Testimony 

Before the Subcommittee on Oversight 

and Investigations, Committee on 

Veterans' Affairs, House of 

Representatives

United States General Accounting Office 

GAO

For Release on Delivery 

Expected at 10:00 a.m. EST 

Wednesday, March 17, 2004 COMPUTER-BASED 

PATIENT RECORDS 

Sound Planning and Project 

Management Are Needed to 

Achieve a Two-Way 

Exchange of VA and DOD 

Health Data 

Statement of Linda D. Koontz 

Director, Information Management Issues 

GAO-04-402T 
www.gao.gov/cgi-bin/getrpt?GAO-04-402T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Linda D. 

Koontz at (202) 512-6240 or 

koontzl@gao.gov. 

Highlights of GAO-04-402T, testimony 

before the Subcommittee on Oversight 

and Investigations, House Committee on 

Veterans' Affairs 

March 17, 2004

COMPUTER-BASED PATIENT RECORDS

Sound Planning and Project Management 

Are Needed to Achieve a Two-Way 

Exchange of VA and DOD Health Data 

Since November, VA and DOD have made little progress in determining their 

approach for achieving the two-way exchange of patient health data. 

Department officials recognize the importance of an architecture to 

articulate how they will electronically interface their health systems, but 

continue to rely on a nonspecific, high-level strategy—in place since 

September 2002—to guide their development and implementation of this 

capability (see figure). 

High-Level Strategy Intended To Allow Two-Way Exchange of Health Data 

----- Under Development

Developed

DOD data 

repository

Electronic 

Interface 

DOD Health 

Information 

System 

VA Health 

Information 

System 

VA data 

repository

----- Under Development

Developed

DOD data 

repository

Electronic 

Interface 

DOD Health 

Information 

System 

VA Health 

Information 

System 

VA data 

repository

Source: VA and DOD 

VA officials stated that an initiative begun this month to satisfy a mandate of 

the Bob Stump National Defense Authorization Act for Fiscal Year 2003 will 

be used to better define the electronic interface needed to exchange patient 

health data. However, this project is at an early stage, and the departments 

have not yet fully identified the approach or requirements for this 

undertaking. Given these uncertainties, there is little evidence of how this 

project will contribute to defining a specific architecture and technological 

solution for achieving the two-way health data exchange. 

These uncertainties are further complicated by the absence of sound project 

management to guide the departments’ actions. At present, neither 

department has the authority to make final decisions binding on the other, 

and day-to-day oversight of the joint initiative to develop an electronic 

interface is limited. Progress toward defining data standards continues, but 

delays have occurred in the development and deployment of the agencies’ 

individual health information systems. 

A critical component of the 

Department of Veterans Affairs’ 

(VA) information technology 

program is its ongoing work with 

the Department of Defense (DOD) 

to achieve the ability to exchange 

patient health care data and create 

electronic records for use by 

veterans, active military personnel, 

and their health care providers. 

GAO testified before the 

Subcommittee last November that 

one-way sharing of data, from DOD 

to VA medical facilities, had been 

realized. At the Subcommittee’s 

request, GAO assessed, among 

other matters, VA’s and DOD’s 

progress since that time toward 

defining a detailed strategy for and 

developing the capability of a twoway exchange of patient health 

information. 
Page 1 GAO-04-402T 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to participate in continuing discussions of 

the Department of Veterans Affairs’ (VA) information technology program. 

My testimony focuses on a critical aspect of that program—VA’s work 

with the Department of Defense (DOD) to achieve the ability to exchange 

patient health care data and create an electronic medical record for 

veterans and active duty military personnel. As you are well aware, having 

readily accessible medical data on these individuals—many of whom are 

highly mobile and may have health records at multiple medical facilities 

within and outside of the United States—is important to providing highquality health care to them and to adjudicating any disability claims that 

they may have. VA and DOD have been pursuing ways to share data in 

their health information systems and create electronic records since 1998, 

yet accomplishing a two-way health data exchange has been elusive. 

When we testified on this initiative last November,1

 VA and DOD had 

achieved a measure of success in sharing data through the one-way 

transfer of health information from DOD to VA health care facilities.2

 Yet 

VA and DOD faced significant challenges and were far from realizing a 

longer term objective: providing a virtual medical record based on the twoway exchange of data, as part of their HealthePeople (Federal) initiative. 

The departments had not clearly articulated a common health information 

architecture, and lacked the details and specificity essential to determining 

how they would achieve this capability. 

At your request, my testimony will discuss our review of VA’s and DOD’s 

actions since November toward defining a detailed strategy and 

developing the capability for a two-way exchange of patient health 

information. In addition, I will provide an update on actions that the 

departments have taken to address recommendations resulting from prior 

 1

U.S. General Accounting Office, Computer-Based Patient Records: Short-Term Progress 

Made, but Much Work Remains to Achieve a Two-Way Data Exchange Between VA and 

DOD Health Systems, GAO-04-271T (Washington, D.C.: November 19, 2003). 

2

The one-way transfer of health care data from DOD to VA is being accomplished as part of 

the Federal Health Information Exchange initiative. 
Page 2 GAO-04-402T 

reviews of their efforts to share medical data,3 including those articulated 

in the May 2003 report of the President’s task force on the development of 

electronic medical records.4

In conducting this work, we analyzed key documentation supporting VA’s 

and DOD’s strategy for developing and implementing the two-way 

electronic exchange of health data, including deployment and conversion 

plans, project schedules, and status reports for their individual health 

information systems. In addition, we reviewed documentation to identify 

the costs incurred by VA and DOD in developing technology to support the 

sharing of health data, including costs associated with the government 

computer-based patient record and federal health information exchange 

initiatives, and with VA’s and DOD’s ongoing projects to develop new 

health information systems. We supplemented our analyses with 

interviews of VA and DOD officials responsible for key decisions and 

actions on the initiatives. Further, we analyzed documentation and 

interviewed relevant VA and DOD officials to determine actions that have 

been taken to address our previous recommendations related to the 

government computer-based patient record initiative and those contained 

in the President’s task force report. We did not verify the departments’ 

reported actions in response to the President’s task force 

recommendations. We performed our work in accordance with generally 

accepted government auditing standards, from December 2003 through 

March of this year. 

Since November, VA and DOD have made little progress toward defining 

how they intend to achieve the two-way exchange of patient health data 

under the HealthePeople (Federal) initiative. Although VA officials 

recognize the importance of having an architecture to describe in detail 

how they plan to develop an electronic interface between their health 

information systems, they acknowledged that the departments’ actions are 

continuing to be driven by a less-specific, high-level strategy that has been 

in place since September 2002. VA and DOD officials stated that they 

 3

U.S. General Accounting Office, Veterans Affairs: Sustained Management Attention Is 

Key to Achieving Information Technology Results, GAO-02-703 (Washington, D.C.: June 

12, 2002) and Computer-Based Patient Records: Better Planning and Oversight By VA, 

DOD, and IHS Would Enhance Health Data Sharing, GAO-01-459 (Washington, D.C.: April 

30, 2001). 

4

President’s Task Force to Improve Health Care Delivery For Our Nation’s Veterans, Final 

Report (Washington, D.C.: May 26, 2003). 

Results in Brief 
Page 3 GAO-04-402T 

intend to rely on an initiative being undertaken this month to satisfy a 

mandate of the Bob Stump National Defense Authorization Act for Fiscal 

Year 20035

 to better define the electronic interface needed to exchange 

patient health information. However, this project is at an early stage, and 

the departments have not yet fully determined the approach or 

requirements for this undertaking. Given these uncertainties, there is little 

evidence as to whether and how this project will contribute to defining an 

explicit architecture and technological solution for achieving the two-way 

exchange of patient health information. 

Adding to the challenge and uncertainties of developing the electronic 

interface is that VA and DOD have not fully established a project 

management structure to ensure the necessary day-to-day guidance of and 

accountability for the departments’ investment in and implementation of 

this capability. Although maintaining that they are collaborating on this 

initiative through a joint working group and receiving oversight from 

executive-level councils, neither department has had the authority to make 

final project decisions binding on the other. Further, the departments are 

operating without a project management plan describing the specific 

responsibilities of VA and DOD in developing, testing, and deploying the 

interface. In the absence of an explicit architecture and critical project 

management, VA and DOD are progressing slowly in their development of 

this important technology. The departments have continued to define data 

standards that are essential to facilitating the exchange of data, but have 

experienced delays in key milestones associated with the development 

and deployment of their individual health information systems. Such 

delays call into question the departments’ ability to meet their target date 

for beginning to exchange patient health information in 2005. 

Both the President’s task force and we have made multiple 

recommendations aimed at improving VA’s and DOD’s success in 

undertaking projects intended to achieve the electronic exchange of 

patient health records. For example, the task force recommended 

developing and deploying, by fiscal year 2005, electronic medical records 

that are interoperable, bidirectional, and standards-based. The 

departments reported that they are currently in various stages of acting on 

the specific recommendations that the task force made for providing 

timely, high-quality care through effective electronic sharing of health 

information. Beyond this, we previously recommended that, among other 

 5

P.L. 107-314, sec. 724 (2002). 
Page 4 GAO-04-402T 

actions, VA and DOD designate a lead entity with final decisionmaking 

authority and establish a clear line of authority for the earlier, near-term 

government computer-based patient record project. In line with our 

recommendations, VA and DOD made overall management and 

accountability enhancements that could provide lessons learned for 

improving the departments’ approach to successfully accomplishing the 

longer term initiative to develop a two-way health information exchange. 

In 1998 VA and DOD, along with the Indian Health Service (IHS), began an 

initiative to share patient health care data, called the government 

computer-based patient record (GCPR) project. At that time, each agency 

collected and maintained patient health information in separate systems, 

and their health facilities could not electronically share patient health 

information across agency lines. GCPR was envisioned as an electronic 

interface that would allow physicians and other authorized users at VA, 

DOD, and IHS health facilities to access data from any of the other 

agencies’ health facilities. The interface was expected to compile 

requested patient information in a “virtual” record that could be displayed 

on a user’s computer screen. 

In reporting on the initiative in April 2001,6

 we raised doubts about GCPR’s 

ability to provide expected benefits. We noted that the project was 

experiencing schedule and cost overruns and was operating without clear 

goals, objectives, and consistent leadership. We recommended that the 

participating agencies (1) designate a lead entity with final decisionmaking 

authority and establish a clear line of authority for the GCPR project, and 

(2) create comprehensive and coordinated plans that included an agreedupon mission and clear goals, objectives, and performance measures, to 

ensure that the agencies could share comprehensive, meaningful, 

accurate, and secure patient health care data. VA, DOD, and IHS agreed 

with our findings and recommendations. 

In March 2002, however, we again reported that the project was continuing 

to operate without clear lines of authority or a lead entity responsible for 

final decisionmaking.7

 Further, the project continued to move forward 

 6

GAO-01-459. 

7

U.S. General Accounting Office, VA Information Technology: Progress Made, but 

Continued Management Attention Is Key to Achieving Results, GAO-02-369T

(Washington, D.C.: March 13, 2002). 

Background 
Page 5 GAO-04-402T 

without comprehensive and coordinated plans and an agreed-upon 

mission and clear goals and measures. In addition, the participating 

agencies had announced a revised strategy that was considerably less 

encompassing than the project was originally intended to be. For example, 

rather than serve as an interface to allow data sharing across the three 

agencies’ disparate systems, as originally envisioned, the revised strategy 

initially called only for a one-way transfer of data from DOD’s current 

health care information system to a separate database that VA hospitals 

could access. In further reporting on this initiative in June 2002, we 

recommended that VA, DOD, and IHS revise the original goals and 

objectives of the project to align with their current strategy, commit the 

executive support necessary to adequately manage the project, and ensure 

that it followed sound project management principles.8

In September 2002 we reported that VA and DOD had made some progress 

toward electronically sharing patient health data.9

 The two departments 

had renamed the project the Federal Health Information Exchange (FHIE) 

program and, consistent with our prior recommendation, had finalized a 

memorandum of agreement designating VA as the lead entity for 

implementing the program. With this agreement, FHIE became a joint 

effort between VA and DOD to achieve the exchange of health care 

information in two phases. The first phase, completed in mid-July 2002, 

enabled the one-way transfer of data from DOD’s existing health 

information system to a separate database that VA hospitals could access. 

A second phase, finalized earlier this month, completed VA’s and DOD’s 

efforts to add to the base of patient health information available to VA 

clinicians via this one-way sharing capability. VA and DOD reported total 

FHIE costs of about $85 million through fiscal year 2003. 

The revised strategy also envisioned VA and DOD pursuing a longer term, 

two-way exchange of health information. This initiative, known as 

HealthePeople (Federal), is premised upon the departments’ development 

of a common health information architecture comprising standardized 

data, communications, security, and high-performance health information 

systems. The joint effort is expected to result in the secured sharing of 

health data required by VA’s and DOD’s health care providers between 

 8

GAO-02-703. 

9

U.S. General Accounting Office, VA Information Technology: Management Making 

Important Progress In Addressing Key Challenges, GAO-02-1054T (Washington, D.C.: 

September 26, 2002). 
Page 6 GAO-04-402T 

systems that each department is currently developing—DOD’s Composite 

Health Care System II (CHCS II) and VA’s HealtheVet VistA. 

DOD began developing CHCS II in 1997 and has completed its associated 

clinical data repository that is key to achieving an electronic interface. 

DOD expects to complete deployment of all of its major system 

capabilities by September 2008.10 The department reported expenditures of 

about $464 million for the system through fiscal year 2003. VA began work 

on HealtheVet VistA and its associated health data repository in 2001, and 

expects to complete all six initiatives that make up this system in 2012.11

VA reported spending about $120 million on HealtheVet VistA through 

fiscal year 2003. 

Under the HealthePeople (Federal) strategy, VA and DOD envision that, 

upon entering military service, a health record for the service member will 

be created and stored in DOD’s CHCS II clinical data repository. The 

record will remain in the clinical data repository and be updated as the 

service member receives medical care. When the individual separates from 

active duty and, if eligible, seeks medical care at a VA facility, VA will then 

create a medical record for the individual, which will be stored in its 

health data repository. Upon viewing the medical record, the VA clinician 

would be alerted and provided access to clinical information on the 

individual also residing in DOD’s repository. In the same manner, when a 

veteran seeks medical care at a military treatment facility, the attending 

DOD clinician would be alerted and provided with access to the health 

information existing in VA’s repository. According to VA and DOD, the 

planned approach would make virtual medical records displaying all 

available patient health information from the two repositories accessible 

to both departments’ clinicians. VA officials have stated that they 

anticipate being able to exchange some degree of health information 

through an interface of their health data repository with DOD’s clinical 

data repository by the end of calendar year 2005. 

 10DOD’s CHCS II capabilities are being deployed in blocks. Block 1 provides a graphical 

user interface for clinical outpatient processes; block 2 supports general dentistry; block 3 

provides pharmacy, laboratory, radiology, and immunizations capabilities; block 4 provides 

inpatient and scheduling capabilities; and block 5 will provide additional capabilities as 

defined. 

11The six initiatives that make up HealtheVet VistA are health data repository, billing 

replacement, laboratory, pharmacy, imaging, and appointment scheduling replacement. 
Page 7 GAO-04-402T 

VA’s and DOD’s ability to exchange data between their separate health 

information systems is crucial to achieving the goals of HealthePeople 

(Federal). Yet successfully sharing patient health information via a secure 

electronic interface between each of their data repositories can be 

complex and challenging, and depends on their having a clearly articulated 

architecture, or blueprint, defining how specific technologies will be used 

to achieve the interface. Developing, maintaining, and using an 

architecture is a best practice in engineering information systems and 

other technological solutions. An architecture would articulate, for 

example, the system requirements and design specifications, database 

descriptions, and software descriptions that define the manner in which 

the departments will electronically store, update, and transmit their data. 

Equally critical is an established project management structure to guide 

project development. Industry best practices and information technology 

project management principles12 stress the importance of accountability 

and sound planning for any project, particularly an interagency effort of 

the magnitude and complexity of this one. Inherent in such planning is the 

development and use of a project management plan that describes, among 

other factors, the project’s scope, implementation strategy, lines of 

responsibility, security requirements, resources, and estimated schedule 

for development and implementation. 

As was the situation when we testified last November, VA and DOD 

continue to lack an explicit architecture detailing how they intend to 

achieve the data exchange capability, or just what they will be able to 

exchange by the end of 2005—their projected time frame for putting this 

capability into operation. VA officials stated that they recognize the 

importance of a clearly defined architecture, but acknowledged that the 

departments’ actions were continuing to be driven by the less-specific, 

high-level strategy that has been in place since September 2002. 

The officials added that just this month, the departments had taken a first 

step toward trying to determine how their separate data repositories 

would interface to enable the two-way exchange of patient health records. 

Specifically, officials in both departments pointed to a project that they 

are undertaking in response to requirements of the National Defense 

Authorization Act for Fiscal Year 2003, which mandated that VA and DOD 

 12Institute of Electrical and Electronics Engineers, IEEE/EIA Guide for Information 

Technology (IEEE/EIA 12207.1- 1997), April 1998.

Lacking A Defined 

Strategy, VA And DOD 

Have Made Limited 

Progress Toward A 

Common Health 

Information Exchange 
Page 8 GAO-04-402T 

develop a real-time interface, data exchange, and capability to check 

prescription drug data for outpatients by October 1, 2004.13 VA’s Deputy 

Chief Information Officer for Health stated that they hope to determine 

from a prototype planned for completion by next September whether the 

interface technology developed to meet this mandate can be used to 

facilitate the exchange of data between the health information systems 

that they are currently developing. 

By late February, VA had hired a supporting contractor to develop the 

planned prototype, but the departments had not yet fully defined their 

approach or requirements for developing and demonstrating its 

capabilities. DOD officials stated that the departments would rely on the 

contractor to more fully define the technical requirements for the 

prototype. Further, according to VA officials, since the departments’ new 

health information systems that are intended to be used under 

HealthePeople (Federal) have not yet been completed, the demonstration 

may only test the ability to exchange data in VA’s and DOD’s existing 

health systems—the Veterans Information Systems and Technology 

Architecture and the Composite Health Care System, respectively. Thus, 

given the early stage of the prototype and the uncertainties regarding what 

capabilities it will demonstrate, there is little evidence and assurance as to 

how or whether this project will contribute to defining the architecture 

and technological solution for the two-way exchange of patient health 

information. 

Further compounding the challenges and uncertainty that VA and DOD 

face is the lack of a fully established project management structure to 

ensure the necessary day-to-day guidance of and accountability for the 

departments’ investments in and implementation of the electronic 

interface between their systems. Officials in both departments maintain 

that they are collaborating on this initiative through a joint working group 

and with oversight provided by the Joint Executive Council and VA/DOD 

 13Sec. 724 of the act mandates that the Secretaries of Veterans Affairs and Defense seek to 

ensure that, on or before October 1, 2004, the two departments’ pharmacy data systems are 

interoperable for VA and DOD beneficiaries by achieving real-time interface, data 

exchange, and checking of prescription drug data of outpatients and using national 

standards for the exchange of outpatient medication information. The act further states 

that if the specified interoperability is not achieved by that date, then the Secretary of 

Veterans Affairs shall adopt DOD’s Pharmacy Data Transaction System for VA’s use. 
Page 9 GAO-04-402T 

Health Executive Council.14 However, neither department has had the 

authority to make final project decisions binding on the other, and there 

has been a visible absence of day-to-day project oversight for the joint 

initiative to develop an electronic interface between the departments’ 

planned information systems. Further, VA and DOD are operating without 

a project management plan describing the overall development and 

implementation of the interface, including the specific roles and 

responsibilities of each department in developing, testing, and deploying 

the interface and addressing security requirements. In discussing these 

matters last week, VA officials stated that the departments had recently 

designated a program manager for the planned prototype. Further, VA and 

DOD officials added that they had begun discussions to establish an 

overall project plan and finalize roles and responsibilities for managing the 

joint initiative to develop an electronic interface. Until these essential 

project management elements are fully established, VA and DOD will lack 

assurance that they can successfully develop and implement an electronic 

interface and the associated capability for exchanging health information 

within the time frames that they have established. 

In the absence of an architecture and project management structure for 

the initiative, VA and DOD have continued to make only limited progress 

toward developing the technological solution essential to interfacing their 

patient health information. To their credit, the departments have 

continued essential steps toward standardizing clinical data—important 

for exchanging health information between disparate systems. The 

Institute of Medicine’s Committee on Data Standards for Patient Safety has 

reported the lack of common data standards as a key factor preventing 

information sharing within the health care industry. Over the past 4 

months, VA and DOD have agreed to adopt additional data standards15 for 

uniformly presenting in any system data related to demographics, 

 14The Joint Executive Council is composed of the Deputy Secretary of Veterans Affairs, the 

Undersecretary of Defense for Personnel and Readiness, and the cochairs of joint councils 

on health, benefits, and capital planning. The council meets on a quarterly basis to 

recommend strategic direction of joint coordination and sharing efforts. The VA/DOD 

Health Executive Council is composed of senior leaders from VA and DOD, who work to 

institutionalize sharing and collaboration of health services and resources. The council is 

cochaired by the VA Undersecretary for Health and DOD Assistant Secretary of Defense for 

Health Affairs, and meets on a bimonthly basis. 

15When we testified last November, VA and DOD had agreed to four standards to allow the 

transmission of messages and one standard allowing laboratory results. 

Progress Toward 

Achieving a Two-Way Data 

Exchange Has Been 

Limited 
Page 10 GAO-04-402T 

immunizations, medications, names of laboratory tests ordered, and 

laboratory result contents. 

Nonetheless, as reflected in figure 1, the technology needed to achieve a 

two-way exchange of patient health information remains far from 

complete, with only DOD’s data repository having been fully developed. 

Figure 1: VA/DOD High-level Strategy for the Two-Way Exchange of Health Data 

----- Under Development

Developed

DOD data 

repository

Electronic 

Interface 

DOD Health 

Information 

System 

VA Health 

Information 

System 

VA data 

repository

----- Under Development

Developed

DOD data 

repository

Electronic 

Interface 

DOD Health 

Information 

System 

VA Health 

Information 

System 

VA data 

repository

Source: VA and DOD. 

Since November, both departments have delayed key milestones 

associated with the development and deployment of their individual health 

information systems. VA program officials told us that completion of a 

prototype for the department’s health data repository has been delayed 

approximately a year, until the end of this June. The officials explained 

that earlier testing of the prototype had slowed clinicians’ use of the 

clinical applications, necessitating a revised approach to populating the 

repository. In addition, while DOD officials previously stated that the 

department planned to complete the deployment of its first release of 

CHCS II functionality (a capability for integrating DOD clinical outpatient 

processes into a single patient record) in September 2005, the agency has 

now extended its completion date to June 2006. According to DOD 

officials, the schedule for completing this deployment was revised because 

of a later than anticipated decision on when the department could proceed 

with its worldwide deployment. Collectively, the lack of an architecture 

and project management structure, coupled with delays in the 

departments’ completion of key projects, places VA and DOD at increased 

risk of being unable to successfully accomplish the HealthePeople 

(Federal) initiative and the overall goal of more effectively meeting service 

members’ and veterans’ health care and disability needs. 
Page 11 GAO-04-402T 

Mr. Chairman, as part of our review, you asked that we update the status 

of VA’s and DOD’s actions to address prior recommendations related to 

sharing electronic medical information. In this regard, both the President’s 

task force and we have made a number of recommendations to VA and 

DOD for improving health care delivery to beneficiaries through better 

coordination and management of their electronic health sharing initiatives. 

In its final report of May 2003,16 the President’s task force recommended 

specific actions for providing timely, high-quality care through effective 

electronic sharing of health information, such as the development and 

deployment, by fiscal year 2005, of electronic medical records that are 

interoperable, bidirectional, and standards-based. The departments 

reported that they are in various stages of acting on these 

recommendations, with anticipated completion dates ranging from June of 

this year to September 2005. Our attachment to this statement summarizes 

these specific recommendations, and the departments’ reported actions to 

address them. Giving full consideration to these recommendations could 

provide VA and DOD with relevant information for determining how to 

proceed with the HealthePeople (Federal) initiative. 

Also, as mentioned earlier, our prior reviews of the departments’ project to 

develop a government computer-based patient record determined that the 

lack of a lead entity, clear mission, and detailed planning to achieve that 

mission had made it difficult to monitor progress, identify project risks, 

and develop appropriate contingency plans. As a result, in reporting on 

this initiative in April 2001 and again in June 2002, we made several 

recommendations to help strengthen the management and oversight of 

this project. VA and DOD have taken specific measures in response to our 

recommendations for enhancing overall management and accountability 

of the project, with demonstrated improvements and outcomes. Extending 

these practices to current activities supporting the development of 

HealthePeople (Federal) could strengthen the departments’ approach to 

successfully accomplishing a two-way health information exchange. 

In summary, Mr. Chairman, achieving an electronic interface to enable VA 

and DOD to exchange patient medical records between their health 

information systems is an important goal, with substantial implications for 

improving the quality of health care and disability claims processing for 

our nation’s military members and veterans. However, in seeking a virtual 

 16President’s Task Force, Final Report, May 26, 2003. 

VA and DOD Could 

Benefit From Current 

And Past 

Recommendations On 

Sharing Electronic 

Medical Records 
Page 12 GAO-04-402T 

medical record based on the two-way exchange of data between their 

separate health information systems, VA and DOD have chosen an 

approach that necessitates the highest levels of project discipline, 

including a well-defined architecture for describing the interface for a 

common health information exchange and an established project 

management structure to guide the investment in and implementation of 

this electronic capability. At this time, the departments lack these critical 

components, and thus risk investing in a capability that could fall short of 

their intended goals. The continued absence of a clear approach and 

sound planning for the design of this new electronic capability elevates 

concerns and skepticism about exactly what capabilities VA and DOD will 

achieve as part of HealthePeople (Federal), and in what time frame. 

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

to any questions that you or other members of the Subcommittee may 

have at this time. 

For information about this testimony, please contact Linda D. Koontz, 

Director, Information Management Issues, at (202) 512-6240 or at 

koontzl@gao.gov, or Valerie C. Melvin, Assistant Director, at (202) 512-

6304 or at melvinv@gao.gov. Other individuals making key contributions to 

this testimony include Nabajyoti Barkakati, Michael P. Fruitman, Carl L. 

Higginbotham, Barbara S. Oliver, J. Michael Resser, Sylvia L. Shanks, and 

Eric L. Trout. 

Contacts and 

Acknowledgments 
Page 13 GAO-04-402T 

Reported Actions 

Recommendations Department of Veterans Affairs (VA) Department of Defense (DOD) 

1. VA and DOD should develop and 

deploy by fiscal year 2005 electronic 

medical records that are interoperable, 

bi-directional, and standards-based. 

The VA/DOD Joint Strategic Plan and the Joint 

Electronic Health Records Plan have set 

September 2005 as the target date by which VA 

and DOD will achieve interoperability of health 

data. The VA/DOD Health Executive Council 

Information Management/ Information Technology 

Work Group is on track to complete this capability 

by the end of fiscal year 2005. In March 2004, the 

departments awarded a contract to develop a bidirectional pharmacy solution that will 

demonstrate interoperability in a prototype 

environment. The departments are on track to 

complete the prototype by October 2004. 

Operational interoperability is planned 

for fiscal year 2005.The pharmacy 

prototype is the initial effort within the 

Clinical Health Data Repositories 

(CHDR) framework. This framework is 

the effort to develop software component 

services that will be used by the VA and 

DOD data repositories. The prototype 

has a planned completion date of 

October 2004. 

2. The Administration should direct the 

Department of Health and Human 

Services to declare the two 

departments to be a single health care 

system for purposes of implementing 

the Health Insurance Portability and 

Accountability Act (HIPAA) regulations. 

This issue remains under review by the Veterans 

Health Administration’s HIPAA Program Office. It 

is VA’s understanding that VA and DOD have 

concluded that this is not necessary in order to 

share information on patients that both 

departments are treating. 

DOD believes that it and VA can achieve 

the appropriate sharing of protected 

health information within the guidelines 

of the current regulations. The HIPAA 

privacy rule has a specific exception 

authorizing one-way sharing of health 

data at the time of a service member’s 

separation. This supports the “seamless 

transition to veteran status.” 

3. The departments should implement 

by fiscal year 2005 a mandatory single 

separation physical as a prerequisite of 

promptly completing the military 

separation process. Upon separation, 

DOD should transmit an electronic 

Department of Defense (DD) 214 

(discharge paperwork) to VA. 

The Joint Strategic Plan has set June 2004 as the 

target date for the departments to develop an 

implementation plan for the one physical exam 

protocol. VA and DOD are currently piloting the 

single separation physical exam that meets DOD 

needs and VA’s rating criteria at 16 Benefits 

Delivery at Discharge sites. 

The departments are currently testing an 

advanced technological demonstration 

project that transfers images of paper 

personnel documents to VA from official 

military personnel file repositories in the 

Army, Navy, and Marine Corps, with Air 

Force integration into the program in 

process (including the DD214). When 

fully operational, this system will send 

digital images of any personnel record to 

the VA within 48 hours of the request. 

Appendix: VA’s and DOD’s Reported Actions to 

Address Recommendations in the President’s 

Task Force Report of May 26, 2003 
Page 14 GAO-04-402T 

Reported Actions 

Recommendations Department of Veterans Affairs (VA) Department of Defense (DOD) 

4. By fiscal year 2004, VA and DOD 

should initiate a process for routine 

sharing of each service member’s 

assignment history, location, 

occupational exposure, and injuries 

information. 

Both the Health Executive Council (through the 

Deployment Health Work Group) and the VA/DOD 

Benefits Executive Council are currently 

developing and implementing processes to 

address these issues. 

DOD is already providing VA with daily 

information on personnel separating 

from active duty, which includes 

assignment history, location, and 

occupational duties through the DD214. 

DOD’s TRICARE On Line provides 

health care professionals with access to 

the individual service member’s pre- and 

post-deployment health assessments 

The Defense Occupational and 

Environmental Health Readiness System 

with CHCS II, is capturing data on 

occupational exposures and transferring 

it to the clinical data repository. When 

these systems are fully operational, 

appropriate information will be able to be 

shared via a two-way exchange with VA.

Source: VA and DOD. 

(310701) 
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