GAO 

United States Government Accountability Office

Report to the Committee on Veterans’ 

Affairs, U.S. Senate 

VETERANS’ 

DISABILITY 

BENEFITS 

Further Evaluation of 

Ongoing Initiatives 

Could Help Identify 

Effective Approaches 

for Improving Claims 

Processing 

January 2010 

GAO-10-213 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

January 2010

VETERANS’ DISABILITY BENEFITS 

Further Evaluation of Ongoing Initiatives Could Help 

Identify Effective Approaches for Improving Claims

Highlights of GAO-10-213, a report to the Processing

Committee on Veterans' Affairs, U.S. 

Senate 

For years, the disability 

compensation claims process has 

been the subject of concern and 

attention by the Department of 

Veterans Affairs (VA), Congress, 

and veteran service organizations 

(VSO), due in part to long waits for 

decisions and the large number of 

claims pending a decision. As GAO 

and other organizations have 

reported over the last decade, VA 

has also faced challenges in 

improving the accuracy and 

consistency of disability decisions. 

GAO was asked to examine 

(1) trends in VA’s disability 

compensation claims processing at 

the initial claims and appeals levels 

and (2) actions that VA has taken 

to improve its disability claims 

process. To do this, GAO reviewed 

and analyzed VA performance data, 

budget submissions, program 

documents, and external studies 

and interviewed VA officials and 

VSO representatives. 

What GAO Recommends

GAO recommends that the 

Secretary of Veterans Affairs direct 

(1) VBA to collect data on 

redistributed claims to help assess 

the effect of workload 

redistribution, (2) VBA and the 

Board of Veterans’ Appeals to 

establish a plan with criteria for 

assessing whether ECA should be 

widely implemented, and (3) VBA 

to develop a plan with criteria for 

assessing whether its pilot 

reorganization of claims processors 

should be expanded. VA agreed 

with the recommendations, and 

noted plans to address them. 

VA’s disability claims and appeals processing has improved in some aspects 

and worsened in others. In recent years, the number of claims completed 

annually by VA has increased but not by enough to keep pace with the 

increasing number of compensation claims received, resulting in more claims 

awaiting a decision. In addition, the average days that VA took to complete a 

claim—196 days in fiscal year 2008—has varied over time, but was about the 

same in fiscal years 2000 and 2008. Several factors have challenged claims 

processing improvements, such as the increase in the number and complexity 

of claims submitted to VA, laws, and regulatory changes. VA has reduced the 

number of pending appeals and improved the accuracy of some appellate 

work, but the time that it takes to resolve appeals has worsened in recent 

years. For example, in fiscal year 2008, VA took on average 776 days to 

process appeals; 78 days longer than in fiscal year 2004. One factor that has 

contributed to worsening appeals timeliness is the increase in the number of 

appeals received by VA. 

 

Pending Claims and Appeals, End of Fiscal Years 2000-2008 

Claims and appeals (in thousands)

Sources: VA data (claims) and GAO analysis of VA data (appeals).

Fiscal year

Pending claims

Pending appeals

0

50

100

150

200

250

300

350

400

2000 2001 2002 2003 2004 2005 2006 2007 2008

188

370

309

227

288

309

335

351 343

127

109 113 124 131 132 124 112 95

VA has taken several steps to improve claims and appeals processing, but 

their impact is not yet known. VA has hired a significant number of disability 

claims staff to process disability workloads. VA’s Veterans Benefits 

Administration (VBA) has also expanded its practice of workload 

redistribution, which could improve the timeliness and quality of its decisions. 

VA is also testing new claims processing approaches—such as shortening 

response periods for certain claims and appeals through Expedited Claims 

Adjudication (ECA) and reorganizing its claims processing units. However, 

VBA has not established plans to evaluate the effect of some initiatives. In 

addition, VA has taken other steps to improve claims and appeals processing, 

such as expanding its quality assurance program; upgrading claims processing 

software; and moving toward paperless processing, which remains elusive in 

part due to technical challenges. 

View GAO-10-213 or key components.

For more information, contact Daniel Bertoni 

at (202) 512-7215 or bertonid@gao.gov. 
Page i GAO-10-213 

Contents 

Letter 1

Background 2 

VA’s Disability Claims and Appeals Processing Has Improved in 

Some Aspects and Worsened in Others 6 

VA Has Taken Some Actions That Have the Potential to Improve 

Claims Processing, but Their Impact Is Not Yet Known 17 

Conclusions 25 

Recommendations for Executive Action 26 

Agency Comments and Our Evaluation 27 

Appendix I Objectives, Scope, and Methodology 29 

Appendix II Comments from the Department of Veterans 

Affairs 33 

Appendix III GAO Contact and Staff Acknowledgments 36 

Related GAO Products 37 

Table 

Table 1: VBA’s Compensation and Pension Service’s Disability 

Claims Processing Teams 5 

Figures 

Figure 1: Overview of VA’s Disability Claims and Appeals 

Processes 4 

Figure 2: Compensation Claims Received and Completed, Fiscal 

Years 2000-2008 7 

Figure 3: Pending Compensation Claims, End of Fiscal Years 2000-

2008 8 

Figure 4: Average Days That Compensation Claims Were Pending, 

End of Fiscal Years 2000-2008 9 

 Veterans' Disability Benefits 
Figure 5: Average Days to Complete Compensation Claims, Fiscal 

Years 2000-2008 10 

Figure 6: Accuracy Rate of VBA Compensation Claims Decisions, 

Fiscal Years 2003-2008 11 

Figure 7: Number of Pending Compensation Appeals, End of Fiscal 

Years 2000-2008 14 

Figure 8: Accuracy Rate of the Board’s Compensation Appeals 

Decisions, Fiscal Years 2000-2008 15 

Figure 9: Average Processing Time for Compensation Appeals, 

Fiscal Years 2000-2008 16 

Figure 10: Number of Compensation Appeals Received, Fiscal 

Years 2000-2008 17 

Abbreviations 

ARRA American Recovery and Reinvestment Act of 2009 

DOD Department of Defense 

ECA Expedited Claims Adjudication 

STAR Systematic Technical Accuracy Review 

VA Department of Veterans Affairs 

VBA Veterans Benefits Administration 

VACOLS Veterans Appeals Control and Locator System 

VETSNET Veterans Services Network 

VSO veteran service organization 

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Page ii GAO-10-213 Veterans' Disability Benefits
Page 1 GAO-10-213 

United States Government Accountability Office

Washington, DC 20548 

 

January 29, 2010 

The Honorable Daniel K. Akaka 

Chairman 

The Honorable Richard Burr 

Ranking Member 

Committee on Veterans’ Affairs 

United States Senate 

The Department of Veterans Affairs’ (VA) disability compensation program 

provides monetary support to veterans with disabling conditions that were 

incurred or aggravated during military service. In fiscal year 2008, VA paid 

$30.7 billion in benefits to nearly 3 million veterans through the 

compensation program. For years, the disability compensation claims 

process has been the subject of concern and attention by VA, Congress, 

and veteran service organizations (VSO), due in large part to long waits for 

decisions and the large number of claims pending a decision. The number 

of veterans awaiting decisions about their eligibility for disability 

compensation could grow as servicemembers returning from ongoing 

conflicts and aging veterans submit claims. As GAO and other 

organizations have reported over the last decade, VA has faced challenges 

not only in decreasing the time it takes to decide veterans’ claims, but also 

with improving the accuracy and consistency of disability decisions. 

At your request, we examined (1) trends in VA’s disability compensation 

claims processing at the initial claims and appeals levels and (2) actions 

that VA has taken to improve its disability claims process. To identify 

trends in disability compensation claims processing, we examined 

workload and performance data from VA’s Veterans Benefits 

Administration (VBA) and Board of Veterans’ Appeals (Board). To identify 

VA’s actions for improving the claims process, we analyzed staffing data; 

reviewed VA’s budget submissions, VA’s strategic plan, and other 

documents such as external studies and VA’s Office of Inspector General 

reports; interviewed VA officials and VSO representatives; and examined 

ongoing initiatives and those initiatives that VA completed after fiscal year 

2005. In addition, we visited four VBA regional offices and the Board to 

learn about ongoing initiatives. In selecting the regional offices—Chicago, 

Illinois; Seattle, Washington; Togus, Maine; and Winston-Salem, North 

Carolina—we considered regional offices that would provide (1) insights 

about ongoing initiatives, such as pilots; (2) a mix of offices located in 

different geographic settings (e.g., urban and rural); and (3) a mix of 

offices that were above and below VBA’s averages for select claims 

 Veterans' Disability Benefits 
 

processing measures. We also reviewed relevant federal laws, regulations, 

and court decisions. Appendix I contains additional information about our 

scope and methodology. 

We conducted this performance audit from November 2008 through 

January 2010 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

VA pays monthly disability compensation to veterans with serviceconnected disabilities (i.e., injuries or diseases incurred or aggravated 

while on active military duty) according to the severity of the disability.1

VA also pays additional compensation for some dependents––spouses, 

children, and parents––of veterans.2

 In addition, VA’s pension program 

pays benefits to low-income veterans who either are elderly or have 

disabilities unrelated to their military service.3

 In fiscal year 2008, the 

disability compensation program represented 78 percent, or $30.7 billion, 

of the cash benefits paid through VBA’s Compensation and Pension 

Service. 

Background 

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

a claim to VBA (see fig. 1). Upon reviewing the claim at 1 of VBA’s 

57 regional offices, a service representative then assists the veteran in 

gathering the relevant evidence to evaluate the claim.4

 Such evidence 

includes veterans’ military service records, medical examinations, and 

treatment records from VA medical facilities and private medical service 

 

1

VA’s ratings are in 10 percent increments, from 0 to 100 percent. Generally, VA does not 

pay disability compensation for disabilities rated at 0 percent. As of November 2009, basic 

monthly payments ranged from $123 for 10 percent disability to $2,673 for 100 percent 

disability. 

2

Additional compensation is available to qualifying dependents of veterans whose disability 

is rated 30 percent or higher as provided by 38 U.S.C. § 1115. 

3

VA also pays pensions to surviving spouses and unmarried children of deceased wartime 

veterans. In addition, VA pays dependency and indemnity compensation to some deceased 

veterans’ spouses, children, and parents. 

4

These representatives are known as “veteran service representatives,” or “VSRs.” 

Page 2 GAO-10-213 Veterans' Disability Benefits
 

providers. Also, if necessary for reaching a decision on a claim, the 

regional office arranges for the veteran to receive a medical examination. 

Once a claim has all of the necessary evidence, a rating specialist 

evaluates the claim and determines whether the claimant is eligible for 

benefits.5

 If so, the rating specialist assigns a percentage rating. Veterans 

with multiple disabilities receive a single composite rating. Veterans can 

reopen claims for additional benefits from VA if, for example, a serviceconnected disability worsens or arises in the future. If the veteran 

disagrees with the regional office’s decision, he or she may submit a 

written notice of disagreement to the regional office. In response to such a 

notice, VBA reviews the case and provides the veteran with further written 

explanation of the decision if VBA does not grant all appealed issues. If the 

veteran still disagrees, he or she may appeal to the Board. Before 

transferring the appeal to the Board, VBA re-reviews the case and if any 

new information is obtained provides a new explanation of the decision to 

the veteran. The Board, whose members are attorneys experienced in 

veterans’ law and in reviewing benefit claims, conducts a hearing if the 

veteran requests one, then grants or denies the appeal or returns the case 

to VBA to obtain additional evidence necessary to decide the veteran’s 

claim. If the veteran is dissatisfied with the Board’s decision, he or she 

may appeal to the U.S. Court of Appeals for Veterans Claims. 

 

5

These specialists are known as “rating veteran service representatives,” or “RVSRs.” 

Page 3 GAO-10-213 Veterans' Disability Benefits
 

Figure 1: Overview of VA’s Disability Claims and Appeals Processes 

Source: GAO analysis of VA procedures.

Obtains

and helps

gather

evidencea

Obtains and helps

gather any needed 

evidence;a

 re-reviews

case and writes new 

explanation of 

decision if additional 

evidence is obtained;b

and certifies that 

appeal is ready for 

the Board

Veterans

Benefits

Administration

(VBA)

Board

of Veterans’

Appeals (Board)

Conducts

a hearing

if claimant 

requests

Grants

or denies

appeal

Or remands 

case to VBA

Veteran

Reviews

claim

Rates

claim

If dissatisfied,

appeals to

the Board

If dissatisfied,

appeals to

the U.S. Court

of Appeals for

Veterans Claims

CLAIMS PROCESS APPEALS PROCESS

If dissatisfied,

submits a

notice of

disagreement

Reviews

claim and 

provides

a written 

explanation

of decisionb

Submits

claim

Processes

decision and 

provides a

written 

explanation

a

VA must make reasonable efforts to help a claimant obtain evidence that is necessary to 

substantiate a claim. 

b

The explanation must include a summary of the evidence relating to the contested issue(s), a 

summary of the applicable laws and regulations, VBA’s determination of each issue, and the rationale 

for such determinations. The process ends if VBA grants all appealed issues or if the veteran is 

satisfied with the explanation. 

To improve workload controls and the timeliness and accuracy of its 

decisions, in fiscal year 2002, VBA organized its claims processing staff by 

teams that perform distinct phases of the claims and appeals processes 

(see table 1). In moving toward this organizational structure, VBA sought 

to reduce the number of tasks a veteran service representative was 

expected to perform and thereby improve its performance. 

Page 4 GAO-10-213 Veterans' Disability Benefits
 

Table 1: VBA’s Compensation and Pension Service’s Disability Claims Processing Teams 

Team Summary of claims processing duties 

Triage Team Reviews claims and establishes the regional office’s tracking procedures for all mail, as well as 

processes claims that only require a brief review to determine eligibility. 

Pre-Determination Team Obtains and helps gather evidence for disability ratings, and prepares administrative decisions. 

Rating Team Makes decisions on claims that require consideration of medical evidence. 

Post-Determination Team Develops evidence for nonrating issues, processes benefit awards, and notifies veterans of rating 

decisions. 

Public Contact Team Conducts personal interviews and handles telephone inquiries, including calls from veterans. 

Appeals Team Handles requests for reconsideration of claims in cases where veterans have submitted a notice of 

disagreement. 

Source: VBA. 

Note: The Rating Team is made up of rating specialists; the Post-Determination and Public Contact 

teams are made up of veteran service representatives; and the Pre-Determination, Triage, and 

Appeals teams are made up of both rating specialists and veteran service representatives. 

VA measures its performance related to compensation claims and appeals 

processing in various ways and considers the timeliness and quality of its 

decisions as key indicators. One way that VBA and the Board assess the 

timeliness of their work is using a joint measure that considers the average 

time it takes appeals to be resolved, regardless of whether they are 

resolved by VBA or the Board. In fiscal year 2009, VA’s timeliness goal for 

resolving appeals was 675 days.6

 In terms of quality, VBA and the Board 

each assess the accuracy of their decisions by reviewing randomly 

selected cases to determine the proportion that contain errors that could 

affect the benefits paid to the veteran. In fiscal year 2009, VBA and the 

Board had an accuracy rate goal of 98 percent and 94 percent, 

respectively.7

 

6

This strategic goal includes compensation- and pension-related appeals. 

7

These strategic goals are based on compensation- and pension-related decisions. 

Page 5 GAO-10-213 Veterans' Disability Benefits
 

Over the past several years, the number of disability compensation claims 

has increased, and VA’s performance in processing such claims has 

improved in some areas and worsened in others. During this time, VA has 

reduced the number of pending appeals and improved the accuracy of 

some appellate work, but in recent years, the time that it takes to resolve 

appeals has increased. 

VA’s Disability Claims 

and Appeals 

Processing Has 

Improved in Some 

Aspects and 

Worsened in Others 

VA Has Increased Its 

Output of Claims 

Decisions but Continues to 

Experience Some 

Challenges with Timeliness 

and Accuracy 

From fiscal years 2000 to 2008, the number of claims completed annually 

by VA has increased but not by enough to keep pace with the increasing 

number of compensation claims it has received, and, as a result, the 

number of pending claims has grown. VA has substantially increased the 

number of claims it completes annually in recent years. In fiscal year 2008, 

VA completed about 729,000 claims, which was nearly 66 percent more 

than it completed in fiscal year 2000 (see fig. 2).8

 However, VA has also 

received significantly more claims in recent years. In fiscal year 2008, VA 

received about 719,000 compensation claims, which was about 71 percent 

more than it received in fiscal year 2000. By the end of fiscal year 2008, 

pending claims—those awaiting a decision—had increased 83 percent 

over fiscal year 2000 levels, from about 188,000 to about 343,000 

(see fig. 3). Moreover, the number of claims awaiting a decision longer 

than 6 months increased about 50 percent, from about 52,000 to about 

78,000. 

 

8

These data exclude appellate work. The reported compensation claims data are comprised 

of the following three VBA categories: initial compensation claims with eight or more 

disabling conditions; initial compensation claims with seven or fewer disabling conditions; 

and reopened compensation claims, whereby a veteran submits a claim for additional 

benefits anytime after submitting the initial claim (e.g., if a new service-connected 

disability arises or a previously claimed disability worsens). 

Page 6 GAO-10-213 Veterans' Disability Benefits
 

Figure 2: Compensation Claims Received and Completed, Fiscal Years 2000-2008 

Claims (in thousands)

Source: VA data.

Fiscal year

Claims received

Claims completed

0

100

200

300

400

500

600

700

800

2000 2001 2002 2003 2004 2005 2006 2007 2008

421 440

531

348

579

641

601

683

632

571

649 629 654 628

678 662

719 729

Page 7 GAO-10-213 Veterans' Disability Benefits
 

Figure 3: Pending Compensation Claims, End of Fiscal Years 2000-2008 

Pending claims (in thousands)

Source: VA data.

Fiscal year

Total pending

Pending over 6 months

0

50

100

150

200

250

300

350

400

2000 2001 2002 2003 2004 2005 2006 2007 2008

188

52

370

159

309

114

227

44

288

309

335

351 343

64 68

78

96

78

VA has also experienced mixed results in improving the timeliness of its 

claims decisions. Overall, the average days that claims were pending 

declined, but the average processing time needed to complete a claim did 

not improve.9

 From fiscal years 2000 to 2008, the average number of days 

that claims were pending fluctuated. In fiscal year 2008, compensation 

claims were pending an average of 23 days less than the 146 days in fiscal 

year 2000 (see fig. 4).10 While fiscal year 2008’s average number of days 

pending was slightly longer than the average 115 days experienced in fiscal 

year 2003, it is a marked improvement over the 188 days that claims were 

 

9

The average days pending is the average time that pending claims have been awaiting a 

decision at a point in time. VA calculates the average days pending for a fiscal year on the 

last day of the year. The average days to complete a claim is the average processing time of 

decisions reached during a specific period. 

10VA’s fiscal year 2008 average days pending goal for compensation claims was 120 days. 

VA does not have a comparable goal for average days to complete compensation claims. 

However, VA’s fiscal year 2008 goal for average days to complete rating-related claims, 

including both compensation and pension claims, was 169 days. 

Page 8 GAO-10-213 Veterans' Disability Benefits
 

pending in fiscal year 2001. VA has also reduced the percentage of claims 

that took more than 1 year to complete, from 22 percent in fiscal year 2002 

to 10 percent in fiscal year 2008. However, VA has made little progress in 

reducing average processing times. The average time that VA took to 

complete a claim fluctuated between fiscal years 2000 and 2008, from a 

high of 246 days in fiscal year 2002 to a low of 181 days in fiscal years 2004 

and 2005 (see fig. 5). Since then, this average has increased, and in fiscal 

year 2008, VA took about the same amount of time—196 days—to 

complete a claim as it did in fiscal year 2000. 

Figure 4: Average Days That Compensation Claims Were Pending, End of Fiscal 

Years 2000-2008 

Average days

Source: VA data.

Fiscal year

0

20

40

60

80

100

120

140

160

180

200

2000 2001 2002 2003 2004 2005 2006 2007 2008

146

188

181

115

122 124

132 137

123

Page 9 GAO-10-213 Veterans' Disability Benefits
 

Figure 5: Average Days to Complete Compensation Claims, Fiscal Years 2000-2008 

Average days

Source: VA data.

Fiscal year

0

60

120

180

240

300

2000 2001 2002 2003 2004 2005 2006 2007 2008

195 202

246

197

181 181

193 200 196

In terms of quality, according to VA’s assessments, the accuracy of 

compensation claims processing remained about the same during fiscal 

years 2003 through 2008.11 The percentage of compensation claims 

processed without errors that could affect benefits paid to veterans 

remained at 85 percent, varying slightly in the intervening years 

(see fig. 6). 

 

11VA changed how it calculates claims processing accuracy in fiscal year 2002. Therefore, to 

analyze and report consistent data, we considered accuracy data for compensation claims 

starting in fiscal year 2003. 

Page 10 GAO-10-213 Veterans' Disability Benefits
 

Figure 6: Accuracy Rate of VBA Compensation Claims Decisions, Fiscal Years 

2003-2008 

Percentage

Source: VA data.

Fiscal year

0

10

20

30

40

50

60

70

80

90

100

2003 2004 2005 2006 2007 2008

85 85 83

88 87 85

One factor that has contributed to VA’s lack of significant improvement in 

claims processing performance is the substantial increase in VA’s 

disability workloads. VA attributes the increase in compensation claims to 

several sources, including the conflicts in Iraq and Afghanistan. According 

to VA, about 35 percent of veterans from ongoing hostilities file claims. In 

addition, VA cites the growing number of reopened claims from current 

disability benefit recipients—many of whom suffer from chronic 

progressive disabilities, such as diabetes—who submit claims for 

increased benefits as their conditions worsen or new conditions arise as 

they age. In fiscal year 2008, VA received about 488,000 reopened claims 

for disability benefits, up 58 percent from about 309,000 in fiscal year 2000. 

In addition, VA attributes increased claims receipt to its enhanced 

outreach to servicemembers and veterans. VA reported that in fiscal year 

2007, it provided benefits briefings to about 297,000 separating 

servicemembers, which was up from about 210,000 in fiscal year 2003. 

According to VA officials, federal laws, VA regulations, and court decisions 

have also adversely affected claims processing timeliness. These changes 

enable veterans to get the benefits they deserve. However, the changes 

expand benefit entitlement and add processing requirements that increase 

VA’s workloads. In recent years, court decisions related to a 1991 law have 

Page 11 GAO-10-213 Veterans' Disability Benefits
 

created new presumptions of service-connected disabilities for many 

Vietnam veterans.12 In October 2009, VA announced that it was expanding 

the list of presumptive service-connected disabilities to include 

Parkinson’s disease and two other conditions for Vietnam veterans.13 VA 

also anticipates an increase in claims stemming from an October 2008 

regulation change that affects how VA rates traumatic brain injuries.14

According to a VA official, a letter was sent to approximately 32,000 

veterans notifying them that their rating for traumatic brain injury could 

potentially increase, even though their symptoms may not have changed. 

In addition to expanded benefit entitlement, a number of laws15 and court 

decisions16 related to VA’s disability claims process have had implications 

for timely claims processing. For example, according to VA officials, the 

Veterans Claims Assistance Act of 2000 added more steps to the claims 

process, lengthening the time that it takes to develop and decide a claim.17

Another factor impacting VA’s claims processing timeliness is the 

complexity of claims received. VA notes that it is receiving more claims for 

complex disabilities related to combat and deployments overseas, 

including those based on environmental and infectious disease risks and 

traumatic brain injuries. In addition, veterans cited more disabilities in 

their claims in recent years than they had in the past. The number of 

compensation claims VA decided with eight or more disabilities increased 

from 11 to 16 percent from fiscal years 2006 to 2008. These claims can take 

longer to complete because each disability must be evaluated separately. 

 

12See, for example, Haas v. Nicholson, 20 Vet. App. 257 (2006). The Agent Orange Act of 

1991, Pub. L. No. 102-4, broadens the presumption of exposure to herbicides in Vietnam. 

See also, 38 C.F.R. § 3.309 (diseases subject to a presumptive service connection). 

13The other conditions are B cell leukemias and ischemic heart disease. 

1438 C.F.R. § 4.124a (73 Fed. Reg. 54693, Sept. 23, 2008). 

15Veterans Benefits Improvement Act of 2008, Pub. L. No. 110-389; Veterans Benefits 

Improvement Act of 2004, Pub. L. No.108-454; Veterans Benefits Act of 2003, Pub. L. No. 

108-183; and Veterans Claims Assistance Act of 2000, Pub. L. No. 106-475. 

16See, for example, Haas v. Nicholson, 20 Vet. App. 257 (2006); Moody v. Principi, 360 F.3d 

1306 (Fed. Cir. 2004); Szemraj v. Principi, 357 F.3d 1370 (Fed. Cir. 2004); and Disabled 

American Veterans v. Secretary of Veterans Affairs, 327 F.3d 1339 (Fed. Cir. 2003). 

17Pub. L. No. 104-475. 

Page 12 GAO-10-213 Veterans' Disability Benefits
 

Since fiscal year 2000, the number of pending appeals has declined, and 

the accuracy of appeals processing has improved in some areas. VA has 

reduced the number of pending appeals by 25 percent, from about 127,000 

in fiscal year 2000 to about 95,000 in fiscal year 2008 (see fig. 7).18 Over the 

same period, agency accuracy reviews indicate that 95 percent of the 

Board’s decisions in fiscal year 2008 were processed accurately compared 

with 86 percent in fiscal year 2000 (see fig. 8). Another indicator of the 

accuracy of appeals processing is the percentage of appeals that are 

remanded to VBA by the Board due to errors that could have been 

avoided.19 Examples of avoidable remands include VBA’s failure to obtain 

identified private treatment records or to send letters to claimants 

indicating what evidence is necessary to substantiate the claim. One of 

VA’s goals is to eliminate avoidable remands.20 Although VBA recently 

expanded accuracy reviews and the Board has provided training to VBA 

staff based on remand reason trends, the percentage of appeals with 

avoidable remands remained about 25 percent from fiscal years 2006 to 

2008.21

VA Has Reduced the 

Number of Pending 

Appeals and Improved the 

Accuracy of Some 

Appellate Work, but 

Appeals Processing 

Timeliness Has Worsened 

in Recent Years 

 

18We analyzed rating-related compensation appeals to the Board from VA’s appeals 

database. 

19VBA includes appellate work in its accuracy assessments. However, because appellate 

work comprises a relatively small portion of the decisions assessed, we cannot reliably 

identify accuracy rates for appellate work from these assessments. 

20VA categorizes remands as “avoidable” when the reason for the remand occurred before 

VBA certified transferring the appeal to the Board. 

21We analyzed avoidable remand data from fiscal years 2006 to 2008 because complete, 

reliable data were previously not available in VA’s appeals database. See appendix I for 

information about avoidable remand calculations. 

Page 13 GAO-10-213 Veterans' Disability Benefits
 

Figure 7: Number of Pending Compensation Appeals, End of Fiscal Years 2000-

2008 

Pending appeals (in thousands)

Source: GAO analysis of VA data.

Fiscal year

0

20

40

60

80

100

120

140

160

2000 2001 2002 2003 2004 2005 2006 2007 2008

127

109 113

124

131 132

124

112

95

Page 14 GAO-10-213 Veterans' Disability Benefits
 

Figure 8: Accuracy Rate of the Board’s Compensation Appeals Decisions, Fiscal 

Years 2000-2008 

Percentage

Source: GAO analysis of VA data.

Fiscal year

0

10

20

30

40

50

60

70

80

90

100

2000 2001 2002 2003 2004 2005 2006 2007 2008

86 88 86 85 84 82

90

93 95

Despite improvements in some aspects of appeals processing, the average 

time needed to resolve appeals has worsened in recent years, reversing 

prior improvements. In fiscal year 2008, the average processing time for 

compensation appeals was 776 days, or approximately 25 months, despite 

reaching lows of 656 days in fiscal year 2001 and 680 days in fiscal year 

2005 (see fig. 9). The majority of appeal processing time is spent 

developing the appeal prior to consideration by the Board. For example, 

appeals resolved in fiscal year 2008 remained at VBA for 502 days before 

being transferred to the Board.22

 

22This average is based on appeals that VBA certified as being ready for the Board. All 

appeals do not reach this stage because appellants may resolve their appeals beforehand. 

Page 15 GAO-10-213 Veterans' Disability Benefits
 

Figure 9: Average Processing Time for Compensation Appeals, Fiscal Years 2000-

2008 

Average days

Source: GAO analysis of VA data.

Fiscal year

0

100

200

300

400

500

600

700

800

900

2000 2001 2002 2003 2004 2005 2006 2007 2008

769

656

835 838

698 680

719

758 776

Several factors have contributed to the worsening trend in appeals 

timeliness. First, the number of appeals that VA has received increased 

about 50 percent from approximately 24,000 in fiscal year 2000 to about 

36,000 in fiscal year 2008 (see fig. 10). In addition, according to VA 

officials, each time appellants submit new evidence, VA must review and 

summarize the case for the appellant again, adding to the time that it takes 

to resolve the appeal. Furthermore, a veteran may submit multiple claims, 

and VBA does not forward an appeal to the Board until all of a veteran’s 

pending claims are resolved, regardless of whether they relate to the 

appeal. This practice follows VBA’s interpretation of a court decision to 

prevent delays in processing undecided claims.23 Therefore, a veteran’s 

unrelated, pending claim could forestall final resolution of the appeal. 

Finally, according to VA officials, processing time is lengthened when 

appeals are remanded back to VBA by the Board. While some appeals are 

remanded due to procedural errors by VBA, many other appeals are 

remanded because of requirements often driven by recent court decisions 

or regulatory changes that occur after the appeal is sent to the Board. For 

 

23Ebert v. Brown, 4 Vet. App. 434 (1993). 

Page 16 GAO-10-213 Veterans' Disability Benefits
 

example, a court decision in January 2008 required VA to notify veterans 

seeking increased compensation for worsened conditions of the rating 

criteria that pertain to the claim.24 Until this decision was overturned in 

September 2009, it required the Board to remand—or VBA to hold back—

any appeals until the claimants were notified.25

hold back—

Figure 10: Number of Compensation Appeals Received, Fiscal Years 2000-2008 

Appeals received (in thousands)

Source: GAO analysis of VA data.

Fiscal year

0

5

10

15

20

25

30

35

40

45

2000 2001 2002 2003 2004 2005 2006 2007 2008

24

12

17

34

41

38 38 37 36

VA has taken several steps to improve claims processing, including 

increasing claims processing staff, redistributing certain workloads, 

piloting alternative approaches to processing certain claims, and 

increasingly leveraging information technology to process claims. VA 

expects these actions to improve decision timeliness, quality, or both. 

However, the effects of these actions are not yet known, and VA lacks 

plans to assess certain actions. 

VA Has Taken Some 

Actions That Have the 

Potential to Improve 

Claims Processing, 

but Their Impact Is 

Not Yet Known 

 

24Vazquez-Flores v. Peake, 22 Vet. App. 37 (2008), vacated Vazquez-Flores v. Shinseki, 

580 F.3d 1270 (Fed. Cir. 2009). 

25See footnote 24. 

Page 17 GAO-10-213 Veterans' Disability Benefits
 

VA has taken several actions to improve decision timeliness at both the 

claim and appellate levels. For example, over the past few years, VA has 

hired a significant number of disability claims staff to process disability 

workloads. From fiscal years 2005 to 2009, VA increased VBA’s claims 

processing staff by 57 percent, from 7,550 to 11,868.26 This increase 

includes 417 staff that VBA hired in fiscal year 2009 using funds from the 

American Recovery and Reinvestment Act of 2009 (ARRA).27 Of the people 

hired using ARRA funds, about three-fourths are temporary employees 

who assist in developing disability claims and perform other 

administrative tasks to free experienced staff to complete more complex 

claims processing tasks. During the same period, VA increased the Board’s 

staff by 20 percent, from 433 to 519, without using ARRA funds. 

VA Has Increased Staffing, 

Redistributed Workloads, 

and Is Piloting New 

Approaches for Processing 

Certain Claims to Improve 

Timeliness, but Lacks 

Plans to Evaluate Some of 

These Actions 

We have reported that adding staff has the potential to improve VA’s 

capacity to complete more claims, but an infusion of a large number of 

new staff will also likely pose human capital challenges for VA in the near 

term.28 VA has processed more claims and appeals decisions annually 

since hiring the additional staff; however, as it has acknowledged, 

individual staff productivity has decreased. Specifically, the number of 

rating-related claims processed per staff person declined from 101 in fiscal

year 2005 to 88 in fiscal year 2008. According to VA, this decline in 

productivity is attributable primarily to new staff who have not yet

become fully proficient at processing claims and to the loss of experienced

staff due to retirements. VA expects individual productivity to decline 

further before it improves, in part because of the challenge of training and 

integrating new staff.

r 

 

29 According to a VA official in charge of training,

VA’s goal is for newly hired veteran service representatives to be 

proficient in 18 months, and for newly hired rating specialists to be 

proficient in 2 years. However, according to VA officials, particularly fo

26These and other data in this paragraph are based on full-time-equivalent staffing. 

27Pub. L. No. 111-5. 

28GAO, Veterans’ Disability Benefits: Claims Processing Challenges Persist, while VA 

Continues to Take Steps to Address Them, GAO-08-473T (Washington, D.C.: Feb. 14, 2008). 

29As required under section 225 of the Veterans’ Benefits Improvement Act of 2008 

(Pub. L. No. 110-389), GAO is in the process of evaluating VA’s training programs for claims 

processors. This evaluation builds on prior work in which we found that increased focus 

on evaluation and accountability would enhance training and performance management for 

claims processors. See GAO, Veterans’ Benefits: Increased Focus on Evaluation and 

Accountability Would Enhance Training and Performance Management for Claims 

Processors, GAO-08-561 (Washington, D.C.: May 27, 2008). 

Page 18 GAO-10-213 Veterans' Disability Benefits
 

rating specialists, becoming proficient often takes longer—about 3

years—because of the complexity of the job, in part given the variety of 

cases and rating issues. Training new staff also reduces productivity in

near term because experienced staff must take time to train and mentor 

them and, therefore, may have less time to process their own claim 

workloads. According to a VBA training official, VBA has developed 

curricula that use practical application of key concepts to accelerate the 

learning curve for new staff. VA expects that the staff hired with ARRA 

funding will help increase the number of claims processed and reduce 

average processing times in 2010. However, even though their 

responsibilities are expected to be limited to less complex claims 

processing tasks, these additional staff could also pose human capita

challenges in the near t

 to 5 

 the 

l 

erm while they are being trained and deployed. 

 

VBA has also expanded its practice of redistributing regional offices’ 

disability workloads. Although this expansion could improve the 

timeliness of its decisions, VBA has not collected data to evaluate the 

effect of this practice. Since 2001, VBA has created 15 resource centers 

that are staffed exclusively to process claims or appeals from backlogged 

regional offices at distinct phases in the claims process.30 From 2001 to 

2002, VBA created 9 resource centers to exclusively rate claims (rating 

centers) from other offices. Since 2007, VBA has created 4 additional 

resource centers to exclusively develop claims (development centers) for 

rating. In 2009, VBA created 2 more resource centers that focus 

exclusively on processing appealed claims (appeals centers) before they 

are sent to the Board. The development resource centers obtain 

information necessary for rating claims, while the appeals resource 

centers review appeals and provide written summaries of cases for the 

veterans. VBA determines the number of claims redistributed to each of 

the resource centers on the basis of the regional offices’ and resource 

centers’ changing workloads and capacities.31 Claims initially had to meet 

specific criteria to be eligible for redistribution, such as having seven or 

fewer disabilities. However, VBA relaxed these criteria in May 2008 to 

allow more claims to be redistributed. The number of claims redistributed 

30VA also redistributes workloads from backlogged regional offices to regional offices 

without resource centers but with more capacity to handle such workloads. VA refers to 

moving workloads—to either a resource center or another regional office—for processing 

as “brokering.” 

31VBA determines the number of claims redistributed to rating and appeal resource centers 

on a monthly basis, and it determines the number of claims redistributed to development 

resource centers on a quarterly basis. 

Page 19 GAO-10-213 Veterans' Disability Benefits
 

for rating has increased from about 88,000 in fiscal year 2006 to about 

140,000 in fiscal year 2008. 

While redistributing workloads is helpful, this practice can pose 

operational challenges. According to several VSO representatives, 

redistributing claims reduces VSOs’ and VA’s ability to monitor claims 

processing. Also, according to some resource center staff we interviewed, 

workload redistribution sometimes creates inefficiencies. For example, 

one rating resource center returned about 20 percent of the claims that it 

received during the first half of fiscal year 2009 to the originating regional 

offices because the claims required further development before they could 

be rated. The resource centers provide written explanations for returned 

claims, so that regional offices can correct the errors and avoid them in 

the future. Despite such challenges, according to VBA officials, 

redistributing backlogged claims to resource centers improves average 

processing times because VBA can better leverage the ever-changing 

capacities of its offices. Although VBA tracks the number of claims 

processed—and recently started monitoring accuracy—by resource 

center, it does not track the average processing times of redistributed 

workloads. Therefore, VA cannot (1) compare the average processing 

times of redistributed versus nonredistributed claims and (2) assess the 

resource centers relative to key performance goals or the overall effect of 

expanded workload redistribution on claims processing. 

In addition to increasing staffing and redistributing workloads, VA is 

piloting several new approaches for processing certain claims to improve 

timeliness. For example, VA is implementing a pilot with the Department 

of Defense (DOD) to perform disability evaluations. Begun in November 

2007, the joint DOD-VA pilot process applies to servicemembers navigating 

the military’s disability evaluation system, which determines whether 

servicemembers are fit for duty or should be released from the military.32

In the pilot, VA completes disability ratings for servicemembers found to 

be unfit for duty. Key features of the pilot include a single physical 

examination conducted to VA standards, disability ratings prepared by VA 

for use by both DOD and VA in determining disability benefits, and 

additional outreach and case management provided by VA staff at DOD 

pilot locations to explain VA results and processes to servicemembers. 

 

32The military’s disability evaluation system involves determining whether a servicemember 

“is unable to reasonably perform the duties of his or her office, grade, rank, or rating,” 

taking into consideration the requirements of a servicemember’s current specialty. 

Page 20 GAO-10-213 Veterans' Disability Benefits
 

The goals of the pilot are to increase transparency and reduce confusion 

about the disability evaluations conducted and, if military separation or 

retirement is necessary, to expedite VA disability compensation benefits 

upon discharge. If implemented widely, the pilot process could change the 

way in which many veterans first receive disability benefits from VA.33

According to DOD, preliminary pilot results suggest that the new process 

expedites delivery of VA benefits to servicemembers following discharge 

from the military. However, the number of claims affected by widespread 

implementation of the DOD-VA pilot process would probably be small 

compared with the total number of compensation claims processed by VA. 

In fiscal year 2008, the military’s disability evaluation system caseload was 

approximately 20,000, while VA processed about 729,000 compensation 

claims that year.34

VA is also piloting another new approach to process certain compensation 

claims and appeals, but it has not yet established a plan to determine 

whether the pilot process is worthy of widespread implementation. In 

February 2009, VA launched a 2-year pilot called Expedited Claims 

Adjudication (ECA) in 4 regional offices. This pilot, a joint effort between 

VBA and the Board, is intended to accelerate the processing time of claims 

and appeals. Claimants who opt into the ECA pilot agree to respond to VA 

within time frames that are shorter than generally required. For example, 

participating claimants agree to submit any notice of disagreement with 

VBA’s decision within 60 days as opposed to within 365 days under VA’s 

normal requirements.35 In return, the expectation is that claimants will 

receive decisions from VBA—and from the Board if the claimant appeals 

the decision—more quickly. VA is collecting data on the timeliness of ECA 

 

33In September 2008, we reported that while DOD and VA had established measures for the 

disability evaluation system pilot’s performance and a mechanism for tracking 

performances, they had not established criteria for determining whether the pilot was 

successful and should be expanded on a large scale. See GAO, Military Disability System: 

Increased Supports for Servicemembers and Better Pilot Planning Could Improve the 

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

34DOD conducts fewer disability evaluations than VA, in part, because there are fewer 

servicemembers than veterans. Currently, there are about 10 times more veterans than 

servicemembers. In addition, DOD only conducts disability evaluations for referred 

servicemembers whose medical conditions may prevent them from performing their 

military duties. VA conducts disability evaluations for veterans as claimed conditions arise 

or worsen. 

35Participating claimants may submit information after the abbreviated response periods, 

but in doing so their participation in ECA is canceled. VA would then process their claims 

or appeals using its normal procedures. 

Page 21 GAO-10-213 Veterans' Disability Benefits
 

processing compared with that of non-ECA processing, but complete data 

are not yet available. VA officials said they intend to evaluate ECA before 

expanding the expedited process within the agency. However, it is unclear 

when and how VA will conduct such an evaluation because it has not yet 

established an evaluation plan with specific criteria and methods to help 

assess ECA’s impact on non-ECA claims and appeals processing and on 

whether ECA is worthy of expansion. For example, it is unclear which 

timeliness metrics VA will use to help assess ECA, and the performance 

goals the new process must meet before being expanded. 

As required under the Veterans’ Benefits Improvement Act of 2008,36 VA is 

also piloting an expedited claims process for claimants who submit “fully 

developed claims”37 and affirm that they do not intend to submit additional 

information to support their claims.38 In return, VA’s goal is to process 

such claims within 90 days of receipt of the claim. VA is piloting this 

alternative process at 10 regional offices for at least 1 year, and the agency 

has hired a contractor to help assess the feasibility and advisability of 

continuing the pilot, and possibly deploying the process nationwide. 

Because certain types of claims—such as those from newer veterans—

may naturally lend themselves to being fully developed and therefore may 

not be representative of all claims, the contractor will not merely compare 

the average processing times for fully developed claims with those of 

other claims. Instead, the contractor is working with VA to identify a 

sound and feasible methodology for evaluating this alternative claims 

process and is scheduled to provide VA with an evaluation of the pilot at 

the end of May 2010. 

 

36Pub. L. No. 110-389. 

37Fully developed claims are claims that do not require additional development by or 

assistance from VA other than scheduling a VA examination or obtaining records held by 

the federal government. 

38As with ECA, participating claimants may subsequently submit additional information; 

however, in doing so, their participation in the pilot is canceled. VA would then process 

their claims or appeals using its normal procedures. 

Page 22 GAO-10-213 Veterans' Disability Benefits
 

VA has taken several additional steps that could improve the quality and 

timeliness of its decisions for compensation claims. For example, in July 

2009, VA began piloting at one regional office a reorganization of its claims 

processors into groups that are collectively responsible for gathering the 

evidence for a claim, rating the claim, and processing the decision. This 

structure is different from the current organization, which has distinct 

teams for each phase of the claims process. This reorganization is based 

on a recent recommendation from a consulting firm that studied VA’s 

rating-related claim development process.39 In addition to reducing claim 

folder movement and thus potentially reducing the average processing 

time, the reorganization is intended to increase claims processing staff’s 

appreciation for how their work quality impacts other aspects of the 

process. Although some VA officials expressed skepticism that this 

reorganization would significantly improve the agency’s performance in 

processing compensation claims, they also acknowledged its potential 

benefits. According to VA officials, VA plans to evaluate the pilot in May 

2010, but it has not yet established specific criteria for expanding the 

reorganization to other locations. Similar to the ECA pilot, VA has not yet 

specified which metrics it will use to help assess the pilot, and the goals 

that the new process must meet before being expanded. 

VA Is Piloting a 

Reorganization and Has 

Implemented Quality 

Assurance and 

Technology-Related 

Initiatives That Could 

Improve Decision Quality 

and Timeliness in the 

Future 

VA has also expanded its capacity to measure claims and appeals 

processing quality, which it uses to help monitor performance and identify 

training opportunities for staff. For example, in fiscal year 2008, VA 

doubled the number of staff working in VBA’s quality measurement group 

from about 10 to 20 staff to improve its ability to assess the accuracy of 

claim decisions and appellate work. In fiscal year 2008, this group more 

than doubled the number of claims it reviews for accuracy from 10 to 

21 cases per month, per regional office. In addition, in fiscal year 2009, 

based in part on a VA inspector general recommendation, VBA began 

monitoring the accuracy of claims decided by rating resource centers as it 

does for regional offices.40 Moreover, starting in fiscal year 2008, based in 

part on our prior recommendation,41 VBA’s quality measurement group 

 

39Booz Allen Hamilton, Veterans Benefits Administration Compensation and Pension 

Claims Development Cycle Study, a report prepared for the Department of Veterans 

Affairs, Veterans Benefits Administration (June 5, 2009). 

40Department of Veterans Affairs, Office of Inspector General, Audit of Veterans Benefits 

Administration Compensation Rating Accuracy and Consistency Reviews (Washington, 

D.C.: Mar. 12, 2009). 

41GAO, Veterans’ Benefits: Quality Assurance for Disability Claims and Appeals 

Processing Can Be Further Improved, GAO-02-806 (Washington, D.C.: Aug. 16, 2002). 

Page 23 GAO-10-213 Veterans' Disability Benefits
 

began conducting studies to monitor the extent to which veterans with a 

similar disability receive consistent ratings across regional offices. 

According to VA officials, VBA’s quality measurement group conducted 

four consistency studies in fiscal year 2008. VBA used these studies to 

identify training needs—such as how to verify a stressor for post-traumatic 

stress disorder—at specific regional offices. The group had planned to 

conduct additional consistency studies the following year, but because it 

doubled the number of case reviews and conducted ad hoc, focused 

reviews (e.g., of appellate work), it was not able to conduct further 

consistency studies. However, in fiscal year 2008, VBA’s quality 

measurement group began testing the consistency of decisions made by 

claims processing staff at different locations on a hypothetical claim.42 The 

group conducted two of these consistency tests during fiscal years 2008 

and six tests in fiscal year 2009. VBA has used the results of these tests to 

help identify training needs related to rating certain disabilities, such as 

cardiovascular conditions. 

VA has also leveraged technology in recent years to improve claims 

processing. For example, VA has upgraded its claims processing software 

in phases to enhance its ability to track information about claims and 

reduce the need for duplicative data entry that could introduce errors. 

According to VA, a software upgrade in October 2007 improved staff’s 

ability to manage their workloads and more easily identify priority cases, 

such as those for veterans returning from the current conflicts in Iraq and 

Afghanistan, by electronically filtering and sorting pending claims. Other 

claims processing software upgrades have allowed VA to capture 

management information that is essential to conducting more robust 

analyses on claims processing performance. For example, the prior 

software system did not allow VA to electronically capture more than six 

conditions per claim. With its current claims processing software, VA 

captures information on the actual number of claimed conditions, which in 

turn allows VA to analyze claim development time by condition. 

Finally, VA has also begun processing certain compensation claims with 

less reliance on paper claim files, but widespread paperless processing 

remains elusive, in part because of technical challenges. As of October 

2008, claims processing staff at two regional offices review scanned 

versions of all compensation claims filed by servicemembers 60 to 

180 days before leaving the military, known as Benefits Delivery at 

 

42VA calls these tests “inter-rater reliability” studies. 

Page 24 GAO-10-213 Veterans' Disability Benefits
 

Discharge claims.43 According to VA officials, this process is currently as 

efficient as paper-based processing, but may eventually be more efficient 

and enable further redistribution of case processing as regional offices’ 

changing capacities and workloads require. In addition, in the spring of 

2009, VA designated one of its regional offices to test emerging 

technologies and processes in a real setting to gauge their potential impact 

on the agency and its employees. For example, VA recently used this office 

to test the impact of claims processing staff using only electronic 

information as opposed to hard-copy reference materials to process 

claims. VA hopes to further test paperless claims processing. However, 

officials said that the current system’s infrastructure cannot sustain the 

high volume of data needed to process paperless claims on a widespread 

basis. Even in processing Benefits Delivery at Discharge claims—which 

comprise a small fraction of total compensation claims—the system 

infrastructure used to process such claims occasionally malfunctions. 

Although VA has taken some steps to strengthen its claims processing 

system’s infrastructure, technical challenges persist, especially given the 

volume of evidence generally received for claims and the piecemeal, 

paper-based fashion in which VA often receives the information. These 

factors challenge VA as it works toward having a fully paperless claims 

processing system by the end of 2012. 

For years, VA’s disability claims and appeals processes have received 

considerable attention as VA has struggled to process an increasing 

number of claims from both veterans of recent conflicts as well as aging 

veterans from prior conflicts. Although VA workload and performance 

data indicate that VA has made progress in improving some aspects of its 

disability claims and appeals processing over the past decade, VA 

continues to wrestle with ongoing challenges that may not be resolved in 

the near future. Specifically, significant increases in claims workloads, 

complicated by more conditions per claim and human capital challenges 

associated with training and integrating VA’s large influx of new staff 

continue to contribute to lengthy processing times and a large pending 

claims inventory. 

Conclusions 

 

43In fiscal year 2009, VA received and began processing about 25,000 Benefits Delivery at 

Discharge claims. 

Page 25 GAO-10-213 Veterans' Disability Benefits
 

VA has little or no control over some contributors to its increasing 

workload, but it has taken steps to address some internal inefficiencies 

and challenges that persist within its disability claims and appeals 

processes. Some of VA’s key actions, including its expansion of workload 

redistribution to resource centers and separate pilots aimed at reducing 

processing times, have the potential to improve the claims and appeals 

processes. However, without fully evaluating these actions, VA will not 

have the necessary information to determine their effectiveness and 

whether VA should continue to invest its limited resources in them. For 

example, workload redistribution to resource centers has the potential to 

improve services to veterans, but without tracking the timeliness and 

accuracy of the decisions processed by these centers, VA will not be able 

to fully monitor the centers’ performance and will lack key inputs for 

determining whether they yield positive returns on investment. As a result, 

VA could miss out on opportunities to either increase efficiencies by 

adding more resource centers, or to scale back workload redistribution if 

it is not having the desired effect. In addition, absent an evaluation plan or 

specific criteria for measuring the effect of its ECA and reorganization 

pilots, VA may not be able to determine whether they are successful or to 

make well-informed decisions about expanding them. Considering the 

challenges VA faces and will likely face in the future, it is important that 

VA make effective long-term decisions based on solid data to improve 

benefit delivery for veterans. 

We recommend that the Secretary of Veterans Affairs direct: 

1. VBA to collect data on redistributed claims for development, rating, 

and appellate work to help assess the timeliness and accuracy of 

resource centers’ output and the effectiveness of workload 

redistribution. 

Recommendations for 

Executive Action 

2. VBA and the Board to establish an evaluation plan for assessing the 

ECA pilot process and guiding any expansion decisions. Such a plan 

should include criteria for determining how much improvement should 

be achieved under the pilot on specific performance measures—such 

as average VBA and Board processing times—and include methods for 

how VBA and the Board will consider ECA’s impact on non-ECA 

claims and appeals processing before implementing the process 

widely. 

Page 26 GAO-10-213 Veterans' Disability Benefits
 

3. VBA to establish a plan to evaluate its claims processing 

reorganization pilot and guide any expansion decisions. Such a plan 

should include criteria for determining how much improvement should 

be achieved in the pilot on specific performance measures—such as 

decision timeliness and accuracy—before the process is implemented 

throughout VBA. 

We provided a draft of this report to VA for review and comment. VA 

generally agreed with our conclusions and concurred with our 

recommendations. Its written comments are reproduced in appendix II. 

Agency Comments 

and Our Evaluation 

VA agreed with our recommendation that VBA collect data on 

redistributed claims and appellate work to help assess the timeliness and 

accuracy of resource centers’ output and the effectiveness of workload 

redistribution. VA stated that, by March 2010, VBA plans to change a 

primary workload management tool to help collect timeliness data of 

redistributed work. Analyzing such timeliness data along with other 

factors, such as quality and cost, will be helpful in evaluating the 

effectiveness of workload redistribution. 

VA also agreed with our recommendation that VBA and the Board 

establish an evaluation plan for assessing the ECA pilot process, and 

stated that the Board will work with VBA to establish evaluation criteria 

and explore the potential impact of ECA on non-ECA claims and appeals 

processing. VA stated that the Board hopes to complete an evaluation of 

ECA and make recommendations regarding potentially expanding the pilot 

process or permanently incorporating successful aspects of it by the end 

of fiscal year 2010. We applaud VA’s intent to evaluate the pilot and 

encourage VA to take steps to ensure that the evaluation design and 

criteria yield valid information for making decisions regarding expansion. 

Finally, VA agreed with our recommendation that VBA establish a plan to 

evaluate its claims processing reorganization pilot, and provided critical 

factors that VBA and a private consulting firm established to help assess 

and report on the pilot. Identifying these factors is an important start; 

however, we believe that VBA should also establish the minimum levels of 

performance improvement by factor that should be achieved before the 

pilot process is considered successful and worthy of expansion. 

Page 27 GAO-10-213 Veterans' Disability Benefits
 

We are sending copies of this report to the relevant congressional 

committees, the Secretary of Veterans Affairs, and other interested parties. 

The report is also available at no charge on GAO’s Web site at 

http://www.gao.gov. 

If you or your staffs have any questions concerning this report, please 

contact me at (202) 512-7215 or bertonid@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this report. Staff members who made key contributions to this 

Daniel Bertoni 

report are listed in appendix III. 

Director, Education, Workforce, 

 and Income Security Issues 

Page 28 GAO-10-213 Veterans' Disability Benefits
Appendix I: Objectives, Scope, and 

Methodology 

Page 29 GAO-10-213 

Appendix I: Objectives, Scope, and 

Methodology 

The objectives of our review were to examine (1) trends in the Department 

of Veterans Affairs’ (VA) disability compensation claims processing at the 

claims and appellate levels and (2) actions that VA has taken to improve 

its disability claims process. For both objectives, we focused our analysis 

on VA’s processing of disability compensation for veterans as opposed to 

other types of benefits, such as pensions. 

To examine workload and performance trends, we analyzed compensation 

claims processing data from VA’s Veterans Benefits Administration (VBA) 

and Board of Veterans’ Appeals (Board). In addition, we interviewed VA 

officials familiar with the claims process and reviewed VA annual 

performance reports and other documents to understand data trends and 

related VA challenges and to corroborate our findings. Further information 

about our analysis of VA workload and performance data is provided in 

the following text. 

To identify actions that VA has taken to improve its disability 

compensation claims and appeals processing, we reviewed relevant VA 

testimony and key documents, such as VA strategic plans, and interviewed 

VA officials responsible for compensation claims and appeals processing. 

We focused on VA actions that are ongoing or those that VA completed 

after fiscal year 2005. To examine these actions, we analyzed VBA and 

Board staffing data; reviewed VA’s budget submissions, internal 

processing guidance, and other documents such as external studies and 

VA’s Office of Inspector General reports; and interviewed VA officials and 

veteran service organization representatives. In addition, we visited four 

VBA regional offices and the Board to learn about ongoing initiatives. In 

selecting the regional offices—Chicago, Illinois; Seattle, Washington; 

Togus, Maine; and Winston-Salem, North Carolina—we considered 

regional offices that would provide (1) insights about ongoing initiatives, 

such as pilots; (2) a mix of offices located in different geographic settings 

(e.g., urban and rural); and (3) a mix of offices that are above and below 

VBA’s averages for select claims processing measures. We also reviewed 

relevant federal laws, regulations, and court decisions. 

We conducted this review from November 2008 to January 2010 in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

 Veterans' Disability Benefits 
Appendix I: Objectives, Scope, and 

Methodology 

To analyze VA disability compensation claim workloads and processing 

timeliness, we obtained nationwide, summary-level workload and 

performance data by fiscal year from VA’s Benefits Delivery Network and 

accompanying Distribution of Operational Resources (known as “DOOR”) 

reports, and Veterans Services Network (VETSNET) system and 

accompanying VETSNET Operations Reports (known as “VOR”), and 

spoke with VA officials about these data and sources. We limited our 

analysis to the following three types of disability claims: (1) initial 

compensation claims with fewer than or equal to seven disabilities, 

(2) initial compensation claims with eight or more disabilities, and 

(3) reopened compensation claims. We analyzed data for fiscal years 

2000 to 2008. To analyze pending claims trends, we considered the number 

of claims that were awaiting a decision on the last day of each fiscal year. 

To analyze and report other claim processing trends besides those for 

receipts—which are designated by fiscal year according to when VA 

received the claim—VA designated claims by fiscal year according to when 

the decisions occurred. To verify the reliability of summary-level workload 

and timeliness data from these systems, we obtained and analyzed recordlevel data from VA and spoke with VA officials about how the data are 

input. 

Analysis of VA Claims 

Workload and 

Performance Data 

We were able to replicate all of the summary-level workload and 

timeliness data that VA provided. However, we questioned VA’s method 

for calculating claim receipts. Therefore, we attempted to replicate claim 

receipt data using VA’s method and our method. VA calculates monthly 

claim receipts by counting the total number of pending claim records at 

the end of a month; subtracting the number of pending claim records from 

the end of the previous month; and adding the number of completed 

claims during the month, regardless of when they originated. To calculate 

the annual number of claims received, VA then adds the monthly claim 

receipt counts. Our method for calculating annual claim receipts was to 

count the number of claims whose claim date was in a given year. We 

compared the results and found that the annual claim receipts data using 

our method were about 2 to 3 percent lower than the data replicated using 

VA’s method. Ultimately, we decided to use the summary-level receipts 

data that VA provided because they were materially close to our counts 

and because we were able to replicate VA’s summary-level data using its 

method. 

To analyze the quality of VA’s disability compensation claims processing, 

we obtained annual, nationwide data from its Systematic Technical 

Accuracy Review (STAR) program and verified the reliability of the data. 

The STAR program audits a randomly selected sample of VBA’s completed 

Page 30 GAO-10-213 Veterans' Disability Benefits
Appendix I: Objectives, Scope, and 

Methodology 

claims for accuracy. We limited our analysis to the following three types of 

disability claims: (1) initial compensation claims with fewer than or equal 

to seven disabilities, (2) initial compensation claims with eight or more 

disabilities, and (3) reopened compensation claims. To report consistent 

data, we analyzed fiscal years 2003 to 2008 because the STAR program 

changed its audit methodology in fiscal year 2002. To verify the reliability 

of STAR data, we spoke with VA officials responsible for overseeing the 

STAR system. We also relied on prior verification of STAR data.1

Consistent with this prior verification, we found that the STAR data were 

reliable for reporting nationwide trends. 

To analyze VA’s disability compensation appellate workloads and 

processing performance, we obtained record-level appeals data extracted 

on April 2, 2009, from the Veterans Appeals Control and Locator System 

(VACOLS). We limited our analysis to rating-related disability 

compensation appeals, which we identified by speaking with Board 

officials about how rating-related disability compensation appeals are 

classified in VACOLS, then limiting the data accordingly. We further 

limited our analysis to original appeals as opposed to appeals that, for 

example, had been previously remanded by the Board. Using the recordlevel appeals data, we generated nationwide annual data for fiscal years 

2000 to 2008.2

 To analyze pending appeals trends, we considered the 

number of appeals that were awaiting a decision on the last day of each 

fiscal year. To analyze other appeals processing trends besides those for 

receipts—which we designated by fiscal year according to when VA 

received the appeal—we designated appeals by fiscal year according to 

when their resolution occurred. 

Analysis of VA 

Appellate Workload 

and Performance 

Data 

Our reporting of avoidable remands—which are appeals that the Board 

does not consider because of claims processing errors that occurred 

before VBA certified transferring the appeal to the Board—varies from 

calculations we received from VBA. For fiscal years 2006 to 2008, we 

calculated avoidable remand rates of 24.3 percent, 25.4 percent, and 

24.7 percent, respectively; whereas VBA reported avoidable remand rates 

of 23.7 percent, 17.9 percent, and 17.7 percent, respectively. Our analysis 

 

1

GAO, Veterans’ Benefits: Further Changes in VBA’s Field Office Structure Could Help 

Improve Disability Claims Processing, GAO-06-149 (Washington, D.C.: Dec. 9, 2005). 

2

We analyzed avoidable remand data from fiscal years 2006 to 2008 because complete, 

reliable data were previously not available in VACOLS. 

Page 31 GAO-10-213 Veterans' Disability Benefits
Appendix I: Objectives, Scope, and 

Methodology 

was limited to compensation appeals, whereas VBA included 

noncompensation-related appeals. In addition, the calculation methods 

differed. We calculated the avoidable remand rate as the number of 

avoidable remands on original appeals—which excludes appeals that were 

previously remanded by the Board—divided by the number of original 

appeals decided by the Board. VBA calculated the rate as the number of 

avoidable remands on original appeals, divided by the total number of 

appeals decided by the Board. We believe that VBA’s method is misleading 

because appeals in the denominator are not restricted as they are in the 

numerator. 

To assess the reliability of record-level appeals data, we (1) interviewed 

Board officials about program and technical operations and (2) performed 

electronic testing to identify missing and potentially invalid data and to 

identify internal inconsistencies. We found that the data were reliable for 

our reporting purposes. 

Page 32 GAO-10-213 Veterans' Disability Benefits
Appendix II: Comments from the Department Appendix II: Comments from the Department of Veterans Affairs 

of Veterans Affairs 

Page 33 GAO-10-213 Veterans' Disability Benefits 
Appendix II: Comments from the Department 

of Veterans Affairs 

Page 34 GAO-10-213 Veterans' Disability Benefits
Appendix II: Comments from the Department 

of Veterans Affairs 

Page 35 GAO-10-213 Veterans' Disability Benefits
Appendix III: GAO

A

 Contact and Staff 

cknowledgments 

Page 36 GAO-10-213 

Appendix III: GAO Contact and Staff 

Acknowledgments 

Daniel Bertoni, (202) 512-7215 or bertonid@gao.gov

Shelia Drake, Assistant Director; Joel Green; Lisa McMillen; and Bryan 

Rogowski made significant contributions to this report. In addition, Walter 

Vance provided guidance on research methodology; Cynthia Grant and 

Christine San provided assistance with data analysis; Roger Thomas 

provided legal counsel; Jessica Orr helped with report preparation; and 

James Bennett provided assistance with graphics. 

GAO Contact 

Staff 

Acknowledgments 

 Veterans' Disability Benefits 
Related GAO Products Related GAO Products 

Veterans’ Disability Benefits: Preliminary Findings on Claims 

Processing Trends and Improvement Efforts. GAO-09-910T. Washington, 

D.C.: July 29, 2009. 

Military Disability System: Increased Supports for Servicemembers and 

Better Pilot Planning Could Improve the Disability Evaluation Process.

GAO-08-1137. Washington, D.C.: September 24, 2008. 

Veterans’ Benefits: Increased Focus on Evaluation and Accountability 

Would Enhance Training and Performance Management for Claims 

Processors. GAO-08-561. Washington, D.C.: May 27, 2008. 

Veterans Benefits Administration: Progress Made in Long-Term Effort 

to Replace Benefits Payment System, but Challenges Persist. GAO-07-614. 

Washington, D.C.: April 27, 2007. 

Veterans’ Disability Benefits: VA Can Improve Its Procedures for 

Obtaining Military Service Records. GAO-07-98. Washington, D.C.: 

December 12, 2006. 

Veterans’ Benefits: Further Changes in VBA’s Field Office Structure 

Could Help Improve Disability Claims Processing. GAO-06-149. 

Washington, D.C.: December 9, 2005. 

Veterans’ Disability Benefits: Claims Processing Challenges and 

Opportunities for Improvements. GAO-06-283T. Washington, D.C.: 

December 7, 2005. 

VA Disability Benefits: Board of Veterans’ Appeals Has Made 

Improvements in Quality Assurance, but Challenges Remain for VA in 

Assuring Consistency. GAO-05-655T. Washington, D.C.: May 5, 2005. 

Veterans’ Benefits: More Transparency Needed to Improve Oversight of 

VBA’s Compensation and Pension Staffing Levels. GAO-05-47. 

Washington, D.C.: November 15, 2004. 

Veterans’ Benefits: Improvements Needed in the Reporting and Use of 

Data on the Accuracy of Disability Claims Decisions. GAO-03-1045. 

Washington, D.C.: September 30, 2003. 

High-Risk Series: An Update. GAO-03-119. Washington, D.C.: January 

2003. 

Page 37 GAO-10-213 Veterans' Disability Benefits
Related GAO Products 

Veterans’ Benefits: Claims Processing Timeliness Performance Measures 

Could Be Improved. GAO-03-282. Washington, D.C.: December 19, 2002. 

Veterans’ Benefits: Quality Assurance for Disability Claims and Appeals 

Processing Can Be Further Improved. GAO-02-806. Washington, D.C.: 

August 16, 2002. 

Veterans’ Benefits: VBA’s Efforts to Implement the Veterans Claims 

Assistance Act Need Further Monitoring. GAO-02-412. Washington, D.C.: 

July 1, 2002. 

Veterans Benefits Administration: Problems and Challenges Facing 

Disability Claims Processing. GAO/T-HEHS/AIMD-00-146. Washington, 

D.C.: May 18, 2000. 

(130903) Page 38 GAO-10-213 Veterans' Disability Benefits
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