Department of Veterans Affairs 

Office of Inspector General 

Audit of 

VA Regional Office 

Claim-Related Mail Processing 

Report No. 08-01759-234 September 30, 2009

VA Office of Inspector General 

Washington, DC 20420 
To Report Suspected Wrongdoing in VA Programs and Operations 

Telephone: 1-800 488-8244 between 8:30AM and 4:00PM Eastern Time

 

Monday through Friday, excluding Federal holidays 

E-Mail: vaoighotline@va.gov
Audit of VA Regional Office Claim–Related Mail Processing 

Table of Contents 

Page 

Executive Summary .....................................................................................................i-v

Introduction

Purpose.............................................................................................................................. 1 

Background....................................................................................................................... 1 

Results and Conclusions ............................................................................................. 3 

Claims Documents Inappropriately Placed in Shred Bins ............................................... 3 

VARO Mail Processing Deficiencies Contributed to Delays in Claims .......................... 7 

Incorrect Receipt Dates Impaired Data Integrity ............................................................. 8 

Use of X-ray Machines for Mail Scanning Unlikely to Improve VARO Security ........ 11 

VBA Mailrooms Not Fully Compliant with Security Requirements ............................. 14 

Appendixes 

A. Scope and Methodology ........................................................................................... 19 

B. Other Matters Identified and Impacting Specific VARO Mailroom Operations...... 21 

C. VBA National Control Time Performance ............................................................... 23 

D. Under Secretary for Benefits Comments.................................................................. 24 

E. OIG Contact and Staff Acknowledgments................................................................ 29 

F. Report Distribution.................................................................................................... 30 

VA Office of Inspector General 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General i 

Executive Summary 

Results in Brief 

The Office of Inspector General (OIG) conducted this audit to evaluate whether VA 

regional offices (VAROs) effectively managed mailroom operations and controlled the 

timely and accurate processing of claim-related mail. In fiscal year (FY) 2008, VBA 

processed about 20 million pieces of incoming mail and 13 million pieces of outgoing 

mail. Both the significant number of claim-related documents handled by VARO 

mailrooms and the potential effect on the processing of veterans claims that can occur if 

documents are inappropriately handled or destroyed make this a high-risk area for VBA. 

VAROs needed to improve the handling, processing, and protection of claim-related 

documents, as well as in meeting mailroom security and other operational requirements. 

The use of amnesty periods and the extensive volume of mail recovered while taking 

these proactive initiatives are strong indicators that controls over mail management in 

VAROs were ineffective. The audit found some claim-related documents at the four 

VAROs visited were inappropriately placed in shred bins, a problem that appeared to be 

systemic. We also noted that VBA mail processing deficiencies led to unnecessary delays 

in establishing control of claims in VBA’s “SHARE” system after receipt, and some 

claim dates were incorrectly entered into the system. In addition, VAROs do not 

effectively use X-ray machines to scan mail for threat objects and improvements are 

needed to strengthen mailroom security plans and practices. 

Background 

The OIG has identified the lack of timeliness for processing compensation and pension 

claims as a serious management challenge for the Department for the past several years. 

During this audit, we were informed some VAROs held “mail amnesty” periods to 

encourage VARO employees to turn in unprocessed claim-related documents in their 

possession without penalty or repercussions. Although these mail amnesty periods were 

considered necessary to ensure all veterans’ claim information was processed, the use of 

mail amnesty periods and the numerous documents recovered while taking these 

proactive initiatives indicates that controls over processing claim-related mail in VAROs 

were ineffective. For example, 

• In July 2007, the Detroit VARO reported that almost 16,000 pieces of unprocessed 

mail that were apparently being held by VARO employees. They included an 

estimated 700 claims not put under proper control and 2,700 medical records and/or 

pieces of medical information not in VBA information systems or associated claim 

files. In response to our draft report, VBA indicated that the majority of the 

remaining documents recovered were drop-file mail requiring no action by the VARO 

except to be filed in the claims folders. 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General ii 

• In October 2008, a mail amnesty at the New York VARO resulted in the recovery of 

over 700 documents from its employees. 

After learning about the mail amnesties, we requested and obtained representations from 

the Directors of the four VAROs visited indicating they were not aware of any significant 

issues or problems related to processing of incoming mail at their VARO that were not 

disclosed to the OIG or occurred subsequent to completion of our on-site work.

Findings 

VAROs needed to improve the handling, processing, and protection of claim-related 

documents, as well as in meeting mailroom security and other operational requirements.

VARO staff inappropriately placed documents needed for claims-processing in 

shred bins. An employee at the Detroit VARO told us that veterans’ claim-related 

documents may have been placed in VARO shred bins for destruction. OIG auditors 

searched the shred bins located near the VARO mailroom and Triage Team areas and 

found documents needed for processing veterans’ claims in shred bins awaiting routine 

destruction. 

A similar search of shred bins at the other three VAROs where we had planned our audit 

work identified similar documentation. Our review of the contents of 37 (30 percent) of 

125 shred bins at 4 VAROs identified a total of 132 claim-related documents 

inappropriately placed in the bins. The 132 claim-related documents consisted of 

45 documents that could affect the benefits of 44 claimants and 87 documents that would 

not have affected claimants’ benefits but should have been retained in claim files. After 

hearing the results of our probes, VBA directed all VAROs to search and inventory the 

contents of every shred bin within their VAROs, and verify that the contents did not 

include documents needed for processing claims. Based on this inventory VBA 

discovered claim-related documents in shred bins awaiting destruction at 41 VBA 

locations nationwide, including 40 of the 57 VAROs and VBA’s Records Management 

Center in St. Louis, MO. 

In response to these findings and VBA’s own administrative review results, VBA issued 

a new and comprehensive policy in November 2008 regarding procedures for the 

maintenance, review, and appropriate destruction of veterans’ paper records located in all 

VBA facilities and work sites. 

VARO mail processing deficiencies contribute to unnecessary delays in establishing 

control of claims. VBA mail processing deficiencies led to unnecessary delays in 

establishing control of claims in VBA’s “SHARE” system. In FY 2008, VBA placed 

82 percent of claims under control (entered claim information into SHARE application to 

officially establish claim) in seven days or less after receipt; however; it took an average 

of 32.5 days to place the remaining 18 percent of claims under control. VAROs could 

improve control time proficiency by improving procedures to identify, analyze, and 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General iii 

monitor conditions that contribute to the delays in establishing control of claims, and 

ensuring that VAROs follow established and improved procedures. 

The date of receipt for claim-related documents was not always entered correctly. 

Our review at four VAROs revealed incorrect dates entered for 22 (9 percent) of 

238 claims established during May 1 through July 31, 2008. These incorrect dates did 

not appear to be intentional, but rather the result of human error. In response to the 

OIG’s February 2009 report, Review of VA Regional Office Compensation and Pension 

Claim Receipt Dates (Report No. 09-00189-81) on this issue, VBA indicated they were 

establishing new procedures to test the accuracy of claim dates. Therefore, we offered no 

additional recommendations. 

Mail processing and mailroom operations need improvements. We also identified the 

following conditions impacting mail-processing activities at VAROs: 

• VAROs did not effectively use X-ray machines to scan incoming mail. 

• VARO mailrooms did not fully comply with critical mailroom operations security 

requirements recommended by Federal regulations and General Services 

Administration (GSA) guidance. 

• VARO mailrooms did not follow all required procedures for the proper handling of 

negotiable instruments. 

• One VARO mailroom visited did not adequately protect Personally Identifiable 

Information (PII) awaiting destruction or in outgoing mail. 

Conclusion 

VBA has adequately addressed our concerns by establishing controls to ensure that 

important claim-related documents are not improperly discarded, and establishing new 

procedures to test the accuracy of claim dates. Nevertheless, improvements need to be 

made in mailroom operations management to ensure that a higher percentage of incoming 

claims are put under timely control. VARO security could also be improved by more 

effectively using X-ray machines to scan incoming mail and implementing guidance in 

accordance with recommended, government-wide mailroom security standards and 

guidelines. Until VBA completes the actions necessary to address these issues, VBA 

cannot be assured claims are being processed in a timely manner and government 

property, VARO employees, visitors, and other tenants are protected from unnecessary 

risks. 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General iv 

Recommendations 

1. We recommend the Under Secretary for Benefits require VAROs to implement 

procedures to identify, analyze, monitor, and take actions to address conditions 

contributing to delays in establishing control of incoming claims within VBA’s 7-day 

requirement. 

2. We recommend the Under Secretary for Benefits develop and issue policy guidance to 

establish VARO requirements to scan incoming mail and how VARO X-ray machines 

should be used to improve security. 

3. We recommend the Under Secretary for Benefits develop and issue policy and 

standards concerning initial and recurring training and certification requirements for 

personnel who operate X-ray machines to scan incoming mail at VBA facilities. 

4. We recommend the Under Secretary for Benefits develop and issue policy guidance 

for all VAROs regarding mailroom physical security based on requirements 

enumerated in 41 CFR, Part 192, Mail Management, and in the GSA Mail Center 

Security Guide. 

5. We recommend the Under Secretary for Benefits issue guidance on establishing the 

minimum interval for updating VBA mailroom security plan risk analyses. 

Management Comments and OIG Response 

The Under Secretary for Benefits concurred with our findings and recommendations. 

VBA will revise and/or issue new policy and guidance in the areas of improving control 

over establishing new claims, and addressing mailroom security requirements and lapses 

noted during the audit, including the use of X-ray machines to scan incoming mail for 

threat items. VBA should be commended for taking proactive actions in advance of 

issuance of this report to address some of the concerns uncovered during the audit and as 

a result of previous OIG and internal VBA reviews. We incorporated VBA’s technical 

comments to our report where appropriate. 

In particular, in November 2008, VBA officials put new controls in place to help ensure 

applications for benefits and other official documentation are not improperly destroyed in 

response to work uncovered during the audit and briefings provided to senior VA and 

VBA management. In addition, during the course of our audit, VBA took action to 

improve controls over claim dates subsequent to the discovery of the problem at the New 

York VARO and in response to a February 2009 OIG report. 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General v 

Therefore, for both of these areas, no additional recommendations were provided to 

VBA. Planned corrective actions for our recommendations were responsive to our 

concerns and we will close the recommendations when all proposed actions have been 

completed by VBA. Appendix D contains the full text of the Under Secretary’s 

comments. 

(original signed by:)

 BELINDA J. FINN 

 Assistant Inspector General 

 for Audits and Evaluations 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 1 

Introduction 

Purpose 

This audit evaluated whether VA regional offices (VAROs) have effective 

controls for the timely and accurate processing of claim-related mail and 

effectively manages its mailroom operations. 

Background 

In FY 2008, VBA paid over $36.3 billion in disability compensation to about 

3.2 million veterans and $3.8 billion in pension compensation to approximately 

514,000 veterans and survivors. VBA processed 20 million pieces of incoming 

mail and 13 million pieces of outgoing mail in FY 2008. According to VBA, 

numerous studies have shown that delays in properly controlling incoming mail 

significantly contribute to delays delivering benefits to veterans. 

A significant first step in processing claims is the rapid handling and delivery of 

incoming mail to action offices within a VARO. All received and dispatched mail 

is processed by VARO mailrooms (or mail centers). Date stamping the mail to 

show the date the VARO received the mail and then moving the mail into the 

Triage Team and other points within the VARO as soon as possible are the most 

significant aspects of mailroom operations. VA policy states the objective of 

incoming mail management is to deliver mail to the action office within the 

shortest possible time after receipt, at least within 4 to 6 hours whenever possible. 

A measure for processing mail associated with Compensation and Pension (C&P) 

claims is control time. VBA‘s goal is for 80 percent of claims to be established 

within seven days of receipt. Control time is the amount of time it takes to enter 

or establish a claim in VBA’s SHARE computer application after receipt of a 

claim. Appendix C of this report contains detailed information on the VAROs’ 

control time performance 

During this audit, we were informed some VAROs held “mail amnesty” periods to 

encourage VARO employees to turn in unprocessed claim-related documents in 

their possession without penalty or repercussions. Although these mail amnesty 

periods were considered necessary to ensure all veterans’ claim information was 

processed, the use of mail amnesty periods and numerous documents recovered 

while taking these proactive initiatives indicates that controls over processing 

claim-related mail in VAROs were ineffective. For example, 

• In July 2007, the Detroit VARO reported that almost 16,000 pieces of 

unprocessed mail that were apparently being held by VARO employees. They 

included an estimated 700 claims not put under proper control and 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 2 

2,700 medical records and/or pieces of medical information not in VBA 

information systems or associated claim files. In response to our draft report, 

VBA stated that the remaining documents recovered were drop-file mail 

requiring no action by the VARO except to be filed in the claims folders. 

• In October 2008, a mail amnesty at the New York VARO resulted in the 

recovery of over 700 documents from its employees. 

According to 41 CFR, Part 102-192, Mail Management, all agencies that spend 

more than $1 million per year on postage are required to develop and maintain an 

annual mail management and security plan. Regulations further state the “mail 

center is a major gateway into any business or government agency...Security is 

critical for this critical nerve center.” Shortly after the anthrax attacks of 

2001, GSA issued the GSA Mail Center Security Guide to assist Federal mail 

center managers in keeping mail centers safe and secure. It provides an outline of 

the planning and preparation that is appropriate for a Federal mail center. 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 3 

Results and Conclusions 

Findings 

VAROs needed to improve the handling, processing, and protection of 

claim-related documents, as well as in meeting mailroom security and other 

operational requirements. The use of amnesty periods and the extensive volume 

of mail recovered while taking these proactive initiatives are strong indicators that 

controls over mail management in VAROs are ineffective. The audit found some 

claim-related documents at the four VAROs visited were inappropriately placed in 

shred bins, a problem that appeared to be systemic. 

We also noted that VBA mail processing deficiencies led to unnecessary delays in 

establishing control of claims in VBA’s “SHARE” system after receipt, and some 

claim dates were incorrectly entered into the system. VAROs do not effectively 

use X-ray machines to scan incoming mail for threat objects and improvements are 

needed to strengthen mailroom security plans and practices. 

Claims Documents Inappropriately Placed in Shred Bins 

Information needed to support the processing of claims was inappropriately 

discarded in 37 shred bins located at the four VAROs visited. All information 

about our nation’s veterans must be treated with the highest level of confidentiality 

and the utmost respect. Employees may only destroy records in accordance with 

approved records control schedules and must never remove records from VA 

without authorization. Shred bins provide employees with a place to dispose of 

unnecessary documents containing Personally Identifiable Information (PII). 

Without effective controls for processing and safeguarding documents, claim 

information is at risk of being misplaced or inappropriately destroyed. 

Document shredding is generally part of routine records management functions 

performed in VAROs. Shred bins were located in different work areas throughout 

the four VAROs visited. 

An employee at the Detroit VARO told us that veterans’ claim-related documents 

may have been placed in VARO shred bins for destruction. OIG Auditors 

searched the shred bins located near VARO Triage Team areas and found 

claim-related documents. We then reviewed the documents, compared them to 

electronic and paper file records to determine whether the documents found in the 

shred bins had been recorded as received and whether the VARO had taken action 

in response to the information contained in those documents. Our search of shred 

bins at the other three VAROs identified additional documents that were 

inappropriately discarded. 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 4 

The OIG reported preliminary findings to Congress in separate white papers 

issued in October and December 2008. In total, at the four VAROs, we recovered 

a total of 132 documents from examined shred bins of which 45 documents could 

have affected claim benefits and 87 other documents, such as death certificates, 

correspondence from the veterans, and award documents that would not have 

affected claims but should have been retained in claims files. (See Table 1 for 

additional details). 

Table 1. Documents Found in Shred Bins 

Documents Identified in Shred VA Regional Offices 

Bins Detroit St. Petersburg St. Louis Waco TOTAL 

Documents Affecting Benefits 

Original Claims 2 4 0 0 6 

Reopened Claims 1 10 2 0 13 

Burial Benefits 0 4 0 0 4 

Dependency Claims 1 1 1 0 3 

Death Benefits 0 1 0 0 1 

Informal Claims 4 0 0 0 4 

Miscellaneous 6 6 0 2 14 

 Subtotal 14 26 3 2 45 

Documents Not Affecting 

Benefits 69 12 3 3 87 

TOTALS 83 38 6 5 132 

The 45 documents that delayed the processing of the claimants’ benefits or 

otherwise impacted the claim included: 

• Original claims for benefits (6). These claims included two from Global War 

on Terrorism (GWOT) veterans that should have received priority processing. 

We found no record of receipt and VARO managers confirmed that the claims 

were never established. 

• Reopened claims for benefits (13). These claims represented requests for 

increased compensation, new entitlement to pension benefits, or entitlement to 

service connection for additional disabilities. For 10 of the 13 claims, there 

was no record of receipt or action by the VAROs to establish a claim. 

Although the VARO had established the remaining three claims cases, for two 

of these claims, the private medical evidence submitted by the claimant was 

discarded, and there were no copies in the official records. For the third claim, 

the VARO used the date of a telephone inquiry instead of the earlier original 

claim date on the records found in the shred bin. 

• Claims for burial benefits (4). The VARO had no record of receipt or 

processing of these claims for reimbursement of burial expenses. 

• Dependency claims (3). These claims included two requests for benefits on 

behalf of claimants’ children and an application to add a dependent to an 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 5 

existing claim. The VAROs had no record of receipt and no evidence of any 

action. 

• Claim for death benefits (1). The VARO had no record that this claim for 

death benefits by a surviving spouse was received or acted upon. 

• Informal claims (4). An informal claim preserves the claimant’s date of 

eligibility for benefits for a 1-year period, indicating a claimant’s intent to 

apply for one or more benefits. The discarded informal claims identified the 

date the VARO received the document, which is necessary to ensure the 

correct date of eligibility. However, the VAROs had no record of receipt and 

control of these documents. 

For example, a veteran did not receive full disability benefits due because the 

VARO had not taken any action on the informal claim received prior to the 

claim being discarded in a shred bin. The VARO received the veteran’s 

informal claim on January 31, 2008. In February 2008, the VARO received 

the veteran’s formal claim and established the claim in SHARE with a 

February 12, 2008, date of claim. The VARO awarded benefits to the veteran 

based on the February 12, 2008, date of claim, with a payment date of 

March 1, 2008. The VARO should have awarded benefits based on a 

January 31, 2008, date of claim with a payment date of February 1, 2008. As a 

result, the veteran did not receive the entitled disability benefit payment of 

$117 for the month of February 2008. 

• Miscellaneous documents (14). These documents included write-outs and 

returned mail that the VAROs had not acted upon and could affect claimants’ 

benefits. A write-out is notification to VA that a discrepancy exists between a 

veteran’s computer record and the amount of monthly benefits the veteran is 

receiving. VARO employee action is required to reconcile the discrepancy. 

Actions Taken by VA and VBA Leadership. On October 14, 2008, the 

Inspector General briefed the prior Secretary of Veterans Affairs, the Under 

Secretary for Benefits, and other senior VA officials concerning claim-related 

documentation found in shred bins. Immediately following this briefing, VA 

senior management directed every VARO to suspend all document shredding. In 

addition, the Under Secretary for Benefits instructed VARO Directors to inventory 

the contents in shred bins, report all claim-related mail or original supporting 

documents found in shred bins, and certify that documentation is not being 

inappropriately destroyed. 

On October 27, 2008, VBA reported to OIG that VARO inventories of shred bins 

identified 500 documents affecting benefit entitlements and eight documents that 

VAROs were required to return to claimants. VBA revised that number of 

documents to 474 after completing its review of the VARO inventories. Of the 

57 VAROs, 40 (71 percent) reported that shred bins included documents affecting 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 6 

benefit entitlements. VBA’s Records Management Center in St. Louis, MO, also 

reported that six documents were inappropriately discarded. Of the 

474 documents, 242 (52 percent) were at three VAROs—Columbia, SC 

(95 documents); St. Louis, MO (94 documents); and Cleveland, OH 

(53 documents). The remaining 232 documents were at 37 other VAROs and the 

Records Management Center. The number of documents in shred bins at these 

facilities ranged from 1 to 95. 

In November 2008, VBA officials improved controls to help ensure applications 

for benefits and other official documentation are not improperly destroyed. On 

March 12, 2009, we conducted a spot check of the physical controls for 15 shred 

bins at the St. Petersburg VARO and found all shred bins locked and secure in that 

VARO. We will assess the effectiveness of these new controls over shredding 

operations in future reviews of VAROs. 

Extent of Inappropriate Claim-Related Shredding Cannot Be Determined. 

The contents of the bins OIG reviewed contained 14 or fewer days of material 

because the shred bins at the four VAROs were generally emptied weekly or 

bi-weekly. We did not have sufficient information to project the findings to the 

universe of VAROs to determine whether the findings represented the typical 

contents for each shred bin or to know what occurred prior to or after our audit. 

Lack of Controls Are Contributing Factors. At the time this audit began, VBA 

had no requirement for any supervisor or other official to review documents 

placed in the shred bins. Further, no requirement existed for any type of official 

review of documents placed in shred bins prior to their destruction. Therefore, an 

employee could easily dispose of documents, either intentionally or 

unintentionally. The identification of documents inappropriately slated for 

shredding nationwide occurred because of a general lack of management controls 

that allowed employees unrestricted access to shred bins. 

While documents may have been unintentionally disposed of by employees, 

VARO officials indicated that the focus on production quotas for processing 

incoming claim-related documents could have potentially motivated some 

employees facing a backlog of work to conceal and/or destroy official documents 

instead of filing or processing them. Similar concerns were raised in a 

congressional hearing by members of Congress, a VBA employee/union 

representative, and representatives from veterans’ organizations. 

We consider any loss of claim-related documents to be unacceptable. These 

actions result in an inaccurate or incomplete record of activities needed to process 

a veteran’s claim, delay claims processing, and potentially result in denial, under, 

or overpayment of benefits. We commend VBA for the immediate response to 

address the documentation-shredding problem. We will monitor corrective actions 

at the VAROs to ensure veterans’ claims and records are appropriately protected. 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 7 

VARO Mail Processing Deficiencies Contributed to Delays in Claims 

VAROs could reduce control times by addressing avoidable delays in mail 

processing practices. While the agency is successfully placing 82.4 percent of 

claims under control within 7 days of receipt, in FY 2008, we found that the 

average control time for the remaining claims was 32.5 days, and 13 of the 

57 VAROs did not meet the processing goal of placing 80 percent of claim-related 

mail under control. 

At the four VAROs visited, we sampled 120 claims to determine the reasons that 

some claims were not established within the 7-day requirement and determined 

that the majority of delays, 103 (86 percent) were avoidable: 

• For 62 (60 percent) of 103 claims, Triage staff responsible for establishing 

control of claims in the SHARE system did not establish these claims within 

seven days of receipt because they did not effectively prioritize their work or 

they incorrectly calculated the 7 day requirement for establishing claims: 

o Claims assistants did not effectively manage their workload to ensure 

claims nearing the 7-day requirement were given priority. As a result, 

some work on claims did not start until after the 7-day requirement lapsed. 

o Some claims assistants did not know how to correctly calculate the 7-day 

requirement in accordance with VBA policy. VBA calculates day one of 

control time using the date of the earliest VA date stamp on the claim. 

However, these claims assistants considered the day after the earliest VA 

facility date stamp as day one. In addition, some claims assistants 

incorrectly thought days were computed using business days (excluding 

weekends and holidays) instead of calendar days as stated in VBA policy. 

As a result, claims assistants may not have been aware that they had already 

exceeded the 7-day requirement when they established control of the 

claims. 

• For 26 (25 percent) of 103 claims, the Triage staff responsible for screening 

and reviewing incoming claim-related mail inappropriately routed claims to 

another team or regional office for processing. These claims should have been 

placed under control by Triage personnel but were not. The primary causes for 

inaccurate screening and reviewing of incoming claims occurred because 

employees either lacked necessary experience or were not thoroughly 

reviewing incoming mail. Consequently, they missed requests for new claims 

included in correspondence pertaining to other matters such as an appeal. 

o For example, at one VARO, the employee assigned the responsibility of 

reviewing, screening, and routing incoming claim-related mail did not 

possess in-depth claims processing experience and consequently, did not 

identify 13 claims during the screening process. This employee 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 8 

inappropriately routed the claims to other teams and contributed to an 

average control time delay of 45 days. 

• For 8 (8 percent) of 103 claims, end products (EP) used as identifiers for 

tracking claims were inappropriately canceled and subsequently re-established. 

VSC managers could not consistently determine why claims were 

inappropriately canceled because evidence to show what happened was not 

always available in either the computer applications used to track claims or in 

the claim folders. 

o For example, available evidence at one VARO showed a request to reopen 

a claim was received on June 10, 2008, and established on 

June 13, 2008, (4-day control time) using an EP identifier to track the 

claim. VSC management stated that a VSC employee inappropriately 

canceled the EP when they sent the claimant an application in response to 

the claim. When the VSC received the application, they re-established the 

claim on July 9, 2008. Instead of cancelling the EP, the VARO should 

have continued processing the claim under the initial EP pending receipt of 

additional information from the claimant. Because the claim had to be 

re-established using the date the initial claim was received on 

June 10, 2008, the elapsed days to establish control of the claim increased 

to 30 days. 

• For 7 (7 percent) of 103 claims, claim-related mail received by other VARO 

program offices, such as the Director’s office and the Homeless Coordinator, 

were not submitted to the Triage teams within seven days of receipt. 

The lack of effective management oversight and monitoring contributed to claim 

processing delays and ultimately to delayed delivery of benefits. VBA policies 

require management to check progress toward achieving goals as well as monitor 

workflow management and inventory control to ensure claims are promptly put 

under control. VAROs could improve control time proficiency by improving 

procedures to identify, analyze, and monitor conditions that contribute to the 

delays in establishing control of claims, and ensuring that VAROs follow 

established and improved procedures. Because VAROs did not have adequate 

procedures in place to identify, analyze, and monitor recurring deficiencies and 

address inadequate workflow deficiencies that contribute to avoidable delays, 

managers did not prevent the delay in placing 103 (86 percent) of 120 claims 

under control within seven days. 

Incorrect Receipt Dates Impaired Data Integrity 

Reviews performed at the four VAROs visited determined the date of receipt for 

claim-related documents was not always entered correctly. The date of receipt 

(stamped onto a document when received by any VA office, not just VBA 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 9 

mailrooms) shows the date of entitlement for an award of pension, compensation, 

or dependency. The date of receipt is also used by VBA to track the timeliness of 

claim processing and to monitor internal workflow. 

In September 2008, a VBA administrative investigation concluded that some 

employees were directed by supervisors at the New York VARO to intentionally 

record inaccurate claim dates in order to ensure that claims were reported as being 

established within 7 days of receipt by the VARO. Our review at VAROs in St. 

Petersburg, FL; Waco, TX; Detroit, MI; and St. Louis, MO, identified a 9 percent 

error rate in the accuracy of claim dates entered into SHARE. Table 2 summarizes 

our review of the claims at the four VAROs visited: 

Table 2. Incorrect Claim Receipt Dates 

VARO Claims Files 

Reviewed 

Did not Use 

Earliest VA 

Facility Date 

Stamp 

Pre-Discharge 

Diary Date Not 

Updated 

Other Total 

Errors 

Error 

Rate 

St. Petersburg 60 1 0 0 1 2% 

Detroit 58 4 1 2 7 12% 

St. Louis 60 2 3 0 5 8% 

Waco 60 8 0 1 9 15% 

TOTALS 238* 15 4 3 22 9% 

*Two of the 240 claims in our original sample were determined not to be within the scope of our review 

and thus omitted. 

• We found no evidence the errors were intentional. Reviews of the files and 

interviews with VARO managers, coaches, and employees indicated that these 

errors were the result of accidental typographical errors or a misunderstanding 

by some staff of established requirements and procedures. Fifteen of the 

22 claims with inaccurate claim receipt dates (representing 6.3% of the total 

claims reviewed) were not established using the earliest date of receipt by a 

VA facility, as required. 

• Four claims established with incorrect dates were identified as Pre-Discharge 

claims entered into the SHARE system with an estimated date of discharge 

from military service as a projected date of claim. Upon receipt of the 

claimant’s military discharge form DD-214, the VARO did not update SHARE 

to reflect the correct date of claim. 

• The three claims classified as “Other” in Table 2 included two claims that were 

established with incorrect dates of receipt due to unintentional typographical 

errors. Another claim identified as having been established with an incorrect 

date was a reopened claim inaccurately identified by a VSC employee as an 

informal claim, who then inappropriately canceled control of the claim and 

sent the claimant an application for benefits. When the VARO received the 

application, they re-established the claim using the date stamped on the 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 10 

application, instead of the date stamped on the claimant’s original request to 

reopen a claim. 

Of the 22 claims, 5 were inaccurately reported as being established within 7 days 

after receipt. Instead, they should have been reported as being established by the 

VARO ranging from 8 to 18 days after receipt. At three of four VAROs, incorrect 

claim dates could have affected benefit payment dates for 5 of 238 claims 

reviewed (2 percent). The VAROs updated the claim receipt dates after the errors 

were identified by the OIG Audit team and brought to the VAROs’ attention. On 

September 16, 2009, we confirmed in SHARE and MAP-D that benefits had not 

been adversely impacted for these 5 claims. 

VBA policy requires VARO management to ensure the accuracy of data entered 

into VBA computer applications. VBA managers are required to perform quality 

reviews to ensure staff follows prescribed procedures when recording information. 

VBA managers must assess the quality of data such as disposition codes, suspense 

dates, and the proper recording of requested and received claim evidence. We 

noted, however, that supervisory and/or quality reviews performed of claim date 

accuracy varied at each VARO location visited and in some instances were not 

performed as required: 

• At the Waco VARO, the VARO quality review team conducted the reviews. A 

quality review checklist was used by the VARO that included a test for date of 

claim accuracy. The VARO’s quality review of 1,680 claims during 

FY 2008 identified only two errors. In contrast, our review identified 

9 (15 percent) of 60 claims established during June 1, 2008 through 

July 31, 2008, with date of claim inaccuracies. 

• At the St. Petersburg VARO, the quality reviews performed by their staff did 

not include date of claim accuracy. 

• At the Detroit VARO, no quality reviews were performed from January 

through September 2008. 

• At the St. Louis VARO, management could not provide evidence that quality 

reviews were performed prior to February 2008. 

Discussions with VBA officials disclosed that VBA training material provided to 

claims assistants does not specifically define the date of claim. As a result, it is 

possible that claims assistants responsible for establishing control of claims may 

not be aware of policy requirements. According to VBA officials, training 

material is currently being updated to address this weakness. 

During the course of our audit, VBA took action to improve controls over claim 

dates subsequent to the discovery of the problem at the New York VARO. VBA’s 

response to the OIG’s February 2009 report, Review of VA Regional Office 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 11 

Compensation and Pension Benefit Claim Receipt Dates, (Report number 

09-00189-81) stated that, in November 2008, VBA’s Compensation and Pension 

Service began reviewing date of claim accuracy on all Systematic Technical 

Accuracy Reviews (STAR), and that the date-of-claim accuracy reviews will be a 

permanent addition to the STAR program to ensure continued monitoring. 

Entering inaccurate claim dates can result in incorrect eligibility dates used to 

calculate veterans’ benefits or inaccurate reporting of timeliness statistics for all 

pending and completed claims, potentially inflating both employee and VARO 

performance. Further, it impairs the reliability of data used to make management 

decisions. In addition to changes already made by VBA, the OIG made 

recommendations in a recent report to VBA concerning the need to improve 

controls over SHARE claim date reliability. 

Specifically, we recommended that VBA establish accuracy goals to measure and 

monitor claim date reliability and require VAROs to perform a Systematic 

Analysis of Operations to validate SHARE claim date accuracy and adequacy of 

claim date documentation in claims folders. Therefore, we are not making 

additional recommendations for this area in this report, which began prior to both 

the VBA internal review and the subsequent OIG special review of the date of 

claims issue. 

Use of X-ray Machines for Mail Scanning Unlikely to Improve VARO 

Security 

VBA lacks adequate assurance that x-ray mail scanning practices are sufficient 

because VAROs do not scan all incoming mail or inconsistently use X-ray 

machines to scan incoming mail for potential threat objects. Despite Federal 

regulations recommending the use of X-ray technology to scan mail at Federal 

mailrooms, VBA reported that only 29 of the 51 VAROs required to scan 

incoming mail either operate their own X-ray machines or are located in Federal 

buildings where Federal Protective Service (FPS) or GSA personnel scan 

incoming mail. 

In addition, VAROs visited had inconsistent practices for using X-ray machines to 

scan incoming mail and did not provide adequate, recurring training to mailroom 

personnel to ensure that X-ray machine operators are sufficiently skilled to 

identify threat objects that may be embedded in incoming mail. This is occurring 

due to a lack of VBA policies and guidance that govern the acquisition and use of 

X-ray machines as well as training for employees to identify threat objects. As a 

consequence, employees, visitors, and other building occupants could be 

unnecessarily exposed to threat objects introduced through VARO mail 

operations. 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 12 

Federal guidance and VBA policy. 41 CFR, 102-192, Mail Management

prescribes the policies for the efficient, economical, and secure management of 

incoming, internal, and outgoing mail in Federal agencies and recommends the 

x-raying of mail as part of an agency’s mail security plan. According to 41 CFR, 

Part 102-192.85, every Federal agency and agency location that has one or more 

full time personnel processing mail must implement a written mail security plan. 

In addition, 41 CFR Part 102-192 states that mail centers should acquire X-ray 

machines to scan mail if possible, and all mail, regardless of carrier, should be 

x-rayed. If mail volume does not permit this practice, all packages should be 

x-rayed. 

The GSA Mail Center Security Guide was first published in the wake of the 

2001 anthrax attacks, recognizing the increased importance of mail center security. 

This guidance recommends that mail operations acquire X-ray machines to scan 

incoming mail, noting that mail centers are vulnerable to threats including mail 

bombs. It further emphasizes the need for trained X-ray machine operators. VBA 

Mail Managers believe it should be mandatory for all VAROs to have incoming 

mail scanned to comply with Federal requirements. 

In 2001, VBA’s Office of Facilities, Access and Administration (OFAA), formerly 

known as Office of Access Management and Facilities, performed an assessment 

to identify physical security vulnerabilities subsequent to the 2001 terrorism and 

anthrax attacks. The assessment considered physical security at VAROs and 

determined that VAROs with 50 or more Full Time Equivalent Employees (FTEs) 

should enhance their security with the use of X-ray machines for mailroom 

operations. This policy applies to 51 of the 57 VAROs. 

VBA lacks assurance that incoming mail is x-rayed where required. 

According to VBA officials, as of September 2008, only 29 of the 51 VAROs 

required to scan incoming mail used X-ray technology. Twenty-one VAROs 

required to scan incoming mail are located in Federal buildings where FPS or 

GSA personnel scan incoming mail. The remaining eight VAROs operate their 

own X-ray machines to scan incoming mail. This occurred because: 

• VBA has not performed a vulnerability assessment since 2001. As a result, 

VBA lacks current information and reasonable assurance that the current 

standard for determining whether the mix of VAROs (based on the number of 

FTE) that scan incoming mail and those that do not is still appropriate. 

The Office of Facilities, Access and Administration has not provided oversight of 

the deployment of X-ray machines and scanning incoming mail. OFAA could not 

provide information on which VAROs scan incoming mail until after all VAROs 

were queried in response to our initial request for information. 

VAROs do not effectively use X-ray machines. In 2002, VBA provided funds 

to 18 VAROs to purchase X-ray machines based on responses to the 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 13 

2001 vulnerability assessments. Some of the 18 VAROs that received X-ray 

machines as part of VBA’s 2002 deployment either never used them, no longer 

use them, or do not use them to scan all incoming mail for potential threats. 

Interviews with managers from 7 of the 18 VAROs disclosed: 

• Six of the seven VAROs reported that their X-rays were either broken or had 

been made surplus. Two of these seven reported having never used their 

machines because they believed their sites were not at risk. 

• One of seven VAROs reported only using its machine to x-ray what the Chief 

of the Support Services Division termed “suspicious” mail items, which had 

not occurred in more than 2 years. 

Furthermore, VAROs visited did not use their X-ray machines consistently. In 

fact, we found one VARO that did not scan mail for more than 21⁄2 years when its 

machine was no longer operational and chose not to have the machine repaired. 

The VARO did not resume scanning mail until October 2008 when it received a 

new machine. 

VBA has not established national training and certification standards for 

operating mailroom X-ray machines. VBA has not issued guidance to VAROs 

regarding the training, recertification, and testing standards for VARO X-ray 

machine operators to identify threat items that could be introduced into VBA’s 

mail stream. Instead, training for the use of the machines to identify threat items 

has been left to the discretion of individual VAROs. Consequently, the type and 

frequency of training varied across VAROs: 

• At one VARO, initial training for identifying suspicious items was limited to 

using the X-ray machine to scan mail items to identify a lipstick case and a pair 

of sunglasses. 

• At another VARO, recurring training had not been conducted for at least 

4 years. 

• At a third VARO, local VA police provided training in FY 2007. However, 

the VARO could not provide documentation or specifics on the training 

provided. Employees hired after the training in 2007 received no formal 

training. 

• Three VAROs could not provide documentation to show the type of training 

provided to X-ray machine operators. 

In addition, none of the three VAROs identified above used “Threat Image 

Projection” (TIP) software. The GSA Mail Center Security Guide recommends 

that training provided to X-ray machine operators should include identifying mail 

bombs and agencies should consider using software that randomly inserts an 

image of a suspicious object among images of actual letters and packages scanned. 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 14 

TIP is a software program that projects images of threat items onto X-ray images 

of carry-on bags as a way to test the abilities of X-ray operators. TIP can be used 

to help train X-ray machine operators and keep them alert to potential threat items, 

but it can also be used as a method to monitor operator performance. 

GSA guidance emphasizes the need for trained X-ray technicians, noting, that 

“training is necessary to qualify someone to inspect letters and packages by 

X-ray. Basic security procedures listed in 41 CFR includes recognizing and 

reporting suspicious packages and maintaining a log of employee training, 

including regular refresher training. 

An FPS official interviewed indicated that FPS provides X-ray machine scanning 

services, operated primarily by FPS contractors, in hundreds of Federal buildings 

and federally occupied facilities nationwide. The official further indicated that all 

X-ray machines used by FPS and their contractors are required to have TIP 

software installed, and FPS contractors must provide 8 hours of training to X-ray 

machine operators every 3 years. He stated that X-ray machine operators need to 

be well trained, tested, and regularly recertified to be effective and proficient with 

X-ray machines and have the ability to routinely identify threat objects. He 

indicated that some other agencies use web-based training for X-ray operators. 

Despite Federal guidance and the potential threat of dangerous items being 

introduced into its VARO mail stream, VBA has not issued guidance to VAROs 

regarding acquiring, deploying, and using X-ray machines or for the training, 

recertification, and testing standards for VARO X-ray machine operators to 

identify suspicious items. Unless VBA promulgates comprehensive policy or 

guidance to VAROs concerning the use of X-ray machines to scan incoming mail 

and ensure X-ray machine operators receive initial and recurrent training and 

certification, VAROs will continue to be vulnerable to threats that may be 

introduced into the VBA mail stream. 

VBA Mailrooms Not Fully Compliant with Security Requirements 

VBA mailroom operations visited have not fully complied with critical mailroom 

security requirements. Although each of the four VAROs visited had security 

plans, the plans did not include all of the standards needed for the VAROs to have 

effective mail center security programs that would minimize disruptions to mail 

operations from potential threats. The VAROs did not perform annual reviews of 

security plans, which according to Federal guidance should include a risk 

assessment, opening and closing procedures, and continuity of operations plans 

(COOP). VAROs do not routinely update their risk assessments to identify 

changes or current information. 

According to 41 C.F.R. 102-92, Mail Management, all Federal agencies are 

required to have written security plans for mail operations at the agency level and 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 15 

any facility where one or more full time personnel process mail. The mail center 

security plan has many objectives. A few include protecting mail center staff and 

all other employees and building occupants; avoiding unwarranted, costly, and 

disrupting evacuations; and providing a visible mail screening operation. In 

addition, the security plan should be updated whenever circumstances warrant, but 

as a minimum, it is required to be reviewed annually. 

Large agencies must verify that facility security plans have been reviewed at the 

agency level. The agency annual report, signed by the VA Mail Manager and sent 

to GSA, must state that all facility security plans have been reviewed by a 

competent authority within the past year. Appendix B, 41 CFR 102-192, lists 

standards that effective mail center security plans should address. GSA’s 

2004 Security Guide provides additional guidance for developing security plans. 

Security Plan Review. None of the four VAROs visited reviewed their mail 

center security plan at least annually. One VARO manager stated that inadequate 

manpower contributed to their lack of performing annual reviews. 

Risk Assessment. According to the GSA Mail Center Security Guide, the first 

step in developing a security program is a site-specific risk assessment for mail 

centers and their operations. The purpose of a risk assessment is to determine the 

likelihood that identifiable threats will harm a Federal agency or its mission. The 

GSA Mail Center Security Guide describes a risk assessment as a snapshot in time 

that needs to be updated whenever operations change or there are significant 

changes in the organization. 

• One VARO was not able to provide any documentation showing a risk 

assessment, had been performed prior to May 2008. The VARO’s security 

plan specified risk assessments are to be performed January of each year. 

• One VARO had not completed a risk assessment, as suggested by GSA, on 

their mailroom operations, since 1995. 

• Two VAROs provided risk assessments dated March 2008. 

Physical Security. According to 41 CFR, Part 102-192, Mail Management, 

Appendix B, mail center managers should develop detailed procedures for opening 

and closing the mail center. The procedures should include the use of checklists, 

which should be posted and signed daily. GSA’s Mail Center Security Guide 

provides guidance covering the mailroom checklist that includes the securing of 

postage meters and other assets. 

None of the four VAROs included opening and closing procedures in their 

security plans or had any written opening and closing procedure checklists. In 

addition, two of the VAROs did not secure their postage meters after business 

hours to prevent unauthorized use and one VARO did not maintain adequate 

control and accountability of postage stamps. During business hours, the VARO 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 16 

kept stamps in an unlocked cabinet accessible to non-mailroom personnel. In 

addition, the mailroom personnel did not perform reconciliations of stamps. 

Continuity of Operations Plans. According to 41 CFR, Part 102-192, Mail 

Management, Appendix B, managers should have a written continuity of 

operations plan (COOP) to deal with emergency situations. The plan should 

include current contact information; the location and contents of a “fly-away” kit; 

and quarterly testing of the COOP. According to GSA, a “fly-away” kit should, at 

a minimum, consist of COOP checklists, key contact lists, diskettes or CDs with 

critical files, any specialized tools that are routinely used, maps to alternate sites, 

and any other information and equipment related to an emergency operation.

• At one VARO, the COOP did not contain current contact information. For 

example, the COOP did not list the current incumbent serving as the Chief, 

Support Services Division as the emergency preparedness coordinator and the 

point of contact for Administrative, Security, Building and Facilities, and 

Failure Assessment. 

• At three of the four VAROs, their COOP did not list the location and contents 

of “fly-away” kits. 

• None of the four VARO mailrooms conducted required quarterly tests of their 

COOP. 

Although VAROs received instructions from OFAA in 2006 to follow 41 CFR, 

mailroom managers claimed to be unaware of the requirements. OFAA Mail 

Managers are responsible for ensuring VAROs have mailroom security plans and 

that the plans are in compliance with 41 CFR. OFAA did not provide sufficient 

oversight to ensure that VARO mailroom security plans were meeting all 

requirements. OFAA Mail Managers acknowledged responsibility for reviewing 

VARO mailroom security plans; however, the managers did not identify any of the 

missing elements we identified. The Mail Managers stated they do not perform 

comprehensive or detailed reviews of mailroom security plans because they are 

unable to devote the time, nor do they have the staff necessary to fulfill this duty. 

Conclusion 

VBA has adequately addressed our concerns by establishing controls to ensure 

that important claim-related documents are not improperly discarded, and 

establishing new procedures to test the accuracy of claim dates. Nevertheless, 

improvements need to be made in mailroom operations to ensure that a higher 

percentage of incoming claims are put under timely control. VARO security could 

also be improved by more effectively using X-ray machines to scan incoming mail 

and implementing guidance in accordance with recommended, government-wide 

mailroom security standards and guidelines. Until VBA completes the actions 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 17 

necessary to address these issues, VBA cannot be assured claims are being 

processed in a timely manner and government property, VARO employees, 

visitors, and other tenants are protected from unnecessary risks. 

Recommendations 

1. We recommend the Under Secretary for Benefits require VAROs to implement 

procedures to identify, analyze, monitor, and take actions to address conditions 

contributing to delays in establishing control of incoming claims within VBA’s 

7-day requirement. 

2. We recommend the Under Secretary for Benefits develop and issue policy 

guidance to establish VARO requirements to scan incoming mail and how 

VARO X-ray machines should be used to improve security. 

3. We recommend the Under Secretary for Benefits develop and issue policy and 

standards concerning initial and recurring training and certification 

requirements for personnel who operate X-ray machines to scan incoming mail 

at VBA facilities. 

4. We recommend the Under Secretary for Benefits develop and issue policy 

guidance for all VAROs regarding mailroom physical security based on 

requirements enumerated in 41 CFR, Part 192, Mail Management, and in the 

GSA Mail Center Security Guide. 

5. We recommend the Under Secretary for Benefits issue guidance establishing 

the minimum interval for updating VBA mailroom security plan risk analyses. 

Management Comments and OIG Response 

The Under Secretary for Benefits concurred with our findings and 

recommendations. VBA will revise and/or issue new policy and guidance in the 

areas of improving control over establishing new claims, and addressing mailroom 

security requirements and lapses noted during the audit, including the use of X-ray 

machines to scan incoming mail for threat items. We incorporated VBA’s 

technical comments to our report where appropriate. 

VBA should be commended for taking proactive actions in advance of issuance of 

this report to address some of the concerns uncovered during the audit and as a 

result of previous OIG and internal VBA reviews. In particular, in November 

2008, VBA officials put new controls in place to help ensure applications for 

benefits and other official documentation are not improperly destroyed in response 

to work uncovered during the audit and briefings provided to senior VA and VBA 

management. In addition, during the course of our audit, VBA took action to 
Audit of VA Regional Office Claim–Related Mail Processing 

VA Office of Inspector General 18 

improve controls over claim dates subsequent to the discovery of the problem at 

the New York VARO and in response to a February 2009 OIG report. 

Therefore, for both of these areas, no additional recommendations were provided 

to VBA. Planned corrective actions for our recommendations were responsive to 

our concerns and we will close the recommendations when all proposed actions 

have been completed by VBA. Appendix D contains the full text of the Under 

Secretary’s comments. 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix A 

VA Office of Inspector General 19 

Scope and Methodology 

We evaluated claim-related mail processing and management of mailroom 

operations at four VAROs (St. Petersburg, FL; St. Louis, MO; Detroit, MI; and 

Waco, TX). We selected St. Petersburg, FL, and Waco, TX VAROs because they 

had the highest volume of completed claims in FY 2007 (11.5 percent of all rating 

claims completed) that together accounted for a significant percentage of mail 

processed within VBA nationwide. We chose VAROs in St. Louis, MO, and 

Detroit, MI because they accounted for a minimum of at least 1 percent of all 

claims completed in FY 2007, but consistently performed below VBA’s control 

time standard. 

To determine whether claim-related documents that could affect benefits or were 

required to be retained for record-keeping purposes were inappropriately 

discarded, we analyzed the contents of shred bins in or near Triage Team areas at 

the four VAROs visited. After identifying documents that appeared to have been 

inappropriately placed in the shred bins, other sources of claim documentation 

were searched. This included claim folders and/or electronic systems such as 

SHARE, Modern Award Processing-Development (MAP-D), and Control of 

Veterans Records System (COVERS). We did this search to determine whether 

the documents found in the shred bins had been received and recorded and 

whether there was evidence that any action had been taken in response to the 

information contained in those records. 

We also reviewed a statistical sample of 240 compensation benefits claims to 

determine whether the VAROs used the correct dates to establish the claims and 

analyzed whether causes for claims not established within 7 days of receipt were 

avoidable. We subsequently dropped 2 of the 240 claims because we determined 

they were not within the scope of our review. Of the 238 claims, 120 were not 

established within 7 days of receipt. We analyzed these 120 claims to determine 

whether causes for claims not established within 7 days of receipt were avoidable. 

For each claim, the date of claim contained in claims folders was compared with 

the date of claim reported in VETSNET Operations Reports (VOR). VSC 

managers and coaches were also interviewed to determine causes for errors and 

claims not established in a timely manner. In addition, at each VARO visited, we 

selected separate pieces of outgoing mail to determine if the mail was processed in 

a way that provided reasonable assurance veterans’ PII was not released 

inappropriately. 

We conducted this performance audit in accordance with generally accepted 

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

the audit to obtain sufficient, appropriate evidence to provide a reasonable basis 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix A 

VA Office of Inspector General 20 

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

the evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix B 

VA Office of Inspector General 21 

Other Matters Identified and Impacting Specific 

VARO Mailroom Operations 

St. Louis VARO Mailroom Did Not Adequately Protect Personally 

Identifiable Information 

The St. Louis VARO did not adequately protect PII contained on documents 

awaiting destruction or have effective measures in place to prevent the release of 

PII on outgoing FedEx address labels. Mailroom personnel placed documents 

containing PII in three large, open bins located in the loading dock area of the 

VARO mailroom. The bins held potentially thousands of documents awaiting 

destruction. Some examples of the documents found in the bins were COVERS 

print outs and veterans’ medical examination reports. In addition, we discovered 

an additional 60 COVERS print outs in a box next to computer equipment 

awaiting disposition. Each COVERS document contained a veteran’s name, social 

security, and VA claim number. 

We reviewed copies of all FedEx labels (141) used on outgoing mail, dated 

June 2 through July 2, 2008, to determine whether the labels inappropriately 

contained PII. We identified nine FedEx labels that inappropriately listed 

veterans’ names and social security or VA claim numbers. After we informed 

VARO management of the issue, they conducted an internal review and 

determined one VARO employee had prepared these labels for shipment of claims 

folders to VA’s Board of Veterans Appeals. 

According to VARO management, it was common practice for mailroom 

operations to place documents containing PII in the large bins located in the 

loading dock area. This practice exposed PII to theft by non-VA personnel who 

are not always escorted in the mailroom area. A VARO representative stated that 

the new procedures VBA implemented should ensure VARO employees do not 

inappropriately discard claim-related documents. Documents awaiting destruction 

that contain PII are now placed in secured bins inside the offices of VARO 

supervisors. In addition, the VARO counseled and provided training to the 

employee who inappropriately included PII on FedEx labels. We consider the 

actions taken acceptable and the issue to be resolved. Therefore, we are not 

making additional recommendations for this issue. 

VARO Mailrooms Inconsistently Follow Required Procedures for 

Handling Negotiable Instruments 

Two VAROs visited did not consistently follow required procedures for 

processing negotiable instruments, such as endorsed checks, money orders, or 

drafts received in and opened by mail room personnel. VARO mailroom staff did 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix B 

VA Office of Inspector General 22 

not submit negotiable instruments found in incoming mail to designated personnel, 

prepare duplicate registry logs used to record receipt of negotiable instruments, 

initial the registry logs, and perform reconciliations of the registry logs. 

• At one VARO, when mail clerks found negotiable instruments in the incoming 

mail, they placed them in a tray accessible by non-mailroom personnel for 

login later instead of giving them to the designated mail clerk. 

• At two VAROs, both the mail clerks who find negotiable instruments in the 

incoming mail and the registry log-in mail clerk were not initialing the registry 

log as required. 

• Reconciliations of the duplicate registry logs maintained by one VARO 

mailroom and the original registry log signed and returned from the agent 

cashier were not performed to check for accuracy. The reconciliation could 

not be accomplished because the original registry log was given to the agent 

cashier and the mailroom did not make a duplicate to compare to the original. 

According to VBA Manual M23-1, Chapter 1, Mail Management, mailroom 

personnel that find a negotiable instrument in the incoming mail are to take the 

instrument to the mail clerk assigned to perform the log-in function. Both are 

required to initial the registry log, which is to be prepared in duplicate. Mail 

operations maintain a duplicate of the registry log and submit the original to the 

agent cashier who signs and returns it. The mail operations supervisor or another 

employee who was not responsible for the log-in function compares the original 

with the duplicate to determine accuracy. 

VARO mailroom staff received initial training for processing negotiable 

instruments; however, the VAROs did not provide recurring training to ensure 

staff stays familiar with and understands the policy. We found:

• At one VARO, mailroom staff did not follow prescribed policy because the 

supervisor misinterpreted the requirements and therefore, established incorrect 

procedures. 

• At another VARO, mailroom staff continued to follow long established local 

procedures for processing negotiable instruments and were not aware that local 

procedures were not compliant with policy. 

Not following the procedures for processing negotiable instruments increases the 

probability that lost or stolen negotiable instruments will go undetected. In 

addition, beneficiaries may not receive credit for repaying or returning excess 

benefit payments. We reported this issue to VARO management during our site 

visit and at the exit briefing with VBA management. Therefore, we have no 

further recommendations. 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix C 

VA Office of Inspector General 23 

VBA National Control Time Performance 

The data presented below indicates the percentage of claims placed under control 

within seven days for FYs 2007 and 2008. The list is ordered by VARO from 

highest to lowest percentage for FY 2008. VBA’s national performance standard 

is 80 percent. 

VARO 2007 2008 VARO (cont’d) 2007 2008 

1 Sioux Falls, SD 93.6% 94.3% 30 Houston, TX 83.6% 84.5% 

2 Fargo, ND 84.8% 93.3% 31 Cleveland, OH 73.6% 84.2% 

3 Louisville, KY 87.3% 92.6% 32 Huntington, WV 87.7% 83.8% 

4 Ft. Harrison, MT 90.1% 91.8% 33 Little Rock, AR 83.7% 83.8% 

5 White River Junction, VT 91.0% 90.8% 34 Salt Lake City, UT 69.0% 83.8% 

6 Muskogee, OK 90.9% 89.8% 35 Los Angeles, CA 74.0% 83.5% 

7 Indianapolis, IN 87.9% 89.1% 36 San Diego, CA 81.3% 83.5% 

8 Reno, NV 88.5% 88.8% 37 Montgomery, AL 77.2% 82.8% 

9 Manila, PI 88.7% 88.5% 38 Columbia, SC 88.5% 82.6% 

10 St. Petersburg, FL 84.9% 88.5% 39 National Average 82.9% 82.4% 

11 Winston-Salem, NC 89.0% 88.5% 40 Pittsburgh, PA 68.1% 81.9% 

12 Providence, RI 90.2% 88.1% 41 Albuquerque, NM 86.5% 81.3% 

13 Boise, ID 88.5% 87.9% 42 Seattle, WA 82.7% 81.3% 

14 Phoenix, AZ 83.0% 87.9% 43 Lincoln, NE 85.7% 81.1% 

15 Hartford, CT 82.0% 87.7% 44 New Orleans, LA 76.9% 80.8% 

16 Boston, MA 78.7% 87.6% 45 Roanoke, VA 86.3% 80.7% 

17 Portland, OR 81.7% 87.6% 46 Jackson, MS 60.4% 79.3% 

18 Denver, CO 87.8% 87.4% 47 Milwaukee, WI 85.6% 78.5% 

19 Buffalo, NY 82.4% 87.2% 48 Oakland, CA 82.0% 77.4% 

20 Anchorage, AK 85.5% 86.7% 49 Honolulu, HI 75.4% 77.2% 

21 Waco, TX 86.5% 86.5% 50 Newark, NJ 84.2% 76.4% 

22 Nashville, TN 83.6% 86.4% 51 St. Louis, MO 86.0% 76.2% 

23 Wichita, KS 80.7% 86.2% 52 Philadelphia, PA 83.4% 75.8% 

24 Togus, ME 92.7% 85.9% 53 Wilmington, DE 91.1% 75.5% 

25 Des Moines, IA 80.6% 85.4% 54 St. Paul, MN 90.3% 68.4% 

26 San Juan, PR 87.0% 84.9% 55 Detroit, MI 83.5% 64.0% 

27 Manchester, NH 86.4% 84.8% 56 Baltimore, MD 77.6% 61.8% 

28 Atlanta, GA 83.9% 84.7% 57 New York, NY 79.9% 48.6% 

29 Chicago, IL 83.4% 84.5% 58 Washington, DC 44.2% 34.2% 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix D 

Under Secretary for Benefits Comments

VA Office of Inspector General 24 

Department of MEMORANDUM

Veterans Affairs 

Date: September 14, 2009 

From: Under Secretary for Benefits (20) 

Subj: OIG Draft Report— Audit of VA Regional Office Claim-Related Mail Processing 

 —WebCIMS 436807 

To: Assistant Inspector General for Audit (52) 

1. Attached are VBA's comments to OIG's Draft Report: Audit of VA Regional Office 

Claim-Related Mail Processing. 

2. Questions may be referred to Nancy Holly, Program Analyst, at 461-9199. 

(original signed by:) 

 P. W. Dunne 

Attachment 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix D 

VA Office of Inspector General 25 

Attachment: 

VBA COMMENTS TO OIG DRAFT REPORT 

Audit of VA Regional Office Claim-Related Mail Processing 

VBA provides the following technical comments on OIG's draft report: 

Page i, 2nd bulleted paragraph from the bottom; and Page 1, last bulleted paragraph: 

"In July 2007, the Detroit VARO reported that almost 16,000 pieces of 

unprocessed mail that were apparently being held by VARO employees. They 

included an estimated 700 claims not put under proper control and 2,700 medical 

records and/or pieces of medical information not in VBA information systems or 

associated claims files." 

VBA Comment: We request that this paragraph be revised in both the Executive 

Summary and the report to clearly indicate that the remaining 79 percent of the 

16,000 pieces of mail in Detroit was drop-file mail requiring no action by the regional 

office except to be filed in the claims record. Without that clarification, this paragraph 

is misleading. 

Page iii, 1st paragraph: 

Entire paragraph beginning "The date of receipt for claim-related documents was 

not always entered correctly." 

VBA Comment: This paragraph leads with and therefore gives primary focus to a 

problem that was uncovered during an internal review conducted by VBA and that 

was the subject of a previous OIG report. We do not believe it is necessary to 

continue to include those findings in the executive summary of this report, particularly 

when this audit found any incorrect dates to be unintentional and the result of human 

error. 

Page iii, Conclusion: 

"In addition, improvements are needed to ensure that ...important claim-related 

documents are not improperly discarded." 

VBA Comment: This statement is not supported by the full report, which states that 

VBA took appropriate action to address this problem. Spot checks of the shred binds 

located at the St. Petersburg RO showed full compliance with the new VBA 

procedures. The report concludes VBA took actions to help ensure that important 

claims-related documents are not improperly discarded. The Executive Summary

should be changed to reflect the findings and conclusion recorded in the report. 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix C 

VA Office of Inspector General 26 

Page 8, last paragraph: 

VAROs could improve control time proficiency by establishing procedures to 

identify, analyze, and monitor conditions that contribute to the delays in 

establishing control of claims. Because VAROs did not have procedures in 

place to identify, analyze, and monitor conditions recurring deficiencies and 

address inadequate workflow practices that contribute to avoidable delays, 

managers did not prevent the delay in placing 103 (86 percent) of 120 claims 

under control within 7 days. 

VBA Comment: VBA has established policies, guidance and rules designed to 

monitor, analyze and take action to address conditions that result in processing 

delays. The deficiencies identified by the OIG occurred when these practices were 

not followed. 

Page 9, 2nd paragraph: 

Entire paragraph beginning "In September 2008" through "and all errors appeared 

unintentional but one." 

VBA Comment: We do not believe it is necessary to continue to highlight findings

from a previous OIG review. 

Page 10, Table 3. Potential Effects Resulting from Claim Date Inaccuracies: 

VBA Comment: OIG identified 5 of 238 cases with an incorrect date of claim that 

"could affect benefit payment." We request that this finding be amended to reflect the 

number of cases, if any, that payments were affected. If none, please make that 

clear. 

Page 18, Conclusion: 

"VBA's practices for tracking control data and handling critical documents call into 

question the validity of VARO-reported timeliness statistics, could result in delay 

of benefits to veterans, and indicates that VARO mailroom operations are highrisk areas." 

VBA Comment: This statement attributes the problems found to "VBA's practices". 

We believe it more appropriate to discuss the problems in terms of deficiencies in 

following appropriate policies and procedures rather than presenting them as 

"practices." We object to the implication that we have established practices that 

produce these undesirable results. 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix C 

VA Office of Inspector General 27 

Recommendation 1: We recommend the Under Secretary for Benefits require 

VAROs to implement procedures to identify, analyze, monitor, and take actions to 

address conditions contributing to delays in establishing control of incoming claims 

within VBA's 7-day requirement. 

VBA Response: Concur. VBA has established guidance designed to monitor, 

analyze and take action to address conditions that result in delays to establish control 

of incoming claims. VBA will revise M21-4, Manpower Control and Utilization in 

Adjudication, to ensure workload management plans incorporate control time reviews 

in order prevent delays in claims establishment. Compliance with VBA guidance is 

reviewed during Compensation & Pension site visits and through announced and 

unannounced site visits conducted by Area Offices. 

Target Completion Date: November 1, 2009. 

Recommendation 2: We recommend the Under Secretary for Benefits develop and 

issue policy guidance to determine which VAROs should scan incoming mail and 

how VARO x-ray machines should be used to improve security. 

VBA Response: Concur. VBA will provide interim policy guidance to locations that 

currently have x-ray machines. VA's Director of Records Management Service, will 

form a working group to develop the VA mail security policy. This policy will be 

applicable VA wide. 

Target Completion Date: November 1, 2009 (VBA interim policy guidance). 

Recommendation 3: We recommend the Under Secretary for Benefits develop and 

issue policy and standards concerning initial and recurring training and certification 

requirements for personnel who operate x-ray machines to scan incoming mail at 

VBA facilities. 

VBA Response: Concur. Training will be provided to personnel who currently 

operate x-ray machines to scan incoming mail at VBA facilities. Policy standards 

concerning initial and recurring training and certification requirements will be 

developed concurrently with the Department mail security policy. 

Target Completion Date: November 1, 2009 (Initial training) 

Recommendation 4: We recommend the Under Secretary for Benefits develop and 

issue policy guidance for all VAROs regarding mailroom physical security based on 

requirements enumerated in 41 CFR, Part 192, Mail Management, and in the GSA 

Mail Center Security Guide. 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix D 

VBA Response: Concur. VBA will provide interim policy guidance to all VAROs 

regarding mailroom physical security based on requirements specified in 41 CFR, 

Part 192, Mail Management, and in the GSA Mail Center Security Guide. 

Final policy guidance will be implemented upon development by the VA Mail 

Manager. Additionally, VBA will coordinate with the Office of Operations, Security 

and Preparedness to develop a plan for an annual review of VARO mail security 

plans by a security subject matter expert, as required by 41 CFR § 102-192.70 (e). 

Target Completion Date: November 1, 2009 (VBA interim policy guidance). 

Recommendation 5: We recommend the Under Secretary for Benefits issue 

guidance establishing the minimum interval for updating VBA mailroom security plan 

risk analyses. 

VBA Response: Concur. VBA will issue policy guidance establishing the 

requirement for an annual mailroom security plan risk assessment, as required by 

41 CFR, Part 192, Mail Management. 

Target Completion Date: November 1, 2009 

VA Office of Inspector General 28 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix E 

OIG Contact and Staff Acknowledgments 

OIG Contact Timothy Crowe 

(727) 395-2422 

Acknowledgments Berry Ward 

Kristine Abramo 

Dennis Capps 

Charles Chiarenza 

Melissa Colyn 

Kristopher Kasey 

Johnny McCray 

Lee Giesbrecht

VA Office of Inspector General 29 
Audit of VA Regional Office Claim–Related Mail Processing 

Appendix F 

Report Distribution 

VA Distribution

Office of the Secretary 

Veterans Benefits Administration 

Assistant Secretaries 

Office of General Counsel 

Directors, VBA Regional Offices 

VBA Area Directors 

Non-VA Distribution

House Committee on Veterans’ Affairs 

House Appropriations Subcommittee on Military Construction, Veterans Affairs, 

 and Related Agencies 

House Committee on Oversight and Government Reform 

Senate Committee on Veterans’ Affairs 

Senate Appropriations Subcommittee on Military Construction, Veterans Affairs, 

 and Related Agencies 

Senate Committee on Homeland Security and Governmental Affairs 

National Veterans Service Organizations 

Government Accountability Office 

Office of Management and Budget 

This report will be available in the near future on the OIG’s Web site at 

http://www.va.gov/oig/publications/reports-list.asp. This report will remain on the 

OIG Web site for at least 2 fiscal years after issue. 

VA Office of Inspector General 30