VA VOCATIONAL 

REHABILITATION 

AND EMPLOYMENT 

PROGRAM

Improved Oversight of 

Independent Living 

Services and Supports 

Is Needed

Report to Congressional Requesters

June 2013

GAO-13-474

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-474, a report to 

congressional requesters

June 2013

VA VOCATIONAL REHABILITATION AND 

EMPLOYMENT PROGRAM

Improved Oversight of Independent Living Services 

and Supports Is Needed

Why GAO Did This Study

The IL “track”—one of five tracks within 

VA’s VR&E program—provides a 

range of benefits to help veterans with 

service-connected disabilities live 

independently when employment is not 

considered feasible at the time they 

enter the VR&E program. These 

benefits can include counseling, 

assistive devices, and other services or 

equipment. GAO was asked to review 

issues related to the IL track. This 

report examines (1) the characteristics 

of veterans in the IL track, and the 

types and costs of benefits they were 

provided; (2) the extent to which their 

IL plans were completed, and the time 

it took to complete them; and (3) the 

extent to which the IL track has been 

administered appropriately and 

consistently across regional offices.

To conduct this work, GAO analyzed 

VA administrative data from fiscal 

years 2008 to 2011, and reviewed a 

random, generalizable sample of 182 

veterans who entered the IL track in 

fiscal year 2008. In addition, GAO 

visited five VA regional offices; 

interviewed agency officials and staff; 

and reviewed relevant federal laws, 

regulations, and agency policies and 

procedures.

What GAO Recommends

GAO recommends that VR&E explore 

options to enhance coordination with 

VHA; strengthen its oversight of the IL 

track; and reassess its policy for 

approving benefits. VA generally 

agreed with GAO’s conclusions and 

recommendations.

What GAO Found

Of the 9,215 veterans who entered the Department of Veterans Affairs’ (VA) 

Independent Living (IL) track within the Vocational Rehabilitation and 

Employment (VR&E) program in fiscal years 2008 to 2011, most were male 

Vietnam era veterans in their 50s or 60s. Almost 60 percent served in the U.S. 

Army, and fewer than 1 percent served in the National Guard or Reserve. The 

most prevalent disabilities among these veterans were post-traumatic stress 

disorder and tinnitus. GAO’s review of 182 IL cases from fiscal year 2008 found 

that VR&E provided a range of IL benefits to veterans. Among these cases, the 

most common benefits were counseling services and computers. Less common 

benefits included gym memberships, camping equipment, and a boat. GAO 

estimated that VR&E spent nearly $14 million on benefits for veterans entering 

the IL track in fiscal year 2008—an average of almost $6,000 per IL veteran. 

Most veterans completed their IL plans, which identify their individual goals to live 

independently and the benefits VR&E will provide. About 89 percent of fiscal year 

2008 IL veterans were considered by VR&E to be “rehabilitated,” that is, 

generally, to have completed their IL plans by the end of fiscal year 2011. VR&E 

discontinued or closed about 5 percent of cases for various reasons, such as the 

veteran declined benefits. Six percent of cases were open at the end of fiscal 

year 2011. Because the complexity of IL cases varied depending on veterans’ 

disabilities and needs, some cases were fairly simple for VR&E to close. For 

example, one IL case only called for the installation of door levers and a bathtub 

rail. Another more complex case involved the provision of a range of IL benefits, 

including home modifications. Rehabilitation rates across regions varied from 0 to 

100 percent, and regions with larger IL caseloads generally rehabilitated a 

greater percentage of IL veterans. While IL plans nationwide were completed in 

384 days, on average, completion times varied by region, from 150 to 895 days. 

VR&E exercises limited oversight to ensure appropriate and consistent 

administration of the IL track across its regions. First, some regions may not be 

complying with certain case management requirements. For instance, while 

VR&E is required to coordinate with the Veterans Health Administration (VHA) on 

IL benefits, VR&E counselors have difficulty obtaining timely responses from 

VHA. VHA physicians respond to VR&E’s IL referrals late or not at all, resulting in 

delayed benefits or VR&E providing the benefits instead of VHA. Second, VR&E 

does not monitor regional variation in IL caseloads and benefits provided. 

Instead, it has relied on its quality assurance reviews and ad hoc studies, but 

these are limited in scope. Third, given counselors have broad discretion in 

selecting IL benefits, VR&E’s written policies for approving IL expenditures may 

not be appropriate as regions were permitted to purchase a range of items 

without any Central Office approval, some of which were costly or questionable. 

For example, in one case, Central Office review would not have been required for 

expenditures of $18,829 for a riding mower, which is prohibited, and other items. 

Finally, VR&E’s system does not collect IL costs and benefits provided. VR&E 

also lacks accurate data on the number of IL veterans served. While the law 

currently allows 2,700 veterans to enter the IL track annually, data used to 

monitor the cap are based on the number of IL plans developed, not on the 

number of individual veterans admitted. Veterans can have more than one plan 

in a fiscal year, so one veteran could be counted multiple times towards the cap.

View GAO-13-474. For more information, 

contact Dan Bertoni at (202) 512-7215 or 

bertonid@gao.gov.
Page i GAO-13-474 VA Independent Living Services and Supports

Letter 1 

Background 3

The IL Track Mainly Serves Older Veterans and Provides a Wide 

Variety of Benefits 12

Most Veterans Completed “Rehabilitation” but with Varying Time 

Frames 20

VR&E Exercises Limited Oversight of the IL Track 27

Conclusions 39

Recommendations for Executive Action 40

Agency Comments and Our Evaluation 41

Appendix I Objectives, Scope, and Methodology 43

Appendix II Statistical Analysis of Independent Living Plan 

Rehabilitation Times 48

Appendix III List of Goods and Services Provided to Sample of 

Independent Living Track Veterans from our Case File 

Review 55

Appendix IV Rehabilitation Rates by Regional Office, FY 2008 

Independent Living Track Entrants 66

Appendix V Days to Complete Independent Living Plans, Veterans 

Entering the Independent Living Track During FY 2008 68

Appendix VI Independent Living Track Caseload Nationwide and by 

Regional Office, FY 2008-2011 70

Contents 
Page ii GAO-13-474 VA Independent Living Services and Supports

Appendix VII Comments from the Department of Veteran Affairs 72

Appendix VIII GAO Contacts and Staff Acknowledgments 76

Related GAO Products 77

Tables

Table 1: Categories of Goods and Services Provided to Independent 

Living Track Veterans 17

Table 2: Level of Approval Required for Construction and NonConstruction-Related Expenditures in Independent Living 

Track Cases 35

Table 3: Size of Sample of Independent Living Track Cases, by 

Strata and Proportion of Population 46

Table 4: Estimates from Cox Hazard Model of Time Spent in 

Independent Living Plans, among Veterans Starting a Plan 

in FY 2008-2011 51

Figures

Figure 1: Location of the Vocational Rehabilitation and 

Employment Program’s Regional and Satellite Offices 6

Figure 2: The Vocational Rehabilitation and Employment 

Program’s Needs Assessment and Independent Living 

Track Benefits Delivery Process 8

Figure 3: Example of an Independent Living Plan Developed for a 

Veteran 10

Figure 4: FY 2008-2011 Independent Living Track Veterans, by 

Gender and Age 12

Figure 5: Independent Living Track Veterans during FY 2008-2011, 

by War Era 13

Figure 6: Independent Living Track Veterans during FY 2008-2011, 

by Branch of Service 14
Page iii GAO-13-474 VA Independent Living Services and Supports

Figure 7: Comparison of the 10 Most Prevalent Disabilities among 

Independent Living Track Veterans from FY 2008-2011 

and Veterans Receiving Disability Compensation for FY 

2011 15

Figure 8: Examples of the Types of Goods and Services Provided in 

Four of the Independent Living Track Cases GAO 

Reviewed 16

Figure 9: Distribution of Independent Living Track Cases Reviewed 

by Costs of Goods and Services Purchased for Veterans 19

Figure 10: Status at the End of FY 2011 of Independent Living 

Track Cases That Began in FY 2008 21

Figure 11: Percentage of FY 2008 Independent Living Track 

Veterans Rehabilitated, by Regional Office Based on 

Caseload 23

Figure 12: Average Length of Time to Complete an Independent 

Living Plan, by Regional Office Based on Caseload 24

Figure 13: Average Time to Complete Independent Living Plans, by 

Veteran Age Groups 25

Figure 14: Estimated Probability of a Veteran Completing an 

Independent Living Plan within Certain Time Periods, by 

Regional Office Based on Caseload 27

Figure 15: The Vocational Rehabilitation and Employment 

Program’s Overall Independent Living Caseload from FY 

2008-2011, by Regional Office 31

Figure 16: Number of and Statutory Cap on Veterans Entering the 

Independent Living Track from FY 2008-2011 38

Figure 17: Multivariate Failure Function Estimates from a Cox 

Hazard Model of Time Spent in Independent Living Plans, 

FY 2008-2011 54
Page iv GAO-13-474 VA Independent Living Services and Supports

Abbreviations

IL Independent Living

PSAS Prosthetics and Sensory Aids Service 

PTSD Post-traumatic Stress Disorder

SAH Specially Adapted Housing

QA Quality Assurance

VA Department of Veterans Affairs

VBA Veterans Benefits Administration

VHA Veterans Health Administration 

VRC Vocational Rehabilitation Counselor

VR&E Vocational Rehabilitation and Employment

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Page 1 GAO-13-474 VA Independent Living Services and Supports

441 G St. N.W.

Washington, DC 20548

June 7, 2013

The Honorable Bill Flores

Chairman

The Honorable Mark Takano

Ranking Member

Subcommittee on Economic Opportunity

Committee on Veterans’ Affairs

House of Representatives

The Honorable Bruce Braley

House of Representatives 

The Honorable Marlin Stutzman

House of Representatives

The Department of Veterans Affairs’ (VA) Vocational Rehabilitation and 

Employment (VR&E) program, under the Veterans Benefits 

Administration (VBA), administers five “tracks” that provide a wide range 

of services and assistance to support veterans with service-connected 

disabilities. Four of VR&E’s five tracks are intended to help veterans 

prepare for, find, and maintain suitable employment. If employment is not 

considered a feasible goal for veterans when they enter the VR&E 

program, they can be assigned to the Independent Living (IL) track for 

separate, non-employment support within the VR&E program, and can 

receive benefits such as counseling, assistive devices, and other services 

or equipment to improve their ability to live independently. By law, the 

number of veterans who can be assigned to the IL track each year is 

limited. There are currently 56 VA regional offices with responsibility for 

administering VR&E’s IL track,1 and almost 3,000 veterans nationwide 

were served in this track during fiscal year 2011.

Given the limited information available on those who participate in 

VR&E’s IL track, you asked us to review issues related to the benefits IL 

 

1 VA officials told us that the Washington Regional Office, located in the District of 

Columbia, was recently designated the “National Capital Region Benefits Office” in 

November 2012. For the purposes of our review, we will refer to this office as one of VA’s 

regional offices. The Manila Regional Office in the Philippines was not included in our 

review because it does not administer the IL track.

 
 

Page 2 GAO-13-474 VA Independent Living Services and Supports

track veterans receive, and their outcomes. This report examines (1) the 

characteristics of veterans who have participated in the IL track, as well 

as the types and costs of benefits they were provided; (2) the extent to 

which their IL plans were completed, and the time it took to complete 

them; and (3) the extent to which the IL track has been administered 

appropriately and consistently across regional offices.

To provide information on the number, characteristics, and outcomes of 

veterans who entered the IL track, as well as how long it took VR&E to 

complete these cases, we analyzed VA administrative data from fiscal 

years 2008 through 2011.2 We also used these data to estimate the 

difference, if any, in the amount of time it took to complete these cases 

across regional offices, as well as across groups of veterans with various 

characteristics. To determine the types of goods and services provided to 

veterans and the direct cost of these benefits, we reviewed the case files 

of a random sample of 182 veterans who were assigned to the IL track at 

some point during fiscal year 2008.

To obtain information about how the IL track has been administered, we 

visited VA regional offices in San Diego, California; Atlanta, Georgia; 

Detroit, Michigan; Philadelphia, Pennsylvania; and the District of 

Columbia.3 We selected these sites because they are geographically 

diverse and have had differing levels of IL caseloads and rehabilitation 

rates. At each of these sites we interviewed officials from VR&E, VA’s 

Specially Adapted Housing (SAH) program, and Prosthetic and Sensory 

Aids Service (PSAS), as well as representatives from local veteran 

service organizations. We also interviewed VR&E officials at the national 

level, and relied on our case file review to determine the extent to which 

VR&E, SAH, and PSAS coordinate in the provision of goods and services 

to IL track veterans. Lastly, we reviewed relevant federal laws and 

regulations, standards for internal controls and managerial cost 

accounting, as well as VR&E policies, procedures, and other relevant 

studies and documentation.

 

2 To assess the reliability of these data, we interviewed knowledgeable officials and 

performed electronic tests to identify missing or erroneous data. We determined the data 

to be sufficiently reliable for our purpose, unless otherwise noted.

3 Our review of IL track administration did not include reviewing the quality of internal or 

external assessments the VR&E program uses to determine the suitability of veterans for 

employment or the extent to which veterans’ activities of daily living may be limited.
 

Page 3 GAO-13-474 VA Independent Living Services and Supports

We conducted this performance audit from February 2012 to June 2013

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. Additional information on our 

scope and methodology is provided in appendices I and II.

VBA’s VR&E program is responsible for implementing five tracks that 

provide a variety of services and assistance to veterans with serviceconnected disabilities. Four of the five tracks are designed to help 

veterans prepare for, find, and maintain suitable employment. VR&E’s 

fifth track—the IL track—generally helps veterans maximize their ability to 

live independently when the achievement of an employment goal is not 

considered feasible at the time they enter the VR&E program.4 To assist 

these veterans, the law allows VR&E broad discretion in determining the 

types of services that can be provided to address their needs.5 When 

assessing each veteran, VR&E focuses not only on assisting veterans 

with activities of daily living,6 but also on veteran’s emotional needs and 

avocational and leisure interests, among other areas.7 Furthermore, 

unlike VR&E’s employment-related tracks, the law caps the number of 

veterans who can be admitted into the IL track annually. While this 

number has increased over the years, the cap was 2,600 veterans in 

 

4 Although not officially admitted into the IL track, veterans in VR&E’s other tracks can 

receive IL services that may assist them in meeting their rehabilitation goals.

5 Under 38 U.S.C. § 3120(d), a veteran’s IL program “shall consist of such services...as 

the Secretary determines necessary to enable such veteran to achieve maximum 

independence in daily living.”

6

 ADLs are basic activities that individuals perform on a daily basis, such as bathing, 

feeding, and dressing themselves.

7 According to VA officials, IL services that “support emotional needs and/or avocational 

and leisure interests may be included in IL plans only when gains in independence are an 

anticipated result.”

VR&E’s Five Tracks At A Glance

Employment-Related Tracks 

• Reemployment: For veterans who need 

assistance returning to their previous 

employer.

• Rapid Access to Employment: For 

veterans with existing skills who are looking 

for immediate employment.

• Self-Employment: For veterans who have 

the skills to start a business, and for whom 

self-employment is the best or only option 

for successful rehabilitation.

• Employment Through Long-Term 

Services: For veterans who need 

specialized training and/or education to 

obtain employment.

Independent Living Track

• Independent Living: For veterans who are 

unable to work and need services to live 

more independently at the time they enter 

the VR&E program.

Background 

VR&E’s IL Track
 

Page 4 GAO-13-474 VA Independent Living Services and Supports

fiscal year 2011 and is currently 2,700.8 VR&E anticipates an increase in 

future demand for IL benefits.

All veterans are required to meet VR&E’s basic entitlement criteria before 

they are assigned to one of its five tracks. To be entitled to VR&E 

services, veterans must generally have at least a 20 percent serviceconnected disability rating and be in need of rehabilitation because of an 

employment handicap.9 The period of eligibility for which veterans can 

receive benefits from VR&E is 12 years and begins on either (1) the date 

of separation from active military duty, or (2) the date that VA notifies the 

veteran of his or her service-connected disability rating. The 12-year 

eligibility period may be deferred or extended if certain conditions prevent 

the veteran from participating in a rehabilitation program or if a veteran 

has a serious employment handicap.10 To be considered for the IL track, 

veterans must meet all of VR&E’s eligibility requirements and be deemed 

currently unable to pursue an employment goal.11

 

8 The Veterans’ Benefits Act of 2010 increased the cap to 2,700 effective “with respect to 

fiscal years beginning after the date of enactment of this Act.” Pub. L. No. 111-275, § 801, 

124 Stat. 2864, 2888. Because the enactment date of the Act was October 13, 2010 

(fiscal year 2011), the cap of 2,700 veterans would have become effective starting in fiscal 

year 2012.

9 38 U.S.C. § 3102(a)(1)(A)(i) and (B). The law defines an employment handicap as an 

impairment, resulting in substantial part from a service-connected disability of a veteran’s 

ability to prepare for, obtain, or retain employment consistent with the veteran’s abilities, 

aptitudes, and interests. 38 U.S.C. § 3101(1). Veterans with a 10 percent serviceconnected disability may also be eligible to receive VR&E services, but not independent 

living services, if they have a serious employment handicap, which is defined as a 

significant impairment, resulting in substantial part from a service-connected disability 

rated at 10 percent or more, of a veteran's ability to prepare for, obtain or retain 

employment consistent with his or her abilities, aptitudes and interests. 38 U.S.C. §§ 

3102(a)(2), 3101(7) and 3120(b). Moreover, servicemembers with a severe injury or 

illness are entitled to certain VR&E services, including independent living services. Pub. L. 

No. 110-181, § 1631(b), 122 Stat. 3, 458 (2008), as extended by Pub. L. No. 112-56, § 

231, 125 Stat. 711, 719 (2011).

10 For veterans rated at 10 percent and veterans beyond their 12-year basic period of 

eligibility, the finding of a serious employment handicap is necessary to establish 

entitlement to VR&E services.

11 38 U.S.C. §§ 3102 and 3120(b).

VR&E’s Eligibility 

Requirements
 

Page 5 GAO-13-474 VA Independent Living Services and Supports

VR&E’s Central Office, located in Washington D.C., has responsibility for 

several areas, including (1) overseeing the implementation of the VR&E 

program, including the IL track, (2) developing program policies and 

procedures, and regional guidance, and (3) formulating and monitoring 

the agency’s budget and program expenditures. Currently, there are 56 

VA regional offices with responsibility for administering the IL track in their 

jurisdiction.12 Reporting to these regional offices are 179 satellite offices 

that help ensure veterans who do not live near a regional office are able 

to access VR&E benefits, including those provided through the IL track 

(see fig. 1).

 

12 While VR&E’s Central Office oversees regional offices that administer the IL track, it 

does not have direct line authority over regional staff. VBA’s Office of Field Operations 

maintains this responsibility.

VR&E’s Structure and 

Administration 
 

Page 6 GAO-13-474 VA Independent Living Services and Supports

Figure 1: Location of the Vocational Rehabilitation and Employment Program’s Regional and Satellite Offices

a The Washington Regional Office, located in the District of Columbia, was recently designated the 

National Capital Region Benefits Office in November 2012.

The VR&E Officer in each regional office is responsible for ensuring that 

the office complies with national policies and procedures for monitoring 

performance to ensure VR&E’s national rehabilitation rate is met.13 In 

addition, this officer supervises regional Vocational Rehabilitation 

 

13 VR&E has two performance measures for its IL rehabilitation rate. VR&E’s fiscal year 

2011 IL rehabilitation target was 92 percent, and its strategic target (or long-term goal) 

was 95 percent.
 

Page 7 GAO-13-474 VA Independent Living Services and Supports

Counselors (VRCs) who are responsible for working directly with veterans 

to assess their IL needs and provide benefits.14

VR&E has established a formal process that all veterans must go through 

to receive any of the benefits offered through its five tracks (see fig. 2). It 

is not possible to be assigned to any of the five tracks without first 

applying and being accepted into the VR&E program.

 

14 VRCs work directly with veterans participating in all of VR&E’s five tracks, not just the IL 

track.
 

Page 8 GAO-13-474 VA Independent Living Services and Supports

Figure 2: The Vocational Rehabilitation and Employment Program’s Needs Assessment and Independent Living Track 

Benefits Delivery Process

a

After both the preliminary and comprehensive IL assessments are performed, a case may be closed 

if it is determined that the achievement of IL goals are not feasible or if potential needs are not 

identified. The VR&E officer must concur with this decision.
 

Page 9 GAO-13-474 VA Independent Living Services and Supports

b 

An individualized IL plan is developed for each veteran admitted to the IL 

track.15 This plan identifies the veteran’s IL goals, the benefits (goods and 

services) VR&E will provide to help the veteran meet those goals, 

estimated time frames for providing benefits, and how improvements in 

the veteran’s independence will be measured, among other areas (see 

fig. 3). In general, IL plans may not exceed 24 months except under 

certain circumstances.16 According to officials, there is also no statutory 

limit on the number of IL plans a veteran can have. Veterans can reapply 

to the VR&E program at any time.

17

IL plans must be approved by the VR&E officer, and in some cases the Regional Director or VR&E’s 

Central Office, before any services are provided.

 

15 An employment-related plan is developed for veterans who are admitted to one of 

VR&E’s other four tracks.

16 38 U.S.C. § 3105(d), 38 C.F.R. § 21.76(b). An additional period of 6 months is allowed 

if it would enable veterans to substantially increase their level of independence in daily 

living. In addition, VR&E may extend the duration up to 36 months for veterans with 

severe disabilities who served on active duty after September 11, 2001. 38 U.S.C. § 

3105(d)(2)(A)(ii) and Department of Veterans Affairs, Veterans Benefits Administration, 

Extension of Independent Living Services related to the Veterans Benefits Improvement 

Act of 2008 (Public Law 110-389), VR&E Letter 28-09-10 (January 30, 2009).

17 Specific criteria must be met before approving new plans for IL services. These criteria 

include meeting requirements for participation in a program of IL services, and the 

worsening of the veteran’s condition or other changes in the veteran’s circumstances 

resulting in a substantial loss of independence. 38 C.F.R. § 21.284(b).
 

Page 10 GAO-13-474 VA Independent Living Services and Supports

Figure 3: Example of an Independent Living Plan Developed for a Veteran

Furthermore, all IL plans are required to be reviewed and approved by the 

veteran, the VRC, and the VR&E Officer before the veteran is admitted to 

the IL track. Once the plan is approved, VRCs are required to meet with 

the veteran at least once a month to track progress in meeting the plan’s 

goals. In addition, VRCs are required to coordinate with other VA 

programs to determine if they can provide any of the goods and services 

identified in the veteran’s plan. The VA programs that officials told us they 

regularly coordinate with are:

• VBA’s Specially Adapted Housing (SAH) Program, which helps 

servicemembers and veterans with certain service-connected 

disabilities purchase or construct an adapted home, or modify an 
 

Page 11 GAO-13-474 VA Independent Living Services and Supports

existing home to accommodate a disability.18 These modifications can 

include specially adapted bathrooms or the installation of exit ramps.

• VHA medical centers, which provide a wide range of health-related 

services to veterans, such as physical therapy and dental and 

optometry services. In addition, VHA’s Prosthetic and Sensory Aids 

Service (PSAS) provides a variety of medical devices and equipment 

to veterans, including artificial limbs, eyeglasses, hearing aids, 

hospital beds, and wheelchairs.19 PSAS also administers the Home 

Improvements and Structural Alterations grant to eligible veterans for 

home modifications, such as the widening of bedroom or bathroom 

doorways to allow wheelchair access.

If the goods and services needed cannot be obtained through other VA 

sources, the VR&E program will purchase them directly or contract for 

them. VR&E may declare a veteran successfully “rehabilitated” when all 

goals in their IL plan have been achieved, or if not all achieved, when the 

following three conditions have been met: (1) the veteran has attained a 

substantial increase in the level of independence; (2) the veteran has 

maintained the increased level of independence for at least 60 days; and 

(3) further assistance is unlikely to significantly increase the veteran’s 

level of independence.20 “Rehabilitation” does not necessarily mean that a 

veteran’s disability has improved, but rather that the goals in the veteran’s 

IL plan have been met to facilitate their independence. When veterans 

are not successfully rehabilitated, their case may be closed as 

“discontinued.” When circumstances arise that affect the ability of VR&E 

to provide the goods and services identified in the IL plan to the veteran, 

VR&E can temporarily “interrupt” the veteran’s case until it becomes 

possible to continue.

 

18 VBA’s Loan Guaranty Program administers two grants—the Specially Adapted Housing 

(SAH) grant and Special Housing Adaptation (SHA) grant—to help address the housing 

needs of veterans with service-connected disabilities.

19 To receive medical devices and equipment through PSAS, VRCs must submit a service 

request to the veterans’ VHA primary care physician. If the primary physician concurs with 

the VRC’s request, he or she will submit a referral to PSAS to meet the veterans’ needs.

20 38 C.F.R. § 21.283(e).
 

Page 12 GAO-13-474 VA Independent Living Services and Supports

From fiscal years 2008 through 2011, the typical participant in the IL track 

was an older male Vietnam-era veteran. Of the 9,215 veterans who 

entered the IL track at some point during these years, most (67 percent) 

were males 50 years old or older. Most women in the IL track were in 

their 40s or 50s (see fig. 4). The gender and age distributions of IL track 

veterans were similar to those of veterans who were receiving VA 

Disability Compensation cash benefits. In fiscal year 2011, about 92 

percent of these veterans were male, and almost 68 percent were age 55 

or older.

Figure 4: FY 2008-2011 Independent Living Track Veterans, by Gender and Age

Note: The number in this figure does not add to the 9,215 veterans who entered the IL track during 

fiscal years 2008 through 2011 because information on gender and age was missing in about 1 

percent of these cases.

The IL Track Mainly 

Serves Older Veterans 

and Provides a Wide 

Variety of Benefits

IL Serves Mainly VietnamEra Veterans and Those

with Post-traumatic Stress 

Disorder 
 

Page 13 GAO-13-474 VA Independent Living Services and Supports

Most of the 9,215 veterans who entered the IL track during fiscal years 

2008 through 2011 served in the Vietnam War. However, there was a 

slight increase in the number of “Global War on Terrorism” veterans—

including those who served during the war in Afghanistan as part of 

Operation Enduring Freedom and the war in Iraq as part of Operation 

Iraqi Freedom—from 13 percent in fiscal year 2008 to 16 percent in fiscal 

year 2011 (see fig. 5).

Figure 5: Independent Living Track Veterans during FY 2008-2011, by War Era

In addition, almost 60 percent of IL track veterans served in the U.S. 

Army and less than 1 percent served in the National Guard or Reserves. 

Forty-one percent served in the U.S Navy, U.S. Air Force, or U.S. Marine 

Corps (see fig. 6).
 

Page 14 GAO-13-474 VA Independent Living Services and Supports

Figure 6: Independent Living Track Veterans during FY 2008-2011, by Branch of 

Service

Note: “Other” branches of service include the U.S. Coast Guard and Merchant Marines.

With regard to severity of service-connected disabilities, more than threequarters of IL track veterans had a combined service-connected rating of 

at least 60 percent. Thirty-four percent of IL track veterans had a

combined service-connected disability rating of 100 percent.21 Many IL 

track veterans may have also been eligible for the VA Disability 

Compensation program’s Individual Unemployability cash benefit.22

Indeed, 38 percent of IL track veterans were eligible for this supplement 

to their disability compensation payments. Moreover, of those IL track 

veterans who were at least 60 years old, 85 percent had combined 

service-connected disability ratings of at least 60 percent and more than a 

third had combined ratings of 100 percent.

 

21 VA pays monthly disability compensation to veterans with service-connected 

disabilities—injuries or diseases incurred or aggravated while on active military duty—

according to the severity of the disability. VA’s ratings are awarded in 10 percent 

increments, from 0 to 100 percent. Veterans with multiple disabilities receive a single 

composite (or combined) rating. 

22 Veterans of any age determined to be “unemployable” because of a combined serviceconnected disability rating between 60 and 90 percent, can qualify for an increase in their 

disability compensation to the amount paid to veterans with a combined serviceconnected disability rating of 100 percent.
 

Page 15 GAO-13-474 VA Independent Living Services and Supports

IL track veterans had a wide variety of service-connected disabilities, and 

most had more than one. Regardless of disability rating level, the most 

prevalent disabilities among this group were Post-traumatic Stress 

Disorder (PTSD), tinnitus (“ringing in the ears”), and hearing loss. As 

shown in figure 7, many of these disabilities—7 of the top 10 we identified 

in these cases—are similar to the most prevalent conditions among 

veterans rated by VA’s Disability Compensation program in fiscal year 

2011.

Figure 7: Comparison of the 10 Most Prevalent Disabilities among Independent Living Track Veterans from FY 2008-2011 and 

Veterans Receiving Disability Compensation for FY 2011

Our review of the case files of 182 randomly selected IL track veterans in 

fiscal year 2008 shows that they were provided a wide range of goods 

and services to help them live independently. Goods and services ranged 

from individual counseling and the installation of ramps to improve 

accessibility of veterans’ homes, to a boat, camping gear, and computers 

intended by VA to help decrease veterans’ social isolation. Figure 8 

provides examples of the types of benefits provided in four IL track cases 

The IL Track Has Provided 

a Wide Range of Benefits
 

Page 16 GAO-13-474 VA Independent Living Services and Supports

we reviewed. (See appendix III for a complete list of goods and services 

we identified in 182 IL track cases.)

Figure 8: Examples of the Types of Goods and Services Provided in Four of the Independent Living Track Cases GAO 

Reviewed

While VR&E can provide a wide range of benefits to IL track veterans, 

VR&E’s policy as of November 2012 prohibits providing courses of study 
 

Page 17 GAO-13-474 VA Independent Living Services and Supports

and training to veterans that would lead to academic degrees, and 

purchasing certain types of equipment, such as lawn tractors.23 Our 

review of fiscal year 2008 IL cases shows instances where VR&E 

purchased lawn tractors and a riding mower. However, VR&E officials told 

us that there was no specific guidance prohibiting provision of such 

equipment in that year. 

As shown in table 1, we classified the wide range of goods and services 

we found in the 182 IL track case files we reviewed into nine general 

categories:

Table 1: Categories of Goods and Services Provided to Independent Living Track Veterans

Category Category Definition Examples

Adaptive equipment Non-electronic goods that aid in independent 

living.

• Mattresses

• Elastic shoelaces

• Grab bars

• Medication dispensers

Assistive devices and technology Electronic goods used to improve veterans’ 

functional capabilities.

• Lift chairs

• Adjustable beds

• Hydraulic patient lifter

• Electric jar opener

Avocational/leisure equipment Goods used for hobbies or recreational 

activities.

• Miter saw

• Camping equipment

• Boat

• Silversmithing and engraving tools

Computer and camera equipment Goods related to the purchase of a computer 

or camera.

• Laptops

• Printers 

• Memory cards

• Video camcorder

 

23 VR&E’s policy states that the agency does not have the authority to purchase or rent 

automobiles, trucks, or other similar “conveyances” for veterans. Also, while VR&E may 

provide mobility aids such as wheelchairs to veterans, tractors or mowers should never be 

approved as a mobility aid. See Department of Veterans Affairs, Veterans Benefits 

Administration, Purchase of Vehicles for Vocational Rehabilitation & Employment (VR&E) 

Participants under 38 U.S.C. Chapter 31 is prohibited, VR&E Letter 28-13-08 (November 

6, 2012).
 

Page 18 GAO-13-474 VA Independent Living Services and Supports

Category Category Definition Examples

Counseling services Social, vocational or psychotherapeutic 

services.

• Rehabilitation services

• IL training

• Adjustment counseling

• Psychotherapy

Education and training Education and training for “non-academic” 

purposes.

• Non-college degrees

• Computer training

• Apprenticeships

• Driving lessons

Medical care and health-related 

services

Services to improve veterans’ health. • Dental care

• Vision care

• Gym memberships

• Personal training

Residential adaptation and repair Goods and services related to home 

remodeling, construction or repairs to enable 

veterans to access their homes more easily.

• Home construction

• Ramp construction

• Bath safety installations

• Smoke detector

Other goods and services Goods and services that we were unable to 

classify in one of the other categories listed.

• IL equipment

• Boat shipping service

• Warranties for goods and services 

purchased

• Riding lawn mower/tractors

• Snow blowers

Source: GAO analysis of 182 case files of IL track veterans from fiscal year 2008.

Although we were unable to estimate the number of times certain goods 

and services were provided in the 182 IL track cases we reviewed,24 we 

generally found that the most common type of goods or services provided 

in the cases we reviewed were in three categories: 1) counseling, 2) 

education and training, and 3) computer and camera equipment.

We were, however, able to estimate the costs of the goods and services 

purchased for IL track cases. For all veterans who entered the IL track in 

fiscal year 2008, we estimate that VR&E purchased a total of almost $14 

million in goods and services.25 The average spent on purchases of 

 

24 See appendix I for more information on the limits of our case file review.

25 For confidence intervals for these estimates, see appendix I. 
 

Page 19 GAO-13-474 VA Independent Living Services and Supports

goods and services per IL track case that year was nearly $6,000.26 In the 

182 IL track cases we reviewed, the total amount VR&E spent on 

purchases of goods and services per veteran varied from $20 to over 

$33,000. Nearly 40 percent of the 182 veterans received $4,000 or more 

on purchases of goods and services (see fig. 9).

Figure 9: Distribution of Independent Living Track Cases Reviewed by Costs of 

Goods and Services Purchased for Veterans

 

26 The median cost per IL track case that year was about $3,900. At the 95 percent 

confidence interval, the amount of median expenditures per veteran who started an IL 

track case in fiscal year 2008 falls between $3,071 and $4,452. For additional confidence 

intervals for these estimates, see appendix I.
 

Page 20 GAO-13-474 VA Independent Living Services and Supports

Based on our analysis of IL track veterans who began only one plan 

during fiscal year 2008, we found that most of these veterans were 

classified by VR&E as “rehabilitated”—successfully reaching and 

maintaining the goals identified in their IL plan.27 By the end of fiscal year 

2011, as shown in figure 10, about 89 percent of veterans who began an 

IL plan in fiscal year 2008 had been classified by VR&E as “rehabilitated.” 

About 5 percent of cases were “discontinued” or closed by VR&E 

because the rehabilitation goals in the veteran’s IL plan were not 

completed. The remaining 6 percent of veterans’ cases were still open at 

the end of fiscal year 2011.

 

27 VR&E officials told us that the law does not limit the number of IL plans VR&E can 

develop for a veteran, and as a result, veterans can have more than one plan. For our 

analysis, we included veterans who began only one plan during fiscal year 2008. Of the 

2,465 veterans who began an IL plan during fiscal year 2008, 2,274—about 92 percent—

had only one IL plan. In addition, our analysis excludes 34 veterans who entered the IL 

track during fiscal year 2008 but whose cases were subsequently transferred to another 

one of VR&E’s employment tracks. We found that less than 1 percent of IL cases 

transferred to one of VR&E’s employment tracks. See appendix I for more information 

about our analyses.

Most Veterans 

Completed 

“Rehabilitation” but 

with Varying Time 

Frames

Most Veterans in the IL 

Track are Ultimately 

Classified by VR&E as 

“Rehabilitated” 
 

Page 21 GAO-13-474 VA Independent Living Services and Supports

Figure 10: Status at the End of FY 2011 of Independent Living Track Cases That 

Began in FY 2008

Of the 122 IL cases from fiscal year 2008 that had been discontinued, we 

found that about half were discontinued because the veteran declined 

benefits or did not respond when VA attempted to contact them. Another 

29 percent were discontinued because the veteran died. Also, some 

VR&E officials and staff we spoke with during our site visits told us that 

veterans may drop out of the IL track for other reasons, such as their 

condition worsens or they experience family problems.

Furthermore, while most veterans were classified by VR&E as 

“rehabilitated,” we found that the nature and complexity of IL plans can 

vary based on veterans’ individual disabilities and needs. As such, some 

plans are easier for VR&E to close as rehabilitated than others. For 

example, in one case we reviewed, the IL plan for a veteran with 

rheumatoid arthritis only called for the purchase and installation of eight 

door levers and a grab rail for the bathtub, so that the veteran could enter 

the rooms of his home without pain or assistance, and be able to safely 

enter and exit the bathtub without fear of falling. Other cases were more 

complex to close as rehabilitated because of the nature of services being 

provided to the veteran. For instance, another case we reviewed called 

for providing a veteran who used a wheel-chair with medical, dental, and 

vision care as needed and about $24,000 in modifications to the veteran’s 

home, including modifying the veteran’s bathroom, widening doors and 

modifying thresholds, and installing an emergency exit ramp in a 

bedroom.
 

Page 22 GAO-13-474 VA Independent Living Services and Supports

While the overall IL rehabilitation rate nationwide of 89 percent is fairly 

high, we found that the percentage of veterans who began an IL plan in 

fiscal year 2008 and were rehabilitated by the end of fiscal year 2011 

varied by regional office.28 IL rehabilitation rates in these cases ranged 

from 029 to 100 percent across regional offices, although about two-thirds 

of regional offices had rehabilitated 80 percent or more of 2008 IL track 

veterans by the end of fiscal year 2011. (See appendix IV for a complete 

list of rehabilitation rates for all regional offices.) In addition, VR&E’s IL 

rehabilitation rate was higher in regional offices with larger IL caseloads. 

Among veterans who entered the IL track in fiscal year 2008, an average 

of 90 percent were rehabilitated at offices with more than 25 IL entrants, 

compared to an average of 79 percent at offices with 25 or fewer IL 

entrants (see fig. 11).30

 

28 We calculated this rate based on both closed and open IL cases for veterans beginning 

the IL track during fiscal year 2008. In our calculation of the IL rehabilitation rate, we did 

not include IL track veterans who were transferred to another VR&E employment track. In 

contrast, VR&E calculates its IL rehabilitation rate using only those IL cases that were 

closed as “rehabilitated” or “discontinued” during a fiscal year.

29 In the Washington D.C. Regional Office, which VA now refers to as the National Capital 

Region Benefits Office, two veterans entered the IL track during fiscal year 2008. One 

case was discontinued, and one case was open at the end of fiscal year 2011.

30 Twenty-six regional offices had more than 25 veterans enter the IL track during fiscal 

year 2008, while 30 offices had 25 or fewer veterans enter the IL track during the same 

time period. Two offices had no IL track entrants that year.
 

Page 23 GAO-13-474 VA Independent Living Services and Supports

Figure 11: Percentage of FY 2008 Independent Living Track Veterans Rehabilitated, 

by Regional Office Based on Caseload

Note: This table represents those veterans with only one IL plan who entered the IL track in fiscal 

year 2008 and who were rehabilitated by the end of fiscal year 2011.

Furthermore, we found that fiscal year 2008 IL track veterans nationwide 

completed their IL plans, i.e., were classified rehabilitated, in an average 

of 384 days (about 13 months).31 About 50 percent of these veterans 

completed their IL plans within 1 year, 79 percent within 2 years, and 88 

percent within 3 years. Average days for these IL track veterans to 

complete their plans varied by regional office from a low of 150 days at 

the St. Paul Regional Office to a high of 895 days at the Roanoke 

Regional Office.32 However, at most regional offices (49 of 53)33 the 

 

31 Our analysis of the amount of time to rehabilitate IL participants is based on the 2,274 

veterans who had a single IL plan developed in fiscal year 2008. These veterans 

represent about 92 percent of the total 2,465 veterans entering the IL track in fiscal year 

2008.

32 The St. Paul Regional Office had nine veterans enter the IL track during fiscal year 

2008, while the Roanoke Regional Office had two veterans enter that year.

The Time to Rehabilitate IL 

Track Veterans Varied by 

Regional Office and 

Veteran Age
 

Page 24 GAO-13-474 VA Independent Living Services and Supports

average time to complete IL plans ranged from 226 to 621 days (8 to 21 

months). (See appendix V for a complete list of rehabilitation times for all 

regional offices.) Also, as shown in figure 12, IL track veterans generally 

completed their plans in less time at regional offices with larger IL 

caseloads than at offices with smaller caseloads.

Figure 12: Average Length of Time to Complete an Independent Living Plan, by 

Regional Office Based on Caseload

Note: This table represents those veterans who began one IL plan in fiscal year 2008 and were 

rehabilitated by the end of fiscal year 2011.

The average time for veterans to complete their IL plans also varied by 

veteran age. The oldest veterans completed their plans slightly more 

quickly than the youngest. More specifically, veterans who were 70 to 79 

 

33 We reported the average time to complete IL plans for 53 of VA’s 56 regional offices 

because two offices did not have veterans begin the IL track in fiscal year 2008. Another 

office had two IL track veterans begin during this period, but these veterans were not 

“rehabilitated.”
 

Page 25 GAO-13-474 VA Independent Living Services and Supports

completed their plans in an average of 369 days, while those who were 

20 to 29 completed them in an average of 413 days (see fig. 13).34

Figure 13: Average Time to Complete Independent Living Plans, by Veteran Age 

Groups

Note: This table represents those veterans who began one IL plan in fiscal year 2008 and were 

rehabilitated by the end of fiscal year 2011.

Because differences in the length of time to complete IL plans could have 

occurred by chance or be explained by many factors—including the type 

and severity of disability or veteran age—we used a statistical model to 

estimate the amount of time it would take certain groups of IL track 

veterans to complete their IL plans while controlling for type and severity 

 

34 While there was no clear pattern for the time it took veterans to complete their IL plans 

based on veterans’ combined service-connected disabilities, totally disabled veterans took 

about a month longer on average to complete their IL plans than non-totally disabled 

veterans.

GAO Analysis of 

Likelihood of Veterans 

Completing Their IL Plans
 

Page 26 GAO-13-474 VA Independent Living Services and Supports

of disability and other demographic characteristics.35 (See appendix II for 

more detailed information on our model and analysis.) The results of our 

model showed that the chance of rehabilitation within 2 years varied by 

regional office. At four regional offices the chance of being rehabilitated 

within 2 years was less than 50 percent. At 18 offices the chance was 

between 50 and less than 90 percent. At 16 offices the chance was 90 

percent or greater.

Our model also estimated that a veteran served by a regional office with a 

large IL caseload had a higher probability of completing an IL plan more 

quickly than a veteran served by an office with a small IL caseload. More 

specifically, we determined that a typical IL track veteran at an office with 

a total of 75 IL cases entering the IL track during fiscal years 2008 

through 2011 had a 48 percent chance of completing an IL plan within 1 

year and a 92 percent chance of completing an IL plan within 3 years,36

while a veteran at a regional office with 700 IL cases had a 57 percent 

chance of completing an IL plan within 1 year and a 96 percent chance of 

completing their plan within 3 years (see fig. 14).37 Finally, based on our 

model we estimated that older veterans had a higher probability of 

completing an IL plan more quickly than younger veterans. For example, 

a 75 year old veteran had a 41 percent chance of completing an IL plan 

within one year, while a 30 year old veteran had a 33 percent chance. We 

found no meaningful differences in the time it takes to complete an IL plan 

as “rehabilitated” according to veteran gender and most disability types. 

However, we found small differences according to length of military 

service, education, and combined service-connected disability rating (see 

appendix II).

 

35 Our model is based on the experiences of veterans who entered the IL track during 

fiscal years 2008 through 2011 and had only one IL plan during this time period. We used 

our model to estimate the probability of a veteran being rehabilitated within 2 years if the 

IL plan was begun at a regional office that had at least 50 IL cases during fiscal years 

2008 through 2011.

36 In general, programs of independent living may not exceed 24 months except under 

certain circumstances. An additional 6 months is allowed if it would enable veterans to 

substantially increase their level of independence in daily living. In addition, VR&E officials 

stated that they may extend the duration up to 36 months for veterans with severe 

disabilities who served on active duty on or after September 11, 2001.

37 Our model shows that VR&E’s rehabilitation rate increases by 4.3 percent for each 

additional 100 cases a regional office completes. The margin of error associated with 

these estimates ranged from 3.3 to 5.4 percent at the 95 percent confidence level. 
 

Page 27 GAO-13-474 VA Independent Living Services and Supports

Figure 14: Estimated Probability of a Veteran Completing an Independent Living Plan within Certain Time Periods, by 

Regional Office Based on Caseload

Note: Estimates were calculated from a statistical model. See appendix I and II for more information.

National oversight of VR&E’s IL track is limited in four key areas: (1) 

ensuring compliance with case management requirements; (2) monitoring 

regional variation in IL track caseload and benefits provided; (3) 

adequacy of policies and procedures for approving expenditures on 

goods and services for IL track veterans; and (4) availability of critical 

program management information.

Based on VR&E’s compliance reports from two of the regional offices we 

visited and interviews with staff in these offices, we found that some 

offices may not be complying with certain VR&E case management 

requirements governing the IL track. Specifically, some Vocational 

Rehabilitation Counselors (VRC) are not fulfilling VR&E’s requirement to 

meet in-person each month with IL track veterans to monitor progress in 

VR&E Exercises 

Limited Oversight of 

the IL Track 

Regional Offices May Not 

Be Complying with VR&E 

Case Management 

Requirements
 

Page 28 GAO-13-474 VA Independent Living Services and Supports

completing their IL plans.38 Site visit monitoring reports39 from two 

regional offices we visited indicated that these offices faced difficulties 

complying with this requirement. According to these reports, some VRCs 

were not able to schedule monthly in-person meetings with IL track 

veterans to check their progress in completing their IL plans. In addition, 

VRCs we spoke with during our site visits said that compliance with this 

requirement continues to be a challenge due to the size of their caseloads 

and the distances that they have to travel to meet with veterans. While 

VR&E’s Central Office acknowledges that it can be challenging for some 

offices to comply with this requirement, officials stated that face-to-face 

contact with IL track veterans is extremely important due to the nature of 

their disabilities and the need for more intensive rehabilitation services.40

Furthermore, while VR&E and VHA both have policies that require them 

to coordinate on the provision of goods and services for IL track veterans, 

we found that some VRCs experience challenges in doing so.41

Specifically, VA regulations governing VR&E’s IL track require that if a 

veteran needs special equipment and is eligible for such equipment under 

another VA program, the items will be provided under that program.42

Therefore, prior to VR&E purchasing services for veterans, officials told 

us that VRCs are required to refer cases to other VA providers, such as 

VHA’s Home Improvements and Structural Alterations (HISA) program 

and VA medical centers, to determine whether veterans are eligible to 

 

38 VR&E’s policy manual states that contact via telephone, email, or mail can be used as 

alternatives when necessary. Department of Veterans Affairs, Vocational Rehabilitation 

and Employment, Chapter 9: Guidelines for the Administration of An Independent Living 

Plan, VR&E manual, Part IV, Section C, Chapter 9.

39 VR&E’s Quality Assurance (QA) Program at the national level periodically performs file 

reviews and site visits of selected regional offices to assess service delivery and 

compliance with VA regulations, procedures, and other directives. After the QA review or 

site visit, a report is provided to the regional office under review that summarizes the key 

results and findings.

40 According to officials, the monthly in-person meeting requirement is only for the IL track, 

not VR&E’s other employment-related tracks.

41 VRCs we interviewed during our site visits reported relatively few challenges 

coordinating with SAH because not many IL cases are referred to this program for home 

modifications. In particular, we found in the 182 IL cases we reviewed that less than 3 

percent were referred to SAH. VRCs commented that many veterans do not qualify for the 

SAH’s home modification grants because of their eligibility requirements.

42 38 C.F.R § 21.216(b).
 

Page 29 GAO-13-474 VA Independent Living Services and Supports

receive the goods and services identified in their plan from these 

providers. In addition, VHA ‘s policy directive for coordinating with VR&E 

is intended to ensure that all VR&E participants, including those in the IL 

track, receive timely access to VHA health care services. The directive 

requires medical center directors to (1) provide clinically appropriate care 

to VR&E participants, (2) establish procedures to manage these 

participants’ timely access to care, and (3) ensure that clinical staff are 

trained in these procedures, including how to alert appropriate VBA 

officials when timeliness of care could be an issue, among other 

requirements.43

Despite these VR&E and VHA policies, our review of 182 IL track records 

found some instances where VR&E purchased goods and services that 

appear to be medically related, such as ramps and grab bars, and could 

have been provided by VHA. There may have been little coordination on 

IL track cases because, as VR&E officials and staff at the five VA regional 

offices we visited told us, coordinating with VHA medical center staff can 

be challenging. Several VRCs indicated that when they refer IL track 

cases to VHA physicians to determine whether any of the medical-related 

benefits identified in the IL plans—such as grab bars, wheelchairs, and 

safety rails—had been or could be provided by VHA, in many instances, 

VHA physicians do not respond or respond too late. As a result, services 

for IL track veterans were either delayed or purchased by VR&E instead 

of VHA. According to some VHA staff, lack of or delays in coordination 

are sometimes due to differences in VR&E rehabilitation goals and VHA 

long-term medical goals for veterans. For example, VHA staff members 

mentioned they would not approve VRCs’ requests for lift chairs unless 

veterans absolutely needed them because VHA staff members said their 

medical goal is to promote continued mobility.

While IL track caseload size and benefits vary across regions, VR&E 

does not systematically monitor these variations. We found regional 

differences in the size of IL caseloads, the range of needs covered in a 

veteran’s IL plan, and the types of goods and services provided. As 

shown in figure 15, the total IL track caseload during fiscal years 2008 

through 2011 ranged from over 900 cases in the Montgomery Regional 

 

43 Department of Veterans Affairs, Veterans Health Administration, VHA Directive 2010-

022, Vocational Rehabilitation: Chapter 31 Benefits, Timely Access to Health Care 

Services (May 14, 2010).

VR&E Does Not 

Systematically Monitor 

Variation in IL Track 

Caseload Size and Benefits 

Provided
 

Page 30 GAO-13-474 VA Independent Living Services and Supports

Office in Alabama to 4 cases in the Wilmington Regional Office in 

Delaware. (See appendix VI for annual IL caseload data.) While one 

would expect differences in caseload size based on the number of 

veterans in an office’s service area, some differences in IL caseload could 

not be explained by the size of the veteran population in an office’s 

service area. For example, while the estimated size of the veteran 

populations in Alabama and Massachusetts are similar, Montgomery’s IL 

caseload of over 900 veterans was more than 100 times as large as 

Boston’s IL caseload of 8 veterans. VR&E officials told us they are aware 

that some offices have low IL participation levels, and attributed some of 

the difference to factors, such as the presence of specialized treatment 

centers in certain areas of the county that can increase caseload 

numbers in those regions. However, evidence from our site visits 

suggests that there may be other factors that drive the number of 

veterans entering a region’s IL track. For example, officials from the 

Detroit Regional Office—which had the second highest total IL caseload 

across fiscal years 2008 through 2011—attributed the size of their 

caseload to their office’s focus on IL cases and community outreach 

efforts, including the involvement of veteran service organizations. The 

Atlanta Regional Office also mentioned that in addition to the size of the 

veteran population in Georgia and the presence of army bases, the size 

of their IL caseload is influenced by increased community interest in the 

IL track in recent years, and the informal efforts of past IL participants to 

provide information about the IL track to other veterans.
 

Page 31 GAO-13-474 VA Independent Living Services and Supports

Figure 15: The Vocational Rehabilitation and Employment Program’s Overall Independent Living Caseload from FY 2008-

2011, by Regional Office

a The Washington Regional Office, located in the District of Columbia, was recently designated the 

National Capital Region Benefits Office in November 2012.

Based on discussions with regional personnel and our review of the 

results of past studies, IL plans and the goods and services provided can 

also vary by region. According to VR&E officials, the law gives VA broad 

discretion in defining the range of needs covered in an IL track plan, as 

well as in choosing the types of goods and services required to achieve 

the plan’s goals. VR&E’s policy does, however, prohibit the agency from 

providing courses of study and training leading to academic degrees, and 

purchasing certain types of equipment, such as lawn tractors. As a result, 

some regions appear to develop IL plans that address a broader range of 
 

Page 32 GAO-13-474 VA Independent Living Services and Supports

needs while others elect to develop more focused plans. Officials we 

spoke with during our site visits also confirmed that regions differ in their 

approach to developing IL plans, and in one region, officials commented 

that some regions may develop simpler plans with fewer benefits to 

achieve VR&E’s rehabilitation goal. Moreover, VR&E’s 2008 study of the 

IL track reported that some regions relied repeatedly on the same types 

of benefits to meet veterans’ IL needs.44 For example, in the New York 

and Hartford regional offices, nearly 90 percent of IL participants were 

provided computer training. This was almost twice the rate of Detroit—the 

office with the next highest rate of providing veterans with computer 

training—in 44 percent of its IL cases. Other offices focused more heavily 

on providing goods or services to support veterans’ avocational interests 

or on finding veterans volunteer opportunities, while some consistently 

focused on providing veterans with health club memberships. For 

example, the St. Petersburg Regional Office accounted for 33 percent of 

veterans receiving volunteer opportunities. In addition, the 2004 VR&E 

Task Force report noted significant differences in field office philosophy 

regarding the scope and administration of the IL track, and also 

recommended providing VR&E Central Office greater “line-of-site 

authority” over VR&E field operations.45 As noted earlier, VBA’s Office of 

Field Operations rather than VR&E’s Central Office has direct line of 

authority over regional VR&E staff and operations.

While VA officials acknowledged the existence of regional variation in 

these areas, VR&E’s current oversight approach may not be adequate to 

ensure consistent administration of the IL track across regions. The 

standards for internal control in the federal government emphasize the 

need for federal agencies to have timely information to effectively monitor 

and mitigate program risks.46 To oversee administration of the IL track, 

 

44 United States Department of Veterans Affairs, Vocational Rehabilitation & Employment 

Services: Independent Living Participant Study (September 26, 2008).

45 VA Vocational Rehabilitation and Employment Task Force. Report to the Secretary of 

Veterans Affairs: The Vocational Rehabilitation and Employment Program for the 21st 

Century Veteran (2004). 

46 The standards for internal control in the federal government state that it is important for 

federal agencies to have timely information to help ensure efficient and consistent 

program administration. In addition, it is also critical for federal agencies, including those 

with highly decentralized program operations, to comprehensively identify risks that may 

impede their ability to achieve program goals. See GAO, Internal Control Management 

and Evaluation Tool, GAO-01-1008G (Washington, D.C.: August 2001).
 

Page 33 GAO-13-474 VA Independent Living Services and Supports

VR&E has relied on the information provided through its general quality 

assurance (QA) activities and a series of periodic ad hoc studies. The QA 

activities are conducted by each region as well as VR&E’s QA staff 

located in Nashville, Tennessee. However, these activities are limited in 

scope, frequency, and how the information is used. At the national level, a 

team of VR&E QA staff are required to perform periodic site visits to each 

VA regional office at least every 3 years, although officials told us they 

have not been able to meet this goal in recent years because of 

budgetary constraints. This team also periodically reviews a sample of 

veterans’ records from VR&E’s IL and employment tracks in selected 

regions. After each site visit and case review, the QA team produces a 

report for the particular region under review. While VR&E officials told us 

that QA results are “analyzed to determine trends,” it is unclear how 

VR&E uses these results to ensure that consistent procedures are used 

by regional offices nationwide. 

In addition to these QA activities, VA has funded two studies over the 

past several years on the VR&E program, including implementation of the 

IL track, and a third is under way.47 In 2003, VA appointed a task force to 

evaluate the overall VR&E program and recommend ways service 

delivery could be improved. In 2008, as mentioned, a study was issued by 

VR&E on the types of services received by IL track participants and the 

impact those services had on veterans.48 This study found, among other 

things, that IL participants received a broad range of services, and that 

some regional offices favored providing certain types of services to IL 

track veterans. Finally, in October 2012, VR&E awarded a contract for 

about $890,312 to study the IL track service delivery process, barriers 

and incentives for field staff when considering the provision of services, 

current and future training strategies, and other areas. VR&E officials 

anticipate receiving the final results from this study in July 2013.

 

47 VA is also mandated by Congress to conduct a longitudinal study of individuals in 

VR&E’s programs, including the IL track, to determine the long-term outcomes of program 

participants. Results from this study are required to be reported to the House and Senate 

Veterans’ Affairs Committees on an annual basis. Veterans’ Benefits Improvement Act of 

2008, Pub. L. No. 110-389, § 334, 122 Stat. 4145, 4172.

48 United States Department of Veterans Affairs, Vocational Rehabilitation & Employment 

Services: Independent Living Participant Study (September 26, 2008).
 

Page 34 GAO-13-474 VA Independent Living Services and Supports

Considering the broad discretion VR&E provides to regions in determining 

the range of needs covered in IL track plans and the types of goods and 

services selected to meet these needs, VR&E’s current policy for 

approving IL track expenditures may not be adequate. To guard against 

fraud, waste, abuse, and mismanagement, the standards for internal 

control emphasize the need for agencies to have appropriate levels of 

supervision and controls in place to prevent one individual from having 

responsibility for all key aspects of a transaction or event.49 VR&E Central 

Office is responsible for managing the program’s national budget. While 

officials told us that VRCs are required to include all cost estimates when 

they submit veterans’ IL plans to be reviewed and approved by the 

region’s VR&E Officer, VR&E was unable to provide any written policy or 

guidance that explicitly states this requirement for all IL expenditures.

50

VR&E’s current written policies allow each region to unilaterally approve 

construction-related expenditures up to $25,000 per case and nonconstruction expenditures up to $100,000 per case without approval from 

VR&E Central Office. In addition, VRCs can spend up to $2,000 on 

construction-related expenditures and up to $25,000 on non-construction 

expenditures without supervisory review of any kind (see table 2). Under 

this policy, regional offices are permitted to purchase a broad range of 

items without any Central Office approval, resulting in some offices 

purchasing goods and services that may be questionable or that are 

costly. For example, in one of the 182 IL cases we reviewed, VR&E 

Central Office would not have been required to approve total 

expenditures of $18,829 for a riding lawn mower—which VR&E policy 

prohibits51—and other IL goods and services including a bed, bed frame, 

desktop computer, and woodworking equipment. In another case, VR&E 

 

49 GAO-01-1008G. 

50 VR&E’s guidelines for the administration of an independent living plan state that VRCs 

are required to obtain appropriate approval if IL costs exceed $25,000—not that all IL 

costs are required to be approved. See Department of Veterans Affairs, Vocational 

Rehabilitation and Employment, Chapter 9: Guidelines for the Administration of An 

Independent Living Plan, VR&E manual, M28, Part IV, Subpart iv, Chapter 9 (December 

29, 2006). Furthermore, a 2010 VR&E policy letter outlines information that must be 

submitted by VRCs to obtain regional or Central Office approval of construction costs that 

exceed certain thresholds. However, this letter does not outline the requirements for nonconstruction related costs. Veterans Benefits Administration, Review of Requests for

Independent Living (IL) Construction Costs in Excess of $2,000, VR&E Letter 28-11-05 

(December 3, 2010).

51 In 2008, the provision of riding lawn mowers was not specifically prohibited by VR&E 

policy.

VR&E Policy for 

Approving IL Track 

Expenditures Might Not Be 

Adequate 
 

Page 35 GAO-13-474 VA Independent Living Services and Supports

Central Office approval would not have been required for the purchase of 

a boat, motor, trailer, and the boat’s shipping cost to Molokai, Hawaii, 

among other items, totaling about $17,500.52 Without appropriate 

approval levels, VR&E’s IL track may be vulnerable to potential fraud, 

waste, and abuse.

Table 2: Level of Approval Required for Construction and Non-Construction-Related Expenditures in Independent Living 

Track Cases

Required level of approval Construction-related expenditures Non-construction related expenditures 

No supervisory approval requireda Less than $2,000 Less than $25,000

Regional VR&E Officer $25,000 to less than $75,000

Regional Office Director $2,000 through $25,000 $75,000 through $100,000

VR&E Central Office More than $25,000 More than $100,000

Source: GAO analysis of VA policies.

a VR&E officials told us that all IL plans require supervisory review. However, VR&E’s written policies 

do not require IL expenditures to be reviewed and approved by the VR&E officer unless they meet 

certain cost-thresholds. 

VR&E does not collect or report critical program management 

information—such as the costs of goods and service purchased, the 

types of benefits provided, and the number of IL veterans served—that 

would help the agency in its oversight responsibilities. Specifically, 

VR&E’s Corporate WINRS case management system—commonly 

referred to as “CWINRS”—lacks information on the total amount of funds 

VR&E expends on IL benefits because the agency does not maintain 

specific cost information on each of its five tracks or the key program 

areas these tracks represent, which are employment services and 

independent living. VR&E aggregates costs across all its tracks, despite 

VA’s managerial cost accounting policies that require the costs of 

 

52 The case record indicates that the veteran was provided a boat to “significantly improve 

independent living and psychosocial functioning”. At the time of assessment, the VRC 

noted that the veteran, who suffered from PTSD, was socially isolated but had an interest 

in fishing. However, the veteran’s old boat “rotted away,” and the cost for purchasing a 

new one was high. The VRC noted in the case file that because the veteran received a 

new boat, he was less depressed and his relationships with family and friends improved.

VR&E Lacks Critical 

Information Needed for 

Oversight
 

Page 36 GAO-13-474 VA Independent Living Services and Supports

products and services to be captured for management purposes.53

Federal financial accounting standards also recommend that costs of 

programs be measured and reported.54 According to officials, they do not 

collect cost information on the IL track alone because they view the five 

tracks as a single program with the same overarching goal—to help 

veterans achieve their employment goals. However, in our 2009 report on 

the VR&E program,55 we reported that VR&E serves veterans with 

fundamentally different program goals and outcomes—those seeking to 

obtain employment and those seeking to live independently.

56 As a result, 

we recommended that VR&E separately track its IL rehabilitation rate.

In addition, the CWINRS system does not collect information on the types 

of IL benefits provided to veterans in a standardized manner that can be 

easily aggregated and analyzed for oversight purposes. Currently, VRCs 

are required to write in a description of the benefits they purchased for IL 

track veterans in CWINRS. We found, however, that the recorded 

descriptions lack consistency and vary in their level of detail. In several of 

the IL track cases we reviewed, the goods and services purchased were 

grouped together under a general description, such as “IL equipment” or 

 

53 VA’s policy states that managerial cost accounting should be performed to measure 

and report the costs incurred by the agency. Specifically, each administration and its units 

should identify the cost of products and services provided. For example, in the case of a 

VHA medical center, the cost of a product or service may include a laboratory test, a 

medical ward bed, or a counseling session. The goal of this effort is to identify the product 

or service at the level in which it is rendered to an external customer, such as a veteran 

receiving benefits from a VA program. Department of Veterans Affairs Managerial Cost 

Accounting: VA Financial Policies and Procedures, volume III, chapter 3 (July 2010).

54 According to these standards, managerial cost accounting is a fundamental part of an 

agency’s financial management system, and each agency and its units should report the 

costs of their activities on a regular basis. This cost information can be used by Congress 

and federal executives in making decisions about allocating federal resources, authorizing 

and modifying programs, and evaluating performance. The cost information can also be 

used by program managers in making managerial decisions to improve operating 

economy and efficiency. Statement of Federal Financial Accounting Standards 4: 

Managerial Cost Accounting Standards and Concepts.. 

55 GAO, VA Vocational Rehabilitation and Employment: Better Incentives, Workforce 

Planning, and Performance Reporting Could Improve Program, GAO-09-34 (Washington, 

D.C.: January 26, 2009).

56 According to VR&E officials, some veterans in the IL track progress to a point where 

they may be able to pursue employment in one of VR&E’s employment-related tracks; 

however, as noted earlier in this report, very few veterans make this transition—less than 

1 percent of the 8,812 IL track veterans who had one plan during fiscal years 2008 

through 2011.
 

Page 37 GAO-13-474 VA Independent Living Services and Supports

“IL supplies,” without any further details. In other cases, VRCs recorded 

each purchase separately. For instance, in one case, the VRC created 

separate entries for each item purchased, for example, “desktop 

computer,” “computer desk,” “Queen Mattress,” “all in one printer,” “USB 

cable and ink,” “threshold ramp,” and “washer.” In addition, we found that 

controls for data entry are not adequate to ensure that all important data 

is recorded.57 For example, we estimated that the service provider field 

was either missing or unclear for one or more services in about 15 

percent of all IL cases that began in fiscal year 2008. Moreover, in 

another 7 percent of IL cases that began during fiscal year 2008, we 

found that service provider data was unavailable because CWINRS had 

overwritten veterans’ 2008 IL plans with subsequent plans. CWINRS only 

retains veterans’ current IL plan.58

Furthermore, CWINRS does not provide VR&E with the information it 

needs to account for the actual number of IL track veterans it serves to 

monitor its statutory entrant cap and program operations. The law allows 

VR&E to initiate “programs” of independent living services and assistance 

for no more than a specified number of veterans each year, which is 

currently set at 2,700.59 A VR&E policy letter to VA regional offices, dated 

December 14, 2010, states that “VR&E Service will monitor new IL 

programs by tracking the number of veterans entering independent living 

case status in each fiscal year and notify the field of any necessary action 

if the 2,700 statutory limit is being approached.”

60 However, in analyzing 

VR&E’s administrative data, we found that VR&E counts the number of IL 

 

57 The standards for internal control emphasize the need to have controls over 

computerized information systems to ensure the data entered is complete and accurate 

(GAO-01-1008G). In addition, GAO’s federal information system controls audit manual 

states that agencies should establish procedures to provide reasonable assurance that all 

inputs into the application have been authorized, accepted for processing, and accounted 

for; and any missing or unaccounted for source documents or input files have been 

identified and investigated. GAO, Federal Information System Controls Audit Manual 

(FISCAM), GAO-09-232G (Washington, D.C.: February 2009).

58 For confidence intervals for these estimates, see appendix I.

59 38 U.S.C. § 3120(e). According to agency officials, “IL plans” are the same as 

“programs” of independent living services and assistance. 

60 According to VR&E officials, entering “independent living case status” means that the 

veteran is admitted into the IL track. For more information on VR&E’s policy, see 

Department of Veterans Affairs, Veterans Benefits Administration, Increase in New 

Independent Living (IL) Programs Allowed by Congress, VR&E Letter 28-11-06 

(December 14, 2010).
 

Page 38 GAO-13-474 VA Independent Living Services and Supports

plans developed annually and not the number of individual veterans 

admitted to the track. VR&E officials told us that the law does not limit the 

number of IL plans that can be developed for a veteran in a single fiscal 

year.61 Because multiple IL plans can be developed for an individual 

veteran during the same fiscal year, veterans with multiple plans are 

counted more than once towards the statutory cap by CWINRS. Based on 

data from CWINRS, 403 (4 percent) of the 9,215 veterans beginning an IL 

plan during fiscal years 2008 through 2011 had more than one plan 

during that time. About 22 percent of these veterans had more than one 

IL plan in the same fiscal year. From fiscal years 2008 through 2011, 

VR&E did not exceed the statutory cap (see fig. 16).

Figure 16: Number of and Statutory Cap on Veterans Entering the Independent 

Living Track from FY 2008-2011

Moreover, VR&E officials indicated that they were unaware that CWINRS 

was calculating the number of plans and not individual veterans. As a 

result, VR&E lacks complete information on the number of veterans it is 

 

61 VR&E officials indicated that another IL plan may need to be developed to address 

subsequent needs that arise from a new medical condition or the progression of an 

existing one. 
 

Page 39 GAO-13-474 VA Independent Living Services and Supports

serving through the IL track at any given time—information it could use to 

better manage staff, workloads, and program resources. According to the 

standards for internal control, it is important for program managers to 

have reliable and timely “operational” information to ensure agency goals 

are met, resources are used efficiently and effectively, and requirements 

under various laws and regulations are being complied with.62

Finally, recent evaluations of CWINRS have determined that the system 

does not meet VR&E’s current needs and limits its oversight abilities 

because important data elements are not captured to support the 

agency’s “evolving business needs.”

63 According to a 2012 VR&E report, 

VR&E plans to improve CWINRS by (1) increasing data automation to 

reduce instances of human error, and (2) enhancing system controls to 

improve the accuracy and comprehensiveness of the data, among other 

improvements. However, it appears that the CWINRS redesign will not 

enable VR&E to obtain data on IL track expenditures from the system or 

to use the system to accurately and efficiently track the types of goods 

and services the IL track provides. While officials told us that they plan to 

modify the system to enable them to track individual veterans served 

through the IL track, they could provide no time frame for this project and 

noted that it could take up to 3 years to obtain funding for it.

VR&E’s IL track can provide a wide range of benefits to help veterans 

with service-connected disabilities maximize their ability to live 

independently when the achievement of an employment goal is not 

currently feasible. Under the law, each VA region has broad discretion in 

determining the range and types of goods and services each IL track 

veteran should receive. Consequently, adequate oversight at the national 

level is extremely important in ensuring that IL track case management 

requirements are met, the track is administered consistently across 

 

62 “Operational” information could include the number of individual veterans being served. 

Furthermore, these standards state that all pertinent information should be identified, 

captured, and distributed in an efficient and timely manner. GAO, Standards for Internal 

Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 

1999).

63 Department of Veterans Affairs, Vocational Rehabilitation and Employment (VR&E) 

Case Management Portal Project, Version 1.0, Case Management Portal, Business 

Requirements Document (September 26, 2012).

Conclusions 
 

Page 40 GAO-13-474 VA Independent Living Services and Supports

regions, expenditures for goods and services are appropriate, and critical 

IL track information is collected and used.

In this context and absent better coordination with VHA, VR&E will 

continue to face challenges in ensuring goods and services for IL track 

veterans are provided by VHA, when appropriate, in a timely manner. 

With regard to VR&E’s Central Office oversight, its current policy 

governing the review and approval of expenditures might not effectively 

mitigate the risk of fraud, waste, abuse, or mismanagement inherent in 

activities, such as the development and implementation of IL plans, where 

there are few limitations on the types and cost of goods and services that 

can be provided. Furthermore, without collecting information on cost and 

the types of benefits regional offices provide to IL track veterans, and 

maintaining an information system that ensures IL track data are recorded 

consistently and are accurate and complete, VR&E cannot effectively 

oversee the performance and activities of its IL track. Finally, as more 

servicemembers from the conflicts in Iraq and Afghanistan transition into 

civilian life and veterans’ programs and as the overall veteran population 

ages, the demand for IL services will likely increase. VR&E must, 

therefore, be able to accurately count the number of individual IL track 

veterans served to ensure it can effectively manage its cap and assess 

program performance and resource needs.

The Secretary of Veterans Affairs should direct the Undersecretary for 

Benefits to take the following actions:

1. Work with the Undersecretary for Health to explore options on ways to 

enhance coordination to ensure IL track veterans’ needs are met by 

VHA, when appropriate, in a timely manner. This could include 

improving staff education, response times to IL referrals, and the 

provision of medically related goods and services.

2. Implement an oversight approach that enables VR&E to better ensure 

consistent administration of the IL track across regions. In developing 

this approach, consider ensuring that VR&E’s CWINRS system:

• Tracks the total cost and types of benefits provided to each 

veteran in the IL track by regional office.

• Accounts for the number of individual veterans served to ensure 

that the agency has the information it needs to adequately 

manage the IL track.

Recommendations for 

Executive Action
 

Page 41 GAO-13-474 VA Independent Living Services and Supports

• Contains stronger data entry controls to ensure that IL track 

information is recorded in a consistent manner and is accurate 

and complete.

3. Reassess and consider enhancing the agency’s current policy 

concerning the required level of approval for IL track expenditures, 

given the broad discretion individual regional offices have in 

determining the types of goods and services IL track veterans receive.

We provided a draft of this report to the Secretary of Veterans Affairs for 

review and comment. VA generally agreed with our conclusions, and 

concurred with our three recommendations. VA’s written comments are 

reproduced in appendix VII. In addition, VA provided technical comments 

that we have incorporated in the report where appropriate. With regards 

to our recommendation that VA enhance coordination between VR&E and 

VHA on the provision of IL benefits to veterans, VA noted there are efforts 

underway that will permit VR&E counselors to make IL referrals to VHA 

providers through VHA’s Compensation and Pension Record Interchange 

system, also referred to as CAPRI. In addition to these efforts, we 

encourage VR&E and VHA to continue to explore other options to 

enhance coordination, such as engaging in staff education and training 

efforts to improve the timely provision of IL benefits and prevent any 

duplication. Furthermore, with regards to our recommendation to improve 

IL track oversight, VA said that it will perform an assessment of its current 

IL track oversight procedures and consider including enhancements to 

CWINRS. Because having a sound information system plays such a 

critical role in helping program managers monitor agency performance 

and operations, we urge VA to take steps to prioritize enhancements to 

CWINRS. Finally, VA noted that, in response to our recommendation that 

it reassess its current policy for approving IL track expenditures, it plans 

to make any needed improvements by March 2014. As part of its 

assessment process, we believe that VA should review its existing costthresholds for approving all IL expenditures, including non-construction 

related expenditures, to ensure adequate oversight of goods and services 

purchased for veterans. 

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Veterans Affairs, and other interested 

parties. The report is also available at no charge on the GAO web-site at 

www.gao.gov. 

Agency Comments 

and Our Evaluation
 

Page 42 GAO-13-474 VA Independent Living Services and Supports

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

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

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. Staff members who made key contributions 

to this report are listed in appendix VIII.

Daniel Bertoni

Director, Education, Workforce,

 and Income Security Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-13-474 VA Independent Living Services and Supports

The objectives of this report were to examine (1) the characteristics of 

veterans who have participated in the IL track, as well as the types and 

costs of benefits they were provided; (2) the extent to which their 

independent living plans were completed, and the time it took; and (3) the 

extent to which the IL track has been administered appropriately and 

consistently.

To answer these objectives, we used a variety of methodologies, which 

are described in greater detail below. Specifically, we analyzed VA 

administrative data from fiscal years 2008 through 2011 to provide 

information on the characteristics and outcomes of veterans who 

participate in the IL track, and how long it takes to achieve these 

outcomes. We also used statistical models to determine any differences 

in rehabilitation times. In addition, to determine the types of benefits 

provided and their costs, we conducted a case file review of a random, 

generalizable sample of 182 veterans who started in the IL track during 

fiscal year 2008. Lastly, to examine the administration of the IL track, we 

visited five VA regional offices and interviewed officials and staff from 

VR&E, Specially Adapted Housing (SAH), Prosthetics and Sensory Aid 

Service (PSAS) under the Veterans Health Administration (VHA), and 

veteran service organizations. We also reviewed relevant federal laws 

and regulations, standards for internal controls and managerial cost 

accounting, as well as VR&E policies, procedures, and other relevant 

studies and documentation.

We analyzed VA administrative data in the Corporate WINRS system—

commonly referred to as “CWINRS”—from fiscal years 2008 through 

2011 to describe the characteristics and outcomes of veterans in the IL 

track, and how long it takes veterans to achieve these outcomes.

64 We began our analysis in fiscal year 2008 because officials told us the 

data was not reliable in previous years and modifications were made to 

improve its reliability in fiscal year 2007. We assessed the reliability of the 

data by performing electronic testing, reviewing existing documentation, 

and interviewing knowledgeable agency officials. Based on these efforts, 

 

64 VR&E has used the CWINRS system since 2001 to track veteran cases through its 

process and to manage program costs. The “WINRS” part of the acronym represents the 

first 5 regional offices that tested the original system. These offices include Waco, Texas; 

Indianapolis, Indiana; Newark, New Jersey; Roanoke, Virginia; and Seattle, Washington.

Appendix I: Objectives, Scope, and 

Methodology 

Analysis of VA 

Administrative Data
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-13-474 VA Independent Living Services and Supports

we found the data to be sufficiently reliable for our purpose, unless 

otherwise noted.

To identify our universe of 9,215 veterans who started in the IL track 

during fiscal years 2008 through 2011, we counted the number of 

individual veterans who had an “IL status” recorded in CWINRS during 

our time frame.65 While veterans can enter into the IL track more than 

once in a given fiscal year, we counted a veteran only once if he or she 

had more than one IL status during these years. To determine the 

characteristics of the 9,215 veterans who began in the IL track during 

fiscal years 2008 through 2011, we examined several demographic 

variables in CWINRS, including veterans’ age, gender, types of 

disabilities, and combined disability rating. Data on the war era in which 

veterans served was obtained from VA’s Benefits Delivery Network.

To examine the outcomes of veterans in the IL track, we limited our 

analysis to veterans who began only one IL plan at some point during 

fiscal year 2008. This accounted for about 92 percent of the 2,465 

veterans who began an IL plan during fiscal year 2008. The remaining 8 

percent of veterans who had more than one plan were excluded from our 

analysis because of potential data reliability issues associated with how 

certain case actions were recorded. In our analysis of IL veteran 

rehabilitation rates, we excluded veterans whose cases were transferred 

to one of VR&E’s employment tracks.

To estimate the difference in rehabilitation times across regional offices 

and groups of veterans with various characteristics, we used different 

statistical models. These “survival modeling” methods allowed us to 

appropriately estimate rehabilitation probabilities at various points in an IL 

plan, even when a significant proportion of the cases are discontinued or 

in progress. Our models used the same VA administrative data noted 

above for veterans in the IL track who began only one IL plan at some 

point during fiscal years 2008 through 2011. Consequently, our model 

results only apply to a subset of veterans, which make up about 95 

 

65 VR&E uses a “case status” approach to track veterans’ movement through its process 

in the CWINRS system. Those veterans who are found eligible for IL benefits enter what 

VR&E refers to as the “IL Status” in the CWINRS system. Veterans officially enter this 

status once an IL plan has been agreed upon and approved by the veteran, counselor, 

and VR&E Officer.
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-13-474 VA Independent Living Services and Supports

percent of the veterans who began in the IL track during this time frame. 

For a detailed discussion of our statistical models, see appendix II.

To obtain information on the types of benefits provided through the IL 

track, as well as the costs and coordination of these benefits, we 

conducted a case file review of a random, generalizable sample of 182 

veterans whose cases started in the IL track at some point during fiscal 

year 2008. To track and manage IL cases, VR&E utilizes both paper 

records located at each regional office, and electronic case records in the 

CWINRS system. For the purpose of our file review, we used veterans’ 

electronic records in CWINRS, and found the information in these records 

to be sufficient for our purpose.66 We selected fiscal year 2008 because it 

allowed us to follow veterans’ progress in the IL track beyond 24 

months—the authorized benefit duration time frame unless a 6-month 

extension is approved.

We stratified our sample of 182 cases into three groups—those veterans’ 

whose cases were (1) rehabilitated, (2) discontinued, or (3) still open.67

We used this approach to obtain information on any differences in IL 

benefits and expenditures by veteran groups. We also elected to use a 

sample design that mixes the features of a proportional allocation and 

equal sample per stratum. Table 3 provides more detailed information on 

our sample stratification.

 

66 We conducted pretests at the Washington, D.C. regional office and at VR&E 

headquarters to compare the information found in veterans’ paper and electronic records. 

We found the electronic case records to be sufficient for our purpose. Certain cost 

information is required to be entered into CWINRS. Nonetheless, we did request a 

physical copy of the closure report for each veteran in our sample. These reports 

summarize veterans’ participation in the IL track.

67 Veterans in the IL track are considered by VR&E to be “rehabilitated” when either all 

goals of the IL plan have been achieved, or if not achieved, when (1) the veteran has 

attained substantial increase in the level of independence, (2) the veteran has maintained 

the increased level of independent for at least 60 days, and (3) further assistance is 

unlikely to significantly increase the veteran’s level of independence. For veterans who are 

unable to successfully complete the IL track, their cases are entered into a “discontinued 

status” where they are closed. Veterans’ cases that are still ongoing are classified as 

open.

Analysis of IL Veteran 

Cases
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-13-474 VA Independent Living Services and Supports

Table 3: Size of Sample of Independent Living Track Cases, by Strata and 

Proportion of Population

Sample strata Number of Cases

Rehabilitated cases 88

Discontinued cases 47

Open cases 47

Total 182

Source: GAO analysis of VA data.

To produce population estimates from our sample of cases, information 

collected from each case reviewed was weighted in the analysis to 

account statistically for the total population of all IL track cases started in 

fiscal year 2008. Because our estimates for the entire population of IL 

track cases that started in fiscal year 2008 are based on a probability 

sample of these cases, they are subject to sampling error. To recognize 

the possibility that other samples drawn from this population might yield 

different results, we express our confidence in the precision of our 

sample’s results as a 95 percent confidence interval. A 95 percent 

confidence interval is expected to include the actual value for the 

population in 95 out of 100 samples drawn from the population. With 

regard to expenditures in IL track cases, at the 95 percent confidence 

interval, the amount of total expenditures across all IL track cases that 

started in fiscal year 2008 falls between $11.3 million and $16.6 million; 

the actual amount expended, on average, in these cases falls between 

$4,835 and $7,104.

To conduct our case file review, we developed a web-based data 

collection instrument to record information from the electronic printouts 

VR&E provided us with of veterans’ records. After these records were 

collected, GAO staff members entered the information into the electronic 

data collection instrument for each veteran case in our sample. Once the 

data was entered, a second GAO staff member reviewed each entry for 

clarity and accuracy. With regard to the types of benefits provided to IL 

track veterans, we cannot generalize the types of goods and services 

provided because we recorded in our data collection instrument 

information on only eight goods and services identified in each of the 182 

IL case files we reviewed. However, we were able to generalize 

information we obtained on IL track service providers from the IL cases 

we reviewed because in less than 3 percent of these cases, there were at 

least eight service providers. Our estimate of the number of cases where 

service provider information was missing, unclear, or overwritten in 
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-13-474 VA Independent Living Services and Supports

CWINRS may be slightly understated. The 95 percent confidence interval 

for the 15 percent of cases where the service provider information was 

unclear or missing for one or more service ranged from 9 to 21 percent. 

The 95 percent confidence interval for the 7 percent of cases we 

reviewed where one or more service was overwritten in CWINRS ranged 

from 4 to 11 percent.

To better understand the extent to which the IL track is being effectively 

administered, we visited five VA regional offices—San Diego, California; 

Atlanta, Georgia; Detroit, Michigan; Philadelphia, Pennsylvania; and the 

District of Columbia.68 We selected these sites because they were 

geographically diverse, and have varying levels of IL track participation 

and success in achieving VR&E’s IL rehabilitation goal. During each of 

our site visits, we interviewed VR&E Officers and vocational rehabilitation 

counselors (VRCs) using a standard set of questions to identify how IL 

cases were managed and any factors that may have affected the 

administration of the IL track. In particular, during our Detroit and Atlanta 

site visits, we interviewed VRCs who specialized in working on IL cases. 

Moreover, we obtained the perspectives of veteran service organizations 

that work with IL track veterans at two regional offices we visited—Detroit 

and Atlanta. Furthermore, we interviewed SAH and PSAS officials at the 

national level and relied on our case file review to determine the extent to 

which the IL track cases were referred to VA and non-VA service 

providers. In addition, we interviewed SAH and PSAS staff during our site 

visits to determine the extent to which VR&E, SAH, and PSAS coordinate 

in the provision of goods and services to IL track veterans.

 

68 VA officials told us that Washington Regional Office, located in the District of Columbia, 

was recently designated the National Capital Region Benefits Office in November 2012. 

For the purpose of our review, we will refer to this office as one of VA’s regional offices. 

Furthermore, our review of IL track administration did not include reviewing the quality of 

internal or external assessments the VR&E program uses to determine the suitability of 

veterans for employment or the extent to which veterans’ activities of daily living may be 

limited.

Regional Site Visits and 

Agency Interviews
Appendix II: Statistical Analysis of 

Independent Living Plan Rehabilitation Times

Page 48 GAO-13-474 VA Independent Living Services and Supports

We used statistical models to estimate the difference in rehabilitation 

times across regional offices and groups of veterans with various 

characteristics. These “survival modeling” methods can appropriately 

estimate rehabilitation probabilities at various points in an IL plan, even 

when a significant proportion of the cases are discontinued or in progress. 

In addition, survival methods allowed us to estimate the unique 

association between rehabilitation times and various other factors, 

described below. In this appendix, we describe the data we used to fit the 

models and their structure, assumptions, and estimates.

We estimated our models using VA administrative data on veterans who 

began exactly one IL plan from fiscal years 2008 through 2011. Due to 

the data reliability issues described in appendix I, our analysis excluded 

veterans who began multiple IL plans during this period. Consequently, 

our results only apply to this subset of 8,737 veterans, who made up 94.8 

percent of the original population.

69 We measured the length of time each veteran spent in his or her IL plan 

as the duration between the start of the plan and one of three later times: 

entering rehabilitation status, discontinuing the plan, or being in progress 

on September 30, 2011, the end of our observation period. We modeled 

rehabilitation as the outcome of interest, treating discontinued or in 

progress plans as having rehabilitation times that were censored. Among 

the veterans starting IL plans from fiscal years 2008 through 2011, 3.2 

percent discontinued their IL plans prior to rehabilitation, and 35.9 percent 

had plans that were in progress on September 30, 2011. These data 

imply that 91.7 percent of the censored observations were in-progress 

cases, which suggests that most of the censoring is likely to be 

uninformative. We found no large differences in the probability of 

dropping out of an IL plan across the covariates we included in our 

models.

 

69 This group also excluded veterans who transferred to a VR&E employment track and 

veterans who had more than one instance of rehabilitation. Missing data on age and 

length of service further reduced our sample size to 8,655 veterans for modeling 

purposes.

Appendix II: Statistical Analysis of 

Independent Living Plan Rehabilitation Times
Appendix II: Statistical Analysis of 

Independent Living Plan Rehabilitation Times

Page 49 GAO-13-474 VA Independent Living Services and Supports

We fit the data to several types of Cox proportional hazards models. The 

primary model took the following form:

λij(t) = λ0j (t) exp(xijβ)

λij(t) denotes the hazard rate of rehabilitation at time t after veteran i 

enters an IL plan, and λ0j (t) denotes the baseline hazard rate for the 

reference veteran with covariates equal to zero, served by one of j = 1, 2, 

... ,36 regional offices. We combined a number of offices that served less 

than 50 veterans into a residual group, in order to ensure sufficient 

sample within each office. The sample sizes within offices ranged from 58 

to 908. xij is a vector of the following covariates: age, length of military 

service, and indicators for sex, branch of service, era of service, 

education, year the IL plan began, partial vs. full disability,70 and disability 

type.71 We coded the covariates such that the baseline reference veteran 

was substantively meaningful—a male Army veteran with a high school 

education, who served in the Vietnam era, entered an IL plan in fiscal 

year 2008, was processed by the Detroit Regional Office, and had a full 

musculoskeletal disability—either by setting values of categorical 

variables to the appropriate levels or by centering continuous variables at 

their means. All categorical variables included levels for missing data.

In this application, the proportional hazard structure of the model implies 

that the instantaneous rate of rehabilitation at any time during an IL plan, 

or the hazard, varies across values of the covariates by a constant 

amount over time. For example, the model assumes that rehabilitation 

rates vary by the same amounts among veterans with different types of 

disabilities after 12 months, 18 months, or any other point in an IL plan. In 

our initial exploratory data analysis, Kaplan-Meier estimates of the hazard 

and survival functions suggested that the hazard was not proportional 

across regional offices. Using an unstratified version of the model above 

that included fixed effects for regional offices, we found that the 

Schoenfeld residuals for many offices were correlated with time at a 

sufficiently high level to reject the hypothesis that the hazard functions 

 

70 We defined partially disabled veterans as those having combined VA disability ratings 

of less than 100 percent. Fully disabled veterans had ratings of 100 percent.

71 We linked each numeric disability code in our sample to one of 16 categories of 

disabilities defined by VA regulations. 

Model Structure and 

Assumptions 
Appendix II: Statistical Analysis of 

Independent Living Plan Rehabilitation Times

Page 50 GAO-13-474 VA Independent Living Services and Supports

were proportional across the covariates (p < .0001).72 These results are 

consistent with our interviews and document reviews suggesting that 

program administration varied across offices, which could produce 

variation in hazard functions. (The body of this report summarizes these 

administrative inconsistencies in more detail.) For these reasons, we 

stratified the baseline hazard function by regional office, and we used this 

version of the model to calculate hazard rate ratios and elasticities, along 

with their standard errors, in table 3. Under the stratified model, we failed 

to reject the proportional hazards assumption for α < .47.

The estimated rehabilitation (failure) probabilities discussed in the body of 

this report came from a version of the model that did not stratify by office 

and, instead, assumed office fixed effects. This allowed us to calculate 

illustrative rehabilitation probabilities by various follow-up points and for 

specific covariate values, without having to produce 36 sets of estimates 

implied by separate hazard functions for each office. The differences in 

the estimated probabilities across covariate values should resemble 

estimates that we would have calculated from the stratified model, 

because estimates of β and their variances were similar in both versions. 

The hazard rate ratios and elasticities in table 3 are consistent with our 

estimated rehabilitation probabilities in the body of the report. To calculate 

these probabilities, we fixed the value of each covariate at its sample 

mode or mean, depending on whether the variable was categorical or 

continuous. For this profile of covariate values, we calculated survival 

probabilities at various times using the estimated parameters of the 

unstratified model, and transformed them to failure probabilities by 

subtracting the survival estimates from 1.

We estimated a final version of the model that used neither office strata 

nor fixed effects. This allowed us to estimate the association between 

office workload, measured by the total number of IL plans developed from 

fiscal year 2008 through 2011, and rehabilitation timeliness. Stratifying 

the model by office or estimating fixed effects would have absorbed the 

variation needed to estimate the coefficient on workload, as an officelevel covariate.

 

72 Schoenfeld residuals measure the difference between each observed covariate value 

for a failure at time t minus the expected value of the covariate. The expected value is 

taken over the probability distribution of failure probabilities at t for units in the risk set.
Appendix II: Statistical Analysis of 

Independent Living Plan Rehabilitation Times

Page 51 GAO-13-474 VA Independent Living Services and Supports

Table 3 provides estimates of β and hazard ratios derived from them, 

along with standard errors and p values for the hypothesis that each ratio 

equals 1. These estimates come from the stratified model above. Figure 

17 presents the failure functions implied by the separate hazard functions 

the model assumes for each regional office. These results are generally 

consistent with those discussed in the body of this report, where we 

interpret the results in more detail.

Table 4: Estimates from Cox Hazard Model of Time Spent in Independent Living Plans, among Veterans Starting a Plan in FY 

2008-2011

Variable

Hazard

ratio

Standard 

error

Pr(Hazard

ratio = 1)

95%

Lower bound

95%

Upper bound

Age (years) 1.0062 0.0022 0.005 1.0019 1.0106

Length of service (years) 1.0066 0.0026 0.012 1.0014 1.0117

Era of service

Vietnam (Reference Group)

Gulf War 1.0375 0.0572 0.505 0.9312 1.1559

Global War on Terror 1.0955 0.0735 0.174 0.9605 1.2495

Korea 1.0179 0.0869 0.835 0.8611 1.2033

Peacetime 0.9689 0.0453 0.499 0.8841 1.0618

World War II 0.8559 0.0956 0.164 0.6876 1.0654

Education

High school (Reference Group)

Less than high school 0.9295 0.0773 0.379 0.7897 1.0940

Some college 0.9772 0.0339 0.507 0.9129 1.0461

College 0.9137 0.0486 0.090 0.8232 1.0142

Graduate 1.1443 0.1224 0.207 0.9280 1.4111

Missing data 1.1732 0.0501 0.000 1.0790 1.2757

Sex 

Male (reference group)

Female 0.9967 0.0527 0.950 0.8985 1.1056

Missing data 0.9292 0.1184 0.565 0.7238 1.1929

Branch of service

Army (reference group)

Results 
Appendix II: Statistical Analysis of 

Independent Living Plan Rehabilitation Times

Page 52 GAO-13-474 VA Independent Living Services and Supports

Variable

Hazard

ratio

Standard 

error

Pr(Hazard

ratio = 1)

95%

Lower bound

95%

Upper bound

Air Force 0.9147 0.0410 0.047 0.8377 0.9987

Coast Guard / other 1.0007 0.1173 0.995 0.7953 1.2591

Marines 1.0362 0.0463 0.425 0.9494 1.1311

Navy 0.9655 0.0400 0.397 0.8902 1.0472

Year entered IL plan

2008 (reference group)

2009 0.8910 0.0312 0.001 0.8319 0.9543

2010 0.7850 0.0306 0.000 0.7272 0.8473

2011 0.7782 0.0485 0.000 0.6887 0.8793

Severity of disability

Combined rating of 100 (reference group)

Combined rating less than 100 1.0948 0.0342 0.004 1.0299 1.1638

PT/missing data 0.7947 0.0806 0.023 0.6515 0.9694

Type of disability

Dental and oral conditions 1.0424 0.0999 0.665 0.8638 1.2578

Gynecological conditions and Disorders of the 

breast

0.9499 0.0883 0.580 0.7916 1.1397

Infectious diseases, immune Disorders and 

nutritional Deficiencies

0.9610 0.0792 0.629 0.8177 1.1294

Muscle injuries 1.0206 0.0666 0.755 0.8981 1.1598

Neurological conditions and Convulsive 

disorders

0.9767 0.0375 0.540 0.9059 1.0531

Other sense organs 0.8735 0.2290 0.606 0.5225 1.4602

The cardiovascular system 0.9355 0.0343 0.069 0.8705 1.0053

The digestive system 0.9368 0.0352 0.083 0.8702 1.0085

The ear 1.0109 0.0334 0.742 0.9475 1.0786

The endocrine system 1.1015 0.0447 0.017 1.0173 1.1926

The eye 0.9667 0.0495 0.509 0.8745 1.0688

The genitourinary system 0.9612 0.0362 0.294 0.8928 1.0349

The hemic and lymphatic systems 1.1455 0.1385 0.261 0.9038 1.4518

The musculoskeletal system 0.9498 0.0310 0.115 0.8909 1.0126

The respiratory system 0.9973 0.0427 0.950 0.9171 1.0845

The skin 0.9840 0.0314 0.612 0.9243 1.0474

VA regional office strata included

Source: GAO statistical analysis of VA administrative data.
Appendix II: Statistical Analysis of 

Independent Living Plan Rehabilitation Times

Page 53 GAO-13-474 VA Independent Living Services and Supports

Note: N = 8,655, with 5,252 failures. Estimates of “hazard ratios” are exponentiated coefficients from 

a Cox hazard model, with reference groups as indicated. For the continuous covariates, age and 

length of service, the entries imply elasticities. For the disability type covariates, the entries represent 

the proportional change in the hazard of completing an IL plan for a veteran who has the listed 

disability, compared to a veteran who does not have the disability. (The disability types are not 

mutually exclusive and exhaustive groups, because veterans can have more than one type of 

disability.)
Appendix II: Statistical Analysis of 

Independent Living Plan Rehabilitation Times

Page 54 GAO-13-474 VA Independent Living Services and Supports

Figure 17: Multivariate Failure Function Estimates from a Cox Hazard Model of Time Spent in Independent Living Plans, FY 

2008-2011

Note: We did not estimate the probability of a veteran being rehabilitated at regional offices where 

fewer than 50 veterans began IL plans during fiscal years 2008 through 2011.
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 55 GAO-13-474 VA Independent Living Services and Supports

The table below lists the goods and services as they were recorded in the 

182 cases we reviewed in the CWINRS system. 

Goods and Services Provided Frequency

Counseling Services

“(1) Specialized Contractial Counseling Services 637” 5 

“(1) Specialized Contractual Counseling” 1 

“(1) Specialized Contractual Counseling Services 637, Vocational, Educational, Psychological or Personal adjustment 

counseling which I” 

3 

“(1) Specialized Independent Living Services 638” 1 

“(1) Specialized Rehabilitation Service 631” 9 

“(1) Specialized Rehabilitation Services” 6 

“(1) Specialized Rehabilitation Services 631, Specialized services involving unique skills and techniques, such as 

learning di” 

3 

“(1) Specialized contractual counseling services 637; IILP Initial Assessment” 1 

“(1)Special contractual Counseling” 1 

“(316) Contract Counseling Assistance 451” 1 

“(339) Special Services 532” 1 

“(343) Rehab SErvices 556” 13

“(343) Rehab Services” 1 

“(343) Rehab Services 556, All services not otherwise described to advance the objectives of the rehabilita” 9 

“(343) Rehab Services 556; Connections Vocational Services; IILP Evals; All service not otherwise described to 

advance the objectives of the rehabilita” 

2 

“(372) Independent Living Services 644, Provide Independent Living services (i.e. IL Evaluation, Occupational Therapy 

Ev” 

1 

“(372) Psychotherapy 667; provide psychotherapy and adjustment counseling” 4 

“Adjustment Counseling 113” 1 

“Rehab Services” 5 

“Rehabilitation Counseling Services 158, Specialized counseling services as required to assist and support veteran in 

ful” 

1 

“SRS/IL Special Rehab Service/Independen Li” 29

“SRS/V Special Rehab Service/Vocaational; Center for Independent Living; IL Case Mgmt” 1 

“SRS/V Special Rehab Service/Vocational” 31

“Special Rehab Service/Independent Living” 7 

“Special Rehab. Srvs/Indepen. Living 24” 1 

“Special Services.” 1 

“Special rehab service/Independent Living” 1 

“Specialized Counseling Services 176” 1 

Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 56 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

Medical Care and Health Related Services

“Cora Coleman Senior Center; 9 month swim membership” 1 

“Dr. Sandoval; Eye exam” 1 

“Exercise gym membership” 1 

“Express Healthcare” 1 

“Gym Membership- 6 Months” 1 

“Medical ID bracelet purchase and delivery” 1 

“Medical care; SRS/M Special Rehab Services/Medical” 1 

“Medical, Dental, Vision / Related Services 169, Comprehensive evaluation of medical, dental, or vision difficulties and 

provisio” 

3 

“Milwaukee VA Medical Center” 2 

“Personal Trainig Session-Master Level” 1 

“Personal Training - 24 Sessions” 1 

“Providence; yoga membership fees - initial” 1 

“Senior gym membership, and seniro swim membership” 1 

“SRS/M Special Rehab Service/Medical” 40

“The Providence Institute; yoga class” 1 

“VA MEDICAL CENTER - ANN ARBOR” 1 

“VA Medical Center - Detroit” 2 

“VA Outpatient Clinic - Mare Island” 1 

“VAMC—Westside” 1 

“YMCA East Belleville Center; YMCA Membership; YMCA annual fee” 1 

“YMCA Memebership” 1 

“yoga classes” 1 

Residential Adaption and Repair

“(317) Independent Living Residence Adaptation 645” 2 

“(317) Independent Living Residence Adaptation 645, Residential adaptations to allow a veteran to complete ILP.” 1 

“A&E services for home modification per ILP” 1 

“Basic construction as approved on IL plan” 1 

“Ch 31 One Time Miscellaneous Items Purchase—Reconstruction of front porch per IL plan” 1 

“Gould’s Discount Medical — Home Improvements” 1 

“Herrera Engineering; house modifications; special contractual services” 1 

“Home Mod Eval” 1 

“Home Reab Equipment — Supply and set up bath mods (up)” 1 

“Home Rehab Equipment — custom railing” 1 

“Home modification: Railing for steps” 1 
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 57 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

“Home safety evaluation” 1 

“Kohler & Lentz Construction; Home modifications for IL case” 1 

“Labor for installing shower grab bar and locksets” 1 

“Lumber for ramp construction” 1 

“Mobile Home Stuff Store, Inc; Plumbing repairs: complete water supply replumbing” 1 

“Plans for modification” 1 

“Provide & install toilet area grab bars w/fasteners” 1 

“Provide and insall shower grab bar w/fasteners” 1 

“Stair railing” 1 

“Veterans Assistance Network; wood handrails; 18 in grab bars; installation grab bar” 1 

“buyrailings.com; stair railing w/brackets” 1 

“ramp installation” 1 

“set up and instruct on stair glides” 1 

set up and supply bath mods 1 

“threshold Ramp” 1 

“scaffolding” 1 

“smoke detectors/fire extinguisher/co2 detector” 1 

Education and Training

“Computer Instruction 13” 1 

“Driving Lessons” 1 

IHL Institute of Higher Learning 1 

“IHL Institutions of Higher Learning” 38

“IHL Institutions of Higher Learning – for period 2/5/08-7/23/08” 1 

“IHL Institutions of Higher Learning; 24 training session” 1 

“IHL Institutions of Higher Learning (College books)” 1 

“IHL Institutions of Higher Learning; Central Community College-Hastings Degree” 1 

“Individual/Independent Instruction / Trg 164” 1 

Jewish Vocational Services; non college degree 4 

“Kendall & Davis, Inc.; computer training” 1 

“Mastering MS Office Made Easy (CD-ROM version)” 1 

“NCD Non-College Degree” 10

“OJT On the Job Training/Apprenticeship” 5 

“PC Training 02/08-04/08” 1 

“Solano County Community College” 1 

“Training” 2 

“Tutorial services 182” 1 
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 58 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

“University of Alaska, Fall Term” 2 

“Computer Instruction 13” 1 

“Computer Training 11/8/07-2/1/08” 1 

computer training 8 

“1-year audio book subscription (2 CDs/month)” 1 

“2 computer innstruction books” 1 

Assistive Devices and Technology

“Adapter” 1 

“Adapter/converter” 1 

“All Temperature system; IL- Heating System” 1 

“Amplified phone with 911 pendent” 1 

“Audio Equipment and Software” 1 

“CPI*Contour living web; wedge cushions/with massage; shipping charge” 1 

“Cap Tel phone for hearing impaired” 1 

“Ch 31 non-Contractual Speicial . . . \r\n” 1 

Computer Evaluation Services 21, Technical evaluation for computer hardware and software needs. 2 

“Computer installation” 1 

“Computer repair” 1 

“Exercycle” 1 

“Forced Heater” 1 

“GPS System” 1 

“Installation of Camera Security System” 1 

“KID 1240 talking dictionary with headphones” 1 

“Kendall & Davis; notebook computer” 1 

“King size adjustable bed with massage” 1 

“Lift chair with heat and massage” 1 

“Metal Detection Club Mem. 1 yr,” 1 

“Pride GL 358M lift chair w/set up and delivery” 1 

“Quick 2008 software” 1 

“Security system per IILP” 1 

“Sleep number bed w/ frame” 1 

“Solutions4Sure - HP IPAQ” 1 

“Spinlife - hoyer hyrdaulic patient lifter” 1 

“Sports authority; Treadmill, delivery & assembly, 4 yr warranty” 1 

“Surge protector” 1 

“True Freedom Mobility; Lift chair” 1 
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 59 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

“US Computers Inc; Shipping/handling fees for computer and furnitures” 1 

“Washer” 1 

“Wireless router” 1 

“day Timer Smartech” 1 

“massagin seat cushion” 1 

“set and instruct on 4 wheel scooter” 1 

“set and instruct on scooter lift with swing arm.” 1 

“set and instruction for lift chair.” 1 

“speakers” 1 

“washer/dryer” 1 

“Electric Jar Opener” 1 

Adaptive Equipment

“All in one accessibility - adaptive equipment” 1 

“24-Inch Grab Bar for Commode” 1 

“ALI*AMIMED INC.; Backrest air obusforme grey; shipping charge” 1 

“Alex Orthopedic; Walking Cane; Shipping charge” 1 

“Appointment book” 1 

“Automobile seat cushion” 1 

“Big-Handle Cup” 1 

“Bowl, blue” 1 

“COLDERS, INC.; Bed & Chair - Independent Living” 1 

“Chair” 2 

“Colder’s; TempurPedic King Size Solution Mattress and Box Sp; HTC-1650 Massage Chair” 1 

“Computer chair” 1 

“Deluxe swivel seat cushion, UpEasy lifting cushion seat assist (plus shipping)” 1 

“Dry Erase Board & Calendar” 1 

“E-Pill 7-day organizer/reminder sys” 1 

“Elastic Shoelaces” 1 

“Ergonomic Office & Shop Stool” 1 

“Eyemasters; eye glasses” 1 

“Frame, Lenses” 1 

“Gallon Tipper” 1 

“Glide rail & shower wand,PT-WR28R,LABOR” 1 

“Grab bar specialists, Inc.; handi-grip portable grab bar and shipping” 1 

“Handicap aid equipment” 1 

“IL Adaptive Equipment \r\nCh 31 Special Equipment” 1 
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 60 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

“IL Adaptive equipment, Shipping and Handling\r\nCh 31 Special Equipment” 1 

“Kitchen Cart w/3 Shelves and Casters” 1 

“Lamp for independent living and surge protector” 1 

“MAXIAUDS; CO2 Alarm; shiping charge” 1 

“Medication dispenser, phone, printer, mouse” 1 

“Mother Earth Design INC.; Trigger point pillow; shipping charge” 1 

“Office furniture” 1 

“Ontime supplies; ergonomic chair, dry erase board” 1 

“Organizing service” 1 

“Perching Stool, Height Adjustable, 250lb Capacity” 1 

“Pill Container AM PM” 1 

“Pill box with alarm, grab bars” 1 

“Portable Lift Cushion, 250 1b Capacity” 1 

“ProMED; Tempurpedic bed” 1 

“ProMed; Long-handled bath brush” 1 

“Queen Matt, Box, Tempura Symphony pillow” 1 

“Queen mattress” 1 

“Rehab Engineering Inc.; Large Handle cups; walker, 3-inch wheels, 300lbs. capacity; 24-inch grab bar, inside tub” 1 

“Rolling laundry cart & ergonomic grabber” 1 

“SENIORSHOPS.COM; Safety bed rail” 1 

“Sit/Stand Stool” 1 

“Sliding Shelves (for Bathroom Cabinet)” 1 

“Small Stool” 1 

“Sock/Stocking Aid” 1 

“Special equipment — one-handed jar opener, suction cup plates, suction cup bowls” 1 

“Stocking Aid w/Loops” 1 

“Stool” 1 

“Trio Jar and Bottle Opener” 1 

“Tub safety bar and lever door handles (QTY 6)” 1 

“Universal Opener” 1 

“Vocational Resource Services; good grips eating utensils; sock assist; elastic shoelaces” 1 

“Vocational Resource Services; locking elevated toilet seat w/ arms; special equipment” 1 

“Walker Furniture; mattress, frame and bed cover” 1 

“adaptive aids” 1 

“computer desk” 1 

“desk and chair” 1 
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 61 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

“desk chair” 1 

“grab bar” 1 

“laundry cart” 1 

“non Skid Mat” 1 

“rolling stool with s/h” 1 

“set up and instruct for K adj bed.” 1 

sock aid 1 

“www.themedicalclub.com; HC-SP-S 1119 Super pole and shipping” 1 

Computer and Camera Equipment

“Adaptive computer system” 1 

“Adobe Photoshop” 1 

“Camera, case, warranty, & Adobe Elements” 1 

“Camera, fash card, carea kit” 1 

“Camera, memory card” 1 

“Camera/Peripherals” 1 

“Carrying case (for laptop) & surge protector” 1 

“Computer” 1 

“Computer & peripherals” 1 

“Computer ILLP” 2 

“Computer Masters; Computer System (IL)” 1 

“Computer Set up-Intenet” 1 

“Computer System, desk & chair” 1 

“Computer and printer and accessories” 1 

“Computer hardware/software and computer desk/chair” 1 

“Computer speakers” 1 

“Computer system with 19 inch moniter, printer software” 1 

“Computer, Printer, Monitor, and Web Cam” 1 

“Computer, flash, microsoft office pro 07” 1 

“Computer/Printer/Accessories/Recliner/Computer cha” 1 

“Computer/Printer/Peripherals” 3 

“Dell - desktop, surge protector, and printer” 1 

“Dell Desk top computer” 1 

“Dell Laptop computer package” 1 

“Dell all in one printer” 1 

“Dell computer, Printer, surge protector” 1 

“Dell; monitor and desktop” 1 
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 62 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

“Desktop computer system” 1 

“Digital Camera” 1 

“Epson Photo inkjet printer” 1 

“Flash Drive” 2 

“IILP - Computer equipment” 1 

“IILP - Digital Photography Equipment” 1 

“Internet Service” 1 

“Internet fees and wireless card” 1 

“Journey Ed; PhotShop CS4” 1 

“Laptop and Accessories” 1 

“Laptop computer” 1 

“Laptop computer system, 3-year warranty” 1 

“Laptop, case,surge prot, flash drive” 1 

“MS Office Home and Student 2007” 1 

“Microsoft Office Proffessional Upgrade Software” 1 

“Milwaukee PC - 75; Laptop computer system” 1 

“Nikon Coolpix Digital Camera” 1 

“Nikon Speedlight Flash for digital camera” 1 

“Norton AntiVirus 2008” 1 

“Office Depot; PC” 1 

“PC” 1 

“Printer” 1 

“Staples; computer and accessories” 1 

“Staples; computer assories” 1 

“Toshiba laptop computer system” 1 

“US Computers Inc; desktop computer system; monitor 19 in LCD; HP printer all-in-one” 1 

“Video Camcorder kit” 1 

“XPS One, Red—Dell Desk Top computer” 1 

“adapted computer” 1 

“all in one printer” 1 

“cable for computer purchased” 1 

“computer” 4 

“computer printer/cables” 1 

“computer w/19 inch monitor, 4n1 printer + internet” 1 

“computer, printer” 1 

“computer, printer, associated supplies” 1 
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 63 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

“desktop computer system” 1 

“digital camera, case, warranty” 1 

“laptop computer and printer” 1 

“laptop printer” 1 

“monitor, camera, headset” 1 

“printer, cable, delivery” 1 

“quicken and mavis” 1 

“software-printer” 1 

“usb cable and ink” 1 

Avocational/Leisure Equipment

“Elite Duo 1500 Workbench and excess weight charge” 1 

“Windward boats; glasspro boat, motor, trailer” 1 

“10” table saw, delivery” 1 

“12 inch dualbevel slide mitersaw 77-141-614 Bosc” 1 

“2hp soft start fixed and plunge base router” 1 

“6 Tool Cordless Combo Kit” 1 

“Craftsman 10 inch table saw” 1 

“Craftsman fixed base router/table combo” 1 

“Embroidery Machine & Accessories, Classes” 1 

“Jarvi Facetron; Facitron Machine with grit; shipping” 1 

“Music Production Equipment” 2 

“Rikon 18 inch bandsaw, excess weight charge” 1 

“Rikon 6 inch jointer” 1 

“Searrs; rts bit saw nailer plnr sander warrenties” 1 

“Sears; router and table and warrenty” 1 

“Shopsmith Mark V” 1 

“Tracrac T3B portable miter saw sta Bosch” 1 

“drill press, protection agreement, shipping” 1 

“The Rock Shed; Thumlers tumbler; 5lbs 60/90 grit; 5lbs 120/220 grit” 1 

“(IL books) Audio Books” 1 

“8 Spools of Thread” 1 

“Accessory Kit, Bench Clamp and shipping for workbench” 1 

“Bagpipe Accessories” 1 

“Bagpipe Uniform & Accessories” 1 

“Blick Art - acrylic paint and supplies” 1 

“Bosch Tool Kit” 1 
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 64 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

“Cookbooks” 1 

“Fishing equipment” 1 

“Metal detector items” 1 

“Models” 1 

“Silversmithing and Engraving Tools/Equipment” 1 

“Trailer hitch” 1 

“Vibration reduction lens” 1 

“Walmart; camping equipment” 1 

“car rack” 1 

Other Goods and Services

“Ch 31 Books” 1 

“Supplies” 1 

“(1) Specialized Equipment Acquisition 589” 1 

“3 year extended laptop warranty” 1 

“3-month membership, Dickinson Parks & Recreation” 1 

“3-month membership, West River Community Center” 1 

Abilities Group 2 

“Assistive Technological Services 599” 2 

“Center for Independent Living” 2 

“Club T.E.A.M “ 1 

“Delivery” 1 

“Downing Properties LLC “ 1 

“Equipment and Installtion Fee” 1 

“Equipment for IL” 1 

“IL Equipment” 1 

“IL Supplies, Shipping and Handling\r\nCh 31 Special Equipment” 1 

“IL equipment & ship” 1 

“Installation ILLP” 1 

“Maids PO#Julia 300; Tub rails; shipping charge” 1 

“Membership” 1 

“Merry Maids; maid services; fee, intial; Refrigerator cleaning” 1 

“PROMED; IL Purchases” 1 

“ProMED; IL Equipment” 1 

“Service Charge” 1 

“Set-up and Shipping (for exercycle)” 1 

“Shipping and Handling” 1 
Appendix III: List of Goods and Services 

Provided to Sample of Independent Living 

Track Veterans from our Case File Review

Page 65 GAO-13-474 VA Independent Living Services and Supports

Goods and Services Provided Frequency

“Shipping/delivery charges for CD-ROM” 1 

“Independence Inc.” 1 

“VR&E/28 “ 1 

“Voc Rehab Panel, PO 348-08-039 dtd 7/23/08” 1 

“Ship Boat to Molokai” 1 

“warranty” 1 

“Cub Cadet Bagger” 1 

“Ariens Snowblower” 1 

“Cub Cadet Riding Lawn Mower” 1 

“McGavic Outdoot power equipment; lawn tractor and delivery” 1 

“lawn tractor” 1 

“one snowblower” 1 

Source: GAO analysis of 182 case files of veterans entering the IL track during fiscal year 2008.
Appendix IV: Rehabilitation Rates by Regional 

Office, FY 2008 Independent Living Track 

Entrants

Page 66 GAO-13-474 VA Independent Living Services and Supports

 Entrants with

One IL Plan

Transfers to a VR&E 

Employment Track Rehabilitated Discontinued Open

Rehabilitation 

Rate

National 2274 34 1987 122 131 89%

Muskogee 35 0 35 0 0 100%

Reno 13 1 12 0 0 100%

Togus 9 0 9 0 0 100%

Huntington 5 1 4 0 0 100%

Boise 4 0 4 0 0 100%

Wichita 3 1 2 0 0 100%

Roanoke 2 0 2 0 0 100%

Pittsburgh 2 0 2 0 0 100%

San Juan 2 0 2 0 0 100%

Manchester 2 0 2 0 0 100%

Montgomery 202 2 198 1 1 99%

Hartford 77 2 74 1 0 99%

Louisville 64 1 62 0 1 98%

Newark 59 0 58 0 1 98%

Atlanta 119 0 114 3 2 96%

Phoenix 141 0 135 6 0 96%

San Diego 41 1 38 1 1 95%

Nashville 18 0 17 0 1 94%

Denver 66 a 0 62 3 1 94%

New York 161 1 149 10 1 93%

Waco 69 0 64 2 3 93%

Philadelphia 26 0 24 1 1 92%

Honolulu 37 0 34 3 0 92%

Milwaukee 20 0 18 1 1 90%

Seattle 29 1 25 3 0 89%

Salt Lake City 27 0 24 1 2 89%

Columbia 26 0 23 0 3 88%

Detroit 131 3 113 7 8 88%

Houston 73 1 63 8 1 88%

Oakland 163 5 138 12 8 87%

Albuquerque 88 0 76 11 1 86%

Winston-Salem 22 0 19 2 1 86%

St. Paul 7 0 6 1 1 86%

Baltimore 7 0 6 0 0 86%

Appendix IV: Rehabilitation Rates by 

Regional Office, FY 2008 Independent Living 

Track Entrants 
Appendix IV: Rehabilitation Rates by Regional 

Office, FY 2008 Independent Living Track 

Entrants

Page 67 GAO-13-474 VA Independent Living Services and Supports

 Entrants with

One IL Plan

Transfers to a VR&E 

Employment Track Rehabilitated Discontinued Open

Rehabilitation 

Rate

Indianapolis 79 4 64 4 7 85%

St. Louis 24 1 19 2 2 83%

Buffalo 20 0 16 0 4 80%

Portland 20 1 15 2 2 79%

St. Petersburg 116 1 90 4 21 78%

Sioux Falls 9 0 7 0 2 78%

Fort Harrison 4 0 3 1 0 75%

Boston 4 0 3 1 0 75%

Los Angeles 97 5 67 9 16 73%

Providence 18 0 13 1 4 72%

Jackson 7 0 5 1 1 71%

Anchorage 7 1 4 0 2 67%

Little Rock 26 1 16 4 5 64%

Lincoln 16 0 10 4 2 63%

Fargo 8 0 5 2 1 63%

Des Moines 21 0 13 2 6 62%

New Orleans 7 0 4 1 2 57%

Chicago 4 0 2 2 0 50%

Cleveland 35 0 17 4 14 49%

Washington 2 b 0 0 1 1 0%

White River 

Junction

0 0 0 0 0 n.a.

Wilmington 0 0 0 0 0 n.a.

Source: GAO analysis of VA data.

a The Denver Regional Office includes totals for the Cheyenne, Wyoming office. This office is 

considered a satellite office of Denver.

b

Note: This table represents those veterans with only one IL plan who entered the IL track in fiscal 

year 2008 and who were rehabilitated by the end of fiscal year 2011. We calculated the IL 

rehabilitation rate using open IL cases, as well as those cases that were closed by VR&E as 

“rehabilitated” or “discontinued.” We did not include IL track veterans who were transferred to another 

VR&E employment track. VR&E calculates the IL rehabilitation rate using only closed cases.

The Washington Regional Office, located in the District of Columbia, was renamed the National 

Capital Region Benefits Office in November 2012.
Appendix V: Days to Complete Independent 

Living Plans, Veterans Entering the 

Independent Living Track During FY 2008

Page 68 GAO-13-474 VA Independent Living Services and Supports

Regional Office

Number of veterans 

completing their IL plan Minimum Mean Median Maximum

Roanoke 2 888 895 895 906

Buffalo 16 263 676 771 1,151

Des Moines 13 142 621 657 1,147

Chicago 2 413 621 621 829

Denver 62 a 0 581 628 931

Sioux Falls 7 183 581 449 1,026

New Orleans 4 168 581 614 924

Los Angeles 67 110 577 566 1,289

St. Petersburg 90 102 552 522 1,121

Seattle 25 150 548 533 1,180

Jackson 5 278 533 405 913

Portland 15 194 526 511 1,209

Cleveland 17 0 515 343 1,154

San Juan 2 343 500 500 657

Togus 9 223 486 310 1,114

Columbia 23 110 482 321 1,172

Honolulu 34 18 457 508 1,052

Oakland 138 55 453 457 917

Detroit 113 0 446 416 975

Indianapolis 64 4 446 416 1,304

Lincoln 10 0 446 555 793

Anchorage 4 131 442 497 646

Milwaukee 18 66 431 398 909

Houston 63 22 420 358 1,129

Boise 4 66 409 274 1,030

Providence 13 4 398 303 986

Philadelphia 24 4 380 387 796

Salt Lake City 24 7 380 325 906

Muskogee 35 40 369 292 1,085

Fargo 5 0 369 321 738

Nashville 17 128 365 321 836

Winston-Salem 19 0 362 300 1,264

Manchester 2 340 362 362 387

Baltimore 6 0 358 435 771

Wichita 2 124 358 358 592

Appendix V: Days to Complete Independent 

Living Plans, Veterans Entering the 

Independent Living Track During FY 2008
Appendix V: Days to Complete Independent 

Living Plans, Veterans Entering the 

Independent Living Track During FY 2008

Page 69 GAO-13-474 VA Independent Living Services and Supports

Regional Office

Number of veterans 

completing their IL plan Minimum Mean Median Maximum

Atlanta 114 69 351 292 1,103

New York 149 22 340 336 942

Hartford 74 0 329 307 836

Little Rock 16 80 325 208 763

Pittsburgh 2 215 318 318 416

Albuquerque 76 37 310 270 891

Waco 64 84 310 256 1,249

Fort Harrison 3 194 310 292 446

San Diego 38 153 307 292 544

Newark 58 26 300 248 829

Louisville 62 44 296 219 891

St. Louis 19 55 296 172 1,147

Phoenix 135 51 289 252 731

Huntington 4 47 267 270 475

Montgomery 198 44 234 208 1,085

Boston 3 91 226 278 307

Reno 12 80 205 186 446

St. Paul 6 0 150 99 329

Source: GAO analysis of VA data.

a 

Note: This table represents those veterans with only one IL plan who entered the IL track during fiscal 

year 2008 and were rehabilitated by the end of fiscal year 2011. The White River Junction and 

Wilmington regional offices had no IL track entrants during fiscal year 2008. The Washington 

Regional Office, renamed the National Capital Region Benefits Office in November 2012, had two 

entrants during fiscal year 2008, but neither were rehabilitated by the end of fiscal year 2011.

The Denver Regional Office includes totals for the Cheyenne, Wyoming office. This office is 

considered a satellite office of Denver.
Appendix VI: Independent Living Track 

Caseload Nationwide and by Regional Office, 

FY 2008-2011

Page 70 GAO-13-474 VA Independent Living Services and Supports

Number of Veterans Who Entered the IL Track by Region Office, FY 2008-2011

Overall IL Entrant 

Count 2008-2011 2008 2009 2010 2011

NATIONAL 9215 2465 2260 2209 2281

Montgomery 908 215 264 189 240

Detroit 709 148 172 202 187

New York 702 178 177 179 168

Atlanta 627 128 99 204 196

St. Petersburg 523 121 104 146 152

Houston 471 82 138 113 138

Oakland 462 181 118 86 77

Phoenix 440 147 114 93 86

Indianapolis 360 93 71 116 80

Waco 264 74 61 52 77

Newark 259 68 62 68 61

Los Angeles 251 101 72 41 37

Hartford 231 82 56 53 40

Albuquerque 221 95 47 32 47

Cleveland 181 36 55 25 65

St. Louis 166 27 40 41 58

Louisville 164 66 50 32 16

Buffalo 154 24 25 54 51

Denver 146 a 68 25 37 16

San Diego 144 41 47 25 31

Columbia 126 27 32 34 33

Muskogee 118 35 17 29 37

Des Moines 97 25 42 10 20

Honolulu 93 38 13 24 18

Reno 89 13 7 32 37

Jackson 85 7 27 27 24

Philadelphia 82 28 21 15 18

Little Rock 80 33 15 20 12

Seattle 79 30 25 10 14

Nashville 78 20 17 20 21

New Orleans 74 10 12 15 37

Winston-Salem 66 25 18 13 10

Salt Lake City 63 28 16 14 5 

Appendix VI: Independent Living Track 

Caseload Nationwide and by Regional Office, 

FY 2008-2011
Appendix VI: Independent Living Track 

Caseload Nationwide and by Regional Office, 

FY 2008-2011

Page 71 GAO-13-474 VA Independent Living Services and Supports

Number of Veterans Who Entered the IL Track by Region Office, FY 2008-2011

 Overall IL Entrant 

Count 2008-2011 2008 2009 2010 2011

Huntington 58 6 8 20 24

Togus 58 9 19 10 20

Providence 58 19 16 17 6 

Lincoln 58 18 35 5 0 

Portland 56 22 10 7 17

Sioux Falls 46 11 22 6 7 

Fargo 45 8 19 11 7 

Baltimore 41 7 14 14 6 

Milwaukee 38 20 6 6 6 

St. Paul 31 9 12 7 3 

Chicago 26 7 10 4 5 

Fort Harrison 25 4 9 3 9 

Roanoke 25 2 4 10 9 

Boise 24 4 2 14 4 

Pittsburgh 22 2 3 4 13

Washington 22 b 4 2 4 12

Wichita 18 3 0 4 11

Anchorage 12 8 1 1 2 

White River Junction 11 0 3 5 3 

San Juan 9 2 0 3 4 

Boston 8 4 3 1 0 

Manchester 7 2 2 1 2 

Wilmington 4 0 1 1 2 

Source: GAO’s analysis of VA administrative data.

a 

b

The Washington Regional Office, located in the District of Columbia, was renamed the National 

Capital Region Benefits Office in November 2012.

The IL entrant total for the Denver Regional Office includes the total number of veterans who 

entered the Cheyenne, Wyoming, office. This office is considered a satellite office of Denver.
Appendix VII: Comments from the Department 

of Veteran Affairs

Page 72 GAO-13-474 VA Independent Living Services and Supports

Appendix VII: Comments from the 

Department of Veteran Affairs
Appendix VII: Comments from the Department 

of Veteran Affairs

Page 73 GAO-13-474 VA Independent Living Services and Supports
Appendix VII: Comments from the Department 

of Veteran Affairs

Page 74 GAO-13-474 VA Independent Living Services and Supports
Appendix VII: Comments from the Department 

of Veteran Affairs

Page 75 GAO-13-474 VA Independent Living Services and Supports
Appendix VIII: GAO Contacts and Staff 

Acknowledgments

Page 76 GAO-13-474 VA Independent Living Services and Supports

Daniel Bertoni, (202) 512-7215 or bertonid@gao.gov. 

In addition to the contact listed above, individuals making key 

contributions to this report were Clarita Mrena (Assistant Director), James 

Bennett, Melinda Bowman, David Chrisinger, Mary Ann Curran, David 

Forgosh, Danielle Giese, Angela Jacobs, Mitch Karpman, John Lack, 

Kirsten B. Lauber, Karen O’Conor, James Rebbe, Martin Scire, Almeta 

Spencer, Jeff Tessin, Jack Warner, and Ashanta Williams.

Appendix VIII: GAO Contacts and Staff 

Acknowledgments 

Contact 

Acknowledgments 
Related GAO Products

Page 77 GAO-13-474 VA Independent Living Services and Supports

Veterans’ Employment and Training: Better Targeting, Coordinating, and 

Reporting Needed to Enhance Program Effectiveness. GAO-13-29. 

Washington, D.C.: December 13, 2012.

VA Health Care: Spending for and Provision of Prosthetic Items. 

GAO-10-935. Washington, D.C.: September 30, 2010.

Veteran Affairs: Opportunities Exist to Improve Potential Recipients’ 

Awareness of the Temporary Residential Adaption Grant. GAO-10-786. 

Washington, D.C.: July 15, 2010.

Veterans Affairs: Implementation of Temporary Residence Adaptation 

Grants. GAO-09-637R. Washington, D.C.: June 15, 2009.

Federal Information System Controls Audit Manual (FISCAM). 

GAO-09-232G. Washington, D.C.: February 2009.

VA Vocational Rehabilitation and Employment: Better Incentives, 

Workforce Planning, and Performance Reporting Could Improve 

Program. GAO-09-34. Washington, D.C.: January 26, 2009.

VA Vocational Rehabilitation and Employment: Service Contract 

Management Is Improving, but Challenges Remain. GAO-07-568R. 

Washington, D.C.: April 23, 2007.

Managerial Cost Accounting Practices: Leadership and Internal Controls 

Are Key to Successful Implementation. GAO-05-1013R. Washington, 

D.C.: September 2, 2005.

VA Vocational Rehabilitation and Employment Program: GAO Comments 

on Key Task Force Findings and Recommendations. GAO-04-853. 

Washington, D.C.: June 15, 2004.

Internal Controls Management and Evaluation Tool. GAO-01-1008G. 

Washington, D.C.: August 2001.

Managing For Results: Barriers to Interagency Coordination. 

GAO/GGD-00-106. Washington, D.C.: March 29, 2000.

Standards for Internal Control in the Federal Government. 

GAO/AIMD-00-21.3.1. Washington, D.C.: November 1999.

Related GAO Products

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