VETERANS’ DISABILITY

BENEFITS

Challenges to Timely 

Processing Persist

Statement of Daniel Bertoni, Director 

Education, Workforce, and Income Security Issues

Testimony Before the Committee on 

Veterans’ Affairs, U.S. Senate

For Release on Delivery 

Expected at 10:00 a.m. EST

Wednesday, March 13, 2013

GAO-13-453T

United States Government Accountability Office

GAO
Page 1 GAO-13-453T 

United States Government Accountability Office

Washington, DC 20548

Chairman Sanders, Ranking Member Burr, and Members of the 

Committee:

I am pleased to discuss the Department of Veterans Affairs’ (VA) 

disability benefits program, which provides monetary support to veterans 

with disabling conditions that were incurred or aggravated during military 

service. In fiscal year 2013, VA estimates it will provide $59.6 billion in 

compensation benefits to 3.98 million veterans and their families.1 For 

years, the disability claims process has been the subject of concern and 

attention by VA, Congress, and Veterans Service Organizations (VSO), 

due in part to long waits for decisions and the large number of pending 

claims. For example, the average length of time to complete a claim 

increased from 161 days in fiscal year 2009 to 260 days in fiscal year 

2012.2 Moreover, VA’s backlog of claims—defined as claims awaiting a 

decision for over 125 days—has more than tripled since September 2009. 

In August 2012, approximately two-thirds of the 568,043 compensation 

rating claims—which include pension and disability rating claims—were 

backlogged.3 In addition, timeliness of appeals processing at VA regional 

offices has also slowed by 56 percent over the last several years.

My remarks are based on a GAO report released on December 21, 2012, 

titled Veterans’ Disability Benefits: Timely Processing Remains a 

Daunting Challenge, and, also include information updated to reflect the 

status of improvement efforts. My testimony focuses on (1) factors that 

contribute to lengthy disability claims and appeals processing times at VA 

regional offices and (2) status of the Veterans Benefits Administration’s 

(VBA) recent improvement efforts. To conduct this work, we reviewed 

relevant federal laws and regulations, court decisions, VBA policy 

manuals, and training materials. We also reviewed past GAO and VA 

Office of Inspector General (OIG) reports and VBA studies, evaluations 

relevant to claims and appeals processing at VBA regional offices, and 

interviewed VBA central office officials and VSO representatives who 

assist veterans with their claims and appeals. We also met with staff from 

 

1

Compensation benefits include disability benefits as well as other benefits, such as 

clothing allowance, and special allowance for dependents.

2

From the beginning of fiscal year 2012 through August 2012, the average number of 

days it took VA to complete a claim was 260 days.

3

VBA does not report out on disability rating compensation claims separately. 

 
 

Page 2 GAO-13-453T 

five VA regional offices—Atlanta, Georgia; Houston, Texas; Los Angeles, 

California; New York, New York; and Philadelphia, Pennsylvania. We 

selected offices based on size of metropolitan area, claims workload, and 

timeliness of claims and appeals processing. Our work was performed in 

accordance with generally accepted government auditing standards.

In summary, we found a number of factors—both external and internal to 

VBA—have contributed to the increase in processing times and 

subsequent growth in the backlog of veterans’ disability compensation 

claims. For example, the number of claims received by VBA has 

increased as the population of new veterans has swelled in recent years. 

Moreover, due to new regulations that established eligibility for benefits 

for new diseases associated with Agent Orange exposure, VBA 

adjudicated 260,000 previously denied and new claims for related 

impairments. Beyond these external factors, issues with the design and 

implementation of the program have also contributed to timeliness 

challenges. For example, the law requires VA to assist veterans in 

obtaining records that support their claim. However, VBA officials said 

that delays in obtaining military records—particularly for members of the 

National Guard and Reserve—and Social Security Administration (SSA) 

medical records impact VA’s duty to assist, possibly delaying a decision 

on a veteran’s disability claim. Further, VBA’s paper-based claims 

processing system involves multiple hand-offs, which can lead to 

misplaced and lost documents and cause unnecessary delays. 

Concerning timeliness of appeals, VBA regional offices have in recent 

years shifted resources away from appeals and towards claims, which 

has led to lengthy appeals timeframes.

VBA has a number of initiatives underway to improve the timeliness of 

claims and appeals processing. Such efforts include leveraging VBA staff 

and contractors to manage workload, modifying and streamlining 

procedures, improving records acquisition, and redesigning the claims 

and appeals processes. According to VBA officials, these efforts will help 

VA process all veterans’ claims within VA’s stated target goal of 125 days 

by 2015. However, the extent to which VA is positioned to meet its 

ambitious processing timeliness goal remains uncertain. VBA provided us 

with several planning documents, but, at the time of our review, could not 

provide us with a plan that met established criteria for sound planning, 

such as articulating performance measures for each initiative, including 

their intended impact on the claims backlog. We have recommended that 

VBA (1) partner with military officials to reduce timeframes to gather 

records from National Guard and Reserve sources, (2) work with SSA to 

reduce timeframes to gather SSA medical records, and (3) develop a 
 

Page 3 GAO-13-453T 

robust plan for its improvement initiatives that identifies performance 

goals that include the impact of individual initiatives on processing 

timeliness. VA generally agreed with our conclusions and concurred with 

our recommendations, and identified efforts that it has planned or 

underway to address them.

VA’s disability compensation claims process starts when a veteran 

submits a claim to VA (see fig. 1). A claim folder is created at 1 of VA’s 57 

regional offices, and a Veterans Service Representative (VSR) then 

reviews the claim and helps the veteran gather the relevant evidence 

needed to evaluate the claim. Such evidence includes the veteran’s 

military service records, medical examinations, and treatment records 

from Veterans Health Administration (VHA) medical facilities and private 

medical service providers. Also, if necessary to provide support to 

substantiate the claim, VA will provide a medical examination for the 

veteran. Once VBA has gathered the supporting evidence, a Rating 

Veterans Service Representative (RVSR)—who typically has more 

experience at VBA than a VSR—evaluates the claim and determines 

whether the veteran is eligible for benefits. If so, the RVSR assigns a 

percentage rating.4 A veteran may subsequently reopen a claim to 

request an increase in disability compensation from VA if, for example, a 

service-connected disability worsens or a new disability arises.

If the veteran disagrees with VA’s decision regarding a claim, he or she 

can submit a written Notice of Disagreement to the regional office 

handling the claim.5 In response to such a notice, VBA reviews the case 

and provides the veteran with a written explanation of the decision—

known as a Statement of the Case—if VBA does not grant all appealed 

 

4

VA’s ratings are awarded in 10 percent increments, from 0 to 100 percent. 38 U.S.C. § 

1155. Generally, VA does not pay disability compensation for disabilities rated at 0 

percent. As of December 2012, basic monthly payments ranged from $129 for a veteran 

with 10 percent disability and no dependents to $3,340 for a veteran with 100 percent 

disability and a spouse, two parents, and a child.

5

38 U.S.C. § 7105. A Notice of Disagreement is a written communication that a claimant 

uses to express disagreement with a decision.

Background 
 

Page 4 GAO-13-453T 

issues.6 If the veteran further disagrees with the decision, he or she may 

appeal to the Board of Veterans’ Appeals (the Board) which conducts a

hearing at the veteran’s request, then grants benefits, denies the appeal, 

or returns the case to VBA to obtain additional evidence necessary to 

decide the claim. If the veteran is dissatisfied with the Board’s decision, 

he or she may appeal, in succession, to the U.S. Court of Appeals for 

Veterans Claims, to the Court of Appeals for the Federal Circuit, and 

finally to the Supreme Court of the United States.7

Figure 1: Overview of VA’s Disability Claims Process

Note: The Veterans Claims Assistance Act of 2000 (VCAA) requires VA to notify veterans of the 

information necessary to evaluate a claim. If the veteran does not respond to this notice within 30 

days, VA may make a decision on the claim based on the information and evidence in the file at that 

time.

In recent years, VA compensation claims processing timeframes have 

increased. Specifically, the average days pending increased from 116 

days in fiscal year 2009 to 254 days in fiscal year 2012.8 During the same 

 

6

If VBA grants some, but not all, of the issues in an appeal or if the grant is less than the 

maximum allowable benefit for the issues under appeal, VBA must send a written 

explanation of the reasons for the decision. VBA is also obligated to send a letter 

explaining the decision in cases where the veteran’s appeal includes a request to be rated 

at a specific percentage, but VBA has decided to grant the appeal at less than that 

requested percentage.

7

38 U.S.C. §§ 7252 and 7292.

8

VA’s average days pending metric is calculated fiscal year-to-date; therefore, it took 254 

days on average to complete a claim once received through the first 11 months of fiscal 

year 2012—October 2011 through August 2012. VBA calculates the average days 

pending for a fiscal year on the last day of the year and for the month on the last day of 

every month.
 

Page 5 GAO-13-453T 

time period, the average days to complete increased from 161 to 260 

days.9 VBA also collects data on the timeliness of the different phases of 

the claims process, which is used to identify trends and bottlenecks 

throughout the process. In fiscal year 2011, each phase took longer on 

average than its stated agency timeliness target (see fig. 2). In fiscal year 

2011, the national averages for the initiating development, gathering 

evidence, and rating decision phases were 44, 72, and 57 days, 

respectively, over their timeliness targets.

Figure 2: Timeliness of Phases in VA’s Claims Process for Fiscal Year 2011

Note: While VBA’s stated goals are to process all claims within 125 days by fiscal year 2015, VBA 

established targets for each phase in the claims process for fiscal year 2011 that collectively add up 

to 132 days.

In recent years, VA’s claims processing production has not kept pace with 

the substantial increase in incoming claims. In fiscal year 2011, VA 

completed over 1 million compensation rating claims, a 6 percent 

increase from fiscal year 2009. However, the number of VA compensation 

rating claims received had grown 29 percent—from 1,013,712 in fiscal 

year 2009 to 1,311,091 in fiscal year 2011 (see fig. 3). As a result, the 

number of backlogged claims—defined as those claims awaiting a 

decision for more than 125 days—has increased substantially since 2009. 

As of August 2012, VA had 856,092 pending compensation rating claims, 

of which 568,043 (66 percent) were considered backlogged.

 

9

The average days to complete metric measures the average processing time for claims 

completed within a given time period.

Rising Workloads, 

along with Program 

Rules, Record 

Gathering, and 

Inefficient Processes, 

Contribute to Lengthy 

Processing Time 

Frames
 

Page 6 GAO-13-453T 

Figure 3: VA Compensation Rating Claims Received, Completed, and Backlogged, 

Fiscal Years 2009 to 2011

One factor that contributed to the substantial increase in claims received 

was the commencement in October 2010 of VBA’s adjudication of 

260,000 previously denied and new claims when a presumptive service 
 

Page 7 GAO-13-453T 

connection was established for three additional Agent Orange diseases.10

VBA gave these claims a high priority and assigned experienced claims 

staff to process and track them. VBA officials said that 37 percent of its 

claims processing resources nationally were devoted to adjudicating 

Agent Orange claims from October 2010 to March 2012. VBA officials in 

one regional office we spoke to said that all claims processing staff were 

assigned solely to developing and rating Agent Orange claims for 4 

months in 2011, and that no other new and pending claims in the regional 

office’s inventory were processed during that time. Also during this time 

period, special VBA teams—known as brokering centers—which 

previously accepted claims and appeals from regional offices 

experiencing processing delays, were devoted exclusively to processing 

Agent Orange claims. According to VBA, other factors that contributed to 

the growing number of claims include an increase in the number of 

veterans from the military downsizing after 10 years of conflict in Iraq and 

Afghanistan, improved outreach activities and transition services to 

servicemembers and veterans, and difficult financial conditions for 

veterans during the economic downturn.

Similar to claims processing, VA regional office appeals processing has 

not kept pace with incoming appeals received. For example, in fiscal year 

2012, VA received 121,786 Notices of Disagreement. However, the 

number of Statements of the Case that were processed by VBA was only 

76,685. As a result, the number of Notice of Disagreements awaiting a 

 

10VBA was required to adjudicate these claims as a result of requirements related to the 

Nehmer litigation. Nehmer v. U.S. Department of Veterans Affairs, Civ. Action No. 86-

6160 (N.D. Cal.). In the preamble to a proposed rule amending its claim adjudication 

regulations (75 Fed. Reg. 14,391 (March 25, 2010)), VA summarized the Nehmer litigation 

generally as follows: this litigation was initiated in 1986 to challenge a VA regulation, 

which has since been rescinded, that limited the diseases shown to be associated with 

herbicide exposure. In an order issued May 3, 1989, the court invalidated the portion of 

the regulation that limits diseases associated with herbicide exposure and voided all VA 

decisions denying benefit claims under that portion of the regulation. Nehmer v. United 

States Veterans’ Administration, 712 F. Supp. 1404 (N. D. Cal. 1989). Pursuant to a 

stipulation agreed to by the parties, VA must provide for readjudication of class members’ 

claims and payment of retroactive benefits whenever VA identifies a new disease that is 

associated with herbicide exposure and adds a new disease to its regulatory list. In 

addition, pursuant to the Agent Orange Act of 1991, VA is required to issue new 

regulations establishing additional presumptions of service connection for diseases that 

the Secretary finds to be associated with exposure to an herbicide agent. 38 U.S.C. 

§ 1116(b). Accordingly, VA amended its adjudication regulations in August 2010 to 

establish presumptive service connection for ischemic heart disease, Parkinson’s disease, 

as well as hairy cell leukemia and other chronic B-cell leukemias. 75 Fed. Reg. 53,202 

(August 31, 2010).
 

Page 8 GAO-13-453T 

decision grew 76 percent from fiscal years 2009 to 2012 and, during that 

period, the time it took VA to process a Statement of the Case increased 

57 percent—from 293 days to 460 days on average.

According to VBA officials, staff shortages represent a primary reason 

that appeals timeliness at VA regional offices has worsened. For 

example, VBA officials at each of the five regional offices we met with 

stated that over the last several years appeals staff have also had to train 

and mentor new staff, conduct quality reviews, as well as develop and 

rate disability claims to varying degrees. A 2012 VA OIG report noted that 

VA regional office managers did not assign enough staff to process 

appeals, diverted staff from processing appeals, and did not ensure that 

appeals staff acted on appeals promptly because, in part, they were 

assigned responsibilities to process initial claims, which were given higher 

priority.11

According to VA officials, federal laws12 and court decisions13 over the 

past decade have expanded veterans’ entitlement to benefits but have 

also added requirements that can negatively affect claims processing 

times. For example, the Veterans Claims Assistance Act of 2000 (VCAA) 

added a requirement that VA assist a veteran who files a claim in 

obtaining evidence to substantiate the claim before making a decision.14

This requirement includes helping veterans obtain all relevant federal and 

 

11The VA OIG made several recommendations regarding appeals resources and 

processing steps to help VBA meet their appeals processing goals. VBA agreed with the 

VA OIG’s findings and is conducting a pilot to assess the feasibility of addressing these 

recommendations. VA Office of Inspector General, Veterans Benefits Administration: Audit 

of VA Regional Office’s Appeals Management Processes, (Washington D.C.: 

May 30, 2012).

12Veterans’ Benefits Improvement Act of 2008, Pub. L. No. 110-389; Veterans’ Benefits 

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

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

13See, for example, Haas v. Nicholson, 20 Vet. App. 257 (2006); Moody v. Principi, 360 

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

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

2003).

1438 U.S.C. § 5103A(a)(1).
 

Page 9 GAO-13-453T 

non-federal records.15 VA is required to continue trying to obtain federal 

records, such as VA medical records, military service records, and Social 

Security records, until they are either obtained or the associated federal 

entity indicates the records do not exist. VA may continue to process the 

claim and provide partial benefits to the veteran, but the claim cannot be 

completed until all relevant federal evidence is obtained.

Because VA must consider all evidence submitted throughout the claims 

and appeals process, if a veteran submits additional evidence or adds a 

condition to a claim late in the process it can require rework and may 

subsequently delay a decision, according to VBA central office officials. 

VBA officials at regional offices we spoke to said that submitting 

additional evidence may add months to the claims process. New 

evidence must first be reviewed to determine what additional action, if 

any, is required. Next, another notification letter must be sent to the 

veteran detailing the new evidence necessary to redevelop the claim. VA 

may also have to obtain additional records or order another medical 

examination before the claim can be rated and a decision made. 

Furthermore, while VA may continue to process the claim and provide 

partial benefits to the veteran, a claim is not considered “complete” until a 

decision is made on all submitted conditions. Moreover, a veteran has up 

to 1 year, from the notification of VA’s decision, to submit additional 

evidence in support of the claim before the decision is considered final. 

Similarly, for an appeal, veterans may submit additional evidence at any 

time during the process. If the veteran submits additional evidence late in 

the process after VA completes a Statement of the Case, VA must review 

the new evidence, reconsider the appeal, and provide another written 

explanation of its decision—known as a Supplemental Statement of the 

 

15VA will make reasonable efforts to obtain relevant records that are not in the custody of 

a federal department or agency, which can include records from state or local 

governments, private medical-care providers, current or former employers, and other nonfederal governmental sources. Reasonable efforts generally consist of an initial request for 

the records, and, if the records are not received, at least one follow-up request 15 days 

later. A follow-up request is not required if a response to the initial request indicates that 

the records sought do not exist or that a follow-up request for the records would be futile. 

38 C.F.R. § 3.159.
 

Page 10 GAO-13-453T 

Case.16 Congress recently passed a law allowing VA to waive review of 

additional evidence submitted after the veteran has filed a substantive 

appeal and instead have the new evidence reviewed by the Board to 

expedite VA’s process of certifying appeals to the Board.17

According to VBA officials, delays in obtaining military service and 

medical treatment records, particularly for National Guard and Reserve 

members, have significantly lengthened the evidence gathering phase. 

According to VBA officials, 43 percent of Global War on Terror veterans 

are National Guard and Reserve members. Department of Defense 

(DOD) guidance requires military staff to respond to VA requests for 

National Guard and Reserve records in support of VA disability 

compensation claims.18 However, VBA area directors and officials at all 

five regional offices we met with acknowledged that delays in obtaining 

these records are system-wide. Military records of National Guard or 

Reserve members can often be difficult to obtain, in particular, because 

these servicemembers typically have multiple, non-consecutive 

deployments with different units and their records may not always be held 

with their reserve units and may exist in multiple places. Moreover, 

according to VBA officials, National Guard and Reserve members may be 

treated by private providers between tours of active duty and VA may 

have to contact multiple military personnel and private medical providers 

 

16A Supplemental Statement of the Case presents the appellant with changes or additions 

to the Statement of the Case. These changes and additions are usually based on 

additional evidence received after the issuance of the Statement of the Case, before or 

after receipt of a substantive appeal, or after a remand. VBA will issue a Supplemental 

Statement of the Case to the appellant when (1) the Statement of the Case or 

Supplemental Statement of the Case was prepared before receipt of additional evidence 

unless the evidence is duplicate or unrelated to the issue under appeal; (2) the new 

evidence does not result in a total grant of the issue under appeal; (3) the appellant 

appeared for a personal hearing; (4) an amended decision has been made, or (5) a 

material error is discovered in the Statement of the Case.

17The Honoring America’s Veterans and Caring for Camp Lejeune Families Act of 2012, 

Pub. L. No. 112-154, § 501, 126 Stat. 1165, 1190. A claimant may request in writing that 

the VA regional office initially review the evidence.

18DOD Instruction 6040.45 states “In the case of the Reserve Component member who 

does not separate from Service, but applies or plans to apply for VA benefits, a copy of 

the STR [Service Treatment Record] shall be sent to the VARO [VA regional office] of 

jurisdiction in relation to the member’s residence. The original service treatment record 

shall be maintained at their Permanent Duty Station, Reserve, or Guard unit as 

applicable.” 
 

Page 11 GAO-13-453T 

to obtain all relevant records, potentially causing delays in the evidence 

gathering process.

Difficulties obtaining SSA medical records can also lengthen the evidence 

gathering phase. Although VBA regional office staff have direct access to 

SSA benefits payment histories, they do not have similar access to 

medical records held by SSA. If a veteran submits a disability claim and 

reports receiving SSA disability benefits, VA is required to help the 

veteran obtain relevant federal records, including certain SSA medical 

records, to process the claim. VBA’s policy manual instructs claims staff 

to fax a request for medical information to SSA and if no reply is received, 

to wait 60 working days before sending a follow-up request. If a response 

is not received after 30 days, claims staff are instructed to send an email 

request to an SSA liaison. VBA officials at four of the five regional offices 

we reviewed told us that when following this protocol, they have had 

difficulty obtaining SSA medical records in a timely fashion. Moreover, 

they reported having no contact information for SSA, beyond the fax 

number, to help process their requests. In complying with VA’s duty to 

assist requirement, VBA staff told us they continue trying to retrieve SSA 

records by sending follow-up fax requests until they receive the records or 

receive a response that the records do not exist. VBA area directors said 

some regional offices have established relationships with local SSA 

offices and have better results, but obtaining necessary SSA information 

has been an ongoing issue nationally. For example, officials at one 

regional office said a response from SSA regarding a medical records 

request can sometimes take more than a year to receive.

VBA’s work processes, stemming mainly from its reliance on a paperbased claims system, can lead to misplaced or lost documents, and 

contribute to lengthy processing times. VBA officials at three of the five 

regional offices we met with noted that errors and delays in handling, 

reviewing, and routing incoming mail to the correct claim folder can delay 

the processing of a claim or cause rework. For example, VBA officials at 

one regional office said that claims may be stalled in the evidence 

gathering phase if mail that contains outstanding evidence is misplaced or 

lost. In addition, claims staff may rate a claim without knowledge of the 

additional evidence submitted and then, once the mail is routed to the 

claim folder, have to rerate the claim in light of the new evidence 

received. Furthermore, VBA officials told us that processing can also be 

delayed if mail staff are slow to record new claims or appeals into IT 

systems. As of August 2012, VBA took 43 days on average to record 

Notices of Disagreement in the appeals system—36 days longer than 

VBA’s national target. VBA area directors said that mail processing 
 

Page 12 GAO-13-453T 

timeliness varies by regional office and that the more efficient offices in 

general do a better job of associating mail with the correct claims folder. 

VBA officials also said that moving physical claims folders among 

regional offices and medical providers contributes to lengthy processing 

times. According to a 2011 VA OIG report, processing delays occurred 

following medical examinations because staff could not match claimsrelated mail with the appropriate claim folders until the folders were 

returned from the VA Medical Center.19 In addition, processing halts while 

a claim folder is sent to another regional office or brokering center.

Based on a review of VA documents and interviews with VBA officials, we 

identified 15 efforts with a stated goal of improving claims and appeals 

timeliness. We selected 9 for further review—primarily based on 

interviews with VBA officials and a review of recent VA testimonies—that 

have the purpose of reducing disability claims and appeals processing 

times.

 

19VA Office of Inspector General, Systemic Issues Reported During Inspections at VA 

Regional Offices, (Washington D.C.: May 18, 2011).

VBA Is Taking Steps 

to Improve Claims 

and Appeals 

Processing, but 

Future Impact Is 

Uncertain 
 

Page 13 GAO-13-453T 

Figure 4: Selected VBA Improvement Efforts

VBA has several ongoing efforts to leverage internal and external 

resources to better manage its workload (see fig. 4). For example, VBA 

began the Veterans Benefits Management Assistance Program (VBMAP) 

in late fiscal year 2011 to obtain contractor support for evidence gathering 

for approximately 279,000 disability claims.20 Under VBMAP, the 

contractor gathers evidence in support of a claim and then sends the 

claim file back to the originating regional office, which reviews the claim 

for completeness and quality and then assigns a rating. Contractor staff 

are required to complete their work within 135 days of receiving the file 

and provide VBA with status reports that include several measures of 

timeliness, including the time it took to receive medical evidence from 

providers and to return a claim to VBA for rating.21 As of June 2012, VBA 

 

20To implement VBMAP, VBA has contracted with ACS Federal Solutions to conduct 

evidence gathering for VBA claims, among other tasks, through a one-time, 12-month 

professional services contract using funds from the fiscal year 2011 VA budget. 

21The contractor is required to complete all claims requesting an increase in existing 

disability benefits within 120 days of receipt.
 

Page 14 GAO-13-453T 

regional offices we spoke with were awaiting the first batch of claims that 

were to be sent to the contractors.

To help speed up the claims and appeals processes, VBA also has 

several efforts that modify program requirements or change procedures 

(see fig. 4). The Fully Developed Claims (FDC) program began as a pilot 

in December 2008 and was implemented nationwide in June 2010. 

Normally, once a veteran submits a claim, VBA will review the claim and 

then send the veteran a letter detailing additional evidence required to 

support it. The FDC program eliminates this step because the required 

notification is provided to the veteran directly on the FDC form, thus 

reducing the time VBA would normally spend gathering evidence for the 

veteran. In exchange for expedited processing, veterans participating in 

the FDC program send VBA any relevant private medical evidence with 

the claim and certify that they have no additional evidence to provide. 

According to VBA officials, in the first 2 years of the program, VBA 

processed 33,001 FDC claims, taking an average of about 98 days to 

complete—8 days longer than the goal of 90 days for these claims. 

However, as of July 2012, veteran participation in the FDC program had 

been low—only 4 percent of all compensation rating claims submitted in 

2012.

The Claims Organizational Model initiative is aimed at streamlining the 

overall claims process (see fig. 4).22 For this initiative, VBA created 

specialized teams that process claims based on their complexity. 

Specifically, an “express team” processes claims with a limited number of 

conditions or issues; a “special operations” team processes highly 

complex claims, such as former prisoners of war or traumatic brain injury 

cases; and a core team works all other claims. Each of these teams is 

staffed with both development and ratings staff, which VBA believes will 

lead to better coordination and knowledge-sharing. Under this model, 

VBA also redesigned the procedures that mailrooms use to sort and 

process incoming claims. As of December 2012, VBA had implemented 

the initiative at 51 regional offices.23 According to VA, the remaining 

 

22We use “the Claims Organization Model” to refer to VBA’s organization model which 

reorganizes claims processing staff into cross-functional teams using segmented 

processing lanes.

23VA first commenced a pilot in three regional offices in March 2012.
 

Page 15 GAO-13-453T 

regional offices will be transitioned to the Claims Organizational Model by 

the second quarter of fiscal year 2013.

In 2010, VBA began to develop the Veterans Benefits Management 

System (VBMS), a paperless claims processing system that is intended to 

help streamline the claims process and reduce processing times (see fig. 

4). According to VBA officials, VBMS is intended to convert existing 

paper-based claims folders into electronic claims folders and allow VBA 

employees electronic access to claims and evidence. Once completed, 

VBMS is also expected to allow veterans, physicians, and other external 

parties to submit claims and supporting evidence electronically. In August 

2012, VA officials told us that VBMS was still not ready for national 

deployment, citing delays in scanning claims folders into VBMS as well as 

other software performance issues. A recent VA OIG report also 

concluded that VBMS has experienced some performance issues and the 

scanning and digitization of claims lacked a detailed plan.24 However, 

according to VA, as of December 2012, 18 regional offices were piloting 

VBMS and all regional offices are expected to implement VBMS by the 

end of calendar year 2013.

We have noted that VA’s ongoing efforts should be driven by a robust, 

comprehensive plan; however when we reviewed VBA’s plan documents, 

we found that they fell short of established criteria for sound planning.25

Specifically, VBA provided us with several documents, including a 

PowerPoint presentation and a matrix that provided a high-level overview 

of over 40 initiatives, but, at the time of our review, could not provide us 

with a robust plan that tied together the group of initiatives, their interrelationships, and subsequent impact on claims and appeals processing 

times. Although there is no established set of requirements for all plans, 

components of sound planning are important because they define what 

 

24VA Office of Inspector General, Office of Audits and Evaluations, Veterans Benefits 

Administration Review of Transition to a Paperless Claims Processing Environment, 

(Washington D.C.: February 4, 2013).

25Past GAO reports have identified best practices in planning. A results-oriented plan to 

achieve established goals should include (1) purpose, scope, and methodology; 

(2) problem definition and risk assessment; (3) goals, subordinate objectives, activities, 

and performance measures; (4) resources, investments, and risk management; 

(5) organizational roles, responsibilities, and coordination; and (6) integration. See GAO, 

Social Security Disability: Additional Performance Measures and Better Cost Estimates 

Could Help Improve SSA’s Efforts to Eliminate Its Hearings Backlog, GAO-09-398 

(Washington, D.C.: September 9, 2009).
 

Page 16 GAO-13-453T 

organizations seek to accomplish, identify specific activities to obtain 

desired results, and provide tools to help ensure accountability and 

mitigate risks.

In our December 2012 report, we recommended that VBA seek 

improvements for partnering with relevant federal and state military 

officials to reduce the time it takes to gather military service records from 

National Guard and Reserve sources. We also recommended that VBA 

develop improvements for partnering with Social Security Administration 

officials to reduce the time it takes to gather medical records. Lastly, we 

recommended that VBA develop a robust backlog reduction plan for its 

initiatives that, among other best practice elements, identifies 

implementation risks and strategies to address them and performance 

goals that incorporate the impact of individual initiatives on processing 

timeliness.

VA generally agreed with our conclusions and concurred with our 

recommendations, and summarized efforts that are planned or underway 

to address them. For example, VA stated it has recently initiated several 

interagency efforts to the timeliness of record exchanges between VBA 

and DOD. In addition, VA stated that it is working with SSA to pilot a webbased tool to provide VA staff a secure, direct communication with SSA 

and to automate VA’s requests for SSA medical records. VA also agreed 

with our recommendation to develop a robust backlog plan for VBA’s 

initiatives and, subsequent to our report, published the Department of 

Veterans Affairs (VA) Strategic Plan to Eliminate the Compensation 

Claims Backlog. This plan includes implementation risks and performance 

metrics used to track the cumulative effect of its initiatives on processing 

times but still lacks individual performance goals and metrics for all 

initiatives.

In conclusion, for years, VA’s disability claims and appeals processes 

have received considerable attention as VA has struggled to process 

disability compensation claims in a timely fashion. Despite this attention, 

VA continues to wrestle with several ongoing challenges—some of which 

VA has little or no control over—that contribute to lengthy processing 

timeframes. For instance, the number and complexity of VA claims 

received has increased. VBA is currently taking steps to improve the 

timeliness of claims and appeals processing; however, prospects for 

improvement remain uncertain because timely processing remains a 

daunting challenge.

Implementation of 

Recommendations 

Could Help Improve 

Evidence Gathering 

and Ensure Better 

Strategic Management 

of Improvement 

Initiatives 
 

Page 17 GAO-13-453T 

Chairman Sanders, Ranking Member Burr, and Members of the 

Committee, this concludes my prepared statement. I am pleased to 

answer any questions you may have.

For further information about this testimony, please contact Daniel Bertoni 

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

Congressional Relations and Public Affairs may be found on the last page 

of this testimony. Other key contributors to this testimony include Lucas 

Alvarez, James Bennett, Michelle Bracy, Brett Fallavollita, Dan Meyer, 

James Rebbe, Ryan Siegel, Walter Vance, and Greg Whitney.

Contacts and Staff 

Acknowledgments 

(131245)
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