U.S. GOVERNMENT PUBLISHING OFFICE

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LEGISLATIVE HEARING ON PRE–DISCHARGE 

CLAIMS PROGRAMS: ARE VA AND DOD EFFECTIVELY SERVING SEPARATING MILITARY PERSONNEL 

HEARING 

BEFORE THE

SUBCOMMITTEE ON DISABILITY 

ASSISTANCE AND MEMORIAL AFFAIRS 

OF THE

COMMITTEE ON VETERANS’ AFFAIRS 

U.S. HOUSE OF REPRESENTATIVES 

ONE HUNDRED FIFTEENTH CONGRESS 

FIRST SESSION 

WEDNESDAY, DECEMBER 13, 2017 

Serial No. 115–42 

Printed for the use of the Committee on Veterans’ Affairs 

( 

Available via the World Wide Web: http://govinfo.gov 

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(II) 

COMMITTEE ON VETERANS’ AFFAIRS 

DAVID P. ROE, Tennessee, Chairman 

GUS M. BILIRAKIS, Florida, Vice-Chairman 

MIKE COFFMAN, Colorado 

BRAD R. WENSTRUP, Ohio 

AMATA COLEMAN RADEWAGEN, American 

Samoa 

MIKE BOST, Illinois 

BRUCE POLIQUIN, Maine 

NEAL DUNN, Florida 

JODEY ARRINGTON, Texas 

JOHN RUTHERFORD, Florida 

CLAY HIGGINS, Louisiana 

JACK BERGMAN, Michigan 

JIM BANKS, Indiana 

JENNIFFER GONZALEZ-COLON, Puerto 

Rico 

TIM WALZ, Minnesota, Ranking Member 

MARK TAKANO, California 

JULIA BROWNLEY, California 

ANN M. KUSTER, New Hampshire 

BETO O’ROURKE, Texas 

KATHLEEN RICE, New York 

J. LUIS CORREA, California 

KILILI SABLAN, Northern Mariana Islands 

ELIZABETH ESTY, Connecticut 

SCOTT PETERS, California 

JON TOWERS, Staff Director 

RAY KELLEY, Democratic Staff Director 

SUBCOMMITTEE ON DISABILITY ASSISTANCE AND MEMORIAL 

AFFAIRS 

MIKE BOST, Illinois, Chairman 

MIKE COFFMAN, Colorado 

AMATA RADEWAGEN, America Samoa 

JACK BERGMAN, Michigan 

JIM BANKS, Indiana 

ELIZABETH ESTY, Connecticut, Ranking 

Member 

JULIA BROWNLEY, California 

KILILI SABLAN, Northern Mariana Islands 

Pursuant to clause 2(e)(4) of Rule XI of the Rules of the House, public hearing records 

of the Committee on Veterans’ Affairs are also published in electronic form. The printed 

hearing record remains the official version. Because electronic submissions are used to 

prepare both printed and electronic versions of the hearing record, the process of converting 

between various electronic formats may introduce unintentional errors or omissions. Such occurrences are inherent in the current publication process and should diminish as the process 

is further refined. 

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C O N T E N T S 

Wednesday, December 13, 2017 

Page 

Legislative Hearing On Pre–Discharge Claims Programs: Are VA And DOD 

Effectively Serving Separating Military Personnel ........................................... 1 

OPENING STATEMENTS 

Honorable Mike Bost, Chairman ............................................................................ 1 

Honorable Elizabeth Esty, Ranking Member ........................................................ 2 

WITNESSES 

Terry A. Adirim, M.D., MPH, Deputy Assistant Secretary of Defense for 

Health Services Policy and Oversight, U.S. Department of Defense ............... 4 

Prepared Statement ......................................................................................... 22 

Willie C. Clark, Sr., Deputy Under Secretary for Field Operations, Veterans 

Benefits Administration, U. S. Department of Veterans Affairs ..................... 6 

Prepared Statement ......................................................................................... 23 

Accompanied by: 

Beth Murphy, Director, Compensation Service, Veterans Benefits Administration, U. S. Department of Veterans Affairs 

Patricia Murray, Chief Officer, Office of Disability and Medical Assessment, Veterans Health Administration, U. S. Department of Veterans 

Affairs 

Gerardo Avila, Deputy Director, Medical Evaluation Board/ Physical Evaluation Board/Department of Defense Correction Board, National Veterans 

Affairs and Rehabilitation Division, The American Legion .............................. 7 

Prepared Statement ......................................................................................... 25 

Ryan M. Gallucci, Director, National Veterans Service, Veterans of Foreign 

Wars ...................................................................................................................... 9 

Prepared Statement ......................................................................................... 27 

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LEGISLATIVE HEARING ON PRE–DISCHARGE 

CLAIMS PROGRAMS: ARE VA AND DOD EFFECTIVELY SERVING SEPARATING MILITARY PERSONNEL 

Wednesday, December 13, 2017 

U.S. HOUSE OF REPRESENTATIVES, 

COMMITTEE ON VETERANS’ AFFAIRS, 

SUBCOMMITTEE ON DISABILITY ASSISTANCE

AND MEMORIAL AFFAIRS, 

Washington, D.C. 

The Subcommittee met, pursuant to notice, at 10:00 a.m., in 

Room 334, Cannon House Office Building, Hon. Mike Bost [Chairman of the Subcommittee] presiding. 

Present: Representatives Bost, Coffman, Banks, Esty, and 

Brownley. 

OPENING STATEMENT OF HONORABLE MIKE BOST, 

CHAIRMAN 

Mr. BOST. Good morning, and welcome. The oversight hearing of 

the Subcommittee on Disability Assistance and Memorial Affairs 

will now come to order. 

There are currently 1.3 million men and women serving in the 

United States armed forces. It is our duty to ensure that those who 

have defended our country receive their earned VA benefits as soon 

as possible. Today’s hearing will review whether VA and DoD predischarge programs are effectively assisting ervice members who 

are leaving the military while coping with illness and injuries. 

In a hearing on pre-discharge programs this Subcommittee held 

in 2014, we heard from veteran service organizations who were 

concerned about the quality of disability examinations, the accuracy of the VA’s ratings, and the lengthy decision process. At this 

hearing we will look at what VA and DoD have done to address 

those concerns since the hearing several years ago. 

Last week I had the privilege to meet with some of the wounded 

warriors at Walter Reed, we were going through one of the pre-discharge programs, the IDES program, more commonly, well, Integrated Disability Evaluation Systems, or IDES as it is commonly 

known. IDES is celebrating its tenth anniversary this year, and is 

the joint VA–DoD program used to determine if servicemembers 

dealing with injuries or illness are able to continue to serve. 

If the servicemember is found unfit for active duty, IDES is designed to ensure that the transition from warrior to veteran is 

seamless. Under IDES, servicemembers received one medical exam 

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from VA which will serve two purposes. First, DoD will use the 

exam to assess if the servicemember is fit to return to duty. And, 

if not, whether the member will be medically retired. 

Second, if DoD finds that the servicemember is not fit for duty, 

the VA uses the exam results to issue a proposed disability rating. 

This process saves the servicemember from having to undergo two 

exams, one from DoD and another from the VA. 

I talked with the servicemembers about IDES last week, and was 

pleased to hear that the people I talked to had no complaints about 

their experience with the program at Walter Reed, but that does 

not mean that the program can’t be improved on. We can always 

do better. 

I want to discuss concrete proposals that will make this process 

more effective to ensure that VA providers provides the men and 

women of the armed forces who go to IDES the support they need 

when they return to civilian life. We are also going to focus on two 

other pre-discharge program benefits deliveries. 

The delivery at discharge—the Benefit Delivery at Discharge, or 

the BDD, and Quick Start, which are also supposed to help 

servicemembers with disabilities access VA benefits soon after separating from the military. The BDD program servicemembers who 

were within 60 to 180 days of discharge could file a claim and receive a VA disability examination before leaving the military. 

The second program, Quick Start, allowed the servicemembers 

who were going to be discharged within 60 days file a claim and 

receive a disability exam from the VA as soon as they were discharged. Both of these programs allowed separate servicemembers 

to get a head start on their VA disability claim. If the system 

worked as intended, individuals would begin to receive disability 

benefits soon after leaving the military. 

However, VA has acknowledged that it had some challenges with 

timeliness when administering the BDD and the Quick Start programs. The VA recently told my staff that it was not meeting timeliness goals for Quick Start because it can be difficult to schedule 

a disability examination for servicemembers who are within 90 

days of discharge. To try to resolve this issue, other VA and others, 

the VA eliminated the Quick Start program on October 31st, 2017, 

and made some changes to the BDD program. 

I am looking forward to hearing feedback from both the Department and VSO witnesses on three of these programs; IDES, BDD, 

and Quick Start. I am particularly interested in whether VA redesigning the BDD program is actually streamlining the disability 

claim process for separating military personnel. Lastly, I am hoping that we can find out ways that the VA and DoD can make all 

of the pre-discharge processes more efficient for our Nation’s military members. 

Again, I want to thank everyone for being here today. And I 

would like to recognize, for opening comments, Ranking Member 

Esty. 

OPENING STATEMENT OF HONORABLE ELIZABETH ESTY, 

RANKING MEMBER 

Ms. ESTY. Thank you very much, Mr. Chairman. And thank all 

of you for being with us here today. We are here today to look at 

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two programs that hold the promise of providing every 

servicemember separating from military with his or her veteran’s 

benefits before discharge. That is our goal. 

And we are not there yet, but the basis to achieve this goal exists 

in the IDES and BDD programs. We now have ten years of experience, and it is clear from what I have seen—and I want to thank 

those of you who did a lengthy briefing with me earlier this week 

in preparation for this—that the most important element that we 

have seen in making improvement is, in fact, better coordination 

between DoD and VA. And I want to commend you for that. That 

is not easy to do, but it is essential if we are going to continue to 

make progress. 

A lot of progress has been made. If you look at the timeliness 

numbers, for example. VA is showing a 102-day improvement in 

terms of scheduling these. Now that is extraordinary. So the time 

to completion has been cut almost in half. The goal has been do 

these exams within 100 days, you are now 19 days under that. 

That is to be commended. And I think it is important to look at 

the progress that has been made. 

But timeliness is one factor. Accuracy is another. Connection is 

another, particularly for high-risk groups. And I want to return to 

that. DoD tells us the result of the customer satisfaction surveys 

of servicemembers are taken twice during the IDES process. You 

are showing a satisfaction rate of 90 percent, and that is with 40- 

plus percent completion rate, which is quite high for surveys. 

Again, we are pleased with that. But it is over time, and it is with 

everyone that we are looking for. 

So in order to set a course towards even greater improvement, 

today I want to do the following. Number one, I want to make sure 

that errors are not slipping through as a result of the recent 

changes in the way in which BDD claims are being tracked. So, accuracy. 

Two, I want to understand what steps are being taken to ensure 

that Guard and Reserve troops have the same opportunity to receive benefit determinations before they leave the Guard and Reserves. BDD may not be the right program for them. But due to 

the uniqueness of their service commitment, we need to make sure 

they are not short-changed. 

And I want to explore that a little bit more with the time requirements and how those do not really line up very well with the 

Guard, and we need to anticipate that and do this. I hear about 

this from Guard and Reservists in Connecticut. And they have frequent deployments, and this process is not really serving them 

well. 

Number three, I want to be assured that the military service coordinators and the physical exam board service officers are receiving the training that they need to help injured or ill 

servicemembers and their families through the process involved in 

IDES in a way that acknowledges and respects the service to the 

Nation that they have given, and particularly for terminally ill or 

those who have struggled with mental health issues when leaving 

the military. I think that respect factor and ensuring that it is not 

just about timeliness and checking the boxes, it needs to be high 

touch and respectful at all times. 

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Fourth, I want to hear that VA intends to update and modernize 

how it is reaching out and communicating with troops pre-separation about what benefits are available to them. I also want to see 

a particular focus on that outreach to high-risk groups that we 

know tend not to connect and suffer even more when they do not. 

Especially looking at women and looking at those who are most 

likely to suffer from PTSD, and all the attendant issues of homelessness, chronic illness, and worse. 

The other thing I want to do today is to ask our witnesses to tell 

us what we in Congress can do to help support DoD and VA to 

achieve greater success. We want an update on where you are but, 

obviously, a charge from you and enlightenment about what we 

need to do to do our jobs. 

Let us know what resources you need, what authority you may 

need to continue going forward to effectively, and appropriately, 

and respectfully serve those who served this great Nation. So, 

again, thank you for being here today, for working with us as we 

exercise our responsibility to provide oversight of these programs. 

I look forward to your testimony and the opportunity to ask questions. Thank you, and I yield back. 

Mr. BOST. Thank you, Ms. Esty. I ask all Members waive their 

opening remarks as per the Committee’s custom. I want to welcome 

the witnesses who are joining us here this morning, and thank you 

for taking the time to be here. 

Our first witness is Dr. Terry Adirim, the Deputy Assistant Secretary of Defense of Health Services and Policy and Oversight for 

DoD. Joining us from VA is Mr. Willie Clark, who is the Department Under Secretary for the Field Operations of VBA. He is accompanied by Ms. Beth Murphy, the Director of Compensation 

Services for VBA, and by Ms. Patrick Murphy—Murray, I am 

sorry, Patricia Murray, the Chief Officer of Office of Disabilities 

and Medical Assistance for VHA. 

Testifying on the behalf of the American Legion is Mr. Gerardo 

Avila—I will get that correct, yeah—who is the Deputy Director for 

the Medical Evaluation Board, Physical Evaluation Board, and Department of Defense Correction Board for the American Legion. 

Also joining us today is Mr. Ryan Gallucci, the Department Director of the National Veterans Services for VFW. We welcome to all 

of you. 

I want to remind the witnesses that your complete written statement will be entered into the hearing record. 

Dr. Adirim, you are now recognized for five minutes for the Department of Defense’s testimony on opening statement. 

STATEMENT OF DR. TERRY ADIRIM 

Dr. ADIRIM. Thank you. And I appreciate you pronouncing my 

name perfectly. 

Mr. BOST. I wish I did it for everybody. 

Dr. ADIRIM. Yeah. No. I am very impressed. Thank you. Good 

morning, everybody. Chairman Bost, Ranking Member Esty, and 

distinguished Members of the Subcommittee, thank you for the opportunity to testify today on the Integrated Disability Evaluation 

System, and we all call it IDES, so thank you for shortening that 

for us. 

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Since 2007, DoD and VA have jointly administered the IDES to 

evaluate our Nation’s wounded, ill, or injured servicemembers, and 

to ensure they receive the benefits they so rightly deserve. As a 

joint venture, DoD and VA implemented the IDES to provide 

servicemembers with quality, efficient, and transparent disability 

evaluations. 

As you know, the IDES is a streamlined process in which 

servicemembers receive a single examination, a single disability 

rating, and simultaneous DoD and VA processing to deliver benefits as early as possible following disability separation or retirement from military service. 

As a result, the IDES process accomplishes two primary DoD objectives. The first, it ensures the medial readiness of the U.S. 

armed forces. And, second, it provides potentially unfit 

servicemembers with expedient transition to benefits and VA care. 

The IDES framework continues to exceed expectations. In 2007, 

prior to the IDES implementation, servicemembers waited an average of 540 days from referral for disability evaluation to receipt of 

VA benefits. Today, I am happy to report, active component cases 

average 258 days for both DoD and VA to complete their combined 

stages of the DES, a 52 percent improvement from the previous 

DES process. 

DoD is also outperforming our core, DoD-only process stage goals 

as required by DoD policy. In October 2017, DoD core stage performance for Active Component disability evaluation was 104 days 

against 105-day goal, while Reserve Component disability evaluation was 88 days against 125-day goal. Nonetheless, DoD and VA 

continuously seek to improve the timeliness and efficacy of the 

IDES. 

Since DoD’s last appearance before this Subcommittee to discuss 

IDES, we have continued to improve processing across all the military departments. We have made a concerted effort to enhance case 

management, upgrade training standards, reduce overall IDES 

timeliness, and expand our quality control program. 

Within IDES, servicemembers have a single point of contact to 

help navigate the process known as a Physical Evaluation Board 

Liaison Officer, or PEBLO. The PEBLO provides servicemembers 

with all the critical information they need to make informed decisions throughout the process that is our direct touch. 

Since 2014, DoD has taken concrete steps to improve the IDES 

staff training. In collaboration with the military departments, we 

issued new training standards and performance objectives to ensure all IDES staff members are armed with the necessary tools to 

assist wounded, ill, or injured servicemembers. 

Further, our quality assurance program enables us to evaluate 

the performance, accuracy, and consistency of the IDES. Our expansion of the quality assurance program gives DoD the necessary 

information to monitor performance and correct inefficiencies. 

For fiscal year 2017, IDES scores reflect an accuracy rate of 94 

percent, a consistency rate of 77 percent, and a duty performance 

rate of 80 percent, and we are still not satisfied. Results of these 

combined efforts can be seen in our most recent survey—as was already mentioned—of over 9,000 servicemembers who indicated an 

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overall 93 percent satisfaction rating with DoD and VA personnel 

implementing the IDES, and their overall IDES experience. 

So I am not surprised, Mr. Bost, that the Walter Reed experience 

demonstrated this. 

Again, I would like to thank you for the opportunity to testify on 

these important issues, and I look forward to answering your questions. 

[THE PREPARED STATEMENT OF DR. TERRY ADIRIM APPEARS IN THE

APPENDIX]

Mr. BOST. Thank you, Doctor, for your testimony. Mr. Clark, you 

are recognized for five minutes. 

STATEMENT OF WILLIE CLARK SR. 

Mr. CLARK. Good morning, Chairman Bost— 

Mr. BOST. Good morning. 

Mr. CLARK [continued]. —Ranking Member Esty, and Members 

of the Subcommittee. My name is Willie Clark, Deputy Under Secretary for Field Operations and the Veterans Benefits Administration. I am joined by Beth Murphy, Director of Compensation Service, and Patricia Murray, Chief Officer, Office of Disability and 

Medical Assessment with the VHA. 

Today I will discuss VBA’s pre-discharge programs for 

servicemembers including IDES—sir, what you spoke to—and 

BDD. I will also discuss improvements in both of these programs; 

servicemembers satisfaction with IDES and training employees involved in IDES and BDD. 

On November 28, 2017, the Department of Veterans Affairs and 

DoD celebrated the tenth anniversary of IDES. In 2007, VA and 

DoD created an integrated disability evaluation process for 

servicemembers who are being medically retired or separated from 

service. This joint process was designed to provide a seamless transition of benefits and health care for medically separating 

servicemembers. 

In fiscal year 2017, more than 22,000 servicemembers were enrolled in IDES. As a result of our collaborative efforts, VBA and 

DoD have met the goals established for IDES. VBA’s average processing time in September 2017 was 81 days, which is a 102-day improvement from May of 2014; the last time we testified here on the 

IDES program. 

This 81 days is 10 days better than the VBA average of 100 days. 

And VBA awarded benefits within an average of 26 days of discharge, exceeding the IDES timeliness goal of 30 days. As of June 

2017, the semi-annual customer satisfaction survey showed that 

satisfaction was at 93 percent for IDES, and 89 percent for our 

military service coordinators. VA continues to collaborate with DoD 

on ways to improve the IDES execution while remaining focused on 

timeliness and accuracy. 

Since 1995, BDD and Quick Start programs have provided transitional assistance to separating servicemembers by engaging them 

in the claims process prior to discharge. VBA’s goal is to ensure 

that each servicemember transitioning from service who wishes to 

file a claim for service-connected disability benefits receives timely 

assistance. 

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In fiscal year 2017, VBA significantly improved BDD production 

and timeliness, completing over 32,000 claims in an average of 90 

days compared to approximately 29,000 in 127 days in fiscal year 

2016. VBA also completed over 25,000 Quick Start claims with an 

average of 109 days in fiscal year 2017. Pretty good accomplishments, but as you mentioned, we have to do better. We realize that, 

and we are embracing that. 

VBA is dedicated to ensuring that veterans receive the benefits 

they earned as quickly and accurately as possible. To this end, 

VBA has redesigned the pre-discharge program to enable 

servicemembers to receive disability benefit decisions, in most 

cases the day after their discharge. 

The redesigned program went into effect October the 1st of 2017. 

Pre-discharge claims are now distributed through the National 

Work Queue, sending these claims to all the VA offices rather than 

just a few. Modifications to the existing BDD program include 

changing the filing deadline from 60 to 90 days, enabling VBA to 

complete all medical examinations prior to the servicemembers’ discharge from active duty. 

So one of the reasons for redesigning the program was to make 

sure that we had enough time to complete all of the exams and get 

them completed along with the servicemembers active duty and 

TDY requirements, and the like. So that is one of the main reasons 

we changed the program. 

As part of the redesign, VBA discontinued the Quick Start program, instead utilizing the new decision ready claims process, fully 

developed claim process, or traditional claims as appropriate. We 

continue to work in concert with our VSO partners who regularly 

collaborate with our MSCs on various military basis in order to facilitate servicemembers’ initial claims submission. 

VBA’s pre-discharge program provide all transitioning 

servicemembers the opportunity to initiate a claim for disability 

compensation benefits. VBA provides substantial training for all 

employees involved in the processing of claims, including pre-discharge claims. 

Ongoing technical training is required each year, and training is 

regularly updated. VBA conducted training on the redesigned BDD 

program in September of 2017, for MSCs in October 2017 for 

claims processes. VBA plans to conduct a comprehensive MSC 

training event in fiscal year 2018. VBA remains committed to supporting our Nation’s servicemembers through improvements in the 

pre-discharge program. 

Mr. Chairman, this concludes my statement. We would be 

pleased to respond to questions you, Ranking Member Esty, or 

other Members of the Subcommittee may have. 

[THE PREPARED STATEMENT OF MR. WILLIE CLARK APPEARS IN

THE APPENDIX]

Mr. BOST. Thank you, Mr. Clark. I guess I should have the mike 

on. Thank you. Mr. Avila, you are recognized for five minutes. 

STATEMENT OF GERADO AVILA 

Mr. AVILA. Chairman Bost, Ranking Member Esty, and distinguished Members of the Subcommittee on Disability Assistance 

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and Memorial Affairs, on behalf of the 2 million members of the 

American Legion and National Commander Denise H. Rohan, 

thank you for the opportunity to testify regarding the American Legion’s positions on the Integrated Disability Evaluation System and 

VA’s pre-discharge program for separating servicemembers. 

The goal of IDES since its inception ten years ago has been to 

streamline the medical board process and create a seamless transition for wounded, ill, and injured servicemembers from DoD to VA. 

The American Legion has testified in the past concerning issues 

with timeliness, lack of information for those enrolled, and gaps in 

medical and compensation benefits after separating. 

Despite these concerns, we believe that the current IDES system 

is an improvement over its predecessor. The issues highlighted in 

our previous testimony have shown to improve. Despite this, we 

have the following concerns. 

DoD’s practice of rating and, in many instances, recommending 

a reduction of disability rating decisions for individuals placed on 

the Temporary Disability Retirement List, also referred to as 

TDRL. A servicemember found unfit with a condition deemed not 

stable to assign the permanent disability rating will end up on 

TDRL. 

Once an individual transitions out of military service, they will 

be required to undergo periodic examinations by DoD to determine 

if the condition has stabilized and able to assign a permanent disability rating. In many instances these examinations are done at 

a DoD medical facility or by a DoD contractor. For instance, I have 

recently been contacted by a Navy veteran in this predicament. 

In 2013 the individual was given a rating for 60 percent for and 

unfit condition and placed on TDRL. After this latest reexamination in October of this year, the Navy considered the condition stable and is proposing a new rating of 20 percent. If nothing changes, 

this individual will be separated with severance despite still being 

rated at 60 percent for the same condition by VA. 

One of the goals of IDES was to have a single rating decision 

used by both VA and DoD. In an effort to keep the integrity and 

spirit of the IDES process, the American Legion believes that DoD 

should communicate with VA when recommending new ratings for 

individuals placed on TDRL. We recommend that if VA has a current rating for the condition, DoD should apply that same rating. 

American Legion service officers continue to encounter lack of resources for members of the National Guard and Reserves, specifically with Line of Duty, or LOD, investigations. An LOD is crucial 

to establish that a disability was caused due to military service. 

Without needed documentation, many servicemembers face a possibility of being separated with no benefits. 

With the hectic nature of military duty, it is not always possible 

to capture the facts when an injury occurs. The failure to capture 

and record crucial details has shown to be harmful for members of 

the National Guard and Reserve when undergoing the IDES process. 

With regards to the pre-discharge program for transitioning 

servicemembers, the American Legion continues to maintain service officers at the regional office in Winston-Salem, North Carolina, 

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and Salt Lake City, Utah. A service officer assists transitioning 

servicemembers with 500 pre-discharge claims quarterly. 

Recently, the Veterans Benefit Administration introduced the 

new changes with the launch of the pre-discharge redesigned program. Major changes include the elimination of the Quick Start 

program and adjusting the filing day for pre-discharge claims between 180 and 90 days before separation. 

The Salt Lake City regional office was selected as the pilot site 

for the program. The early feedback from a representative there 

has been positive. A representative states that he has seen more 

pre-discharge claims being completed prior to the date of separation. This was not the case under the previous program. This new 

expedited method is beneficial to the veterans as they will receive 

their compensation immediately upon separating. 

The American Legion has concerns with the elimination of the 

Quick Start program due to the loss of the in-service diagnosis. 

Without this diagnosis, servicemembers are at greater risk at being 

denied, or at least delayed, in being considered service-connected. 

The American Legion continues their commitment to 

transitioning the servicemembers by maintaining a dedicated staff 

to assist during this crucial phase. We feel that these challenges 

can be improved with the integration of stakeholders at all levels 

and improve channels of communication, we owe it to the men and 

women who have volunteered for service to the Nation. 

Thank you, again, Chairman Bost, Ranking Member Esty, and 

distinguished Members of the Subcommittee. We appreciate the opportunity to present the American Legion’s views, and look forward 

to answering any question that you and/or the Subcommittee may 

have. 

[THE PREPARED STATEMENT OF MR. GERARDO AVILA APPEARS IN

THE APPENDIX]

Mr. BOST. Thank you, Mr. Avila. And, Mr. Gallucci, you are recognized for five minutes. 

STATEMENT OF RYAN M. GALLUCCI 

Mr. GALLUCCI. Thank you. Chairman Bost, Ranking Member 

Esty, and Members of the Subcommittee, on behalf of the VFW, 

thank you for the opportunity to testify on VA and DoD’s pre-discharge claims programs. 

To the VFW, there is no more critical point than when a 

servicemember leaves the military and seeks to access their benefits. Filing an initial claim is just the beginning of what the VFW 

considers a lifetime of advocacy that resulted in nearly $7.7 billion 

in benefits delivered to all VFW-represented veterans in 2017. 

We serve 24 military installations through our pre-discharge program, and I want to thank both VA and DoD for allowing our highly-trained and professional advocates to assist in this transition. By 

working together, we ensure timely delivery of benefits for veterans 

at a pivotal point, and we set up veterans for positive interactions 

with VA moving forward. 

As transition programs evolve, we seek to make changes to improve the experience. Many times they yield positive results such 

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charge claims, but sometimes changes have unintended consequences. This is where it is the VFW’s responsibility to inform 

the agencies and this Committee of our concerns. 

Recently, VA made two significant changes that concern the 

VFW. First, VA shifted its timelines for BDD, only allowing 

servicemembers to submit claims from 180 to 90 days prior to discharge. Second, VA eliminated Quick Start, meaning 

servicemembers with 89 days or fewer left on active duty no longer 

have an option tailored to their needs. 

On its own, the shift to 90 days makes sense. VA can complete 

exams and propose decisions in time for separation. However, coupled with DoD’s VOW Act requirements to deliver transition training and the elimination of Quick Start, the VFW believes this only 

makes it more difficult for transitioning servicemembers to access 

their benefits at separation, and more difficult to evaluate whether 

VA is effectively serving this population. 

GAO recently reported that DoD still struggles to meet the 90- 

day requirement to commence transition. This is problematic for 

lower-ranking servicemembers who do not control their schedules 

and for those who must remain operational as long as possible. 

VFW data shows that nearly half of our clients were Quick Start 

prior to October 1. This is not a knock on DoD. We know military 

mission requirements come first and believe the VOW Act standard 

is reasonable. This is where VA needs to be flexible and cutting off 

BDD at 90 days does not help. If servicemembers have not been 

briefed yet on how to access their benefits, how can we expect them 

to file their claims? 

In the past, the Quick Start EP code allowed both the VFW and 

VA to track pre-discharge work and ensure the best possible outcome for the veteran. VA argues that eliminating the code is not 

a big deal, and that BDD excluded claims can be worked in regular 

order once the servicemember is discharged. However, this unique 

population deserves unique attention. 

It troubles us that VA is telling servicemembers they will no 

longer work up to 50 percent of pre-discharge claims until they officially leave the military. Additionally, by losing the EP code, we 

lose optics on this population at a critical point. 

Pre-discharge claims are treated differently when we review 

them, and we can find errors in up to 20 percent of them. If we 

cannot identify problems early, we are not setting the 

servicemember up for post-military success. 

To make matters worse, when VA receives a claim with fewer 

than 90 days, the servicemember now receives a letter that implies 

that they did something wrong and that VA did not accept their 

claim. Since this change went into effect, all of our pre-discharge 

reps on military installations have heard from clients who received 

this letter and believe that something went wrong. 

Many have confidence that we can resolve the issues, but for 

those who believe that the VFW did something wrong, we have lost 

our ability to advocate. At best, these letters are unnecessary. At 

worst, they are tone deaf and viewed as irresponsible. 

The solutions are simple. First, stop the disqualification letters. 

Second, reinstate an EP code for pre-discharge claims filed with 

fewer than 90 days. And, third, address the ambiguity and code reLeonard.horne on VACREP0180 with DISTILLER

11 

garding VA’s authority to accept these claims. In Title 10 and Title 

38, nothing explicitly directs VA to accept them. Instead, the authority is inferred through the statutes of authorizing TAP and VA 

compensation generally. We should clarify this. 

Finally, the VFW worries that these changes are the latest in a 

series of changes that obfuscate VA’s pending workload , but not 

all pending work is bad for the veteran. While VA does not get a 

pass on drawing out certain processes, some pending work is legitimate. 

If we set reasonable expectations and explain the process, veterans will have positive experiences. But this also means we can’t 

seek out headlines every time VA reports that something took more 

than 125 days. It is time to have a reasonable discussion about 

workload and what it really means to the veteran’s experience. 

The military to civilian transition can be unknown and unpredictable. All of us in the room have dedicated substantial time and 

resources to make sure we get it right. The VFW values the role 

that we play alongside VA and DoD, and we are always looking for 

ways to improve. Our goal is to work together to ensure that our 

transitioning servicemembers have access to the benefits they have 

earned. 

Mr. Chairman, this concludes my testimony, and I am happy to 

answer any questions you or the Subcommittee may have. Thank 

you. 

[THE PREPARED STATEMENT OF RYAN M. GALLUCCI APPEARS IN

THE APPENDIX]

Mr. BOST. Thank you, Mr. Gallucci. Thank you. We are going to 

go on now with questioning. I will recognize myself for five minutes. 

Mr. Avila, you stated that the agreement and the spirit of IDES 

is so DoD stays out of the rating business and leaves part of the 

process—that part of the process to the VA. Can you explain why 

the American Legion recommends that the VA rather than DoD 

conduct the needed periodic exams, and assigns any—just a 

minute, let me get this right—and then assign any revised rating 

for veterans who have already been placed on TDRL? 

Mr. AVILA. The American Legion—sorry. The American Legion 

does not feel that DoD is doing this on purpose or is doing it to 

low-ball the military member when giving them a rating. And we 

understand that ratings can change. Maybe they were given 60 

percent, in the sample that I used, and it’s now maybe a lower, or 

maybe even a higher rating if the condition has gotten worse. 

But I think if we are trying to get it—if the goal is to get an accurate reading of what the current condition is today, I think the 

conversation needs to happen between DoD and VA. Specifically, if 

the member is now receiving the health care through the VA, I 

think VA can paint a complete picture to DoD by saying this is the 

current condition, this is his latest appointment, this is the current 

medication, or what has been the action plan. 

And I think once the VA has that—I mean, once DoD has a complete picture, then they can make perhaps a better decision than 

just bringing the member in and doing a one-time compensation 

and pension examination, for lack of a better word, and then basLeonard.horne on VACREP0180 with DISTILLER

12 

ing a rating off that one decision. Going forward, like I mentioned 

in my testimony, let’s use one rating. 

If we start changing ratings and we have different ratings between DoD, then we are going back to the old system, and that was 

kind of the change of IDES that we would have one rating decision 

and the only rating decision would be used by both DoD and VA. 

I do not think we want to head back down that road. 

Mr. BOST. Mr. Clark, why doesn’t the VA conduct the follow up 

exams and ratings when a veteran is placed on TDRL? 

Mr. CLARK. Chairman Bost, we would have to work with DoD to 

change the process. But as it currently stands, then that is a DoD 

responsibility for the temporary, and even permanent due to retirement list. But I am in agreement, and certainly we would have to 

work with our DoD partners that VA can take that responsibility 

on and provide this one rating. 

But as Mr. Avila just mentioned, as it presently stands, that is 

a DoD responsibility. But we are certainly open to making that 

happen, and I feel that we can make that happen. But we will have 

to speak to that. And Dr. Adirim— 

Mr. BOST. Dr. Adirim, does DoD agree with that? 

Dr. ADIRIM. Whenever there is a—in general, when there is a VA 

rating, and we have access to that, and we have found about, at 

least Army, about 70 percent of the time has access to that rating, 

we do use that exam. But we are happy to work with our VA colleagues to see where we can make improvements. 

Mr. BOST. Thank you. Ms. Murphy, I am going to ask some real 

quick things here. Quick Start was eliminated, and then BDD was 

changed around and tried to revamp. What were the reasons for 

the changes— 

Ms. MURPHY. Certainly. 

Mr. BOST [continued]. —and getting rid of quick Start? 

Ms. MURPHY. Good morning. Thank you. So we are always looking to improve, and streamline, and modernize in our processes 

with DoD, within VA, to best help our transitioning 

servicemembers and our veterans. I heard some of the comments, 

and certainly your concerns are our concerns as well for our 

servicemembers and our veterans about giving them the head start 

on their disability claim before they leave service for tailoring the 

process to them. And I think we have maintained that in our new 

redesign of the pre-discharge program. 

In BDD, now instead of 60 days prior to dis-charge, we have 

moved that back 90 to 120 days. I think we are doing a better job 

through our TAP program to get the word out to transitioning 

servicemembers about what is available to them through VA. And 

we are getting them educated, if you will. 

So giving us a little bit more time prior to discharge to get all 

the records together, to get the exams done, it is—we see it as better service to them in that time. We did not want to leave a gap, 

in fact, for some time we considered just completely eliminating 

Quick Start and not replacing it with anything, and just saying we 

will meet you on the other side of discharge and we will work with 

your claim there. 

We had some feedback from our VSO partners. They were very 

adamant about working with the servicemember while they were 

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13 

still on active duty. So we went back to the table, we thought about 

it, and we decided we would go ahead and open up some of our 

other options—traditional claim process, fully developed claim process, and our brand new decision ready claim process—that 

transitioning members can have that available now tailored to 

them, and they get to be in the driver’s seat. 

They decide when it is best for them to get the exam, they work 

with a service officer if that is helpful to them. Quick Start was not 

quick, and with decision ready claims, we are seeing an early result 

of about eight days after— 

Mr. BOST. Okay. I have one quick question, my time is about out, 

too. But this is for Ms. Murray. Was VA having difficult—why was 

VA having difficulty scheduling and completing the medical exams 

before? What are some reasons that were in there? 

Ms. MURRAY. Can you repeat the question, please? 

Mr. BOST. Yeah. Why were we having trouble scheduling these 

exams? You know, there was a problem with scheduling, correct? 

What were some of the reasons that the scheduling problems were 

occurring? 

Ms. MURRAY. I think in terms of scheduling in VHA, we initially 

had a contract that we were using for surge capacity. And so we 

had examiners that we could tap into under contract. But then the 

contract was removed from VHA, and so we are now limited to our 

internal capacity. And so we did have a challenge with being able 

to surge outside of VA, and so we are limited to our in-house capacity. And so now we are sharing that overflow of capacity with the 

VBA contract. So we had to shift to a different way of scheduling. 

Mr. BOST. Okay. Thank you. Ms. Esty, you are recognized for five 

minutes. 

Ms. ESTY. Thank you very much. Dr. Adirim, I wanted to ask— 

drill down a little bit more on the Guard and Reservists, because 

we are getting feedback about difficulty with records. So, for example, they are often in a rush to try to get their records updated. 

Now this is done much better with active duty. As soon as the Reservists come back, everybody, everybody disperses. Those records 

do not get updated, and that then poses huge problems. 

That is the kind of thing we get calls in our office all the time. 

I can’t find my records, nobody updated them. I will tell you here 

is where I was, this happened, and there is no records available to 

us. As part of this process, I think we need to make sure that that 

is being dealt with. So I would like you to start, and anyone else 

who has—it is not directly on this, but this is literally we do not 

get the medical records updated, and that causes enormous problems down the line because you can’t get accurate evaluation if the 

records are not present at the time that they are transitioning 

back. 

Dr. ADIRIM. All right. Well, thank you for bringing up this issue. 

It is a struggle because when you are in active duty the records are 

there, it is a central, you know, health record and so it is easy to 

access. With the Guard and Reserves, their care could be, you 

know, outside of the military system which makes it a struggle. 

And as a physician, I know this struggle in getting records for my 

patients. 

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14 

So I think this is something that we would like to take back, and 

we would like to look at, and determine what we can do to help 

our Guard and Reserve access their records quicker. Whatever that 

we need to do to help them with that. And we can get back to you 

on that. 

Ms. ESTY. Thank you, because I think that is important as part 

of this process, and, again, as we are relying so much on Guard 

and Reserve. This is not occasional, these are our seasoned fighters 

at this point, and they deserve to have those records updated. And, 

again, I hope we can schedule to have a hearing in a few months’ 

time so that we can put our heads together and find out what 

needs to happen to get this fixed. And— 

Dr. ADIRIM. I agree. And thank you for bringing up the issue. 

Ms. ESTY. Thank you. We had discussed earlier some of the challenges, earlier in my office, some of the challenges we are looking 

at. Can you talk about what is being done with outreach for populations who do not seem to be connected, who we know, based on 

other surveys and other data, are more at risk for not getting employment? Suffering from PTSD, becoming homeless. What are you 

doing to use technology and to use every resource available to improve outreach at that transition point? 

Mr. CLARK. I will start, and then Ms. Murphy, or Ms. Murray, 

and even Dr. Adirim may join. As we discussed, that is an opportunity for improvement. We have a TAP program that I am working with DoD. We are attempting to get that word out sooner and 

to more people. We have a division in VBA benefits services led by 

Margarita Devlin that is in charge of TAP, to get that information 

out. 

And as our MSCs and our other members of the regional offices 

go on and engage with the military members before they get out, 

we provide information on VA benefits. But we need to do a better 

job because one servicemember that does not get the word is one 

servicemember too many. 

So we have ways that we get out using TAP, but we have to do 

a better job, and then we have to reinforce it because a one and 

done won’t get it. Often times you have members that they are at 

a point in their lives that they are transitioning, they are thinking 

about a lot of things, and even when they get the briefing, it may 

not be a point in time that they are ready to receive that. 

So we need to do a better job of going back and telling them 

again, and yet again, until they get that. And that is an opportunity for improvement that we need to do, and we have taken that 

and embraced that. 

Ms. ESTY. Well, I hope you will come back to us maybe when we 

reconvene in a couple months’ time with specific things. Are there 

resources you need to do that? I think ensuring that we get Internet, you know, appropriate email that is good for every single departing servicemember is one key thing. And then you can actually 

code them and do outreach, at least online outreach, at two months 

out, six months out when people might be more ready, more aware 

of the challenges they are facing, and we can target that a lot better. 

So I think we have to be using technology, we have to be capturing all pieces of information as we can when they are making 

Leonard.horne on VACREP0180 with DISTILLER

15 

that transition so it does not get lost, and they do not get lost. And 

that is, again, I know all of you are committed to that, but we have 

to do better, and I do think we need to use technology as well to 

capture who these folks are so that we have a way systematically 

when they move around the country to be able to reach back out 

and make sure they are connected. 

I am over time. Thank you, and I yield back. 

Mr. BOST. Thank you. Mr. Banks, you are recognized for five 

minutes. 

Mr. BANKS. Thank you, Mr. Chairman. Mr. Avila, to Ms. Esty’s 

point, the Ranking Member’s point. As a Navy Reserve Officer myself, I have seen first-hand the difficulties that Reservists and 

Guardsmen sometimes have in comparison with their active duty 

counterparts. In your testimony, you mentioned the American Legion’s concerns regarding the lack of resources for members of the 

National Guard and Reserves who are undergoing the IDES process in their home station. 

I know we have heard some others on the panel about their perspective, but could you elaborate on the American Legion’s perspective on that point? 

Mr. AVILA. As Chairman Bost mentioned going out to Walter 

Reed earlier, and I think if you go there you see the resources that 

are available in-house to everybody. You have JAG, social work, 

your medical appointments are there. There is a benefit to National 

Guard Reservists doing the medical process at their home station. 

They are home, they are with the family, they are not separated. 

But I think the fear there is that they do not have the resources 

that their active duty counterparts have. So it is a double-edged 

sword. Do we send them somewhere as a TDY to make sure they 

do their IDES process at a consolidated location where the resources are there. So I think that is the biggest gap that we see. 

I receive emails from Guard members or Reservists going 

through the IDES process at their home station, and they are telling me, I just got my proposed ratings and my 199 back from DoD, 

and I need to make some elections. And my JAG lawyer is, you 

know, at the state capital, or something like that. So they do not 

have somebody readily available to go there. 

And I think that is where we see the biggest difference. And then 

whenever you talk about available resources that are there on 

hand to assist the member make the crucial decisions, they are always going to be crucial as they separate, and what are the benefits they are going to receive. 

Mr. BANKS. Thank you. Ms. Murphy, in place of Quick Start, the 

VA is allowing servicemembers who are within 90 days of discharge to begin preparing but not submit a fully developed claim, 

decision ready claim, or a traditional claim. If the servicemember 

has a character of discharge determination and has completed all 

requirements to develop their claim, why must this servicemember 

wait until after separation to file their claim with the VA? 

Ms. MURPHY. We can begin working on this and we track these 

things, but until you are a veteran, we can’t start paying you, until 

you are out of service. We do have some in-house tracking of end 

products and tracking those claims, but we are just working with 

you ahead of time. 

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As far as the decision ready claim, your formal claim is what 

really starts our clock. So a servicemember works with a veteran 

service officer, collects records, goes gets the exam. And then when 

it is time, submits that to us. And as I said earlier, we have been 

turning those around in about eight days. 

And I do want to clarify that that new program is not just available to transitioning servicemembers that is available to any veteran who wants to work with a VSO. Right now we are limited to 

claims for increase, but we have recently expanded just this week 

to additional new issues on claims that we have already seen. So 

if you want to add an issue, a secondary issue, maybe your back 

is hurting because of your knee, also presumptive claims. So we 

have expanded about 500 percent the eligible pool there. 

But to your point, we are working with them ahead of time, it 

is just that we are not processing the claim and paying the benefits 

until they are on the discharged side. 

Mr. BANKS. Okay. Thank you. 

Mr. GALLUCCI. Mr. Banks, I would like to comment on that, if 

I could, for just a couple of minutes because this is— 

Mr. BANKS. No, I do not have a couple of minutes. 

Mr. GALLUCCI. Okay. Well— 

Mr. BANKS. Let me move onto my next— 

Mr. GALLUCCI. About just— 

Mr. BANKS. Excuse me. Mr. Avila, and Mr. Gallucci, to get to you 

on another point. Do you think that the fully developed claim program and decision ready claim program will meet the needs of separating servicemembers who are unable to file a BDD claim, to 

that point? 

Mr. GALLUCCI. I am glad you asked that, because that is what 

I was about to talk about. 

Mr. BANKS. All right. 

Mr. GALLUCCI. So, no. Unequivocally, no. From the VFW’s perspective, we have not had positive experiences with the decision 

ready claims process. I would say about 60/30 negative—or 70/30 

negative to positive experiences. What we are talking about here 

is that control over the exam, the official submission date. There 

is no product on the VA side. We are requesting exams, a veteran 

may conduct an exam— 

Mr. BANKS. I have five seconds. Mr. Avila, do you agree with 

that? 

Mr. AVILA. I think from part of my testimony, we have seen some 

positive experience. We are seeing the claims completed prior to 

the discharge date. Obviously, it is early on, and we got to keep an 

eye on it. 

Mr. BANKS. Okay. Thanks. My time is expired. 

Mr. BOST. Ms. Brownley. 

Ms. BROWNLEY. Thank you, Mr. Chairman. I have two quick 

questions. One to the VA. If you could speak to the issue that VFW 

raised with regards to letters that the servicemembers are receiving saying that veterans are disqualified from BDD. I think what 

is happening is they are receiving those letters and thinking, well, 

I am not eligible for any kind of benefit. But you are saying that 

they are not eligible right now but they will be later. But that is— 

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17 

the letter, they way it is written, is I think creates a lot of misunderstanding. 

Mr. CLARK. Well, we will have to take that back, and certainly 

in working in concert with the VSOs to make sure that we are 

clear when we send that letter what that is about. So, obviously, 

we have to work closer with them to make sure that between the 

two of us, you know, we have got military service coordinators out 

there, we have got outreach specialists in the field that go out to 

military bases to let folks know that, hey, we have got these programs. The combined program just started on 1 October, so we 

have not gone the full 90 days. 

But as the testimony was shown by American Legion, we are 

finding that it is successful, and we need to do better. And, obviously, we need to get more information out there and let folks 

know. But we think it is a good program. 

Ms. BROWNLEY. So does VFW, would you like to respond? 

Mr. GALLUCCI. Thank you, Ms. Brownley, absolutely. Based on 

the volume that we see, we anticipate significant challenges, especially in tracking how we serve that population who does not meet 

that 90-day deadline. I respectfully have to disagree with the Legion’s perspective on this. 

The VFW processed more than 15,000 pre-discharge claims last 

year, and in reviewing our pending workload, it has gone down. I 

was out at the San Diego VA Regional Office, where we have a rating review team, just last week, and they have all but processed 

all of their Quick Start claims. 

Whether they are processed as DRC, FDC, or a traditional claim, 

we do not know that it is a transitioning servicemember anymore. 

To us that is problematic from a quality control standpoint to 

evaluate the efficacy of these programs as we have discussed in detail today. 

Ms. BROWNLEY. Thank you. And, hopefully, we can follow up on 

this and improve upon that process. So the other question I wanted 

to ask is, you know, I want to commend everybody for improvement 

of timeliness. This is good, we seem to be moving in the right direction. I am sort of interested in the spirit of, I guess, transparency 

and really pealing the onion to have a good look at everything that 

is going on. 

What about, you know, are there cases where they are sort of 

outliers to the averages of the data? And so I would appreciate candidness with an answer. And, you know, if there is, you know, 

what are we doing to identify those issues and barriers, and how 

to improve upon the process for where there are, indeed, outliers? 

Mr. CLARK. You know, with the IDES process, and I can let the 

Doctor speak to that. But overall, you know, we have said that 

there is an average processing time, well less than 100 days for all 

claims in VA. Certainly IDES and BDD processes it shorter still, 

but that is an average. So we do have scenarios where it will take 

a little longer. 

Sometimes there are issues that are added later in the process, 

there are attempts if they are Guard and Reserve trying to get the 

records. But we have identified those and we continue to work and 

collaborate on ways to make sure that we get all of the records, 

and that we just be mindful that we have got the need from DoD 

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18 

to transition as quickly as possible while also trying to understand 

that we are dealing with members that are unsure about their future and where they are going, and we need to be compassionate 

in our approach and worry about them whether than our processes. 

Ms. BROWNLEY. So you said two things. You said, all claims are 

under a hundred and some days. And then you said, but we are 

dealing with averages. So those are two very different things. An 

average is an average, and, you know, there are highs and lows, 

and all means all. So, anyway, Doctor, do you have any comments? 

Dr. ADIRIM. No, I would just add, thank you for that question. 

And, certainly, with any process there are going to be outliers, and 

those are cases that are more complicated. And we do monitor 

those cases, and we look into what the issues are to see where we 

can address those issues. But I would caution you that we want to 

make sure that every servicemember, you know, gets all due consideration. So if there are problems where we can expedite those 

cases, we do do that. But then there are cases where, you know, 

time is helpful to that servicemember. So thank you for brining 

that up. 

Ms. BROWNLEY. Well, and I appreciate that answer. I, you know, 

in those more complicated cases I think, you know, the expectation 

is that we are hanging in there with the veteran, and communicating and standing by them shoulder to shoulder because, you 

know, both the veteran and their family, obviously, are going to be 

very, very concerned in those more complicated processes. 

Dr. ADIRIM. Right. Good point. Thank you. 

Ms. BROWNLEY. Yes. Thank you. I yield back. 

Mr. BOST. Mr. Coffman. 

Mr. COFFMAN. Thank you, Mr. Chairman. Dr. Adirim, what conditions does the Department of Defense require somebody who has 

an injury to be on a medical hold status subject to treatment? If 

somebody says that I have a physical injury, I have some type of 

stress related condition, is there ever a situation where that individual is put on medical hold, and that is subject to treatment, and 

that discharge is delayed? 

Dr. ADIRIM. I am not certain I quite understand the question. Do 

you mean that the servicemember is put on TDRL, or? 

Mr. COFFMAN. I do not know what TDRL is. A medical hold 

being that their discharge is suspended pending some sort of treatment, medical treatment. 

Dr. ADIRIM. I think what you are talking about is the TDRL. 

That when a servicemember has a condition under which they, you 

know, may have a condition where they will—where it is anticipated that they will eventually need to be put through the disability evaluation system. However, they will undergo treatment, 

and then a determination is made subsequently whether or not 

they can return to service versus being put through the disability 

evaluation system. That is what you are talking about, right? 

Mr. COFFMAN. Yes. 

Dr. ADIRIM. Okay. Good. And so your question is, what conditions? 

Mr. COFFMAN. Well, how often does that occur, and under what 

conditions? 

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Dr. ADIRIM. We have—I believe we have—I can get back to you 

on that because I know the number but it is not coming to me right 

now, of servicemembers who are on that particular list. And the 

conditions would include any condition for which they are currently 

undergoing treatment which it is anticipated that they may improve but, you know, and they are reassessed at 18 months. So I 

am not sure if I answered the question. 

Mr. COFFMAN. Well, if they are going through the disability process, and they are claiming something that the Department of Defense, the health system, could rehabilitate, you know, through surgery, through treatment, or through any process. What is the connection between our DoD health care system and that claims process relative to that issue? 

Dr. ADIRIM. Sure. Well, there are multiple different steps, and I 

just want to make sure I understand clearly what you are asking. 

If there is—a servicemember has a condition or an injury to which 

they need treatment, they would be put on a profile or limited 

duty, that would be the first step. If it is determined that it is likely that they will not be able to serve but they are still undergoing 

treatment, they would be put on the Temporary, TDRL— 

Mr. GALLUCCI. Temporary Disability. 

Dr. ADIRIM [continued]. —Disability, right. They may be put on 

that particular status, and they would undergo their treatment, 

and then at 18 months they would have another exam to determine 

whether or not they would need to be separated versus—undergo 

the disability system and separated versus going back to service. 

Mr. COFFMAN. Okay. So we have 20 veterans committing suicide 

on a daily basis in the United States. I would suspect a fair 

amount are going through the process, let’s say it is post-traumatic 

stress— 

Dr. ADIRIM. Sure. 

Mr. COFFMAN [continued]. —or depression, or whatever. So my 

concern is what type of treatment are they then receiving before 

the discharge, and what connection do they have with the VA for 

an automatic hand-off to continue that treatment? 

Dr. ADIRIM. Thank you for that question. Now I understand what 

you are asking. Suicide and mental health conditions is a top priority of both DoD and the VA. We have a program in DoD called 

In Transition, which provides a warm hand-off for a servicemember 

to their care when they are out of the service. 

So a coach calls any servicemember that has had any mental 

health visits within that past year, or has been diagnosed with a 

mental health condition over that past year, and the 

servicemember’s able to opt in. So all are called who have a mental 

health condition. 

And those that opt in get coaching and are provided with information about care that they may receive, and there is a warm 

hand-off, for example, to the VA. So we do have a program to do 

that for people who have mental health conditions. 

Mr. COFFMAN. Okay. And I think that in Congress—and I can’t 

remember if it is this Committee or armed services—I think passed 

a provision in the last couple years that provided a physical for 

Guard and Reserve prior to their retirement. Am I correct in that? 

Dr. ADIRIM. I believe that is true, yes. 

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Mr. COFFMAN. Okay. I yield back. 

Mr. BOST. All right. With that, I would like to recognize the 

Ranking Member for any closing remarks you might have. 

Ms. ESTY. Thank you very much, I really appreciate your joining 

us here today. And there are a couple of issues that sort of came 

up in the course of our discussion today that I wanted to flag for 

you and have you think about. 

One is to facilitate transition, and this, frankly, has to do with 

other hearings we have had here. It seems to me that getting accurate email address is unbelievably important to stay in touch with 

our veterans, particularly in this transition time. 

They are much more likely to keep their email address and be 

findable that way than when we know from past experience, they 

are moving around, they are not sure where they are going to be 

living. That leads to a whole host of problems. We are not able to 

find them, we have had all those issues about service of process 

and receiving notice. It seems to me vital that we figure out a way 

to capture, as best we can, their email addresses. 

And I understand there has been some question about whether 

that can or should be asked as part of the DD–214. But I would 

like you to consider what we can do to ensure that we have our 

best possible, not only physical presence mail address which we ask 

for, but that is a legacy. The reality is right now a cell phone number and—that you could send text to, which we know to, in fact, 

be very effective. 

In a lot of the mental health issues, being able to text is actually 

vitally important. So I would ask you to consider the utility of having email addresses and cell phone numbers to facilitate interacting with and not, frankly, losing our veterans. So that is one, 

and where can we do that? 

And the other is, in my discussion with folks on my team, is to 

ask you, too, what kind of outreach is being done by the VA at that 

transition time to advise people of what state benefits might be 

available? Some of the states have very extensive programs, some 

do not. And it would seem to me, as part of our one-stop shopping, 

that we should be looking at that issue of what we can do. 

And there, again, having email addresses then allows us, as people are moving around, to say, say in a check-in, two months out, 

six months out, to say where are you currently living, and, if so, 

you should be aware, here are at least links to your state programs 

that you should explore. And we could, I think—again, using technology, we could do a much better job. 

So I would like, when we next convene, to look at both of those 

pieces as to how we do a better job. And it is just, frankly, 

leveraging the resources. States who have very good programs and 

are devoted, we should be utilizing and making those available to 

our veterans and not waiting for them to try to find them, or requiring our VSOs to try to find the veterans we have lost track of. 

So this is, again, in part of a spirit in doing a better job, connecting better with our veterans, faster, and better, and not losing 

one single one of them. So, again, thank you all very much. Thank 

you, Mr. Chairman. 

Mr. BOST. Thank you. And the only thing I would add is, obviously, from the conversation that we had today, you will be workLeonard.horne on VACREP0180 with DISTILLER

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ing with the VSOs on trying to—notification letter, try to correct 

that. So thank you. I want to thank all the witnesses for being 

here. 

And as I said at the beginning of the hearing, the complete written statements of today’s witnesses will be entered into the hearing 

record. 

Hearing no objection, so ordered. 

I also ask unanimous consent that all Members have 5 legislative 

days to revise and extend their remarks, and include extraneous 

material. 

Hearing no objection, so ordered. 

This hearing is now adjourned. 

[Whereupon, at 11:04 a.m., the Subcommittee was adjourned.] 

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(22) 

A P P E N D I X 

Prepared Statement of Dr. Terry A. Adirim 

REGARDING 

THE INTEGRATED DISABILITY EVALUATION SYSTEM 

Opening Remarks 

Chairman Bost, Ranking Member Esty, distinguished Members of the Subcommittee, thank you for the opportunity to appear before you today to discuss the 

Integrated Disability Evaluation System, also known as the IDES. 

The IDES is a joint Department of Defense (DoD) and Department of Veterans 

Affairs (VA) program that achieves two primary DoD objectives: (1) ensuring the 

readiness of our military forces, and (2) providing timely, quality disability evaluation of wounded, ill, or injured Service members so we can assess their fitness-forduty and, if unfit, the appropriate disability disposition and compensation. 

Improved IDES Performance 

The IDES is a success story that reflects the two Departments’ shared commitment to collaboratively improve the evaluation of Service members transitioning to 

Veteran status due to disability. Since DoD’s last appearance before this Subcommittee to discuss the IDES, the Department has continued to improve the efficiency and quality of the disability evaluation process. 

Since 2014, improved processing of nearly 22,000 physically unfit Service members per year has allowed the Military Departments to significantly reduce the 

amount of time Service members spend in a permanent non-deployable status and 

direct their resources towards accessing, training, and equipping ≥≥≥physically 

ready forces. 

The IDES also provides improved case management and transparency for Service 

members undergoing evaluation due to disability. Within the IDES, there is a single 

point of contact for providing information to the Service member or their representative, as applicable, about the DES process. The IDES also provides a more transparent disability evaluation process by allowing Service members to receive their 

proposed VA disability ratings and compensation at the same time they receive their 

DoD physically unfit determination. This allows the member to make an informed 

decision about the best course of action, which is a great help to Service members 

who have their military career unexpectedly ended by a disabling condition. 

Today, Active Component (AC) IDES cases average 258 days from the date of referral to notification of VA disability benefits, well within the 295-day goal. This 

represents a 23 percent improvement since Fiscal Year (FY) 2014 and an overall 52 

percent improvement over the 540 days Service members averaged to complete the 

Departments’ separate disability processes prior to the worldwide implementation of 

the IDES. Similarly, Reserve Component (RC) IDES cases achieved a 22 percent 

timeliness improvement since FY 2014. 

DoD is responsible for four core IDES process steps: Referral, Medical Evaluation 

Board, Physical Evaluation Board, and Transition. We are outperforming the DoD 

core process stage goals required by DoD policy. For example, in October 2017, DoD 

Core Stage performance for AC disability evaluation was 104 days against a 105- 

day goal, while RC disability evaluation was 88 days against a 125-day goal. 

Although exceeding IDES performance goals, DoD is analyzing opportunities to 

reduce these goals to improve the readiness of our military forces and allow Service 

members to more quickly transition to veteran status. 

Improved IDES Efficiency 

In 2014, DoD consolidated and revised its disability evaluation issuances to provide clear policy guidance on Military Department operation of their respective DES 

processes. To accomplish this goal, DoD combined thirteen previous disability evaluation issuances and directive-type memoranda. A revised DoD Instruction, supLeonard.horne on VACREP0180 with DISTILLER

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ported by specific topics presented in three DoD Manuals, addresses each aspect of 

the disability evaluation system and set requirements for each Military Department’s execution of disability evaluation activities. This effort was the first attempt 

to establish a DoD-wide group of consolidated disability evaluation policy and procedure issuances since the 1996 publication of a legacy DES directive and instruction. 

As a result, the Military Departments now operate with a much-improved, well-defined set of policy and process documents. 

As directed by Congress in the FY2013 National Defense Authorization Act, the 

Department implemented the DES Quality Assurance Program (QAP) in 2014. The 

DES QAP enables DoD to evaluate the accuracy and consistency of Military Department disability determinations, the degree to which Military Departments comply 

with DoD policy in their disability determinations, and the duty performance of 

Medical and Physical Evaluation Boards and Physical Evaluation Board Liaison Officers. DoD requires a minimum 80 percent score for quality assurance measures, 

and uses case reviews to help assess and monitor Military Departments’ DES performance in those areas. DES QAP scores for FY 2017 reflect an accuracy rate of 

94 percent, a consistency rate of 77 percent, and 80 percent for duty performance. 

Consistency scores fell under the 80% goal in FY 2017 due to a purposeful effort 

to increase the complexity of test case themes used to evaluate Military Departments’ consistent application of DoD policy. DoD increased the number of conditions 

for each test case, as well as the complexity of conditions presented. This added 

rigor in DoD’s evaluation methodology identifies deficient areas so that the Military 

Departments ensure equitable and consistent application of DoD policy. 

Training remains vital to the continued success of the IDES. DoD issued, in collaboration with the Military Departments, training standards and performance objectives (TSPOs) to ensure all IDES staff are prepared to provide Service members 

with the critical assistance on which they depend. Collectively, these efforts ensure 

that disability evaluation personnel are prepared to provide final adjudicative decisions accurately and in compliance with law and DoD policy. 

Service Member Satisfaction 

DoD remains committed to continuously evaluating the IDES to enhance the experience of wounded, ill, and injured Service members as they undergo this process. 

Constant oversight is critical to identify needed IDES improvements, monitor implementation, and measure Military Department performance. As such, DoD surveys 

Service members at the end of both the Medical Evaluation Board and Physical 

Evaluation Board phases of the IDES process, assessing their satisfaction with DoD 

and VA personnel and their overall IDES experience. Survey results taken from 

over 9,000 Service members from April to September 2017 indicate 93 percent of 

Service members were satisfied with their IDES experience. DoD will continue to 

utilize survey information and data to identify improvements. 

Conclusion 

DoD is committed to the IDES process and identifying potential improvements to 

the program. Moving forward, we will maintain our close collaboration with the VA 

to meet our shared goals of providing quality and timely integrated disability evaluations of America’s wounded, ill, and injured Service members. 

Mr. Chairman, Ranking Member Esty, and distinguished members of the subcommittee, I thank you for your unwavering support of the brave men and women 

that serve our nation, and your dedication to ensuring we have the most efficient 

systems in place to meet their evaluation and transition needs. 

f 

Prepared Statement of Willie C. Clark, Sr. 

Good morning Chairman Bost, Ranking Member Esty, and Members of the Subcommittee. My name is Willie Clark, Deputy Under Secretary for Field Operations, 

in the Veterans Benefits Administration (VBA). I am joined by Beth Murphy, Director of VBA’s Compensation Service, and Patricia Murray, Chief Officer, Office of 

Disability and Medical Assessment, Veterans Health Administration (VHA). I appreciate the opportunity to discuss several of VBA’s pre-discharge programs for 

Servicemembers, including the Integrated Disability Evaluation System (IDES) and 

Benefits Delivery at Discharge (BDD). My testimony will also cover improvements 

to the IDES and BDD programs; Servicemember satisfaction with IDES; and training for employees involved in IDES and BDD claims. 

Integrated Disability Evaluation System (IDES) 

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On November 28, 2017, the Department of Veterans Affairs (VA) and the Department of Defense (DoD) will celebrate the 10th Anniversary of IDES. In 2007, VA 

and DoD created an integrated disability evaluation process for Servicemembers 

who are being medically retired or separated from service. This joint process was 

designed to eliminate the duplicative, time-consuming, and often confusing elements 

of the separate and consecutive disability processes within VA and DoD. In fiscal 

year (FY) 2017, more than 22,000 Servicemembers were enrolled in the IDES program. 

IDES provides a single set of disability examinations and a single-source disability rating that are used by both departments in executing their respective responsibilities - eliminating the duplicate medical examination and rating determinations within DoD and within VA processes. The joint VA and DoD partnership 

through IDES has resulted in more consistent disability ratings, faster decisions, 

and more timely delivery of benefits for those personnel being medically retired or 

separated. Following discharge, VA can deliver disability compensation benefits in 

the shortest period allowed by law, thus reducing the ‘‘benefit gap’’ that previously 

existed under the legacy process. The integration of VBA’s Military Service Coordinators (MSCs), disability examinations, and proposed disability ratings into the 

IDES process prior to separation ensures Servicemembers no longer have to navigate the VA disability compensation system on their own to apply for VA benefits. 

As a result of our collaborative efforts, VA and DoD have met the six goals established for IDES. These goals are (1) develop a single set of medical exams used by 

VA and DoD for disability rating; (2) eliminate the benefits delivery gap from separation to receipt of VA benefits; (3) increase transparency and consistency of the disability evaluations for Servicemembers; (4) reduce the combined processing time; (5) 

develop a less complex and non-adversarial process; and (6) provide a seamless transition of benefits and health care for separating Servicemembers through IDES. 

VA is responsible for four core IDES process steps: claim development, medical 

examination, proposed rating, and benefit notification. For the combined four core 

steps, VA’s average processing time in September 2017 was 81 days, a 102-day improvement from the last time we testified on the IDES program in May 2014, and 

19 days better than the VA target of 100 days. In addition, VBA awarded benefits 

within an average of 26 days of discharge, under our IDES timeliness goal of 30 

days. 

DoD provides Servicemembers with IDES customer service satisfaction surveys 

when they separate. DoD publishes the results on a semi-annual basis, which includes VBA MSC customer satisfaction. At the end of June 2017, customer satisfaction with the overall IDES program was 93 percent and with MSCs was 89 percent. 

VA continues to collaborate with DoD on ways to improve IDES execution, while 

remaining focused on meeting timeliness standards. Our continued partnership with 

DoD is critical. VA and DoD are committed to supporting our Nation’s wounded, ill, 

and injured Servicemembers through the IDES process. 

Benefits Delivery at Discharge (BDD) 

Since 1995 when the BDD pilot started, the BDD and Quick Start programs have 

provided transitional assistance to separating or retiring Servicemembers and engaged Servicemembers in the claims process prior to discharge. VBA’s goal is to ensure that each Servicemember separating from active duty and who wishes to file 

a claim with VA for service-connected disability benefits receives the upfront and 

timely assistance in doing so. Just as IDES provides Servicemembers, who are facing medical discharge, with the opportunity to initiate a claim for disability compensation benefits, the program has also provided this opportunity to 

Servicemembers who are transitioning via traditional or ‘‘non-medical’’ separation. 

In FY 2017, VBA significantly improved BDD production and timeliness, completing over 32,000 claims in an average of 90 days, compared to approximately 

29,000 claims in 127 days in FY 2016. VBA also completed over 25,000 Quick Start 

claims in an average of 109 days in FY 2017. 

VA is dedicated to ensuring that Veterans get the benefits they have earned and 

deserve as quickly and accurately as possible. As a result, VA has redesigned its 

pre-discharge program to enable Servicemembers to receive disability benefit decisions, in most cases, the day after their discharge. The redesigned program went 

into effect October 1, 2017. Since then, pre-discharge claims are distributed through 

the National Work Queue to all VBA regional offices. Prior to this change the claims 

were distributed only to the rating activity sites that were processing these types 

of claims. The new modifications to the existing BDD program include changing the 

filing deadline to 90 days, rather than 60 days, in order to enable VBA to schedule 

and complete all of the medical examinations that are necessary to prepare the disability compensation claim decision prior to the Servicemember’s discharge from 

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military service. As part of the redesign, VBA discontinued the Quick Start program 

and instead will fill the gap by utilizing the new Decision Ready Claim program in 

addition to the Fully Developed Claim or traditional claim processes as appropriate 

after separation. We continue to work in concert with our Veterans Service Organization (VSO) partners on the pre-discharge program. VSOs regularly collaborate 

with our MSCs on various military bases, in order to facilitate Servicemembers’ initial claims submission. 

Training 

VBA provides substantial training for all employees involved in the processing of 

claims, including pre-discharge claims. VBA’s Challenge Training program provides 

the basic technical skills to process claims in a blended learning format that includes both classroom and practical application. Ongoing technical training is also 

required each year. 

In September 2017, BDD redesign training was provided to MSCs, and VBA plans 

to conduct a comprehensive MSC training event in FY 2018. In October 2017, VBA 

conducted focused training on the new redesigned BDD program for claims processors. 

Conclusion 

VA remains committed to supporting our Nation’s Servicemembers through improvements in pre-discharge programs. VA believes its continued enhancements are 

critical to program success in delivering the benefits and services our 

Servicemembers and future Veterans deserve. 

Mr. Chairman, this concludes my statement. We would be pleased to respond to 

questions you or other Members may have. 

f 

Prepared Statement of Gerardo Avila 

ON 

‘‘THE INTEGRATED DISABILITY EVALUATION SYSTEM (IDES) AND VA’S 

PRE–DISCHARGE PROGRAMS FOR SEPARATING SERVICEMEMBERS’’ 

December 13, 2017 

Chairman Bost, Ranking Member Esty and distinguished members of the Subcommittee on Disability Assistance and Memorial Affairs (DAMA); on behalf of the 

2 million members of The American Legion and National Commander Denise H. 

Rohan; The American Legion, the largest patriotic service organization for veterans 

serving every man and woman who has worn the uniform for this country, thank 

you for the opportunity to testify regarding The American Legion’s position on the 

‘‘Integrated Disability Evaluation System and VA’s pre-discharge programs for separating servicemembers’’. 

The goal of the Integrated Disability Evaluation System (IDES) since its inception 

in 2007 has been to streamline the medical separation process and create a seamless transition for wounded, ill, and injured servicemembers from the Department 

of Defense (DoD) to the Department of Veterans Affairs (VA). This seamless process 

would create a one-stop shop and encourage better coordination between DoD and 

VA. Key components would include reducing the overall time it takes a 

servicemember to complete the IDES process, a medical evaluation for receipt of VA 

benefits, utilizing a single examination process that meets the needs of both VA and 

DoD, and increasing transparency of both the DoD disability evaluation system and 

the VA claims process. 

Prior to the IDES program, the transfer of wounded, ill and injured 

servicemembers from DoD to VA was fragmented. This led to large gaps in medical 

care and VA disability compensation. These large gaps in coverage placed further 

stress on those servicemembers most at risk and at the crucial point of transitioning 

out of active duty service. It also hindered their ability to plan for their financial 

future due to their VA claims not being adjudicated for months and in some cases, 

years after their separation. In many instances it seemed that DoD and VA were 

using different sets of criteria to rate disabilities, all too often unfit conditions received a different set of ratings from DoD compared to VA. Servicemembers were 

confused by this new system, and many were unaware of their rights and how the 

process worked. 

As a response to fill the void, The American Legion works to assist 

servicemembers across the United States. Until recently, The American Legion assisted with the Medical Evaluation & Physical Evaluation Board (MEB/PEB) procLeonard.horne on VACREP0180 with DISTILLER

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ess at the Servicemember & Family Assistance Center (SFAC) at Joint Base LewisMcChord, WA. Additionally, the National staff offices in Washington D.C. supports 

surrounding region by assisting transitioning servicemembers at the Warrior Transition Units located at Walter Reed National Military Medical Center (WRNMMC), 

and Fort Belvoir, VA. The American Legion helps in reviewing the findings of the 

board, writing rebuttals, and answering questions on the IDES process. Also, The 

American Legion maintains service officer staff at the VA’s Benefits Delivery at Discharge (BDD) sites in Winston-Salem, NC and Salt Lake City, UT and have assisted 

veterans with over 500 BDD and Quick Start (QS) claims quarterly. The service officers also review exam results, as well as represent servicemembers in hearings 

when warranted. 

The American Legion continues to focus on the many challenges facing today’s 

transitioning servicemembers. The IDES program, while not perfect, has been helpful in reducing the number of days it takes to complete the medical board process, 

which has drastically reduced the gap from separation date to receipt of benefits. 

The American Legion supports the idea of having one compensation & pension 

(C&P) exam and rating decision with the results being accepted by both VA and 

DoD. 

While the above improvements have been made, The American Legion still has 

the following concerns: 

DoD Rating individuals placed on the Temporary Disability Retirement List 

(TDRL): 

Servicemembers found unfit to continue service for a condition that is not stable 

enough to assign a permanent rating will end up on TDRL. If the individual is retired and is transitioned out of service, they will be required to undergo periodic examinations by DoD to see if the condition has improved, worsened, or become stable 

enough to assign a permanent rating. The agreement and spirit of IDES is that DoD 

would stay out of the rating business and leave the decision to VA. The American 

Legion believes that DoD is violating the principles of IDES and should not be conducting ratings. The American Legion suggests that DoD communicate with VA and 

inquire if the individuals ratings have changed. By doing so, the one rating decision 

will be maintained. Additionally, the ability to add new conditions once a 

servicemember is enrolled in IDES can cause issues. Medical appointments and 

treatment do not stop once an individual is enrolled in IDES and the probability 

of receiving a new diagnosis is likely. The American Legion has represented individuals who were unable to add new conditions and told to file a claim with VA once 

they were separated. While the advice is true, the goal of IDES was to correctly rate 

an individual by both DoD and VA concurrently and prior to seperation. By allowing 

new conditions to be added, the servicemember will have a complete picture of their 

financial outlook and can concentrate on transitioning and not have to think about 

another VA claim. 

A lack of available resources by members of the National Guard and Reserves undergoing the IDES process at their home station: 

In the past, The American Legion has expressed concern about Line of Duty 

(LOD) investigations, lack of resources, and the accurate dissemination of information on the IDES process for this group of servicemembers. Unlike their active duty 

counterparts, LOD investigations are crucial to proving that the disability was incurred due to their service, without it, they will be separated with no retirement 

or severance. Attempting to undergo this endeavor at home is much more difficult 

compared to their active duty counterparts who are located at a military instillation 

where medical, legal services, and transition assistance are co-located. If feasible, 

members of the Reserves and National Guard should be recommended for assignment to a Warrior Transition Unit while enrolled in IDES. 

The American Legion would also like to see improvements in other areas as well, 

specifically, the pre-discharge program previously referred to as Benefits Delivery 

at Discharge (BDD) and Quick Start (QS) program. Under BDD, transitioning 

servicemembers could file their VA disability claim between 60–180 days from their 

separation dates and those under 60 days could file under the QS program. The goal 

of the program was to initiate the claim while the servicemember was still on active 

duty, with the goal of shortening the gap from separation to the benefits receipt 

date. BDD intended to have the claims completed within 60 days of discharge. According to our two BDD field service officers, this goal was never reached. Almost 

all BDD claims were taking an average of 6–12 months after discharge to be completed, with QS claims taking even longer earning the nickname ‘‘quick start, slow 

finish.’’ 

These statements are supported by the last audit conducted by the VA Office of 

the Inspector General (VAOIG) which conducted a review of the Quick Start program. VAOIG found delays remained and accuracy figures well below VA target 

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1 VAOIG Report 12–00177–138 ‘‘Audit of VA’s Quick Start Program’’ May 20, 2014 

2 Resolution No. 42: ‘‘Compensation Benefits Information Disseminated at all Transition and 

Access Points’’ 3 Resolution No. 32: ‘‘Enhancements to Integrated Disability Evaluation System Process’’ 

numbers. While VA was able to reduce the Average Days to Complete a Claim 

(ADTC) from 291 days in 2011 to 249 days in 2013 the accuracy of those claims remains below 70 percent. 1 The OIG found the lengthy ADTC rates were due to insufficient program controls in VA and recommended recurring program evaluations and 

increased training on processing QS claims. 

In 2017, the Veterans Benefits Administration (VBA) introduced new changes to 

the BDD program with the launch of the pre-discharge redesign. The major changes 

include doing away with the QS program and combining it with BDD. Timelines 

have also changed. Now servicemembers must file their claim between 90–180 days 

of their separation. VA will hold claims filed under the 90 day window and begin 

to work as a traditional or fully developed claims once the separation date is 

reached. The Salt Lake City Regional Office was selected as the pilot site for the 

program, and our representative has indicated that the recent changes have been 

positive thus far. They base their opinions on seeing more pre-discharge claims completed prior to discharge, previously BDD claims were rated after discharge. For example, a claim was completed on October 31st for someone with a discharge date 

of November 30th and another completed on October 17th with a discharge date of 

October 31st. Our representatives stated that this was not the case under the previous program and mentioned that the new program is good for veterans because 

they will receive their compensation right after discharge. 

The elimination of the QS program creates a serious concern for The American 

Legion in cases where VA is quicker to grant service-connection for conditions that 

are diagnosed while still in service, as opposed to being diagnosed even one day 

after. Servicemembers are at a greater risk of being delayed service-connection for 

medical conditions unless it’s a condition subject to presumptive service-connection 

under Code of Federal Regulations (CFR) paragraph 3.309. 

If this is the case, a veteran will have to gather supporting documentation to establish the nexus between the disability and their time in service to be granted 

service-connection for the condition. This could result in additional obstacles the veteran must overcome to receive their benefits. Another concern is the inability to add 

new conditions once under the 90-day window. New conditions claimed will not be 

accepted and written notification will be sent reminding the servicemember the 

need to file a new claim after separating. 

The American Legion has lent its voice and taken direct actions to ensure today’s 

transitioning servicemembers are fully supported and have all the information available to make sound decisions. We also support a more robust presence of veteran 

service organizations and other private stakeholders on the DoD side to ensure 

transitioning veterans have the support required. The American Legion has asked 

for better dissemination of information by both DoD and VA, as well as requesting 

to make the IDES system robust enough to assist veterans with Vocational Rehabilitation and Employment 2programs 3. Better support is needed for National Guard 

and Reserve members to ensure they do not fall behind their active duty counterparts. 

All of these challenges can be improved with better integration of stakeholders at 

all levels of the process. We cannot allow this severe disparity in access of medical 

support between the military and veteran communities. These men and women who 

deserve these earned services must not continue to struggle unnecessarily. 

As always, The American Legion thanks this subcommittee for the opportunity to 

elucidate the position of the 2 million veteran members of this organization. For additional information regarding this testimony, please contact Mr. Derek 

Fronabarger, Deputy Director of The American Legion’s Legislative Division at (202) 

861–2700 or dfronabarger@legion.org. 

f 

Prepared Statement of Ryan M. Gallucci 

WITH RESPECT TO 

‘‘To Discuss the Integrated Disability Evaluation System (IDES) and VA’s Pre-Discharge Programs for Separating Service Members’’ 

Chairman Bost, Ranking Member Esty and members of the Subcommittee, on behalf of the men and women of the Veterans of Foreign Wars of the United States 

(VFW) and its Auxiliary, I would like to thank you for the opportunity to testify on 

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the Integrated Disability Evaluation System (IDES) and the Department of Veterans Affairs’ (VA) pre-discharge programs for separating servicemembers. 

As the nation’s oldest major veterans service organizations (VSO), the VFW serves 

24 military installations to help veterans navigate and understand their earned VA 

benefits. Given the structure of the IDES program, we only have minimal interaction with servicemembers as they navigate this process. Therefore, most of this 

testimony will focus on VA’s pre-discharge claims programs. 

To the VFW, filing claims prior to separation from the military is one of the most 

important processes that a servicemember can complete during the transition process. Not only does this ensure timely delivery of benefits after discharge, but it also 

increases the likelihood of granting benefits, setting veterans up for future success. 

The reason that the VFW has invested significant resources to support 

transitioning servicemembers is to foster a lifetime of advocacy on their behalf. As 

you know, the VFW and organizations like us provide this service free of charge. 

This is not just a courtesy that we provide. This highly-regulated professional service is a cornerstone of the VFW’s mission to advocate for our nation’s veterans. 

When we say a lifetime of advocacy, we mean that the advocacy we provide does 

not stop after the initial appointment with a transitioning servicemember to file an 

initial VA claim. Instead, from that point forward, we hold limited power of attorney 

to advocate on behalf of the veteran and his or her dependents in any claim actions 

before VA. What this means is that after service, if a condition worsens, if the veteran marries or has children, the VFW’s global network of more than 1,900 highlytrained, professional, and VA-accredited advocates is there to help navigate the 

process. Even when the veteran passes away, VFW advocates are there to support 

the surviving family members in understanding and accessing any benefits to which 

they are entitled. According to VA, this lifetime of advocacy yielded nearly $7.7 billion in earned 

benefits for nearly 500,000 VFW-represented claimants in fiscal year (FY) 2017— 

an increase of more than $200 million over FY 2016. The VFW believes in this lifetime of advocacy, and the most critical point in establishing this relationship is the 

time when a servicemember chooses to leave the military. For this, I want to thank 

both VA and the Department of Defense (DoD), whom we heard from today, for allowing the VFW to play a critical role in this transition. 

I just had the opportunity to visit with our work sites on Camp Pendleton, Naval 

Base San Diego, and in the San Diego VA Regional Benefits Office, so I have seen 

firsthand the importance of collaboration among DoD, VA, and the VSOs to best 

serve our transitioning servicemembers. 

A positive experience for a transitioning servicemember in navigating their VA 

benefits sets everyone up for success. The veteran receives timely, accurate benefits, 

setting them on a course to financial stability during a difficult transition. VA can 

more easily process benefits for veterans whose health conditions clearly manifest 

during their time on active duty, making VA an approachable and non-adversarial 

steward of these critical benefits. DoD fosters a smooth transition into civilian life, 

solidifying its rapport with veterans and ensuring the sustainment of the all-volunteer force. Finally, it postures the VFW to provide the best possible service to our 

clients no matter where they choose to go after they leave the military. 

As transition programs evolve, Congress, DoD, and VA all seek to make changes 

to better suit the transition experience. Many times, these changes result in improved service for the transitioning servicemember, such as the Transition Assistance Program (TAP) mandate included in the VOW to Hire Heroes Act; DoD’s deployment of the military lifecycle model for transition; VA’s establishment of the 

pre-discharge claims program; or the joint DoD/VA commitment to develop a single 

medical record for servicemembers and veterans. 

Unfortunately, sometimes changes have unintended consequences that may result 

in a degraded transition experience for the servicemember. This is where the VFW 

takes its responsibility as a veterans’ advocate to inform the agencies of jurisdiction 

and this committee of our concerns. 

Recently, VA made two significant changes to its pre-discharge claims programs 

that make the VFW concerned about the future of this critical interaction and the 

professional services we provide to our transitioning military members. First, VA 

shifted its timelines for the Benefits Delivery at Discharge (BDD) program, only allowing servicemembers to submit BDD claims from 180 - 90 days prior to discharge. 

Second, VA eliminated the Quick Start (QS) claims program entirely, meaning veterans with 89 days or fewer left on active duty no longer have an option tailored 

to their unique circumstances to easily access their earned benefits. 

The VFW understands why VA wanted to shift the timeline for BDD to 90 days. 

We understand that this allows VA to complete exams and propose rating decisions 

to deliver benefits as close to a servicemember’s date of discharge as possible. In 

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a vacuum, this is a positive step. However, coupled with the elimination of QS and 

the military’s cumbersome transition timelines, the VFW believes this change would 

disqualify most servicemembers the VFW serves from easily accessing their benefits 

on their way out of the military. 

According to VA, the VFW’s claimants on military installations who filed QS 

claims fluctuated between 33 and 50 percent over the past year. In visiting with 

our pre-discharge claims sites, we hear that most clients visit our offices with far 

fewer than 90 days left on active duty, meaning most of our past BDD clients would 

no longer be qualified for the program. Yes, VA still accepts these claims, but they 

are no longer processed expediently while the veteran still serves on active duty, 

and they are no longer tracked with a unique end product (EP) code specific to QS 

claims, formerly EP code 337. 

In the past, this EP code allowed the VFW to track pre-discharge claims work to 

perform rating reviews and ensure the best possible outcome for our transitioning 

servicemembers. Now, with the elimination of the QS EP code, claims we submit 

on behalf of transitioning servicemembers are assigned as any other claim in VA’s 

National Work Queue. VA will argue that this is not a big deal and that VFW-accredited representatives anywhere can conduct these rating reviews. While this is 

technically true, we lose optics on these claims and can no longer properly track and 

report how well VA is serving the transitioning servicemember population. If we 

cannot identify problems this early in the process, we are not setting up the 

servicemember for post-military success. 

This is why the VFW commits substantial resources at the national level to not 

only initial claims intake but also quality controls on adjudication of the original 

claim. As of this hearing, the VFW has six personnel stationed at the VA regional 

offices (VARO) responsible for pre-discharge claims adjudication whose sole responsibility is to review rating decisions and correct any possible errors. Our most recent 

data indicates that our rating review specialists catch VA adjudication errors in up 

to 20 percent of pre-discharge claims and are able to resolve such errors prior to 

promulgation of the award. This quality control allows us to establish the aforementioned lifetime of advocacy that we consider so vital to a veteran’s future, posturing 

our local advocates for success once a recently-transitioned veteran settles down. 

Several years ago, recognizing the unique needs of transitioning servicemembers, 

VA committed not to broker work from the consolidated pre-discharge claims worksites at the VAROs in Winston-Salem, Salt Lake City, and San Diego. VA reneged 

on this promise last year with its across-the-board implementation of the National 

Work Queue, as we have testified in the past, and we do not expect VA will go back 

to its old workflows, since this has seemed to increase productivity and efficiency 

for VA. However, through unique EP codes and Station of Origination filtering in 

Veterans Benefits Management System (VBMS), our pre-discharge quality control 

team was able to track and review work regardless of the VARO of jurisdiction for 

adjudication. This was a satisfactory middle ground to meet both the needs of VA 

to broker its work and the VFW’s need to maintain optics on specific claims for quality control purposes. However, with the elimination of the QS EP code, we lose optics on this work and can no longer fulfill our commitment to transitioning 

servicemembers to perform the proper quality controls on their claims. 

We have not seen the full effects of this yet, but our rating review specialist at 

the San Diego VA Regional Benefits Office already reports that QS claims for review 

are declining, and in meeting with the VARO Director, we learned that the total 

pending QS workload is all but adjudicated. So what happens now? 

This becomes especially problematic for servicemembers who are lower in rank— 

the servicemembers who need our services the most. Through surveying the VFW’s 

clients, we have learned that many of our junior enlisted clients do not receive their 

TAP training in time to file a BDD claim. We also know that the military branches 

are just narrowly able to satisfy the VOW to Hire Heroes Act requirement for 

servicemembers to start their transition training with no fewer than 90 days remaining on active duty. If servicemembers have not been briefed yet on how to access their earned benefits, how can VA expect them to file their claim actions? 

This is especially problematic on installations, like Camp Pendleton, that serve 

large numbers of junior enlisted transitioning servicemembers. On my recent site 

visit, I saw that most of the clients visiting our representative are much closer to 

their discharge date than 90 days. Based on our internal numbers, most of our clients on Camp Pendleton were QS claimants prior to October 1. 

Moreover, VA exacerbated an already tenuous situation by notifying transitioning 

servicemembers with fewer than 90 days on active duty that they were ‘‘disqualified’’ from filing BDD claims. This is a situation where language is critical. When 

the VFW was first presented with this letter, we vehemently disagreed with VA’s 

decision to send it as worded. This concern was ignored. Since the change went into 

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effect October 1, we have heard from all of our pre-discharge claims sites and several of our VARO worksites that veterans have called or visited the office, concerned 

that something went wrong with their claim. We even have one report from our office at Walter Reed National Military Medical Center that a retiree received a BDD 

disqualification letter 92 days prior to separation. 

Thankfully, many of these clients have confidence in our representatives to explain the situation or resolve any discrepancies. However, what concerns us are the 

servicemembers that we do not hear from who thinks that the VFW did something 

wrong. For these veterans, we have lost our ability to advocate, and they already 

have a negative perception of how both VFW and VA will handle their benefits. 

The VFW calls on VA to put veterans, not appearances, first. It must accept 

claims prior to separation instead of punishing transitioning servicemembers whose 

chain of command does not permit them the opportunity to begin their transition 

process 90 days before they separate from military service. At the very least, VA 

must reestablish an EP code for transitioning servicemembers who file a claim within 90 days of separation to ensure the VFW and other veterans organizations are 

able to assist veterans in successfully transitioning from military service back to civilian life, regardless of where they choose to call home. 

VA must also rework the disqualification letters to simply notify the veterans that 

their claims have been received, but it cannot be worked until they separate from 

service and submit their DD–214 paperwork. It is unconscionable that transitioning 

servicemembers be led to believe they are not eligible for VA benefits simply because VA refuses to change the wording on its letters. These simple steps will once 

again ensure that the VFW and similarly-structured organizations can continue to 

provide the advocacy our clients expect, and transitioning servicemembers will once 

again have peace of mind that VA is responsibly handling their pending benefits 

claims. 

Unfortunately, the VFW worries there is a larger objective with the recent 

changes to VA’s pre-discharge claims programs. While VA asserts that moving the 

window to 90 days results in better claims service, the elimination of the QS EP 

code and the rapid deployment of programs like the Decision-Ready Claims (DRC) 

process indicate to the VFW that VA’s primary objective is to obfuscate the total 

pending workload. 

Based on the VFW’s estimates, we would lose optics on up to 50 percent of our 

pre-discharge workload simply by VA shuffling the BDD timelines and eliminating 

the QS EP code. The problem is not only that we lose optics on the claims, but VA 

will not formally establish the BDD-excluded claims until veterans formally submits 

their DD–214 after they separate from service. This means that any time from 89 

days to the time of the veteran’s submission does not count as pending work as it 

formerly counted when the claim was established under a QS EP code. 

On December 11, 2017, VA deployed new functionality in DRC, encouraging VSOs 

to work DRC claims for transitioning servicemembers. While it may seem advantageous for VSOs to be able to request VA exams for separating servicemembers 

who are not BDD eligible, the process completely falls apart with the requirement 

for the separating servicemembers to formally submit the claim once they leave 

military service. Per VA guidance, if we were to work with a separating 

servicemember to prepare a DRC claim, the VSO would never actually submit the 

claim. Instead, the servicemember would be responsible for not only formally submitting their DD–214 after they leave active duty, but for also completing and submitting the formal paperwork to establish their claim. This is a non-starter for the 

VFW and our clients because we lose all control of our client’s claim. Veterans come 

to us so that they do not have to worry about these processes and wonder whether 

or not they are doing something right. Moreover, after our pre-discharge claims representatives work with a separating servicemember who leaves the military, we 

have lost the ability to help them without their proactive effort. Our preferred method of doing business is to take care of all the required claims processes while the 

servicemember is still on active duty—especially establishing a claim. To the VFW, 

the only benefit to shifting the onus to file onto the veteran is that, once again, 

there is no formal work product pending with VA, implying that claims processing 

times have improved. To the VFW, we cannot compromise quality customer service 

so that VA can report more favorable adjudication numbers. 

Please do not read this as VFW accusing VA of having nefarious motives in clearing its pending workload. After all, the VA pending workload has been the subject 

of heavy scrutiny from VSOs, the public, and this committee for years. But maybe 

it is time to have an honest discussion about this. VA is notorious for unnecessarily 

drawing out certain business processes, but not all pending work is because of VA 

inaction, such as development for QS claims, and not all pending work is bad for 

the veteran, such as the 48-hour review period. As veterans’ advocates, it is our job 

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to properly explain these nuances in the VA claims process to veterans before the 

barracks lawyers get a hold of them and tells them VA is out to get them. We can 

help do this. In fact, I did it just this week on a site visit to our pre-discharge claims 

site in San Diego. During a Transition Goals, Plans, Success (TGPS) Capstone briefing, I had the opportunity to speak with a sailor who was going through the IDES 

process at Naval Base San Diego. He had been notified of his VA rating, but still 

has a few weeks left on active duty. His question was simple: When do my benefits 

start? After a brief explanation of the next steps, he understood why he would not 

receive his VA benefits while on active duty, and he understood the timelines he 

would experience once he received his discharge paperwork. After the conversation, 

he seemed more confident and understanding of what was happening. To this sailor, 

the timelines did not matter nearly as much as the clarity. If we all set reasonable 

expectations, and explain the processes behind the timelines, veterans will have a 

positive experience. This is what we do as advocates. 

Unfortunately, confusion and constant changes only perpetuate negative perceptions of VA and the programs VA administers. I say this in our regular meetings 

with VA: Help us help you. After all, we are the veterans’ community. Many of us 

have been through this transition. We understand what our clients are going 

through. Our personal experiences, coupled with the training VA requires of us to 

understand this highly-regulated process means that we can explain things in a context that separating servicemembers will understand. We can carry the water if the 

focus is veteran-centric. 

To the VFW, the time when servicemembers transition off of active duty is one 

of the most significant changes they will experience in their lives. This Congress 

and the VSO community have dedicated substantial resources to make sure that we 

get this right. The VFW values the role that we are allowed to play in the process 

through both VA and DoD, and we are always looking for ways to improve. Our goal 

is that we can move forward together to ensure that our transitioning 

servicemembers have access to the programs, information, and services they need 

for a successful transition out of military life. 

Mr. Chairman, this concludes my testimony. I will be happy to answer any questions you or the Committee members may have. 

Æ 

Leonard.horne on VACREP0180 with DISTILLER