (PMBOK Guide); GAO, GAO Schedule Assessment Guide: Best Practices for 

Project Schedules, GAO-16-89G (Washington, D.C.: December 2015); and, GAO Cost 

Estimating and Assessment Guide: Best Practices for Developing and Managing Capital 

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

VA’s Appeals Plan Needs 

a Reliable Implementation 

Schedule to Manage the 

Project
Page 17 GAO-18-352 VA Disability Benefits

gauge progress, identify and address potential problems, and promote 

accountability.

The master schedule VA provided in its appeals plan should have 

included other sound practices for project management related to a 

reliable schedule. Specifically:

• Key activities and their duration are not included: VA’s master 

schedule does not capture specific Board-related activities, such as 

efforts to develop metrics, and the schedule and other project plans 

we reviewed do not go beyond February 2019. For example, the 

schedule does not indicate the period of time when VA expects to no 

longer be processing legacy appeals.31 Also, VA’s master schedule 

submitted with its November 2017 appeals plan did not include the 

Rapid Appeals Modernization Program (RAMP) activities, even 

though this pilot test is occurring at the same time VA is preparing for 

full implementation of appeals options at VBA and the Board. 

However, VA’s updated schedule that accompanied its comments on 

our draft report was updated to include RAMP. 

When all key and necessary activities are not included, it raises 

questions about whether all activities are scheduled in the correct 

order, resources are properly allocated, or the estimated completion 

dates are reliable.32 In addition, if the schedule does not fully and 

accurately reflect VA’s efforts, it will not serve as an appropriate basis 

for analysis and may result in unreliable completion dates and delays.

• Sequencing and linkages among activities are not identified: For 

the high-level activities VA’s appeals plan identifies, VA’s master 

schedule does not indicate whether there were sequencing or 

linkages among them, which is not consistent with sound scheduling 

 

31Sound practices suggest that the schedule should reflect the duration of each activity 

and have specific start and end dates. 

32In addition, if some necessary activities are missing from an agency’s implementation 

schedule, it is much more difficult for the agency to adhere to other best practices. Our 

prior work has identified 10 practices associated with developing and maintaining a 

reliable schedule. These practices are (1) capturing all activities, (2) sequencing all 

activities, (3) assigning resources to all activities, (4) establishing the duration of all 

activities, (5) integrating schedule activities horizontally and vertically, (6) establishing the 

critical path for activities, (7) identifying float between activities, (8) conducting a schedule 

risk analysis, and (9) updating the schedule using actual progress and logic, and (10) 

maintaining a baseline schedule. Float is the amount of time an activity can slip before 

affecting the critical path. The critical path is the longest path through the schedule. If an 

activity on the critical path slips, the entire project will be delayed. See GAO-16-89G. 
Page 18 GAO-18-352 VA Disability Benefits

practices. Sequencing and linkages would show, for example, if any of 

these activities or sub-activities must finish prior to the start of other 

activities, or the amount of time an activity could be delayed before 

the delay affects VA’s estimated implementation date.33 For example, 

VA cannot train new employees until after it hires them.

The activities VA identifies also do not appear supported by lowerlevel project schedules. Specifically, when we requested 

documentation to support VA’s high-level summary of activities and 

milestones, VA officials did not provide intermediate or more detailed 

schedules that reflected these practices. In particular, VA’s appeals 

plan lacks a complete schedule for IT modifications that clearly 

defines what is to be achieved and the time frames for achievement.34

We previously recommended that VA develop a schedule for IT 

updates that explicitly addresses when and how process reform will 

be integrated into new systems and when these systems will be ready 

to support the new appeals process at its onset.35 For example, VA’s 

appeals plan references several required IT modifications that do not 

appear in its master schedule.36 Schedules that are defined at too 

high a level may disguise risk that is inherent in lower-level 

activities.37

• Interim goals are not reflected: VA officials stated that they have 

interim goals and milestones, though VA’s appeals plan and 

supporting documentation generally do not include this information. 

 

33GAO-16-89G. 

34Federal internal control standards state that program managers should define objectives 

clearly to enable the identification of risks that may impede the achievement of program 

objectives. This includes clearly defining what is to be achieved and the time frames for 

achievement. See GAO, Standards for Internal Control in the Federal Government, 

GAO-14-704G (Washington, D.C.: September 2014). Additionally, IT investment best 

practices stress the need for oversight regarding a project’s progress toward predefined 

schedule expectations. See GAO-04-394G. 

35GAO-17-234. 

36VA’s master schedule lists three IT requirements; however, VA’s appeals plan 

references several other requirements not included in the master schedule: eFolder; 

Caseflow Work Queue, Caseflow Hearings Scheduling, and Reporting Functionality. In 

supplemental materials, VA provided an IT “road map” that lists nine IT requirements; 

however, several of these requirements (e.g., Caseflow Dispatch) do not appear in either 

VA’s appeals plan or master schedule. In addition the “road map” reflects 6 months of 

planning and does not extend to or beyond the end dates reflected in VA’s master 

schedule.

37GAO-16-89G. 
Page 19 GAO-18-352 VA Disability Benefits

Sound planning and redesign practices suggest closely monitoring 

implementation and developing project goals that include a mix of 

intermediate goals to be met at various stages. We previously made a 

recommendation that VA develop a more robust plan for closely 

monitoring implementation of process reform, including metrics and 

interim goals to help track progress, evaluate efficiency and 

effectiveness, and identify trouble spots—all of which are consistent 

with sound planning practices.38 Without interim goals and milestones, 

VA lacks information to support sequencing of activities and to track 

and ensure accountability for steady progress.

• Resources are not assigned to all identified activities: The highlevel summary schedule that VA provided us also lacks details 

regarding the assignment of resources for all activities. Specifically, 

while the plan identifies workgroups responsible for coordinating 

elements in the plan, such as regulations, training, and outreach, the 

schedule does not assign resources to the 40 listed activities. As 

discussed previously, VA’s appeals plan also does not provide 

information on the total resources required for this reform effort. 

Assigning resources to the listed activities, as well as providing other 

information, could provide a better indication of the estimated total 

resources required to implement the new appeals process and 

address legacy appeals.

In commenting on our findings, VA officials stated that the agency is 

developing lower-level project schedules for key activities—such as 

RAMP and IT requirements—and will provide these schedules as part of 

the required progress reports to the appropriate committees of Congress 

and GAO. VA officials also noted that future updates will include 

additional dependencies and risks, which VBA and the Board are still 

developing. Further, in discussing our findings at a January 2018 House 

Committee on Veterans’ Affairs hearing, the Deputy Secretary of 

Veterans Affairs reiterated VA’s commitment to developing more robust 

project plans, particularly for IT. Until VA has a robust integrated master 

schedule, supported by detailed project plans that adhere to sound 

practices, VA’s appeals plan does not provide reasonable assurance that 

decision makers have the essential program management information 

needed for this complex and important effort.

 

38GAO-17-234. 
Page 20 GAO-18-352 VA Disability Benefits

VA’s appeals plan includes an assessment of risks involved in 

implementing the new appeals system, but could more comprehensively 

reflect key risks posed by such a significant reform effort.39 VA’s appeals 

plan and supplemental materials include a “risk register” that describes 

risks associated with many elements of its plan, and the remaining level 

of risk after its planned response to these risks. VA’s appeals plan also 

states that senior leaders will receive regular updates of risks and 

mitigation strategies. However, because VA has not yet articulated a 

balanced set of performance goals and measures in its appeals plan, it is 

hindered in its ability to identify and assess risks.

Federal internal control standards state, and our previous work at VA and 

other agencies demonstrates, that establishing clear performance goals 

and objectives is a necessary pre-condition to effectively assessing risk.40

Having, for example, more complete timeliness goals, and goals and 

measures reflecting other areas of performance, would allow VA to better 

identify and target risks associated with managing two processes in 

parallel, including the potential that veterans with appeals in the legacy 

process may experience significant delays relative to those in the new 

appeals process.

Importantly, VA is missing an opportunity to fully benefit from RAMP by 

not testing and assessing other aspects of the new appeals process. The 

Act authorizes VA to test the feasibility and advisability of any facet of the 

new appeals process, and VA is taking a positive step to mitigate some 

risks by testing the two review options available within VBA (review of a

claim by a higher-level official based on the same evidence and review of 

a supplemental claim with additional evidence) through RAMP. In 

November 2017, VA began RAMP by inviting 500 veterans whose 

appeals have been pending the longest to participate. According to VA 

officials, VA plans to continue offering RAMP to additional eligible 

 

39A risk assessment is the identification and analysis of risks related to achieving the 

defined objectives. This assessment provides the basis for developing appropriate risk 

responses. See GAO-14-704G. 

40GAO-14-704G. See the following reports for examples of agencies that did not have 

measureable performance goals to assess and mitigate risks: GAO, Veterans Justice 

Outreach Program: VA Could Improve Management by Establishing Performance 

Measures and Fully Assessing Risks, GAO-16-393 (Washington, D.C.: April 28, 2016); 

and GAO, Telecommunications Relay Service: FCC Should Strengthen Its Management 

of Program to Assist Persons with Hearing or Speech Disabilities, GAO-15-409 

(Washington, D.C.: April 29, 2015). 

VA’s Plan Addresses 

Some but Not All Key 

Risks Related to the New 

Appeals Process
Page 21 GAO-18-352 VA Disability Benefits

veterans with pending legacy appeals each month until January 2019—a 

month before VA anticipates fully implementing the new appeals system. 

However, as designed, RAMP does not include features—consistent with 

a well-developed and documented pilot test program—that would provide 

VA with an opportunity to evaluate fully the soundness of new processes 

and practices on a smaller scale.41 Specifically:

• VA’s plan does not clearly define success criteria for RAMP: VA’s 

appeals plan states that the agency will collect certain data from 

RAMP, such as the rate at which eligible veterans opt into the 

process, timeliness of claims processing, and individual employee 

productivity. VA also established an overall average processing time 

goal of 125 days for the two VBA options; however, the plan and 

supporting documentation did not clearly articulate whether RAMP 

reviews are expected to meet this timeliness goal. The plan also did 

not identify other success criteria for RAMP or the types of results 

expected before fully implementing the new appeals process. For 

example, VA’s plan does not articulate the expected number and type 

of subsequent appeals to the Board that result from RAMP.

In commenting on our findings, VA noted that its intent in 

implementing RAMP was to collect data and test aspects of the new 

process, and that RAMP was not an initiative in and of itself. However, 

developing performance measures and data gathering procedures 

and defining success criteria for a pilot test before proceeding to full 

implementation are sound practices for process redesign and pilot 

testing. In addition, because RAMP was not included in VA’s risk 

assessment, we asked VA if it had identified any risks or mitigation 

strategies specific to RAMP. In its supplemental materials, VA stated 

that the greatest risk to RAMP is a low participation rate among 

eligible veterans with legacy claims. VA also indicated that it would 

need 10 percent of eligible veterans to opt into RAMP to yield 

meaningful results. However, this threshold is not articulated in VA’s 

appeals plan as an explicit success criterion or objective. According to 

data provided by VA, as of January 22, 2018, 238 veterans opted in.42

 

41GAO/AIMD-10.1.15, and GAO, Data Act: Section 5 Pilot Design Issues Need to Be 

Addressed to Meet Goal of Reducing Recipient Reporting Burden, GAO-16-438 

(Washington, D.C.: April 19, 2016).

42According to VA, as of January 22, 2018, RAMP invitations were sent to 15,500 

veterans via three separate mailings—500 in November 2017, 5,000 in December 2017, 

and 10,000 in January 2018. As of January 22, 2018, VA reported that the opt-in rate was 

about 3 percent for the November and December mailings, and 1 percent for January.
Page 22 GAO-18-352 VA Disability Benefits

Of veterans with pending claims in RAMP, two-thirds chose the 

higher-level review option. VA also reported that 47 RAMP decisions 

have been made so far. As of yet, no appeals of RAMP decisions 

have been filed.

• VA’s plan does not articulate how it will assess RAMP before 

proceeding with full implementation: Although VA’s appeals plan 

describes a “close-out” phase in which VA intends to assess the 

results of RAMP, it does not detail the conditions that would have to 

be met (or not met) to trigger changes. For example, VA’s plan does 

not explain when or how it might respond to low opt-in rates for 

RAMP—other than stating it will increase outreach to eligible 

veterans—or to unexpectedly high appeal rates to the Board resulting 

from RAMP decisions. Sound redesign and change management 

practices both suggest that pilot tests be rigorously monitored and 

evaluated, and that further roll-out occur only after an agency’s 

transition team takes any needed corrective action and determines 

that the new process is achieving previously identified success 

criteria. Without fully articulating its plan for deciding how and when to 

roll out changes more broadly, it is not clear whether VA would be 

prepared to fully implement a new appeals process that achieves its 

aim of better serving veterans.

• RAMP does not test all aspects of the new appeals process:

RAMP provides an opportunity to learn about experiences at VBA 

under the new system, such as the rate at which eligible veterans 

choose those options and the resources that will be required to 

process their appeals. However, RAMP was not designed to test how 

many veterans would choose to appeal directly to the Board and, 

therefore, it will not provide comparable information on the Board 

appeals options. Sound workforce planning practices suggest that 

agencies identify the total resources needed to manage the risk of 

implementing new processes and conduct scenario planning to 

determine those needs.43

In addition, although we previously recommended VA conduct additional 

sensitivity analyses to inform projections of future appeals inventories,44

 

43GAO-09-3SP. 

44GAO-17-234. Sensitivity analysis—used in scenario planning to, for example, determine 

the resources needed for implementing a new process—is an analysis to determine how 

sensitive outcomes are to changes in assumptions, such as those used to determine 

resource needs. 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 23 GAO-18-352 VA Disability Benefits

VA’s appeals plan does not reflect VA’s use or intended use of sensitivity 

analyses when projecting staffing needs for new appeals options at the 

Board.45 In commenting on our findings, VA officials said they do not plan 

to conduct additional sensitivity analyses to project future workloads until 

they have more information from RAMP to inform their assumptions. As a 

result, VA will lack data on scenarios in which veterans may 

overwhelmingly choose options available at the Board over those at VBA 

when the appeals plan is fully implemented. This presents a risk that VA’s 

early production projections and initial resource allocations may not be 

properly balanced between the Board and VBA. This, in turn, may result 

in an unexpectedly large number of appeals pending with the Board, and 

corresponding lengthy average wait and decision times for some, if not 

all, Board options.

Having information on the number of veterans who are likely to appeal to 

the Board is particularly critical, given that similar efforts to create 

additional review options at VBA did not achieve their goals of reducing 

the percentage of appeals that continue on to the Board. In 2001, VA 

established the Decision Review Officer (DRO) process—in which senior 

staff have the authority to overturn an initial disability claim decision 

without any new evidence—to resolve more appeals at the regional level 

and avoid long waits at the Board. However, we reported in 2011 that, 

although the DRO process helped some veterans get additional benefits 

at the regional office level, it did not accomplish the program’s primary 

goal of reducing the percentage of appeals continuing on to the Board.46

In responding to our findings, VA officials reiterated their plans to increase

outreach in the event of low opt-in rates for RAMP and indicated they 

recently began to send follow-up RAMP invitation letters. With respect to 

assessing all appeals options, VA officials stated that, while no legal bar 

prevents testing of the Board options, the Board is focused on reducing 

its inventory of pending appeals while RAMP provides early resolution of 

appeals within the new VBA-only options. Officials conceded that this 

approach means they cannot collect data on the rate at which veterans 

opt to appeal directly to the Board (e.g., bypassing additional VBA review) 

 

45As noted previously, we determined that VA’s plan does not estimate personnel required 

by either VBA or the Board for the period when they are not processing legacy appeals. 

Sensitivity analyses could aid VA in forecasting such resources. 

46GAO, Veterans Disability Benefits: Clearer Information for Veterans and Additional 

Performance Measures Could Improve Appeal Process, GAO-11-812 (Washington, D.C.: 

Sept. 29, 2011).
Page 24 GAO-18-352 VA Disability Benefits

until the new process is fully implemented. However, they noted that they 

can collect some data on the rate at which veterans whose appeals go 

through RAMP file subsequent appeals to the Board, even though the 

Board will not begin processing those appeals until full implementation. At 

a January 2018 House Committee on Veterans’ Affairs hearing, the 

Deputy Secretary of Veterans Affairs stated that given our assessment, 

VA will adjust its approach to identify and mitigate risks associated with 

implementing all of the appeals options, including those at the Board.

Until VA pursues an approach that identifies and mitigates significant 

risks associated with implementing a new process, VA is taking a chance 

that untested aspects will not perform as desired. The Act provides VA 

authority to pilot aspects of the process and flexibility on the timing of 

implementing the new process, which could allow some additional time 

for VA to carefully measure performance under RAMP and determine 

whether any corrective actions are necessary. If VA does not take full 

advantage of this authority, it risks moving forward without knowing 

whether the new appeals process improves experiences for veterans, and 

potentially implementing a process that is more expensive or results in 

longer wait times than originally anticipated.

In implementing appeals reform after the enactment of the Veterans 

Appeals Improvement and Modernization Act of 2017, VA is undertaking 

a complex endeavor that has the potential to affect the lives of hundreds 

of thousands of veterans with service-connected disabilities. Such an 

endeavor demands a commensurate level of planning to be successful. 

While the Act required VA to submit its plan within 90 days of enactment, 

VA had proposed and began to plan for appeals reform much earlier, and 

had our March 2017 recommendations to guide its planning efforts from a 

foundation of sound practices.

VA’s November 2017 appeals plan is a positive step forward. Certain 

elements of the plan—such as establishing an agency-wide governance 

structure to oversee implementation and testing aspects of reform prior to 

full implementation—are notable gains since our March 2017 report. At 

the same time, the plan partially addresses or does not address five of 

the required elements called for by the Act, such as delineating the total 

resources required by VBA and the Board to implement and administer 

the new appeals process and address legacy appeals. The plan also is 

not fully responsive to our past recommendations and does not reflect a 

number of sound planning practices that are essential for gauging 

progress, establishing accountability, and linking resources to results.

Conclusions
Page 25 GAO-18-352 VA Disability Benefits

One such key practice is articulating a desired “end state”—a vision for 

what successful implementation would look like for the new appeals 

process as well as the wind-down of the legacy process, such as 

accurate and timely processing of appeals while ensuring veteran 

satisfaction. Without establishing a complete and balanced set of goals 

and related performance measures to achieve this end state, and 

monitoring and assessing progress along the way, VA risks falling short of 

its overarching objective—to improve timeliness of appeals decisions for 

veterans overall. By not fully articulating how it plans to monitor workloads 

and devote resources to both the new and legacy processes, VA runs the 

risk of disadvantaging veterans with legacy appeals relative to those in 

the new process, or vice versa.

Just as important is establishing a robust integrated master schedule—

rather than a high-level timeline—that is built upon and clearly reflects 

extensive detailed planning and includes all activities necessary to 

execute the program and interdependencies between these activities. 

Without such a road map, VA’s appeals plan does not provide reasonable 

assurance that decision makers have the essential information needed to 

manage this complex and important program.

We are encouraged that VA has taken some steps toward assessing 

risks, including establishing a risk register and implementing RAMP to 

collect information on the two VBA appeals options. However, unless VA 

assesses risks against a balanced set of goals and measures, VA may 

not be fully aware of risks that may impede successful implementation of 

appeals reform. Further, although VA will undoubtedly learn from the 

RAMP experience, it may not learn all that it should from its efforts 

without (1) establishing clear criteria for what success looks like (or the 

circumstances that would cause VA to consider making course 

corrections), and (2) building in time to take stock of the lessons learned 

before moving to full implementation.

VA’s plan places a lot of weight on RAMP to, among other efforts, 

mitigate risk and generate estimates of the resources needed for 

successful implementation after fiscal year 2018, even though RAMP 

does not fully test options for appealing to the Board that will be available 

to veterans after full implementation. Unless VA addresses key risks 

associated with fully implementing appeals reform—by either testing or 

conducting sensitivity analyses for all five appeals options, to better 

understand potential workloads at the Board—VA runs the risk of fully 

implementing the process without knowing if it is improving the process 

for veterans.
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We are making the following four recommendations to VA:

The Secretary of Veterans Affairs should address all of the required 

elements in the Act in VA’s appeals plan to Congress—including 

delineating resources required for all VBA and Board appeals options—

using sensitivity analyses and RAMP results, where appropriate and 

needed. (Recommendation 1)

The Secretary of Veterans Affairs should clearly articulate in VA’s appeals 

plan how VA will monitor and assess the new appeals process compared 

to the legacy process, including specifying a balanced set of goals and 

measures—such as timeliness goals for all VBA appeals options and 

Board dockets, and measures of accuracy, veteran satisfaction, and 

cost—and related baseline data. (Recommendation 2)

The Secretary of Veterans Affairs should augment the master schedule 

for VA’s appeals plan to reflect all activities—such as modifications to IT 

systems—as well as assigned responsibilities, interdependencies, start 

and end dates for key activities for each workgroup, and resources, to 

establish accountability and reduce overall risk of implementation failures. 

(Recommendation 3)

The Secretary of Veterans Affairs should ensure that the appeals plan 

more fully addresses risk associated with appeals reform—for example, 

by assessing risks against a balanced set of goals and measures, 

articulating success criteria and an assessment plan for RAMP, and 

testing or conducting sensitivity analyses of all appeals options—prior to 

fully implementing the new appeals process. (Recommendation 4)

We provided a draft of this report to the Department of Veterans Affairs 

(VA) for comment. In its comments, reproduced in appendix II, VA 

outlined its planned actions to address the recommendations. VA clarified 

in a subsequent communication that the agency agreed with all our 

recommendations. VA did not provide technical comments.

With respect to our first recommendation that VA address all the required 

elements in the Act in VA’s appeals plan (including delineating total 

resources), VA stated that both VBA and the Board will use existing

resources to implement the new appeals process. VA also stated it plans 

to take additional steps to determine resource requirements for 

addressing workloads under both the legacy and new appeals process. 

For VBA, VA stated that it will continue to rely on RAMP to project 

resource requirements, while acknowledging the need to augment its 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 27 GAO-18-352 VA Disability Benefits

analysis of RAMP data by adopting additional strategies to project 

resource requirements. VA did not describe these strategies, but stated 

that it will share them with Congress and GAO in the near future. 

Meanwhile, VA noted that its 2019 budget request includes 605 additional 

FTEs for VBA to process appeals, but did not indicate how it developed 

this budget request. For the Board, VA stated that it plans to develop 

better predictions regarding resource allocations among dockets by 

leveraging project management and other support within the agency. We 

will continue to monitor VA’s efforts to delineate needed resources, 

including how it uses the results of pilot tests and prediction analysis. 

With respect to our second recommendation to articulate how it will 

monitor and assess the new appeals process compared to the legacy 

process, VA stated that it is working to develop a complete and balanced 

set of measures for the new appeals process, and timeliness goals for all 

appeals options. Further, VA indicated it will track performance for Board 

appeal options using an existing process. We are encouraged by VA’s 

proposed actions, which will provide a more complete picture of VA’s 

vision for the new appeals process. However, VA does not detail whether 

or how the agency will develop a baseline or compare performance of the 

new appeals process to the legacy process. Until VA develops a baseline 

and a plan for monitoring and assessing both the new and legacy 

processes—using a complete and balanced set of goals and measures—

VA risks not fully understanding whether the new process is an 

improvement.

With respect to our third recommendation to augment its master 

implementation schedule to manage the project, VA provided an updated 

schedule with additional key activities and responsibilities, such as 

RAMP. Moreover, VA restated its plans to use an agency-wide 

governance structure to coordinate and track implementation of its new 

appeals process. We are encouraged by VA’s efforts to develop a more 

detailed implementation schedule. However, the updated schedule VA 

provided does not include major activities, such as integrated IT system 

testing, and completion dates for major activities, for example, adding 

functionality to VA’s primary claims processing system. In addition, VA 

provided an updated calendar for six major IT activities through the end of 

calendar year 2018. However, we continue to believe that VA will need to 

develop a longer term schedule that projects when processes will be 

integrated into new systems and when new systems will be ready to 

support the new appeals process. The schedule also does not indicate 

whether activities are interrelated, such that a delay in one activity could 

affect other activities and thereby affect VA’s estimated implementation 
Page 28 GAO-18-352 VA Disability Benefits

date. This sound planning practice is especially important because VA 

stated the agency is concurrently executing many of the activities.

With respect of our fourth recommendation to more fully assess risks 

associated with appeals reform prior to its full implementation, VA stated 

that it will assess risks against a balanced set of goals it plans to select. 

Moreover, using its existing risk management process, VA stated it has 

identified additional risks and mitigation strategies after submitting its 

November 2017 plan. For example, VA states that it is addressing the 

continued low opt-in rate for RAMP, which is testing the new VBA-only 

options. VA is also acknowledging that delays in the development of IT 

required to implement the appeals process may prevent the agency from 

certifying readiness in January 2019. Importantly, VA states that the 

Board is exploring the development of a pilot program to identify needs 

and concerns related to full implementation—including all Board appeals 

options—and to make predictions about timeliness and productivity under 

the new appeals process. However, VA did not define success criteria for 

its current pilot test, RAMP, or clearly articulate how the agency will 

assess results of either RAMP or a new test of Board appeals options 

before proceeding to full implementation. Implementing our 

recommendation in a complete and timely manner is important because it 

would improve VA’s ability to identify and mitigate significant risks 

associated with implementing a new process. 

We will continue to monitor the status of VA’s actions to address our 

recommendations and how they are implemented, to help ensure that VA 

is undertaking a level of planning appropriate to implementing a complex 

endeavor, and thereby improving VA’s chance of success. 
Page 29 GAO-18-352 VA Disability Benefits

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Veterans Affairs, and other interested 

parties. In addition, the report is available at no charge on GAO’s website 

at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

Elizabeth Curda at (202) 512-7215 or curdae@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 contributed to this 

report are listed in appendix III.

Elizabeth H. Curda

Director

Education, Workforce, and Income Security
Page 30 GAO-18-352 VA Disability Benefits

List of Committees

The Honorable Johnny Isakson

Chairman

The Honorable John Tester

Ranking Member

Committee on Veterans’ Affairs

United States Senate

The Honorable Phil Roe

Chairman

The Honorable Tim Walz 

Ranking Member

Committee on Veterans’ Affairs

House of Representatives

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 Charlie Dent 

Chairman 

The Honorable Debbie Wasserman Schultz 

Ranking Member 

Subcommittee on Military Construction, Veterans Affairs, 

and Related Agencies 

Committee on Appropriations 

House of Representatives
Appendix I: Our Assessment of VA’s Appeals 

Plan Against Required Elements in the Act

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To assess the extent to which VA’s appeals plan addresses the required 

elements in the Veterans Appeals Improvement and Modernization Act of 

2017 (Act), we first identified and developed a checklist reflecting each 

required element for VA’s appeals plan (including sub-parts) under 

section 3(a) and (b) of the Act. To compare the required elements and 

their sub-parts against VA’s appeals plan and supplemental materials 

provided by VA, we developed decision rules for determining whether 

VA’s appeals plan addressed, partially addressed, or did not address 

each required element (see table 2). Specifically, we concluded that VA’s 

plan addressed (or partially addressed) a required element if the plan 

included information related to all (or some) subparts of the requirement. 

We focused on the plan as presented, rather than auditing the information 

VA relied on in developing the plan. For example, the Act’s section 

3(b)(10) required VA’s plan to include a description of the modifications to 

the information technology (IT) systems required to carry out the new 

appeals system, including cost estimates and a timeline. We concluded 

that VA’s plan addressed all sub-parts of this element because it provided 

a description of required IT modifications, a reference to costs included in 

the Appeals Modernization IT budget, and a timeline. However, our 

determination that VA addressed this element should not be construed to 

necessarily mean that VA fully identified or described all IT requirements, 

or provided complete estimated costs and timelines associated with those 

requirements, or that the information in VA’s appeals plan comported with 

sound planning practices. This type of assessment was outside the scope 

of this objective.

Appendix I: Our Assessment of VA’s Appeals 

Plan Against Required Elements in the Act
Appendix I: Our Assessment of VA’s Appeals 

Plan Against Required Elements in the Act

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Table 2: Summary of GAO’s Assessment of VA’s Appeals Plan Against the Required Elements in the Veterans 

Appeals Improvement and Modernization Act of 2017 (Act)

Required elements of plan

(from sec. 3(a) and (b) of the Act)

Summary of 

GAO’s assessment

Section 3(a)(1)

[A comprehensive plan for] the processing of appeals of decisions on legacy claims that the 

Secretary considers pending.

Addressed

Section 3(a)(2)

[A comprehensive plan for] implementing the new appeals system.

Addressed

Section 3(a)(3)

[A comprehensive plan for] timely processing, under the new appeals system, of— 

(A) supplemental claims under section 5108 of title 38, United States Code, as amended by section 2(i);

(B) requests for higher-level review under section 5104B of such title, as added by section 2(g); and

(C) appeals on any docket maintained under section 7107 of such title, as amended by section 2(t).

Addressed

Section 3(a)(4)

[A comprehensive plan for] monitoring the implementation of the new appeals system, including metrics and 

goals— 

(A) to track the progress of implementation;

(B) to evaluate the efficiency and effectiveness of the implementation; and

(C) to identify potential issues relating to the implementation.

Partially addressed

Section 3(b)(1)

Delineation of the total resource requirements of the Veterans Benefits Administration and the Board of 

Veterans’ Appeals, disaggregated by resources required to implement and administer the new appeals 

system and resources required to address the appeals of decisions on legacy claims.

Not addressed

Section 3(b)(2)

Delineation of the personnel requirements of the Administration and the Board, including staffing levels 

during the— 

(A) period in which the Administration and the Board are concurrently processing— 

(i) appeals of decisions on legacy claims; and

(ii) appeals of decisions on non-legacy claims under the new appeals system; and

(B) the period during which the Administration and the Board are no longer processing any appeals of 

decisions on legacy claims.

Partially addressed

Section 3(b)(3)

Identification of the legal authorities under which the Administration or the Board may— 

(A) hire additional employees to conduct the concurrent processing described in paragraph (2)(A); and

(B) remove employees who are no longer required by the Administration or the Board once the 

Administration and the Board are no longer processing any appeals of decisions on legacy claims.

Addressed

Section 3(b)(4)

An estimate of the amount of time the Administration and the Board will require to hire additional employees 

as described in paragraph (3)(A) once funding has been made available for such purpose, including a 

comparison of such estimate and the historical average time required by the Administration and the Board to 

hire additional employees.

Addressed
Appendix I: Our Assessment of VA’s Appeals 

Plan Against Required Elements in the Act

Page 33 GAO-18-352 VA Disability Benefits

Required elements of plan

(from sec. 3(a) and (b) of the Act)

Summary of 

GAO’s assessment

Section 3(b)(5)

A description of the amount of training and experience that will be required of individuals conducting higherlevel reviews under section 5104B of title 38, United States Code, as added by section 2(g).

Addressed

Section 3(b)(6)

An estimate of the percentage of higher-level adjudicators who will be employees of the Department of 

Veterans Affairs who were Decision Review Officers on the day before the new appeals system takes effect 

or had experience, as of such date, comparable to that of one who was a Decision Review Officer.

Addressed

Section 3(b)(7)

A description of the functions that will be performed after the date on which the new appeals system takes 

effect by Decision Review Officers who were Decision Review Officers on the day before the date the new 

appeals system takes effect.

Addressed

Section 3(b)(8)

Identification of and a timeline for— 

(A) any training that may be required as a result of hiring new employees to carry out the new appeals 

system or to process appeals of decisions on legacy claims; and

(B) any retraining of existing employees that may be required to carry out such system or to process such 

claims.

Addressed

Section 3(b)(9)

Identification of the costs to the Department of Veterans Affairs of the training identified under paragraph (8) 

and any additional training staff and any additional training facilities that will be required to provide such 

training.

Addressed

Section 3(b)(10)

A description of the modifications to the information technology systems of the Administration and the Board 

that the Administration and the Board require to carry out the new appeals system, including cost estimates 

and a timeline for making the modifications.

Addressed

Section 3(b)(11)

An estimate of the office space the Administration and the Board will require during each of the periods 

described in paragraph (2), including— 

(A) an estimate of the amount of time the Administration and the Board will require to acquire any additional 

office space to carry out processing of appeals of decisions on legacy claims and processing of appeals 

under the new appeals system;

(B) a comparison of the estimate under subparagraph (A) and the historical average time required by the 

Administration and the Board to acquire new office space; and

(C) a plan for using telework to accommodate staff exceeding available office space, including how the 

Administration and the Board will provide training and oversight with respect to such teleworking.

Addressed

Section 3(b)(12)

Projections for the productivity of individual employees at the Administration and the Board in carrying out 

tasks relating to the processing of appeals of decisions on legacy claims and appeals under the new appeals 

system, taking into account the experience level of new employees and the enhanced notice requirements 

under section 5104(b) of title 38, United States Code, as amended by section 2(e).

Partially addressed
Appendix I: Our Assessment of VA’s Appeals 

Plan Against Required Elements in the Act

Page 34 GAO-18-352 VA Disability Benefits

Required elements of plan

(from sec. 3(a) and (b) of the Act)

Summary of 

GAO’s assessment

Section 3(b)(13)

An outline of the outreach the Secretary expects to conduct to inform veterans, families of veterans, 

survivors of veterans, veterans service organizations, military service organizations, congressional 

caseworkers, advocates for veterans, and such other stakeholders as the Secretary considers appropriate 

about the new appeals system, including— 

(A) a description of the resources required to conduct such outreach; and

(B) timelines for conducting such outreach.

Addressed

Section 3(b)(14)

Timelines for updating any policy guidance, Internet websites, and official forms that may be necessary to 

carry out the new appeals system, including— 

(A) identification of which offices and entities will be involved in efforts relating to such updating; and

(B) historical information about how long similar update efforts have taken.

Addressed

Section 3(b)(15)

A timeline, including interim milestones, for promulgating such regulations as may be necessary to carry out 

the new appeals system and a comparison with historical averages for time required to promulgate 

regulations of similar complexity and scope.

Addressed

Section 3(b)(16)

An outline of the circumstances under which claimants with pending appeals of decisions on legacy claims 

would be authorized to have their appeals reviewed under the new appeals system.

Addressed

Section 3(b)(17)

A delineation of the key goals and milestones for reducing the number of pending appeals that are not 

processed under the new appeals system, including the expected number of appeals, remands, and hearing 

requests at the Administration and the Board each year, beginning with the one year period beginning on the 

date of the enactment of this Act, until there are no longer any appeals pending before the Administration or 

the Board for a decision on a legacy claim.

Partially addressed

Section 3(b)(18)

A description of each risk factor associated with each element of the plan and a contingency plan to 

minimize each such risk.

Addressed

Source: GAO analysis of VA’s November 2017 appeals plan and any supporting documents VA provided on or before January 18, 2018, the Veterans Appeals Improvement and Modernization Act of 

2017, and agency input by VA. | GAO-18-352
Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs
Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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of Veterans Affairs

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of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix II: Comments from the Department 

of Veterans Affairs

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Appendix III: GAO Contact and Staff 

Acknowledgments

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Elizabeth H. Curda, (202) 512-7215 or curdae@gao.gov. 

In addition to the contact above, the following staff members made 

significant contributions to this report: Michele Grgich (Assistant Director), 

James Whitcomb (Analyst in Charge), and Rachael Chamberlin.

In addition, key support was provided by Susan Aschoff, Mark Bird, David 

Chrisinger, Daniel Concepcion, Clifton Douglas, Alex Galuten, Nisha 

Hazra, Melissa Jaynes, Benjamin Licht, Patricia McClure, Sheila McCoy, 

Lorin Obler, Gloria Proa, Almeta Spencer, James Sweetman, Walter 

Vance, and Greg Whitney.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102381)
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