VETERANS’ 

DISABILITY 

BENEFITS

Timely Processing 

Remains a Daunting 

Challenge

Report to Congressional Requesters

December 2012

GAO-13-89

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-89, a report to 

congressional requesters

December2012

VETERANS’ DISABILITY BENEFITS

Timely Processing Remains a Daunting Challenge 

Why GAO Did This Study

For years, VA has struggled with an 

increasing workload of disability 

compensation claims. The average 

time to complete a claim was 188 days 

in fiscal year 2011, and VA expects an 

increase in claims received as 1 million 

servicemembers leave military service 

over the next 5 years. As GAO and 

other organizations have previously 

reported, VA has faced challenges in 

reducing the time it takes to decide 

veterans’ claims. GAO was asked to 

review these issues. Specifically, this 

report examines (1) the factors that 

contribute to lengthy processing times 

for disability claims and appeals, and

(2) the status of VBA’s recent efforts to 

improve disability claims and appeals 

processing timeliness. To do this, GAO 

analyzed VBA performance data and 

program documents, reviewed relevant 

studies and evaluations, met with staff 

from five VA regional offices, and 

interviewed VBA officials and Veterans 

Service Organizations.

What GAO Recommends

GAO recommends that VBA (1) 

partner with military officials to reduce 

timeframes to gather records from 

National Guard and Reserve sources, 

(2) partner with SSA to reduce 

timeframes to gather SSA medical 

records, and (3) ensure the 

development of a robust plan for its

initiatives that identifies performance

goals that include the impact of 

individual initiatives on processing 

timeliness. In response to a draft of this 

report, VA officials generally agreed 

with GAO’s conclusions and concurred 

with the recommendations, and 

summarized efforts that are planned or 

underway to address the 

recommendations.

What GAO Found

A number of factors—both external and internal to the Veterans Benefits 

Administration (VBA)—have contributed to the increase in processing timeframes 

and subsequent growth in the backlog of veterans’ disability compensation 

claims. As the population of new veterans has swelled in recent years, the 

annual number of claims received by VBA has gone up. Compared to the past, 

these claims have a higher number of disabling conditions, and some of these 

conditions, such as traumatic brain injuries, make their assessment complex. 

Moreover, due to new regulations that have established eligibility for benefits for 

new diseases associated with Agent Orange exposure, VBA adjudicated 260,000 

previously denied and new claims. Beyond these external factors, issues with the 

design and implementation of the compensation program have contributed to 

timeliness challenges. For example, the law requires the Department of Veterans 

Affairs (VA) to assist veterans in obtaining records that support their claim. 

However, VBA officials said that lengthy timeframes 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. As a result, the 

evidence gathering phase of the claims process took an average of 157 days in 

2011. Further, VBA’s paper-based claims processing system involves multiple 

hand-offs, which can lead to misplaced and lost documents and can cause 

unnecessary time delays. Concerning timeliness of appeals, VBA regional offices 

have shifted resources away from appeals and toward claims in recent years, 

which has led to lengthy appeals timeframes. 

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. VBA is using contractors to 

handle some aspects of the claims process, and is also shifting some workload 

between regional offices. Also, VBA is modifying and streamlining certain claims 

and appeals processing procedures for veterans who opt to participate in these 

initiatives in exchange for an expedited decision. For example, veterans receive 

expedited processing when they submit a claim that is certified as having all 

required evidence. Not many veterans have elected this option, but VA is making 

adjustments to increase its attractiveness. In addition, VBA is trying to decrease 

the amount of time it takes to gather medical evidence. For example, VBA 

recently encouraged medical providers to use a standardized form when 

responding to VBA’s request for information. However, results of this initiative 

have been mixed. VBA is also taking steps to streamline the claims process, 

including implementing initiatives to create (1) standardized language for 

decision letters sent to veterans, (2) specialized teams that process claims based 

on level of complexity, and (3) a paperless claims system. According to VBA 

officials, these efforts will help VA process veterans’ claims within 125 days by 

2015. However, the extent to which VA is positioned to meet this ambitious goal 

remains uncertain. Specifically, VBA’s backlog reduction plan—its key planning 

document—does not articulate performance measures for each initiative, 

including their intended impact on the claims backlog. Furthermore, VA has not 

yet reported on how these efforts have affected processing times, a condition 

which raises concern given the mixed results that have emerged to date.

View GAO-13-89. For more information, 

contact Daniel Bertoni at (202) 512-7215 or

bertonid@gao.gov
Page i GAO-13-89 VA Disability Benefits Processing

Letter 1 

Background 4

Rising Workloads, along with Program Rules and Inefficient 

Processes, Contribute to Lengthy Processing Time Frames 9

VBA Is Taking Steps to Improve Claims and Appeals Processing, 

but Future Impact Is Uncertain 21

Conclusions 29

Recommendations for Executive Action 29

Agency Comments and Our Evaluation 30

Appendix I Objectives, Scope, and Methodology 35

Appendix II Veteran Notification during the Claims and Appeals Processes 39

Appendix III Selected VBA Efforts to Improve Claims and Appeals 

Timeliness 43

Appendix IV Comments from the Department of Veterans Affairs 46

Appendix V GAO Contact and Staff Acknowledgments 51

Related GAO Products 52

Table

Table 1: Selected VBA Efforts to Improve Claims and Appeals 

Timeliness 43

Figures

Figure 1: Selected VA Regional Offices That GAO Reviewed 3

Figure 2: Overview of VA’s Disability Claims Process 5

Contents 
Page ii GAO-13-89 VA Disability Benefits Processing

Figure 3: Average Days VA Compensation Rating Claims Were 

Pending and Average Days It Took to Complete Claims, 

Fiscal Year 2009 to August 2012 7

Figure 4: Timeliness of Phases in VA’s Claims Process for Fiscal 

Year 2011 8

Figure 5: VA Timeliness Measures of Notices of Disagreement and 

Appeals Certification, Fiscal Year 2009 to August 2012 8

Figure 6: VA Compensation Rating Claims Received, Completed, 

and Backlogged, Fiscal Years 2009 to 2011 10

Figure 7: Notices of Disagreement Received by VA and Awaiting a 

Decision, Fiscal Years 2009 to 2012 11

Figure 8: Selected VBA Improvement Efforts 22

Figure 9: VBA Notifications to Veterans throughout the Claims 

Process 39

Figure 10: VBA Notifications to Veterans throughout the Appeals 

Process 41
Page iii GAO-13-89 VA Disability Benefits Processing

Abbreviations

ACE Acceptable Clinical Evidence

Board Board of Veterans’ Appeals

DBQ Disability Benefits Questionnaire 

DOD Department of Defense 

DRO Decision Review Officer 

FDC Fully Developed Claim

FTE full-time equivalent 

IRIS Inquiry Routing and Information System

MAP-D Modern Award Processing-Development 

MSA Metropolitan Statistical Area 

OIG Office of Inspector General 

QRT Quality Review Team

RVSR Rating Veterans Service Representative 

SNL Simplified Notification Letter 

SOC Statement of the Case 

SSA Social Security Administration 

SSOC Supplemental Statement of the Case 

VA Department of Veterans Affairs 

VACOLS Veterans Appeals Control and Locator System 

VBA Veterans Benefits Administration 

VBMAP Veterans Benefits Management Assistance Program 

VBMS Veterans Benefits Management System 

VCAA Veterans Claims Assistance Act of 2000

VETSNET Veterans Services Network 

VHA Veterans Health Administration 

VONAPP Veterans On Line Application

VOR VETSNET Operations Reports

VSO Veterans Service Organization 

VSR Veterans Service Representative 

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Page 1 GAO-13-89 VA Disability Benefits Processing

United States Government Accountability Office

Washington, DC 20548

December 21, 2012

Congressional Requesters

The Department of Veterans Affairs (VA) disability compensation program 

provides monetary support to veterans with disabling conditions that were 

incurred or aggravated during military service. In fiscal year 2011, the 

program provided $39.4 billion in benefits to 3.35 million veterans. For 

years, the disability compensation claims process has been the subject of 

concern and attention by VA, Congress, and Veterans Service 

Organizations (VSO), due in large part to long waits for decisions and the 

large number of claims pending a decision. Moreover, VA’s backlog of 

claims—defined as claims awaiting a decision for over 125 days—has 

more than tripled since September 2009. Against this backdrop, 1 million 

servicemembers are expected to become veterans in the next 5 years 

according to VA officials, with a significant number expected to apply for 

disability benefits. As we and other organizations have reported over the 

last decade, VA has faced challenges in reducing the time it takes to 

decide veterans’ claims. For example, the average length of time to 

complete a claim has increased from 161 days in 2009 to 260 days in 

2012.1 Moreover, in August 2012, 568,043 claims—approximately twothirds of all compensation rating claims—were backlogged.2

1. What factors contribute to lengthy processing times for disability 

claims and appeals?

In addition, 

timeliness of appeals processing at VA regional offices has also slowed 

by 56 percent over the last several years. The Veterans Benefits 

Administration (VBA) has a number of ongoing initiatives in place to help 

meet its stated timeliness goals. In this context, we were asked to 

examine issues VA regional offices face in processing disability claims 

and appeals in a timely fashion. Specifically, we addressed the following 

questions:

 

1 From the beginning of fiscal year 2012 through August 2012, which was the most recent 

data available at the time of publishing, the average number of days it took VA to 

complete a claim was 260 days. 

2 Compensation rating claims include pension rating and disability compensation rating 

claims. Workload and timeliness data provided to us by VBA include all compensation 

rating claims. Furthermore, VBA does not report out on disability rating compensation 

claims separately.

 
 

Page 2 GAO-13-89 VA Disability Benefits Processing

2. What is the status of VBA’s recent efforts to improve disability 

claims and appeals processing timeliness?

To address our objectives, we collected and analyzed information through 

multiple methods. We reviewed relevant federal laws and regulations, 

court decisions, VBA policy manuals and documents, and training 

materials. We also reviewed past GAO and VA Office of Inspector 

General (OIG) reports, VBA studies and evaluations, and other 

documents relevant to claims and appeals processing at VBA regional 

offices. We collected data on claims and appeals processing workload 

and timeliness from VBA’s internal dashboard.3

 

3 VBA’s internal dashboard is a data report that aggregates key metrics that are used to 

assess performance from a variety of data sources into one integrated tool. 

To assess the reliability of 

the data, we conducted interviews with VBA officials in charge of 

maintaining VBA’s internal dashboard about their quality control 

procedures and practices used to extract timeliness and workload data 

from underlying data sources. We relied on past GAO data reliability 

assessments of the underlying data sources where enterprise-wide data 

on workload and timeliness of claims and appeals processing is stored 

and extracted into the internal dashboard tool. In addition, we collected 

data on claims processing resources from VBA’s Personnel and 

Accounting Integrated Database. To assess the reliability of these data, 

we interviewed officials in VBA’s Office of Human Resources about 

practices to record personnel actions, quality control procedures 

conducted within the Office of Human Resources to ensure the quality of 

the data, as well as potential limitations to the data. We reviewed the data 

and found it to be sufficiently reliable for the purpose of analyzing 

timeliness, workload, and resources assigned to claims processing. We 

interviewed VBA central office officials, including officials in VBA’s 

Implementation Center (which was established as a project management 

office to manage improvement initiatives), and VSO representatives who 

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

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. For each location, we 

interviewed regional office management and staff, analyzed workload 

management documents, and reviewed written notifications sent to 
 

Page 3 GAO-13-89 VA Disability Benefits Processing

veterans (see fig. 1). For additional information on our scope and 

methodology, see appendix I.

Figure 1: Selected VA Regional Offices That GAO Reviewed

Note: MSA rank refers to the rank order of the population of all Metropolitan Statistical Area (MSA) 

across the nation, according to the 2010 Census. An MSA is a geographic entity defined by the U.S.

Office of Management and Budget for use by federal statistical agencies, based on the concept of a 

core area with a large population nucleus, plus adjacent communities having a high degree of 

economic and social integration with that core.

We conducted this performance audit from March 2012 through 

December 2012 in accordance with generally accepted government 

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

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.
 

Page 4 GAO-13-89 VA Disability Benefits Processing

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

while on active military duty) according to the severity of the disability.4

VA also pays additional compensation for certain dependent spouses, 

children, and parents of veterans.5 VA’s disability compensation claims 

process starts when a veteran submits a claim to VBA (see fig. 2). 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. Later, the veteran 

can reopen a claim to request an increase in disability compensation from 

VA if, for example, a service-connected disability has worsened or a new 

disability arises.

 

4 38 U.S.C. §§ 1110, 1155. VA’s ratings are awarded in 10 percent increments, from 0 to 

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

percent. As of December 2011, basic monthly payments ranged from $127 for a veteran 

with 10 percent disability and no dependents to $ 3,285 for a veteran with 100 percent 

disability and dependents.

5 38 U.S.C. § 1115.

Background 

Disability Claims Process
 

Page 5 GAO-13-89 VA Disability Benefits Processing

Figure 2: 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.

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.6 In response to such a notice, VBA reviews the case 

and provides the veteran with a written explanation of the decision if VBA 

does not grant all appealed issues.7

 

6 38 U.S.C. § 7105. A Notice of Disagreement is a written communication that a claimant 

uses to express disagreement with a decision. 

Appendix II contains more 

information regarding VBA’s notifications to veterans throughout the 

disability compensation claims and appeals processes. If additional 

evidence is provided, VBA reviews the case again and if this new 

evidence does not result in a grant of all appealed issues, VBA produces 

another written explanation of the decision. If the veteran further 

disagrees with the decision, he or she may appeal to the Board of 

Veterans’ Appeals (the Board). Before transferring the appeal to the 

Board, VBA reviews the case again and then certifies that the appeal is 

ready for review by the Board. After the appeal has been certified, the 

Board conducts a hearing if the veteran requests one, then grants 

7 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.

Appeals Process
 

Page 6 GAO-13-89 VA Disability Benefits Processing

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.8

Congress clarified VA’s duties with regard to assisting in the development 

of claims in the Veterans Claims Assistance Act of 2000 (VCAA).

9 VCAA 

eliminated the requirement that a veteran submit a “well-grounded” claim 

before VA could assist in developing the claim and instead obligated the 

agency to assist a claimant in obtaining evidence that is necessary to 

establish eligibility for the benefit being sought. Specifically, VA must: (1) 

notify claimants of the information necessary to complete the 

application;10 (2) indicate what information not previously provided is 

needed to substantiate the claim;11 (3) make reasonable efforts to assist 

claimants in obtaining evidence to substantiate claimants’ eligibility for 

benefits, including relevant records;12 and (4) notify claimants when VA is 

unable to obtain relevant records.13 According to VA regulations, VA 

efforts to obtain federal records should continue until the records are 

obtained or until VA has deemed it reasonably certain that such records 

do not exist or that further efforts to obtain those records would be futile.14

Timeliness of VA compensation rating claims and appeals processing has 

worsened in recent years. As a key indicator of VBA’s performance in 

claims and appeals processing, timeliness is measured in various ways. 

To measure overall claims processing timeliness, VBA uses two 

 

8 38 U.S.C. §§ 7252 and 7292.

9 Pub. L. No. 106-475, 114 Stat. 2096, amending various provisions of Chapter 51 of title 

38, U.S. Code. 

10 38 U.S.C. § 5102(b).

11 38 U.S.C. § 5103(a).

12 38 U.S.C. §§ 5103A(a)(1) and 5103A(b)(1). 

13 38 U.S.C. § 5103A(b)(2).

14 38 C.F.R. § 3.159(c)(2).

VA’s Duty to Assist 

Requirements

Timeliness of Claims and 

Appeals Processing
 

Page 7 GAO-13-89 VA Disability Benefits Processing

measures: (1) the number of days the average pending claim has been 

awaiting a decision (Average Days Pending) and (2) the average number 

of days that VBA took to complete a claim where a decision has been 

reached (Average Days to Complete). Both measures of claims 

processing timeliness have worsened substantially over the last several 

years (see fig.3).15

Figure 3: Average Days VA Compensation Rating Claims Were Pending and 

Average Days It Took to Complete Claims, Fiscal Year 2009 to August 2012

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. 4). The 

evidence gathering phase is the most time-intensive phase, taking over 5 

months (157 days) on average in fiscal year 2011 and continuing to grow 

throughout fiscal year 2012.

 

15VBA 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. The Average Days to Complete 

measures the average processing time for claims completed within a given time period.
 

Page 8 GAO-13-89 VA Disability Benefits Processing

Figure 4: 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.

The timeliness of appeals processing at VA regional offices has worsened 

as well. The average timeframes in VBA’s response to Notices of 

Disagreement and the certification of appeals to the Board have 

increased since fiscal year 2009 (see fig. 5).

Figure 5: VA Timeliness Measures of Notices of Disagreement and Appeals 

Certification, Fiscal Year 2009 to August 2012
 

Page 9 GAO-13-89 VA Disability Benefits Processing

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

the increase in incoming claims. In fiscal year 2011, VA completed over 1 

million compensation rating claims, a 6 percent increase from 2009. 

However, the number of VA compensation rating claims received has

grown 29 percent—from 1,013,712 in fiscal year 2009 to 1,311,091 in 

fiscal year 2011 (see fig. 6). 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.

Rising Workloads, 

along with Program 

Rules and Inefficient 

Processes, Contribute 

to Lengthy Processing 

Time Frames

Rise in Claims Submitted 

Is Outpacing Claims 

Production 
 

Page 10 GAO-13-89 VA Disability Benefits Processing

Figure 6: VA Compensation Rating Claims Received, Completed, and Backlogged, 

Fiscal Years 2009 to 2011

Similar to claims processing, VA regional office appeals processing has 

not kept pace with incoming appeals received. The number of Notices of 

Disagreement—the first step in the appeals process when the veteran 

provides a written communication to VBA that he or she wants to contest 

the claims decision—received by VBA fluctuated over the last 4 years, yet 

those awaiting a decision grew 76 percent over that time period (see fig. 

7). Moreover, the number of Statements of the Case—an explanation of 

VBA’s decision on the appellant’s case—that were mailed by VBA 

decreased 24 percent over the last 4 years—from 100,291 in 2009 to 

76,685 in 2012. In addition, the time it took to mail a Statement of the 

Case increased 57 percent over that time period—from 293 days to 460 

days on average. 
 

Page 11 GAO-13-89 VA Disability Benefits Processing

Figure 7: Notices of Disagreement Received by VA and Awaiting a Decision, Fiscal 

Years 2009 to 2012

A number of factors have contributed to the substantial increase in claims 

received. One factor was the commencement in October 2010 of VBA’s 

adjudication of 260,000 previously denied and new claims when a 

presumptive service connection was established for three additional 
 

Page 12 GAO-13-89 VA Disability Benefits Processing

Agent Orange-related diseases.16

 

16 VBA 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). 

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 to 

processing Agent Orange claims exclusively. 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. In conjunction with 

an increase in claims received, VBA officials said that claims today are 

more complex than in the past. As we reported in 2010, VBA said it is 

receiving more claims for complex disabilities related to combat and 

deployments overseas, including those based on environmental and 
 

Page 13 GAO-13-89 VA Disability Benefits Processing

infectious disease risks and traumatic brain injuries.17

Some claims processing staff have been assigned additional 

responsibilities that can impede their ability to process claims or appeals 

in a timely fashion. According to VBA officials, because of a large influx of 

newly hired and promoted claims processing staff—1,973 new staff were 

hired since 2009 and approximately 50 percent of claims processing staff 

have been in their current role for less than 2 years—many staff have not 

yet become fully proficient in their new roles and experienced staff have 

been diverted from their claims processing responsibilities to conduct 

training, mentor new hires, and review others’ work.

Claims with many 

conditions can take longer to complete because each condition must be 

evaluated separately and then combined into a single percentage rating. 

According to VA, in 2011, the number of medical conditions claimed by 

veterans who served in Iraq and Afghanistan averaged 8.5, an increase 

from 3-4 conditions per claim for Vietnam veterans.

18 In addition to 

training and mentoring, some claims processing staff at each of the five 

regional offices we met with had been assigned to exclusively conduct 

quality reviews instead of processing claims as part of the Quality Review 

Team initiative.19

 

17 GAO, Veterans’ Disability Benefits: Further Evaluation of Ongoing Initiatives Could Help 

Identify Effective Approaches for Improving Claims Processing, 

At one regional office, 17 of 277 claims processing staff 

were assigned to this team. Regional office officials said that while this 

initiative has increased the quality of the ratings produced, it has 

negatively affected the overall timeliness of claims processing. 

Furthermore, officials at several regional offices we met with noted that 

they diverted staff away from processing the oldest claims to respond to 

inquiries from Congress, the administration, and veterans. Moreover, VBA 

GAO-10-213 

(Washington, D.C.: January 29, 2010). 

18 As we reported in 2010, VBA’s goal is for newly hired VSRs to be proficient within 18 

months and new RVSRs to be proficient within 2 years. See GAO-10-213. However, 

becoming proficient often takes longer—about 3 to 5 years for RVSRs. While VBA hired 

additional temporary staff using American Recovery and Reinvestment Act of 2009 funds, 

they were given limited training and less complex claims processing tasks. According to 

VBA officials, in 2011, VA received authority to convert temporary employees into 

permanent staff, which required additional training and mentoring. 

19 The Quality Review Team (QRT) initiative was implemented nationally in March 2012 

and consists of specially trained teams at regional offices that review claims files in the 

development and rating phases to provide immediate feedback to employees and catch 

adjudicative errors, as well as provide immediate feedback to claims processing staff 

before their claims are finalized.
 

Page 14 GAO-13-89 VA Disability Benefits Processing

officials at one regional office said the number of claims processing staff 

assigned to outreach activities has increased. Specifically, at the time of 

our review, 37 out of 302 claims processing staff were conducting 

outreach activities to servicemembers and veterans, such as giving 

briefings and distributing materials at military bases about pre-discharge 

and transition assistance programs.20

According to VBA officials, a primary reason that appeals timeliness at VA 

regional offices has worsened is a lack of staff focused on processing 

these appeals. 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. For example, at one regional 

office, all staff on the appeals team focused exclusively on rating disability 

claims for a 9-month period in 2010 instead of processing appeals. 

Officials at another regional office stated that until 2012, their appeals 

staff spent up to 2 weeks per month on non-appeals tasks. In addition, we 

reported in 2011 that regional office managers estimated that Decision 

Review Officers (DRO) spent on average 36 percent of their time on nonappeals processing tasks.21

 

20 The pre-discharge program is a joint VA and Department of Defense (DOD) program 

that affords service members the opportunity to file claims for disability compensation up 

to 180 days prior to separation or retirement from active duty or full-time National Guard or 

Reserve duty. There are four components of the pre-discharge program: Benefits Delivery 

at Discharge, Quick Start, Disability Evaluation System, and Seriously Injured/Very 

Seriously Injured. The Transition Assistance Program consists of comprehensive 3-day 

workshops that are designed to help servicemembers as they transition from military to 

civilian life. The program includes job search, employment and training information, as 

well as VA benefits information for servicemembers who are within 12 months of 

separation or 24 months of retirement. A companion workshop, the Disabled Transition 

Assistance Program, provides information on VA's Vocational Rehabilitation and 

Employment Program, as well as other programs for the disabled.

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 

21 In 2001, VA established the Decision Review Officer (DRO) review—an alternative 

review process at the regional level. If a veteran chooses the DRO review, a DRO 

conducts a de novo review of the claim, meaning a new and complete review without 

deference to the original decision, and can revise that decision without new evidence or a 

clear and unmistakable error—in other words, based on a difference of opinion. A DRO 

also may make a new decision based on new evidence or clear and unmistakable error. 

See GAO, Veterans Disability Benefits: Clearer Information for Veterans and Additional 

Performance Measures Could Improve Appeal Process, GAO-11-812 (Washington, D.C.: 

September 29, 2011). 
 

Page 15 GAO-13-89 VA Disability Benefits Processing

on appeals promptly because, in part, they were assigned responsibilities 

to process initial claims, which were given higher priority.22 The VA OIG 

recommended that VBA identify staffing resources needed to meet their 

appeals processing goals, conduct DRO reviews on all appeals, and 

revise productivity standards and procedures to emphasize processing 

appeals in a timely manner, such as implementing criteria requiring 

appeals staff to initiate a review or develop for Notices of Disagreement 

and certified appeals within 60 days of receipt. VBA agreed with the VA 

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

addressing these recommendations.

According to VA officials, federal laws23 and court decisions24 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 VCAA requires VA to assist a veteran who files a 

claim in obtaining evidence to substantiate the claim before making a 

decision.25 This requirement includes helping veterans obtain all relevant 

federal records and non-federal records.26

 

22 VA Office of Inspector General, Veterans Benefits Administration: Audit of VA Regional 

Office’s Appeals Management Processes, (Washington D.C.: May 30, 2012). 

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, 

23 Veterans’ 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.

24 See, 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). 

25 38 U.S.C. § 5103A(a)(1).

26 VA 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.

Program Requirements 

Contribute to Long 

Processing Times
 

Page 16 GAO-13-89 VA Disability Benefits Processing

but the claim cannot be completed until all relevant federal evidence is 

obtained.

While VA must consider all evidence submitted throughout the claims and 

appeals processes, if a veteran submits additional evidence or adds a 

condition to a claim late in the claims 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 and 

additional steps VA will take in light of the new evidence. Then, VA may 

have to obtain additional records or order another medical examination 

before the claim can be rated and a decision can be 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 conditions submitted by the veteran. 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. In 

addition, a veteran may submit additional evidence in support of their 

appeal at any time during the process. If the veteran submits additional 

evidence 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 

Case. 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.27

While federal law requires veterans to use an application form prescribed 

by VA when submitting a claim for original disability compensation 

benefits, VBA central office officials said they accept reopened claims or 

claims requesting an increase in disability compensation benefits in any 

 

27 The 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.
 

Page 17 GAO-13-89 VA Disability Benefits Processing

format, which can contribute to lengthy processing times.28 VBA will 

accept an original disability claim informally if it is submitted in a nonstandard format, but within 1 year the veteran must submit a VA Form 21-

526, Veteran’s Application for Compensation and/or Pension.29 VBA does 

not track the number of claims submitted in non-standard formats; 

however, officials at three regional offices we met with said they receive 

claims submitted in various formats, including hand-written letters. 

Officials at these three regional offices said that when such claims are 

submitted, there is a risk that claims staff may not be able to identify all 

the conditions the veteran would like to claim during initial development. 

For example, officials at one regional office stated that if these conditions 

are discovered later in the process, then VA must redevelop the claim—

which could include sending another letter to the veteran, obtaining 

additional records, and conducting another medical exam—before the 

claim can be rated and a benefit amount determined and disbursed. VBA 

officials said they expect the number of non-standard applications for 

disability claims to decrease as more veterans file claims electronically 

through the Veterans On Line Application (VONAPP), which is available 

at VA’s eBenefits website.30

Similar to processing for reopened claims, VA’s procedures allowing 

veterans to submit appeals in any format can negatively affect appeals 

processing times, according to VBA officials. For example, a veteran’s 

intention to appeal a prior decision may be overlooked initially by staff 

because there is no standard appeals submission form and a veteran’s 

statement to appeal a prior decision may be included along with other 

written correspondence for other purposes, such as submitting a new 

claim, according to VBA officials. When appeals are overlooked and later 

 

28 38 U.S.C. § 5101(a). VA defines an original claim as an initial formal application on the 

form prescribed by VA under the statute, and a reopened claim to include any application 

for a benefit received after final disallowance of an earlier claim, or any application based 

on additional evidence. 38 C.F.R. § 3.160(b) and (e). 

29 Under VA regulations, an informal claim is generally defined as any communication or

action indicating an intent to apply for one or more VA benefits, but which must identify the 

benefit being sought. 38 C.F.R. § 3.155(a).

30 The VONAPP website, created by VA in 2008, enables servicemembers, veterans, and 

their beneficiaries, as well as other designated individuals, to apply for benefits, including 

VA disability compensation, using the Internet. VA and DOD launched the eBenefits 

website in 2009 to help servicemembers and veterans manage their benefits and personal 

information.
 

Page 18 GAO-13-89 VA Disability Benefits Processing

found, it can delay recording Notices of Disagreement in appeals data 

systems and result in longer processing times, according to VBA officials.

According to VBA officials, delays in obtaining military service and 

medical treatment records, particularly for National Guard and Reserve 

members, is a significant factor lengthening the evidence gathering 

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

veterans are National Guard and Reserve members. According to a VA 

official, Department of Defense (DOD) Instruction 6040.45 requires 

military staff to respond to VA requests for National Guard and Reserve 

records in support of VA disability compensation claims. However, VBA 

area directors and officials at all five regional offices we met with 

acknowledged that delays in obtaining these records are a system-wide 

challenge. 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 to obtain all relevant records, 

potentially causing delays in the evidence gathering process.

Difficulties in obtaining timely and complete medical information, 

especially from private medical providers, can also contribute to a lengthy 

evidence gathering phase. For example, officials at one regional office 

said the process may be delayed if veterans are slow to return their 

consent forms that allow VA to pursue private medical records. Also, 

according to VBA officials, private medical providers may not respond to 

VA records requests in a timely fashion. In addition, officials at one 

regional office we met with mentioned that time frames can also be 

affected if veterans fail to show up for scheduled examinations. Officials 

at two regional offices we met with said that even when medical records 

are obtained, medical exams and opinions may include erroneous 

information or be missing necessary evidence, which then requires VA 

officials to follow-up with medical providers to clarify information. In some 

cases, another examination must be ordered before a decision can be 

made on the claim, which can add months to the process. VBA area 

directors acknowledged that obtaining complete and sufficient medical 

information is a system-wide challenge.

Gathering Records from 

Federal Agencies and 

Others Can Take Months
 

Page 19 GAO-13-89 VA Disability Benefits Processing

Difficulties obtaining Social Security Administration (SSA) medical 

records, as one specific example, can also lengthen the evidence 

gathering phase. Currently, an interagency agreement exists that

establishes the terms and conditions under which SSA discloses 

information to VA for use in determining eligibility for disability benefits, 

according to VBA officials. Although VBA regional office staff have direct 

access to SSA benefits payment histories, they do not have direct 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 fax request. If a 

response to the follow-up request is not received after 30 days, the 

manual instructs claims staff 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, which can 

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

regional offices we met with mentioned 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 a claim may be stalled in the evidence 

gathering phase if a piece of 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 at one regional office we 

met with said that processing can also be delayed if mail staff are slow to 

Some Work Processes Are 

Inefficient
 

Page 20 GAO-13-89 VA Disability Benefits Processing

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. In May 2011, 

the VA OIG reported that VA regional office mailroom operations needed 

strengthening to ensure that staff process mail in an accurate and timely 

manner. Specifically, the VA OIG found that staff did not always record 

incoming mail into IT systems within 7 days of receipt and that they did 

not properly process and route mail to existing claims folders in a timely 

fashion in 10 of the 16 VA regional offices they reviewed.31 VBA area 

directors said that mail processing 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. In addition, VBA area directors said that 

standardizing the mail handling and sorting process in an integrated mail 

processing center—a component of the Claims Organizational Model 

implemented in 18 regional offices in fiscal year 2012—is intended to 

improve mail processing by involving more senior staff in the process. 

VBA officials also said that moving 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 claims-related mail with the 

appropriate claim folders until the folders were returned from the VA 

Medical Center.32

Lastly, according to VBA officials, the lack of an integrated IT system that 

provides all necessary information and functionality to track and process 

claims and appeals can decrease the productivity of claims processing 

staff. For example, according to staff at one VA regional office we spoke 

with, currently, they must use different systems to track claims folders, 

order medical exams, record claim processing actions taken by VBA staff 

and evidence received on a claim, rate claims, process awards, and 

record the status of appeals to the Board. The lack of an integrated 

system requires staff to enter claim information multiple times, search 

through multiple systems for claim information, and maintain processing 

notes on the status of the claim or appeal in multiple systems. For 

In addition, processing halts while a claim folder is sent 

to another regional office or brokering center.

 

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

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

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

Regional Offices.
 

Page 21 GAO-13-89 VA Disability Benefits Processing

example, officials at two regional offices we met with said RVSRs must 

enter information into the Rating Board Automation system that was 

already entered in the Modern Award Processing-Development (Map-D) 

system. In addition, appeals staff must maintain claim processing notes 

and information on the status of appeals in two different systems—one 

maintained by the Board (Veterans Appeals Control and Locator System) 

and one maintained by VBA (MAP-D). According to regional office staff, 

the redundant data entry takes extra time that could have been spent 

working on other cases. Moreover, staff at one regional office said they 

did not always keep their claim processing notes up-to-date in both 

systems. 

VBA is currently taking steps to improve the timeliness of claims and 

appeals processing. 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. VBA’s improvement efforts include using existing VBA staff 

and contractors to manage workload, modifying and streamlining 

procedures, improving records acquisition, and redesigning the claims 

and appeals processes (see fig. 8). Although VBA is monitoring these 

efforts, the planning documents provided to us lack key aspects of sound 

planning, such as performance measures for each effort.

VBA Is Taking Steps 

to Improve Claims 

and Appeals 

Processing, but 

Future Impact Is 

Uncertain 
 

Page 22 GAO-13-89 VA Disability Benefits Processing

Figure 8: Selected VBA Improvement Efforts

VBA has several ongoing efforts to leverage internal and external 

resources to help manage its workload (see fig. 8).33 One ongoing effort 

that began in 2001 is the use of brokering centers—which are 13 special 

teams that process claims transferred from regional offices experiencing 

a large backlog of claims. As we reported in 2010, these teams are 

staffed separately from other regional office teams.34

 

33 For more information on all VBA initiatives to reduce claims and appeals processing 

times, see appendix III.

According to VA 

officials, brokering centers gather evidence for the claim, make a 

decision, process awards payments, and work on appeals. Brokering 

center teams processed nearly 171,000 claims in fiscal year 2009, 

according to the VA OIG. VA central office officials told us that in fiscal 

years 2010 and 2011, all brokering centers focused exclusively on the readjudication of Agent Orange claims. Through the first 11 months of fiscal 

34 See GAO-10-213. 

VBA Is Using Existing VBA 

Staff and Contractors to 

Manage Its Growing 

Workloads 
 

Page 23 GAO-13-89 VA Disability Benefits Processing

year 2012, brokering centers processed approximately 24,000 claims. 

VBA officials at several regional offices told us that brokering, over the 

past year, has helped to manage their overall claims workload.

VBA also 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.35 Under VBMAP, 

regional offices send cases to a contractor to gather evidence. After 

evidence has been gathered for an individual claim, the contractor sends 

the 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.36 As 

of June 2012, VBA regional offices we spoke with were awaiting the first 

batch of claims that were to be sent to the contractors, so it remains to be 

seen if VBMAP reduces processing times. Contractors are required to 

provide VBA with status reports that include several measures of 

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

providers and the time it took to return a claim to VBA for rating.

With the intent of speeding up the claims and appeals processes, VBA 

has several efforts that modify program requirements or relieve VA of 

certain duties (see fig. 8). One effort is the Fully Developed Claims (FDC)

program, which began as a pilot in December 2008 and was implemented 

nationwide in June 2010. The FDC program was implemented in 

response to a congressional mandate that required VBA to conduct a pilot 

program to expedite processing of fully developed claims in 90 days or 

less.37

 

35 To 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. ACS 

employs contract staff at its London, Kentucky site to gather supporting evidence. Once 

the evidence gathering is complete, the ACS contractor returns the evidence package to 

VBA. ACS receives a fixed price for each completed evidence package.

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

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

disability benefits within 120 days of receipt. 

37 Veterans’ Benefits Improvement Act of 2008, Pub. L. No. 110-389, § 221, 122 Stat. 

4145, 4154. A fully developed claim is one where the veteran indicates that he or she 

received appropriate assistance or does not intend to submit any additional information 

and certifies that no additional information or evidence is available or needs to be 

submitted.

VBA Is Changing 

Procedures and Modifying 

Requirements to Expedite 

Claims and Appeals 

Processing
 

Page 24 GAO-13-89 VA Disability Benefits Processing

claim and then send the veteran a letter detailing additional evidence 

required to support the claim. The FDC program eliminates this step and 

saves time because the required notification is provided to the veteran 

directly on the FDC form. The program also attempts to reduce 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. While VBA 

officials and VSOs expect the program to reduce processing delays for 

veterans, claims submitted without the required evidence are considered 

incomplete. Furthermore, claims submitted under the FDC program with 

incomplete evidence sometimes lose their priority status and are 

processed with VBA’s non-expedited workload, which can result in 

additional processing time. According to VBA officials, in the first 2 years 

of the program, VBA has 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. VBA officials attribute not meeting FDC processing

time goals to the increased workload resulting from processing Agent 

Orange claims. As of July 2012, veteran participation in the FDC program 

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

in 2012. A VBA official told us that in response to VSO input, they have 

made the FDC form easier to use. Moreover, the VBA official we spoke 

with expects more FDC claims once veterans are able to electronically file 

claims. While FDC claims are currently submitted by paper, the proposed 

electronic system will guide veterans through the steps to gather the 

necessary evidence in support of their claim and draw information needed 

on the form from VBA electronic databases.

VBA also began the Appeals Design Pilot—implemented at a single 

regional office—in spring 2012 to expedite appeals processing. The pilot 

modifies several program procedures with the goal of decreasing appeals 

processing times, according to management at the regional office 

conducting the pilot. For example, veterans participating in the pilot do not 

file appeals in non-traditional formats. Instead, they use a standardized 

Notice of Disagreement form. The pilot also forgoes the election of a 

traditional versus a DRO review of an appeal—providing DRO reviews for 
 

Page 25 GAO-13-89 VA Disability Benefits Processing

all appeals from veterans participating in the pilot.38 This change 

eliminates the need for VBA to wait up to 60 days for a veteran to make 

an election on the type of regional office review in an appeal. In addition, 

veterans submitting new evidence during the appeal can opt to have their 

case expedited directly to the Board without having the regional office 

review the additional evidence submitted. In addition to those mentioned 

above, the Appeals Design Pilot also has several other elements. For 

example, expedited processing is provided to appeals that are filed with 

only one or two disabling conditions. Under the pilot, some VSOs are also 

waiving the right to a local review of the appeal, but preserving the current 

practice of permitting VSOs to review the appeal once it goes before the 

Board.39

VBA has established efforts to standardize and expedite the process for 

acquiring medical records of veterans (see fig. 8). According to a VBA 

official, in September 2010, in seven regional offices, VBA began the 

Vendors for Private Medical Records initiative, which uses a contractor to 

obtain veterans’ medical records from private physicians.

From March through June 2012, 2,300 veterans participated in 

the pilot. According to VBA, pilot changes have, based on early results, 

significantly improved processing times.

40

 

38 As we reported in 2011, a veteran can appeal to the VA regional office that made the 

initial decision. And if the veteran remains dissatisfied, he or she can appeal to the Board. 

Appealing to the Board, however, can add more than 2 years, on average, to the wait time 

for a decision. To resolve more appeals at the regional level and avoid waits at the Board, 

VA established the DRO review as an alternative to the traditional regional office appeal 

review. A DRO is given authority to grant additional benefits after reviewing an appeal 

based on a difference of opinion with the original decision, without new evidence or a clear 

and unmistakable error, as required in a traditional review (see 

According to 

VBA, as of July 2012, the contactor had obtained 39,662 treatment 

records from private medical providers. VBA officials at one site told us 

that the contractor is frequently able to communicate with doctors more 

quickly because unlike claims staff who are tasked with multiple duties, 

the contractor focuses solely on obtaining medical records.

GAO-11-812 ). Under this 

process, veterans who submit a Notice of Disagreement are sent an election letter asking 

them to decide between a traditional or DRO review of their appeal (veterans would 

typically be given up to 60 days to make this selection).

39 VBA’s procedures allow a veteran’s representative, often a VSO, an opportunity to 

review an appeal and submit a statement regarding the appeal.

40 VBA’s claims staff remain responsible for gathering evidence from VHA records. 

Efforts to Improve 

Records Acquisition Have 

Produced Mixed Results 
 

Page 26 GAO-13-89 VA Disability Benefits Processing

VBA has another effort intended to reduce the amount of time spent 

processing medical documentation. Specifically, physicians are asked to 

complete Disability Benefits Questionnaires (DBQ), which are 

standardized medical forms–downloaded from VA’s website—that are 

designed to speed up the evidence gathering process by using check 

boxes and standardized language that are intended to more accurately 

capture information needed from providers.41 The DBQ forms have been 

available since March 2012, and VBA claims staff at the sites we visited 

reported mixed results. For instance, the forms have helped to 

standardize the medical evidence gathering process, but regional office 

claims staff in four of the regional offices we met with said that some DBQ 

forms are quite lengthy, requiring them to scan through multiple pages to

find certain information, which can be time-consuming. Claims staff also 

reported that some of the medical terminology used in the forms is not 

current, which may make it difficult for providers to complete. VBA 

officials said that improvements will be made to the forms when the 

agency converts to a paperless claims system, which might make it 

easier for claims staff to locate information contained in them. VBA has 

begun to track through their performance reporting system the number of 

DBQs completed and the completeness of those submitted by physicians, 

but is not measuring the initiative’s impact on timeliness.

In March 2012, VBA implemented a nationwide initiative that requires 

staff to use the Simplified Notification Letter (SNL), a process to 

communicate ratings decisions to veterans.42

 

41 There are more than 70 DBQs that cover a full range of medical conditions. While some 

DBQs are specific to a single condition—such as hypertension, arthritis, or prostate 

cancer—most forms can be used for several related conditions. 

According to VBA officials, 

the goal of the SNL is to reduce the time it takes claims staff to provide 

veterans with claims decisions that are more consistent and easier to 

understand. The SNL aims to reduce the time that VA staff spend 

composing rating decisions for claims by providing staff with codes that 

are associated with template language for rating decisions instead of the 

previous practice of composing a free-form narrative for each claims 

decision. According to claims staff at each of the regional offices we 

42 According to one VBA central office official, claims staff are not required to use the SNL 

in all circumstances. For example, claims staff may opt to use a traditional decision letter 

for decisions involving complex issues that require more information to explain the 

rationale for the decision. 

Efforts to Redesign Key 

Aspects of the Process Are 

Under Way without a 

Comprehensive Plan
 

Page 27 GAO-13-89 VA Disability Benefits Processing

visited, SNL has decreased the time it takes to rate claims, but claims 

staff in three regional offices told us it created additional steps in 

preparing the decision letter sent to the veteran, adding time to the 

processing awards phase. Claims staff we interviewed in one regional 

office estimated that the time needed to authorize a claim had increased 

from 3 minutes to 15 minutes. VBA officials said they have provided 

additional guidance to staff experiencing challenges with the SNL. In spite 

of these challenges, VBA reports an increase in production in two 

regional offices that piloted the SNL initiative.

The Claims Organizational Model initiative is aimed at streamlining the 

overall claims process (see fig. 8). 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. As of August 2012, 

VBA had implemented the initiative at 18 regional offices.43

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. 

According to VBA officials, VBMS is intended to convert existing paperbased claims folders into electronic claims folders that will allow VBA 

employees electronic access to claims and evidence. Once completed, 

VBMS will allow veterans, physicians, and other external parties to submit 

claims and supporting evidence electronically. VBMS is currently being 

Under this 

model, VBA also redesigned the procedures that mailrooms use to sort 

and process incoming claims. According to VBA central office staff, these 

changes entail incorporating more experienced claims staff to improve the 

process of routing incoming mail to the appropriate team and claims 

folder. This change aims to reduce the time it takes for claims-related mail 

to be entered into the claims processing systems. VBA tracks the impact 

of the claims process model using existing timeliness metrics and 

regional office performance measures.

 

43 Before the initiative is rolled out to 18 of VA’s regional offices, VA commenced a pilot in 

three regional offices in March 2012.
 

Page 28 GAO-13-89 VA Disability Benefits Processing

piloted in four VA regional offices. Although the most recent VBMS 

operating plan calls for national deployment of VBMS to start in 2012, 

VBA officials told us that VBMS is not yet ready for national deployment, 

citing delays in scanning claims folders into VBMS as well as other 

software performance issues. According to VBA officials, the Claims 

Organizational Model and VBMS will work together to reduce processing 

times and help VA process veterans’ claims within 125 days by 2015. 

Although VBMS began its pilot in 2010, VBA has not yet reported on how 

VBMS has affected processing times.

These ongoing efforts should be driven by a robust, comprehensive plan; 

however when we reviewed VBA’s backlog reduction plan, we found that 

it fell short of established criteria for sound planning.44

 

44 Past 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, 

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 

could not provide us with a robust plan that tied together the group of 

initiatives, their inter-relationships, 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 organizations seek to accomplish, identify 

specific activities to obtain desired results, and provide tools to help 

ensure accountability and mitigate risks. Some of VBA’s planning 

documents identify problems, summarize the overall purpose and goals of 

the redesign effort, and include some general estimates of project 

completion dates for some of the initiatives, as well as identify resources 

for managing the overall implementation efforts. However, the planning 

documents lack key elements of results-oriented planning. For example, 

they do not identify implementation risks or strategies to address them. In 

addition, the planning documents do not include performance goals, 

measures to assess the effectiveness of each initiative, or their impact on 

claims and appeals processing timeliness. VBA officials pointed out to us 

the challenges in isolating the impact of any one initiative on processing 

GAO-09-398 

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

Page 29 GAO-13-89 VA Disability Benefits Processing

times. Nonetheless, sound practices require assessing the effectiveness 

of each initiative.

VA provides a critical benefit to veterans who have incurred disabilities as 

a result of their military service. 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. And that number is 

projected to continue to increase as 1 million servicemembers become 

veterans over the next 5 years due to the drawdown of troops from a 

decade of conflict in Afghanistan and Iraq. Moreover, the evidence 

gathering phase in fiscal year 2011, which took over 5 months (157 days) 

on average, continues to worsen in 2012, partly due to difficulties in 

obtaining records for National Guard and Reserve and SSA medical 

records, according to VBA officials. While recent process and technology 

improvements hold some promise, without improved evidence gathering, 

VBA may struggle to meet its goal of processing all compensation claims 

within its 125 day goal by 2015. Although VBA is attempting to address 

processing challenges through various improvement initiatives, without a 

comprehensive plan to strategically manage resources and evaluate the 

effectiveness of these efforts, the agency risks spending limited resources 

on initiatives that may not speed up disability claims and appeals 

processes. This may, in turn, result in forcing veterans to continue to wait 

months and even years to receive compensation for injuries incurred 

during their service to the country.

We recommend the Secretary of Veterans Affairs direct the Veterans 

Benefits Administration to:

1. Develop 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.

2. Develop improvements for partnering with Social Security 

Administration officials to reduce the time it takes to gather medical 

records.

3. Ensure the development of a robust backlog reduction plan for VBA’s 

initiatives that, among other best practice elements, identifies 

implementation risks and strategies to address them and performance 

Conclusions 

Recommendations for 

Executive Action
 

Page 30 GAO-13-89 VA Disability Benefits Processing

goals that incorporate the impact of individual initiatives on processing 

timeliness.

VA provided us with comments on a draft of this report, which are 

reprinted in appendix IV. In its comments, VA stated it generally agreed 

with our conclusions and concurred with our recommendations, and 

summarized efforts that are planned or underway to address the 

recommendations. Specifically, VA agreed with our recommendation to 

partner with relevant federal and state military officials to develop 

improvements to reduce the time it takes to gather military service 

records for National Guard and Reservists. VA stated it has recently 

initiated several interagency efforts to improve receipt of military service 

records. According to VA, on December 3, 2012, the joint VBA and DOD 

Disability Claims Reduction Task Force met to begin to evaluate the 

process to request records, among other issues, with the aim of 

improving the timeliness of record exchanges between the two agencies. 

In addition, VA stated that the joint VA-DOD Virtual Lifetime Electronic 

Record initiative is focused on developing a complete electronic health 

record for each servicemember that will be transmitted to VA upon the 

service member’s military discharge, including National Guard and 

Reservists. VA identified a targeted completion date of November 2013. 

We believe these initiatives are heading in the right direction in order to 

improve the timeliness of meeting VA requests for National Guard and 

Reservists records.

VA agreed with our recommendation to work with SSA officials to develop 

improvements to reduce the time it takes to gather SSA medical records. 

VA stated that it is working with SSA to pilot a web-based tool to provide 

VA staff a secure, direct communication with SSA staff and to automate 

VA’s requests for SSA medical records. VA officials did not mention this 

pilot during the course of our data collection and it was not included on 

the agency’s list of efforts to improve claims and appeals processing 

initiatives provided to us. VA identified a targeted completion date of 

November 2013.

VA agreed with our recommendation to develop a robust backlog plan for 

VBA’s initiatives that, among other elements, identifies implementation 

risks and strategies as well as performance goals that incorporate the 

impact of individual initiatives on processing timeliness. VA describes a 

number of approaches it has taken to address our recommendation. Most 

relevant are the Transformation Plan, which was provided to us during the 

data collection phase and which we determined fell short of established 

Agency Comments 

and Our Evaluation 
 

Page 31 GAO-13-89 VA Disability Benefits Processing

criteria for sound planning, and the Operating Plan, which was not 

mentioned during the course of our data collection. According to VA, the 

operating plan, currently under development, will focus on: (1) integration 

of people, process, and technology initiatives, (2) identification of new 

ways to improve efficiency and reengineer the claims process, (3) efforts 

to automate the current paper-based claims process, and (4) the 

measurement process. However, it is unclear at this time how the key 

elements of the operating plan will better position VA to address our 

recommendation. Moreover, without further information on how the 

operating plan will focus on the measurement process, it is difficult for us 

to determine at this time if VA will sufficiently address our 

recommendation to include performance goals that incorporate 

measuring the impact of individual initiatives to processing timeliness.

As agreed with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 28 days from its 

issue date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of Veterans Affairs, 

and other interested parties. In addition, the report will be made available 

at no charge on GAO’s website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

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

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix V.

Daniel Bertoni

Director, Education, Workforce, and Income Security Issues
 

Page 32 GAO-13-89 VA Disability Benefits Processing

List of Requesters

The Honorable Jeff Miller

Chairman

Committee on Veterans’ Affairs

House of Representatives

The Honorable Karen Bass

House of Representatives

The Honorable Shelley Berkley 

House of Representatives

The Honorable Howard L. Berman

House of Representatives

The Honorable Brian P. Bilbray

House of Representatives

The Honorable Mary Bono Mack

House of Representatives

The Honorable Ken S. Calvert

House of Representatives

The Honorable John Campbell 

House of Representatives

The Honorable Lois Capps

House of Representatives

The Honorable Judy Chu

House of Representatives

The Honorable Jim Costa

House of Representatives

The Honorable Susan Davis

House of Representatives

The Honorable David Dreier

House of Representatives
 

Page 33 GAO-13-89 VA Disability Benefits Processing

The Honorable Elton Gallegly

House of Representatives

The Honorable Joe Heck

House of Representatives

The Honorable Duncan D. Hunter

House of Representatives

The Honorable Darrell Issa

House of Representatives

The Honorable Jerry Lewis

House of Representatives

The Honorable Kevin McCarthy

House of Representatives

The Honorable Howard P. McKeon

House of Representatives

The Honorable Gary Miller

House of Representatives

The Honorable Grace Napolitano

House of Representatives

The Honorable Laura Richardson

House of Representatives

The Honorable Dana Rohrabacher

House of Representatives

The Honorable Lucille Roybal-Allard

House of Representatives

The Honorable Ed Royce

House of Representatives

The Honorable Loretta Sanchez

House of Representatives
 

Page 34 GAO-13-89 VA Disability Benefits Processing

The Honorable Adam Schiff

House of Representatives

The Honorable Brad Sherman

House of Representatives

The Honorable Henry A. Waxman

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-13-89 VA Disability Benefits Processing

This report examines the (1) factors that contribute to lengthy processing 

times for disability claims and appeals at the Department of Veterans 

Affairs (VA) and (2) status of the Veteran Benefits Administration’s (VBA) 

recent efforts to improve disability claims and appeals processing 

timeliness.

To examine factors that contribute to lengthy processing times for 

disability claims and appeals, we reviewed past GAO and VA Office of 

Inspector General (OIG) reports and other relevant studies on VA’s 

claims and appeals processing, such as the Veterans’ Disability Benefits 

Commission’s 2007 report, Honoring the Call to Duty: Veterans’ Disability 

Benefits in the 21st Century.1

To examine the status of VBA’s recent efforts to improve disability claims 

and appeals processing timeliness, we reviewed past GAO and VA OIG 

We reviewed congressional testimonies, 

federal statutes, relevant court decisions, and policy manuals and 

documents, including VA’s Web Automated Reference Manual System to 

understand the program rules and procedures that govern the claims and 

appeals processes. We also analyzed disability compensation and 

pension rating claims processing data from VBA’s internal dashboard and 

data on claims processing resources from VBA’s Personnel and 

Accounting Integrated Database. Moreover, we interviewed VBA officials, 

including VBA area directors, the Office of Field Operations, 

Compensation Service, and the Office of Performance Analysis and 

Integrity to gain a national perspective on factors affecting the timeliness 

of claims and appeals processing. To identify factors within VA regional 

offices that contribute to lengthy processing times, we conducted reviews 

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

Angeles, California; New York, New York; and Philadelphia, 

Pennsylvania. These reviews consisted of interviewing regional office 

management and claims processing staff and supervisors, reviewing 

workload management and performance documents, and reviewing 

written notifications sent to veterans. We did not conduct case file reviews 

in these regional offices. We also spoke with representatives of Veterans 

Service Organizations (VSO) in Los Angeles and in Washington, D.C. to 

gather perspectives of veterans’ representatives on challenges in the 

claims and appeals processes. 

 

1 Veterans' Disability Benefits Commission, Honoring the Call to Duty: Veterans' Disability 

Benefits in the 21st Century (Washington, D.C.: October 2007).

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-13-89 VA Disability Benefits Processing

reports and congressional testimonies. We conducted interviews with 

officials from the VBA Implementation Center, Office of Strategic Planning

and Office of Field Operations. Also, during our review of five VA regional 

offices, we interviewed claims and appeals processing staff about their 

experiences with VBA’s initiatives. To identify which VBA efforts were 

designed to improve timeliness, we reviewed documents providing an 

overview of the efforts, which included documentation identifying the 

purpose of each effort. We requested additional information for those 

initiatives that VBA identified as having the purpose of reducing disability 

claims and appeals processing times. Furthermore, we selected a sample 

of nine of VBA’s efforts identified as having the purpose of reducing 

disability claims and appeals processing times for further review primarily 

based on interviews with VBA officials and a review of recent VA 

testimonies. In addition, we spoke with representatives of national VSOs 

to gather their perspectives on the impact on the veterans they represent 

of recent and ongoing efforts. (For more information on VBA’s 

improvement efforts, see appendix III).

To assess VBA disability claims workload and processing timeliness, we 

obtained monthly regional office and national data from VBA’s internal 

dashboard, which aggregates key metrics used to assess performance 

from a variety of data sources into one integrated tool. We limited our 

analysis to timeliness and workload metrics used to measure the 

performance of the disability compensation and pension rating claims and 

appeals processing. We analyzed data from fiscal year 2009 through 

August 2012. To verify the reliability of VBA’s internal dashboard, we 

conducted interviews with officials from VBA’s Office of Performance 

Analysis and Integrity about quality control procedures of VBA’s internal 

dashboard and practices used to extract timeliness and workload data 

from underlying data sources. We relied on past GAO data reliability 

assessments on the Veterans Services Network (VETSNET) system and 

accompanying VETSNET Operations Reports (VOR), and the Veterans 

Appeals Control and Locator System (VACOLS), where enterprise-wide 

workload and timeliness of claims and appeals processing data, 

respectively, are stored and extracted into the internal dashboard tool. 

We found the dashboard data to be reliable for reporting regional office 

and national workload and timeliness trends.

To analyze VBA’s claims and appeals processing resources, we obtained 

data from VA’s Personnel and Accounting Integrated Database and 

accompanying ProClarity system. We limited our analysis to data on VBA 

job titles that typically include claims or appeals processing 

Analysis of VBA 

Claims and Appeals 

Processing Timeliness 

and Resource Data
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-13-89 VA Disability Benefits Processing

responsibilities—Veterans Service Representatives (VSR), Rating 

Veterans Service Representatives (RVSR), and Decision Review Officers 

(DRO)—from fiscal years 2009 through 2012. We reviewed data on fulltime equivalents (FTE), number of employees, and personnel actions. To 

assess the reliability of these data, we interviewed officials in VBA’s 

Office of Human Resources about practices to record personnel actions, 

quality control procedures conducted within the Office of Human 

Resources to ensure the quality of the data, as well as potential 

limitations to the data. We found the data provided to us by the Office of 

Human Resources reliable for reporting on claims and appeals 

processing resources.

We selected five VA regional offices for review to gather information on 

the challenges these selected regional offices face in not only processing 

disability claims and appeals in a timely fashion, but also in implementing 

initiatives designed to address processing timeliness. Our five selected 

sites, which account for 15 percent of all disability compensation and 

pension rating claims, were Atlanta, Georgia; Houston, Texas; Los 

Angeles, California; New York, New York; and Philadelphia, 

Pennsylvania. We conducted site visits with the Los Angeles, 

Philadelphia, and Atlanta regional offices and teleconferences with the 

New York and Houston regional offices.

We selected regional offices for review based on the following criteria:

• Geography: We selected at least one VA regional office in each of 

VBA’s four areas. The New York and Philadelphia regional offices are 

in the Eastern Area, Atlanta is in the Southern Area, Houston is in the 

Central Area, and Los Angeles is in the Western Area.

• Size of metropolitan area: We limited our selection process to 

regional offices in the Top 15 Metropolitan Statistical Areas (MSA) 

according to 2010 Census data, due to concerns about the ability of 

these offices to recruit and retain staff and upper management.

• Workload: We selected VA regional offices with medium or high 

disability compensation and pension rating claims workloads. All 

regional offices in the top 15 MSAs had more than 10,000 disability 

compensation and pension rating claims pending. According to VBA’s 

internal dashboard, the median regional office had 8,850 disability 

compensation and pension rating claims pending as of April 2012. 

The sites we selected had workloads ranging from 15,874 to 37,805 

pending disability compensation and pension rating claims in April 

2012.

Selection of VA 

Regional Offices for 

Review 
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-13-89 VA Disability Benefits Processing

• Timeliness: To examine the timeliness of claims processing at VA 

regional offices, we examined two metrics: the percentage of 

backlogged disability compensation and pension rating claims—

defined as claims pending over 125 days–and the average number of 

days a disability compensation and pension rating claim was pending. 

According to VBA’s internal dashboard, 65.6 percent of disability 

compensation claims nationally were pending over 125 days in April 

2012. For the regional offices we selected, the percent of backlogged 

claims ranged from 61.6 percent to 79.9 percent. Claims were 

pending an average 243.2 days nationally. For the regional offices we 

selected, the average days pending ranged from 219.6 days to 325.3 

days.

We conducted this performance audit from March 2012 through 

December 2012 in accordance with generally accepted government 

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

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.
Appendix II: Veteran Notification during the 

Claims and Appeals Processes

Page 39 GAO-13-89 VA Disability Benefits Processing

After VBA receives a disability claim, it generally sends notifications to 

veterans to either help gather evidence or to let them know that a 

decision has been made (see fig. 9). Throughout the claims process, VBA 

sends a standard form letter at the 60-, 120-, and 180-day marks, as 

applicable, to inform the veteran that VBA has received the claim and that 

the claim is still pending. During the initiating development phase, VBA 

sends the Veteran Claims Assistance Act (VCAA) letter acknowledging 

receipt of the claim, explaining the claims process, and outlining what 

additional information is needed and what steps VBA will take to 

substantiate the claim. Much of the notification to veterans occurs during 

the evidence gathering phase. During this phase, VBA sends the veteran 

a notification every time VBA makes an attempt to obtain additional 

evidence or when attempts to obtain evidence have been unsuccessful.

Finally, at the end of the award processing phase, a decision letter is sent 

to the veteran.

Figure 9: VBA Notifications to Veterans throughout the Claims Process

During the appeals process, VBA generally reaches out to veterans when 

additional evidence or the veteran’s input is needed, or to announce and 

explain a decision. The appeals process generally begins when a veteran 

disagrees with VA’s decision on their disability claim, and files a Notice of 

Disagreement (see fig. 10). If the veteran does not specify the type of 

review in the Notice of Disagreement, VBA sends an election letter that 

details the differences between a traditional and DRO review and asks 

the veteran to choose a review process. Once a veteran indicates the 

Appendix II: Veteran Notification during the 

Claims and Appeals Processes
Appendix II: Veteran Notification during the 

Claims and Appeals Processes

Page 40 GAO-13-89 VA Disability Benefits Processing

type of review desired, VBA sends a process letter that explains the 

review process chosen and details the veteran’s rights throughout the 

appeals process.1

 

1 If the veteran does not reply to the election letter within 60 days, the appeal proceeds as 

a traditional review. 

Then, if additional evidence is needed to make a 

decision, such as ordering another Veterans Health Administration (VHA) 

examination, VBA sends notifications to the veteran throughout the 

evidence gathering process, similar to the initial claims process. Once all 

additional evidence is gathered, VBA will review the case. If VBA grants 

the appeal in full, a decision letter is sent. If VBA denies the appeal or 

does not grant the appeal in full, it sends a Statement of the Case (SOC) 

explaining the decision. At this point, the veteran has the option to send in 

additional evidence, which VBA must consider, and if this evidence does 

not lead to a full grant, then VBA must send a Supplemental Statement of 

the Case (SSOC) explaining their decision.
Appendix II: Veteran Notification during the 

Claims and Appeals Processes

Page 41 GAO-13-89 VA Disability Benefits Processing

Figure 10: VBA Notifications to Veterans throughout the Appeals Process

Note: If the veteran chooses the traditional review, the reviewer, who may be a RVSR or DRO, 

examines the claim file and any new evidence that the veteran submits and may hold a formal, 

transcribed hearing with the veteran. The reviewer may overturn the original decision based only on 

(1) new evidence or (2) a clear and unmistakable error made in the original decision. However, if a 

veteran chooses the DRO review, a DRO conducts a de novo review of the claim, meaning a new 

and complete review without deference to the original decision, and can revise that decision without 

new evidence or a clear and unmistakable error—in other words, based on a difference of opinion. 38 

C.F.R. §3.2600

In addition to receiving written notifications during the claims and appeals 

processes, veterans can proactively learn about the status of their claims 
Appendix II: Veteran Notification during the 

Claims and Appeals Processes

Page 42 GAO-13-89 VA Disability Benefits Processing

in several ways. For example, veterans can use eBenefits, a website that 

VA and the Department of Defense launched in 2009 to help 

servicemembers and veterans manage their benefits and personal 

information. Veterans can also speak with staff in VA’s national call center 

or can contact VA through VA’s web-based Inquiry Routing and 

Information System (IRIS). Veterans can also visit a VA regional office to 

speak with VA public contact staff.
Appendix III: Selected VBA Efforts to Improve 

Claims and Appeals Timeliness

Page 43 GAO-13-89 VA Disability Benefits Processing

According to VBA, there are currently over 40 ongoing improvement 

efforts that are tracked by VBA’s Implementation Center. Below is a list of 

15 improvement efforts we identified as having a stated purpose of 

improving timeliness of claims or appeals processing, based on a review 

of VA documents and interviews with VBA officials.

Table 1: Selected VBA Efforts to Improve Claims and Appeals Timeliness 

VBA effort Description Purpose Status 

Selected for 

review by GAO 

Acceptable Clinical 

Evidence (ACE) 

Pilot

The ACE process allows a VHA clinician to 

complete a Disability Benefit Questionnaire in lieu 

of conducting a medical exam if a veteran’s 

existing medical record contains sufficient 

evidence. 

To improve the 

timeliness of 

obtaining medical 

examinations 

Piloted in one 

regional office 

No 

Agent Orange 

Development 

Assistance (“Fast 

Track”) 

The Fast Track Claims Processing System is an 

accelerated claims process dedicated to Vietnam 

veterans who are diagnosed with an Agent Orange 

presumptive condition, such as ischemic heart 

disease, hairy cell and other B-cell leukemias, and 

Parkinson’s disease.

To reduce average 

days to complete 

Agent Orange 

claims

Implemented 

nationally in 

October 2010 

No 

Appeals Design 

Pilot 

The Appeals Design Pilot has made several 

changes to the appeals process during the pilot 

including:

• Creating an express lane for appeals with one 

or two issues;

• Developing a standard Notice of Disagreement 

form; 

• Obtaining waivers from veterans to allow VBA 

to expedite their substantive appeal directly to 

the Board of Veterans’ Appeals without having 

the regional office review new evidence 

submitted;

• Conducting Decision Review Officer (DRO) 

reviews for all appeals;

• Proactive phone outreach to veterans to 

reduce the need for formal DRO hearings; and

• Obtaining waivers of local VSO review period 

prior to certifying the appeal to the Board of 

Veterans’ Appeals.

To improve appeals 

processing 

timeliness 

Pilot stage began 

in March 2012 

Yes 

Brokering centers The brokering process is used to manage workload 

across regional offices by permitting a regional 

office to shift claims either to another regional 

office or to a specialized brokering center for 

processing.

To reduce workload 

at regional offices 

experiencing 

processing delays 

Implemented 

nationally in 2001 

Yes 

Appendix III: Selected VBA Efforts to 

Improve Claims and Appeals Timeliness
Appendix III: Selected VBA Efforts to Improve 

Claims and Appeals Timeliness

Page 44 GAO-13-89 VA Disability Benefits Processing

VBA effort Description Purpose Status 

Selected for 

review by GAO 

Claims 

Organizational 

Model

The Claims Organizational Model streamlines the 

claims process by organizing claims staff into 

cross-functional teams, creating segmented lanes 

based on type and complexity of claims, and 

standardizing the mail triage and sorting process in 

an integrated mail processing center.

To reduce the 

average days to 

complete claims by 

40 days

Implemented at 

selected regional 

offices; national 

implementation

scheduled for 

completion by end 

of fiscal year 2013 

Yes 

Disability Benefits 

Questionnaire 

(DBQ) 

DBQs are standard checklists that VA asks 

physicians to fill out instead of preparing a 

narrative report of an examination. 

To increase the use 

of standard 

evaluation forms to 

speed up claims 

determination 

Implemented 

nationally in March 

2012 

Yes 

Fully Developed 

Claims (FDC)

The FDC initiative expedites processing of claims 

submitted by veterans who submit all relevant 

private medical evidence.

To reduce the 

average days to 

complete a decision 

by 140 days

Implemented 

nationally in May 

2010 

Yes 

Immersion Teams Management teams from high performing offices 

observe low performing offices and help codify best 

practices to help the low performing offices 

improve. 

To improve regional 

office performance 

management

Implemented in 

four regional 

offices in October 

2011 

No 

National Level 

Challenge Training 

Challenge training is a course designed for newlyassigned claims processing staff. In 2011, the 

curriculum was redesigned to lengthen the training 

period and incorporate the hands-on instruction 

previously conducted within regional offices into 

training at centralized sites. Additionally, challenge 

training is sometimes used to retrain experienced 

staff as well.

To increase the 

number and 

accuracy of 

completed claims 

per claims 

processing staff fulltime equivalents 

(FTE) 

Implemented 

nationally in fiscal 

year 2011 

No 

Proactive Phone 

Development

In place of writing letters to gather evidence, VBA 

will use phone calls to speed the development 

process and clarify veteran information/requests.

To decrease 

average days to 

completion of a 

claim

Implemented 

nationally in May 

2010; revised in 

March 2012 

No 

Simplified 

Notification Letter 

(SNL) 

SNL is a standardized process that integrates 

decision information into one simplified letter for 

veterans. 

To increase the 

number of claims 

rated per year by 

250,000 

Implemented 

nationally in March 

2012 

Yes 

Timeliness 

Performance 

Standards

One VA regional office has an effort to improve 

timeliness by changing individual performance 

goals for claims staff by incorporating timeliness 

goals into their performance goals.

To improve 

timeliness of claims 

processing 

Implemented at 

one regional office 

in March 2012 

No 

Vendors for Private 

Medical Records

Vendors for Private Medical Records is an initiative 

in which a contractor collects medical records from 

private physicians.

To reduce average 

record collection 

time from 40 days 

to 7-10 days and 

substantially 

increase physician 

response rate

Piloted at seven 

regional offices 

since September 

2010 

Yes 
Appendix III: Selected VBA Efforts to Improve 

Claims and Appeals Timeliness

Page 45 GAO-13-89 VA Disability Benefits Processing

VBA effort Description Purpose Status 

Selected for 

review by GAO 

Veterans Benefits 

Management 

Assistance 

Program (VBMAP)

VBMAP is an effort to manage workload by 

permitting a regional office to shift a predetermined number of claims to a contractor for 

evidence gathering. 

To reduce evidence 

gathering workload 

at regional offices 

Implemented 

nationally; contract 

began in 

September 2011 

Yes 

Veterans Benefit 

Management 

System (VBMS)

VBMS is an effort to design a paperless claims

system that will allow electronic submission of 

claims and supporting evidence and convert paperbased claims folders into electronic claims folders. 

To decrease the 

average days to 

complete a claim

Partially 

implemented; 

plans to implement 

nationally in 2013 

Yes 

Source: GAO analysis of VBA documentation and interviews with VBA officials.

Note: Primarily based on a review of VA documents and interviews with VBA officials, we selected for 

review a sample of 9 VBA efforts (out of 15) that have the purpose of reducing disability claims and 

appeals processing times.
Appendix IV: Comments from the Department 

of Veterans Affairs

Page 46 GAO-13-89 VA Disability Benefits Processing

Appendix IV: Comments from the 

Department of Veterans Affairs 
Appendix IV: Comments from the Department 

of Veterans Affairs

Page 47 GAO-13-89 VA Disability Benefits Processing
Appendix IV: Comments from the Department 

of Veterans Affairs

Page 48 GAO-13-89 VA Disability Benefits Processing
Appendix IV: Comments from the Department 

of Veterans Affairs

Page 49 GAO-13-89 VA Disability Benefits Processing
Appendix IV: Comments from the Department 

of Veterans Affairs

Page 50 GAO-13-89 VA Disability Benefits Processing
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 51 GAO-13-89 VA Disability Benefits Processing

Daniel Bertoni, Director, Education Workforce and Income Security, 

bertonid@gao.gov, 202-512-7215

In addition to the contact named above, Brett Fallavollita (Assistant 

Director); Lucas Alvarez; Michelle Bracy; and Ryan Siegel made key 

contributions to this report. In addition, key support was provided by 

James Bennett, Robert Campbell, Susan Chin, James Rebbe, Almeta 

Spencer, Kathleen van Gelder, and Walter Vance.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO contact

Staff 

Acknowledgments 
Related GAO Products

Page 52 GAO-13-89 VA Disability Benefits Processing

VA Disability Compensation: Actions Needed to Address Hurdles Facing 

Program Modernization. GAO-12-846. Washington, D.C.: September 10, 

2012.

VA Enhanced Monthly Benefits: Recipient Population Is Changing, and 

Awareness Could Be Improved. GAO-12-153. Washington, D.C.: 

December 14, 2011.

Veterans Disability Benefits: Clearer Information for Veterans and 

Additional Performance Measures Could Improve Appeal Process. 

GAO-11-812. Washington, D.C.: September 29, 2011.

Information Technology: Department of Veterans Affairs Faces Ongoing 

Management Challenges. GAO-11-663T. Washington, D.C.: May 11, 

2011.

GAO’s 2011 High-Risk Series: An Update. GAO-11-394T. Washington, 

D.C.: February 17, 2011.

Veterans’ Disability Benefits: Expanded Oversight Would Improve 

Training for Experienced Claims Processors. GAO-10-445. Washington, 

D.C.: April 30, 2010.

Veterans’ Disability Benefits: Further Evaluation of Ongoing Initiatives 

Could Help Identify Effective Approaches for Improving Claims 

Processing. GAO-10-213. Washington, D.C.: January 29, 2010.

Social Security Disability: Additional Outreach and Collaboration on 

Sharing Medical Records Would Improve Wounded Warriors’ Access to 

Benefits. GAO-09-762. Washington, D.C.: September 16, 2009.

Veterans’ Benefits: Increased Focus on Evaluation and Accountability 

Would Enhance Training and Performance Management for Claims 

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

Veterans’ Disability Benefits: Claims Processing Challenges Persist, while 

VA Continues to Take Steps to Address Them. GAO-08-473T. 

Washington, D.C.: February, 14, 2008.

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