Veterans' Disability Benefits: VA Can Improve Its Procedures for Obtaining Military Service Records
Published: 2006-12-12T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Ranking Democratic Member, House Committee on Veterans' Affairs, asked GAO to determine (1) whether VA's internal assessments indicate its regional offices are complying with the requirements of the Veterans Claims Assistance Act (VCAA) of 2000 for obtaining military service records for veterans' disability compensation claims and (2) whether VBA could improve its procedures for obtaining military service records for claims involving post-traumatic stress disorder (PTSD).
section_title: What GAO Found
paragraphs: The Department of Veterans Affairs' (VA) internal assessments indicate its regional offices generally comply with VCAA's requirements for obtaining military service records for veterans' compensation claims. For example, of the decisions made by regional offices on compensation claims during the first half of fiscal year 2006, Veterans Benefits Administration (VBA) quality reviewers found that less than 4 percent contained errors involving failure to obtain military service records. Similarly, of the appealed compensation cases decided by the Board of Veterans' Appeals during November 2004-January 2006, the board remanded less than 3 percent to VBA for rework due to deficiencies in obtaining military service records. However, VBA does not systematically evaluate the quality of research done on behalf of regional offices by a VBA unit at the National Personnel Records Center, where the service records of many veterans are stored. Regional offices rely on this unit to do thorough and reliable searches and analyses of records and provide accurate reports on the results. Without a systematic program for assessing the quality of this unit's work, VBA does not know the extent to which the information that this unit provides to regional offices is reliable and accurate. VBA potentially could improve its procedures and reduce the time required to process some veterans' claims for PTSD, which may result after a veteran participates in, or is exposed to, stressful events or experiences (stressors). Regional offices sometimes must turn to information contained in the military historical records of the Department of Defense (DOD) to verify the occurrence of claimed stressors. While regional offices are able to directly access and search an electronic library of such records for many Marine Corps veterans, they must rely on DOD's U.S. Army and Joint Services Records Research Center (JSRRC) to research such records for all other service branches. The JSRRC's response time to regional office requests approaches an average of 1 year. However, by building on work already done by several regional offices to establish and use an electronic library of DOD military historical records for the other service branches, VBA may be able to greatly reduce the time required to process many veterans' PTSD claims.

section_title: Letter
paragraphs: In fiscal year 2005, the Department of Veterans Affairs (VA) paid about  $24.4 billion in cash benefits to approximately 2.6 million veterans to  compensate them for disabling medical conditions connected to injuries or  diseases they incurred or aggravated during active duty military service.  During that year, VA made decisions on about 198,000 original disability  compensation claims. Under the Veterans Claims Assistance Act (VCAA)  of 2000, VA is assigned the duty to assist veterans in obtaining any records  relevant to their claims, provided the veterans adequately identify such  records so that VA is able to request them. In addition to military service  records, relevant records can include, for example, records related to  medical treatment provided by VA or private health care providers and  disability decisions made by the Social Security Administration. When  needed to make a decision, the act also requires VA to obtain a medical  opinion or a current medical examination of the veteran. VA relies on the  Veterans Benefits Administration (VBA) and its 57 regional offices to meet  the requirements of this law. Failure to comply with the requirements for  obtaining relevant records could result in veterans not receiving benefits  they deserve. You asked that we determine (1) whether VA’s internal  assessments indicate regional offices are complying with the law’s  requirements for obtaining military service records and (2) whether VBA  could improve its procedures for obtaining military service records for  claims involving post-traumatic stress disorder (PTSD).
To address this request, we obtained and analyzed the federal regulations  promulgated by VA to implement the duty-to-assist provisions of the  Veterans Claims Assistance Act; VBA’s written procedures for obtaining  military service records from appropriate custodians, such as the National  Personnel Records Center; VBA’s user manuals for automated systems  that regional offices use to request military service records from certain  custodians; VBA’s procedures for and data from its reviews of the quality  of regional office decisions; and procedures of and data from the Board of  Veterans’ Appeals for its reviews of regional office decisions appealed by  veterans. In the process of collecting and analyzing such documents and  data, we interviewed key officials of VBA and its regional offices, the  board, veterans’ advocacy groups, and custodians of military service  records. For more details on our scope and methodology, see appendix I.  We conducted our work during November 2005 to December 2006 in  accordance with generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: Veterans submit their disability compensation claims to 1 of VBA’s   57 regional offices. These claims contain, on average, five disabling  medical conditions that the veteran believes are service connected. For  each claimed condition, VA must determine if credible evidence is  available to support the veteran’s contention of service connection. VA  grants service connection for an average of three of the five conditions  claimed by a veteran. Key sources of evidence for determining service  connection are veterans’ military service medical and personnel records.  To determine service connection in some cases, VA also may need to  obtain information from DOD historical military records for the units in  which veterans served.
VBA’s regional offices face a complex task in obtaining veterans’ military  service records because (1) service records consist of numerous types of  records that can originate from numerous sources within or outside DOD,  (2) the process for collecting and storing service records has varied  substantially for different groups of veterans over time, (3) service records  cannot always be found at the expected storage locations, and (4) the  service records of many veterans were destroyed by a fire in 1973 at the  National Personnel Records Center, a primary repository for service  personnel and medical records. For detailed information on military  service records, including the types and locations of the records and the  process for collecting and storing them, see appendix II.
Once a claim has all the necessary evidence, the regional office evaluates  the claim and determines whether the claimant is eligible for benefits. If a  veteran disagrees with a regional office’s decision on any of the issues in  his or her claim, the veteran may file an appeal with the Board of Veterans’  Appeals, requesting a more favorable decision. In many cases, the board  finds it cannot make a final decision on a veteran’s appeal until VBA does  additional work on the case. In such cases, the board sends (remands) the  case back to VBA to perform the necessary additional work. The  additional work required for remands can include making initial or follow- up attempts to obtain relevant records in accordance with the  requirements of the Veterans Claims Assistance Act. Under the act, if  relevant records—such as military service records—are believed to be in  the custody of a federal agency, VBA’s regional offices must continue  requesting the records until either the agency provides the records or the  regional office is reasonably certain the records do not exist or that  further efforts would be futile. VA’s regulations state that the regional  office cannot discontinue its efforts unless it has obtained a statement  from the agency advising VA that the records either do not exist or are not  in the agency’s possession. For detailed information on VA’s disability  compensation claims and appeals process, see appendix III.
section_title: Internal Assessments Indicate General Compliance, but VBA Has Not Assessed the Quality of Its Research Performed at the National Personnel Records Center
paragraphs: VA’s internal assessments indicate that regional offices generally comply  with the requirements of the Veterans Claims Assistance Act for obtaining  veterans’ military service records. However, VBA does not have a system  for assessing the reliability and accuracy of research done on behalf of  regional offices by a VBA unit located at the National Personnel Records  Center, where the service records of many veterans are stored. The VBA  quality review unit that evaluates the accuracy of regional office decisions  on compensation claims has found that that less than 4 percent of these  decisions contain errors involving regional offices’ failing to obtain  military service records as required by law. Similarly, of all the  compensation appeals cases decided by the Board of Veterans’ Appeals  during November 2004–January 2006, the board remanded less than   3 percent of these cases to VBA for rework due to deficiencies in obtaining  military service records. However, because VBA does not systematically  evaluate the quality of the research done on behalf of regional offices by  the VBA unit at the National Personnel Records Center, VBA does not  know the extent to which the information that this unit provides to  regional offices is reliable and accurate.
subsections: section_title: VBA Quality Reviews Show Regional Offices Generally Comply with Veterans Claims Assistance Act Requirements for Obtaining Military Service Records
paragraphs: VBA maintains a quality review program known as the Systematic  Technical Accuracy Review (STAR) program. VBA selects random  samples of each regional office’s compensation decisions and assesses the  regional office’s accuracy in processing and deciding such cases. For each  decision, the STAR quality review unit reviews the documentation  contained in the regional office’s claim file to determine, among other  things, whether the regional office complied with claims assistance act  duty-to-assist requirements for obtaining relevant records, made correct  service connection determinations for each claimed condition, and made  correct disability rating evaluations for each condition determined to be  service connected. An error in any of these decision elements has the  potential to result in a different decision outcome. One of VBA’s fiscal year  2007 performance goals is that 88 percent of compensation decisions  should contain no errors that could affect decision outcomes, and the  long-term strategic goal is 98 percent.
STAR data from reviews of regional office decisions made during the first  half of fiscal year 2006 showed that less than 4 percent of the cases  reviewed contained any type of error related to the law’s requirements for  developing evidence. Because military service records are only one  component in the overall body of evidence that regional offices must  develop, the percentage of cases with errors related to military service  records would be even smaller than the 4 percent error rate. While the  STAR database does not capture statistical data on specific types of errors  in evidence development, it does contain quality reviewers’ narrative  comments on the nature of errors found. A VBA analysis of these narrative  comments showed that over half of all evidence development errors were  due to regional offices not obtaining VA medical examinations or opinions  when needed and using inadequate medical examinations. Thus, on the  basis of STAR data, one would conclude that errors related to military  service records account for less than half—or about 2 percent—of all  evidence development errors.
section_title: Decisions of Board of Veterans’ Appeals Show Regional Offices Generally Comply with Claims Assistance Act Requirements for Obtaining Military Service Records
paragraphs: Since November 2004, when the Board of Veterans’ Appeals began  tracking whether remands are the fault of regional offices, it has remanded  relatively few cases—less than 3 percent—because of regional office  deficiencies in obtaining military records. For example, as of January  2006, the board had made decisions on 41,517 compensation cases and had  remanded at least one issue in 44 percent of these cases (see table 1).  However, of the 41,517 cases, 25.6 percent contained issues that had been  remanded for reasons considered to be the fault of the regional office, and  only 2.8 percent contained issues remanded specifically because of  deficiencies in obtaining military service records.
For each case decided by the appeals board, it also tracks the outcome of  each contested issue in the case—for example, a veteran may have  contested the denial of service connection for a specific medical condition  and also may have asked for a higher disability rating on another condition  for which the regional office granted service connection. The   41,517 compensation cases decided by the board contained a total of  88,156 contested issues, of which 39 percent (34,351) were remanded to  VBA. However, of the total contested issues, 23 percent (20,191) were  remanded for reasons considered to be the fault of the regional offices.
For the 20,191 issues remanded because of regional office deficiencies, the  board identified a total of 36,812 reasons for remanding these issues (see  table 2). Of these remand reasons, only 7.6 percent were related to  inadequacies in obtaining military service records (service medical  records, 3.5 percent; service personnel records, 2.4 percent; and military  unit historical records, 1.6 percent). The predominant reasons for remands  were deficiencies in obtaining medical examinations or opinions and  nonmilitary records and in providing proper due process.
Focusing only on issues in which veterans asked the appeals board to  grant service connection for a medical condition that the regional office  had denied, the board identified about 12 percent of the reasons for  remanding service connection issues as being related to inadequacies in  obtaining military service records.
section_title: VBA Lacks Systematic Quality Review of Research Performed by the VBA Unit Located at the National Personnel Records Center
paragraphs: To obtain service records stored at the National Personnel Records  Center, regional offices submit requests to a VBA unit located at the  center, asking the VBA unit to provide copies of service records and/or  provide information contained in the records. This unit responded to such  requests from regional offices for about 290,000 cases in calendar year  2005. For certain types of compensations claims, such as herbicide  exposure and PTSD claims, VBA’s written procedures instruct regional  offices not to request a copy of the veteran’s entire service personnel  record, which can be voluminous. Instead, regional offices are supposed to  rely on the VBA unit at the National Personnel Records Center to obtain  the veteran’s files, perform a physical search of the files for relevant  records, provide copies of only certain specified records, analyze certain  types of records, and provide regional offices with narrative answers on  the results of their research and analyses. Thus, regional offices rely on the  VBA unit at the National Personnel Records Center to do thorough and  complete searches of records, do reliable analyses of records, and provide  accurate and clear narrative reports on the results.
VBA, however, does not have a systematic quality review program that  evaluates the accuracy of the work that the VBA unit at the National  Personnel Records Center performs on behalf of the regional offices. Such  a program is needed as part of an adequate system of internal management  controls for VBA’s administration of the compensation program. An  example of why the records research done by VBA employees at the  National Personnel Records Center must be reliable is provided by  disability claims based on exposure to herbicides in Vietnam. Under the  Agent Orange Act of 1991, VA presumes that any veteran who had set foot  on land in the Republic of Vietnam at any time during the Vietnam era  (January 9, 1962, to May 7, 1975) was exposed to herbicides such as Agent  Orange. If any such veteran files a claim for certain specified diseases that  have been determined to be attributable to herbicide exposure, VA must  presumptively grant service connection to the veteran for such diseases. If  a veteran claims that he or she was officially stationed on land in Vietnam  during that period, the VBA unit at the National Personnel Records Center  should be able to verify this fact by examining standard personnel forms in  his or her service personnel file. However, if a veteran who was not  officially stationed on land in Vietnam claims that on some occasion he or  she did set foot on land in Vietnam during that period, VBA may encounter  more difficulty obtaining the evidence needed to verify the veteran’s claim  because standard personnel forms would not document such occasions.
In such cases, VBA procedures instruct regional offices not to ask for the  veteran’s entire service personnel file, but instead, the regional office must  ask the VBA unit at the National Personnel Records Center to search the  veteran’s personnel file for any evidence that might corroborate his or her  claim of having set foot on land in Vietnam. One regional office that we  visited provided an example of how the VBA unit at the National  Personnel Records Center could overlook corroborating evidence  contained in the file and cause a significant delay of benefits for a veteran.  In this particular case, an Air Force veteran claimed that he had been  assigned to an aircraft that had landed and spent a short time on the  ground in Vietnam during the presumptive period. The VBA unit at the  National Personnel Records Center did not provide the regional office  with evidence supporting this claim, and the regional office ultimately  denied the claim. However, the veteran appealed the decision to the Board  of Veterans’ Appeals, which remanded the case to the regional office and  ordered the regional office to obtain and review the veteran’s entire  personnel file. After obtaining the entire file from the National Personnel  Records Center, the regional office found documents in the file that  provided sufficient evidence to conclude that the veteran’s claim was  credible. If the VBA unit at the National Personnel Records Center had  found and reported this evidence to the regional office during the initial  claims process, the veteran’s claim could have been granted without his  having to go through the appeals process.
Also, for many PTSD claims, regional offices potentially must rely on the  VBA unit at the National Personnel Records Center to do thorough  research of personnel records. PTSD results from personal exposure to  traumatic events (stressors) that can occur during combat events;  noncombat events—such as plane crashes, ships sinking, explosions, burn  ward duty, or graves registration duty—and personal assault. For such  claims, if evidence substantiates that a veteran engaged in a combat event,  the veteran’s own testimony is sufficient to substantiate the occurrence of  a claimed stressor associated with that event. If engagement in combat is  not substantiated, then the regional office must seek other evidence  substantiating the occurrence of the stressor claimed by the veteran.
Only for PTSD claims involving personal assault do VBA’s procedures  instruct regional offices to request a copy of the entire personnel file from  the National Personnel Records Center. Routinely requesting the entire file  for personal assault cases is permitted because such cases can involve  personal and sensitive incidents that sometimes are not officially reported.  Therefore, the entire file needs to be examined for indications of changes  in behavior or performance that may have been related to the alleged rape  or assault. For all other types of PTSD stressors claimed by veterans, the  documents that regional offices may routinely request from the veterans’  service personnel files do not include performance reports or written  justifications for awards and commendations. According to regional office  officials, however, these documents sometimes can contain evidence that  supports a veteran’s PTSD claim. As a result, the regional offices depend  on the VBA employees stationed at the National Personnel Records Center  to read such documents and report any supporting evidence to the  regional office.
Officials of VBA’s Records Management Center—which oversees the work  of the VBA unit at the National Personnel Records Center—informed us  they are considering implementing a systematic program for reviewing the  quality of all types of research work performed by this unit. Although a  quality review function is already in place, only one analyst has been  responsible for reviewing a 3 percent random sample of each employee’s  work products. Given the volume of work products and limited time  because of other duties, the analyst told us he examined few actual service  record files to assess the accuracy of the work done by the employees.  Instead, the analyst had resorted to using professional judgment to assess  whether the content of the responses that employees provided to regional  offices appeared reasonable in light of the nature of the request to which  they were responding. Only if the analyst thought the response content  looked questionable did he actually obtain the service record files and  examine the records to determine the accuracy of the response. For  example, the analyst told us that in a recent month he had reviewed actual  service record files for only 17 of the approximately 700 responses  randomly selected for review.
According to officials of the VA Records Management Center, they are  considering establishing a team of three or four full-time quality review  specialists that would report to the director of the VA Records  Management Center. If implemented, this team would review the quality of  work done by VBA employees at the National Personnel Records Center  and at the VA Records Management Center. The team would continue to  randomly select a 3 percent sample of each employee’s completed work  products prepared in response to regional office requests. However, unlike  the current review, to determine accuracy, the new team would be able to  review the actual service record files for all responses selected for review.  A quality review specialist position description has been developed, but at  the time of our review, implementation milestones for the new system had  not been established.
section_title: Potential Improvements in Procedures Could Reduce Time Required to Process PTSD Claims of Some Veterans
paragraphs: VBA potentially could improve its procedures and reduce the time  required to process some veterans’ PTSD claims. During fiscal years   1999-2004, the number of veterans receiving compensation benefits  because of PTSD increased by about 80 percent, from about 120,000 to  almost 216,000. VBA potentially could improve its procedures to reduce  the time required to process some veterans’ PTSD claims. To verify the  occurrence of claimed stressors, regional offices sometimes cannot find  needed evidence in the veteran’s personal service records and must turn to  information contained in the military historical records of DOD. While  regional offices are able to directly access and search an electronic library  of such records for many Marine Corps veterans, they must rely on a DOD  research organization—the U.S. Army and Joint Services Records  Research Center (JSRRC)—to research such records for all other service  branches. JSRRC’s average response time to regional office requests for  such research approaches 1 year; by contrast, VBA’s average processing  time strategic goal for claims involving disability compensation issues is  125 days. The opportunity may exist for VBA to establish an electronic  library of DOD military historical records for the other service branches  and greatly reduce the time required to process the PTSD claims of many  veterans.
According to VBA’s procedures, if the regional office verifies that a PTSD  claimant engaged in combat or was a prisoner of war, the claimant’s own  personal testimony is sufficient evidence to verify the occurrence of a  stressor associated with the combat or the prisoner-of-war experience.  Otherwise, the regional office must obtain other credible evidence to  verify the claimed stressor. For Marine Corps veterans from the Vietnam  era and the Korean conflict, the regional office can electronically view and  search a set of compact discs provided by the Marine Corps University  Archives. These discs contain Marine Corps historical records for the  Vietnam era (1960-1975) and the Korean conflict. Officials of regional  offices we visited estimated that, on average, they can perform these  electronic searches of Marine Corps records in less than a day. If the  regional office cannot find the needed corroborative evidence on the  compact disks, the regional office must ask the Marine Corps University  Archives to search its records for any evidence corroborating the veteran’s  claim, and only if the Marine Corps University Archives cannot find  corroboration may the regional office deny the veteran’s PTSD claim.
By contrast, for veterans of armed service branches other than the Marine  Corps, DOD has not created an electronic historical library of records that  regional offices can search when the veteran’s service medical or  personnel records do not provide evidence to verify engagement in  combat or to verify the claimed stressor. Instead, VBA’s procedures call  for regional offices to ask JSRRC to conduct research of military historical  records of the units in which veterans served in order to provide the  needed corroboration. Many of the records that JSRRC may search are  voluminous, are not stored electronically, and must be searched manually  (see app. V for information on such records). After conducting its  research, JSRRC provides the regional office a summary of its findings but  does not evaluate evidence, render opinions, make conclusions, or decide  the merits of a claim. According to its Director, the center has 13 full-time- equivalent employees and a steady backlog of about 4,000 cases, of which  about 85 percent come from VBA regional offices; the remaining requests  are submitted by individual veterans and veterans service organizations.
In our visit to VBA’s Oakland regional office, we learned that the regional  office recently had begun a local initiative in which the regional office had  designated three employees who—when other decision-making duties  permit—search an electronic library of unclassified historical military  records compiled by the Chicago regional office’s military records  specialist. According to the Chicago regional office’s military records  specialist, several other regional offices also have been provided this  electronic library. The Oakland regional office employees doing this  research and the Chicago regional office military records specialist stated  that they have been able to find sufficient evidence in the electronic  library to grant service connection for a substantial portion of PTSD cases  that otherwise would have required that the regional office ask the JSRRC  to search for evidence corroborating the veteran’s claim. According to  these officials, they can complete these searches within a few weeks after  being asked to do the search. These regional offices now request searches  by JSRRC for PTSD cases only if sufficient evidence cannot be found in  the electronic library to grant service connection. The Director of JSRRC  told us that such research by regional offices could greatly reduce JSRRC’s  backlog of research requests and reduce the average response time,  assuming JSRRC’s staffing level remained constant.
A related issue is that some veterans may not be willing to disclose to  regional offices certain details needed to process their PTSD claims  because the claimed stressful event occurred during classified operations.  For example, to alleviate the possibility of such reluctance on the part of  hundreds of thousands of veterans who had participated in classified  atmospheric atomic testing and possibly been exposed to nuclear  radiation, the Secretary of Defense issued a memorandum in 1996  authorizing such veterans to divulge to VA the name and location of their  command, duties performed, dates of service, and related information  necessary to validate exposure to nuclear radiation. Similarly, in PTSD  cases for which regional offices cannot find sufficient evidence in  veterans’ service records to grant the claims, if the veterans, because of  concerns about classified operation, will not provide the regional office  with certain minimum details, the regional office will not be able to submit  requests to JSRRC to search military historical records for corroborating  evidence. We discussed the classified operations issue with the Director of  JSRRC, who stated that he personally had talked with veterans who had  directly contacted his organization and who maintained they could not  divulge to him the details of their participation in classified operations. He  said that after he explained to them that the entire JSRRC staff are DOD  employees and have appropriate security clearances, the veterans were  willing to provide him with the details needed to conduct searches of DOD  records, including any pertinent classified records maintained by DOD.  While the extent of the classified problem is unknown, the Director had no  objections to regional offices advising veterans to directly contact JSRRC  if they are unwilling to disclose sufficient details to the regional office to  process their claims because their disabilities allegedly were incurred  during classified operations.
section_title: Conclusions
paragraphs: VA is responsible for providing reasonable assurance that it is complying  with applicable laws and regulations. While VA’s internal assessments  indicate that its regional offices generally comply with the requirements of  the Veterans Claims Assistance Act for obtaining military service records,  VA does not have a systematic quality review program for ensuring the  reliability and accuracy of records research done on behalf of regional  offices by the VBA unit located at the National Personnel Records Center.  As a result, VA cannot reasonably ensure the quality of the research on  which regional offices rely to assist many veterans in obtaining service  records relevant to their compensation claims.
PTSD claims have been a growing portion of the claims processed by  regional offices. Many present challenges in obtaining the evidence needed  to process them, resulting in veterans having to wait for long periods for  their claims to be decided. VBA’s establishment of a claims-processing  timeliness performance goal demonstrates that high-quality service should  result not only in correct decisions, but also decisions rendered in a  reasonable length of time. The experience of several regional offices  suggests that VBA could improve its timeliness in deciding the PTSD  claims of many veterans nationwide if VBA systematically utilized an  electronic library of historical military records such as the one compiled  by the Chicago regional office. The average time for the Joint Services  Records Research Center to respond to such requests is about 1 year; by  contrast, officials in some regional offices have found that using the online  library compiled by the Chicago regional office enabled them to find  sufficient evidence in a matter a few weeks to grant the PTSD claims of  many veterans.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Secretary of the Department of Veterans Affairs  direct the Under Secretary for Benefits to take the following actions.
To adequately ensure the quality of the records research done on  behalf of regional offices by the VBA unit at the National Personnel  Records Center, VBA should move forward in implementing a  systematic quality review program that evaluates and measures the  accuracy of the unit’s responses to all types of regional office research  requests.
To improve its timeliness in deciding PTSD claims, VBA should assess  whether it could systematically utilize an electronic library of historical  military records, such as the one compiled by the Chicago regional  office, to identify veterans whose PTSD claims can be granted on the  basis of information contained in such a library, rather than submitting  all research requests to the Joint Services Records Research Center.
section_title: Agency Comments and Our Response
paragraphs: In its written comments on a draft of this report (see app. VI), VA agreed  with our findings and concurred with our recommendations. VA stated it  had increased the number of VBA quality reviewers at the National  Personnel Records Center in order to better ensure the quality of  responses provided to regional offices. VA also noted that VBA will  determine the feasibility of regional offices’ using other databases to  research cases in order to reduce the number of cases sent to the JSRRC.  We believe these are positive steps toward ensuring the quality of the  records research done by the VBA unit at the National Personnel Records  Center and improving timeliness.
As agreed with your office, unless you publicly announce it contents  earlier, we plan no further distribution until 30 days after the date of this  report.  At that time, we will send copies of this report to the Secretary of  Veterans Affairs, appropriate congressional committees, and other  interested parties. The report will also be available at GAO’s Web site at  http://www.gao.gov.
If you or your staff have any questions regarding this report, please call me  at (202) 512-7215. Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this report.  Other contacts and staff acknowledgments are listed in appendix VI.
section_title: Appendix I: Scope and Methodology
paragraphs: To identify Veterans Benefits Administration (VBA) procedures for  obtaining relevant military service records, we obtained and analyzed  Department of Veterans Affairs (VA) regulations governing the processing  of compensation claims; VBA’s written procedures, user guide for the  automated system for requesting military records, training materials, and  other VBA instructions for directing regional offices’ efforts in obtaining  military records; locally written procedures and guides developed by  regional offices to direct their employees in obtaining military records; and  information electronically available to regional offices through VBA’s  internal network.
To gain an operational context for the information obtained from these  sources and to obtain stakeholders’ views on the effectiveness of VBA’s  procedures for obtaining relevant military service records, we interviewed  officials of VA’s Board of Veterans’ Appeals and Office of Inspector  General; VBA’s Compensation and Pension Service, Office of Field  Operations, Appeals Management Center, Records Management Center,  VA Liaison Office at the National Personnel Records Center, and regional  offices located in Atlanta, Georgia, Baltimore, Maryland, Oakland,  California, and St. Petersburg, Florida; custodians of military records and  organizations that research military records on behalf of VBA’s regional  offices, including Department of Defense (DOD) U.S. Army and Joint  Services Records Research Center, Defense Threat Reduction Agency,  DOD Joint Requirements and Integration Office, and National Personnel  Records Center, which is operated by the National Archives and Records  Administration; and veterans’ advocacy groups, including Disabled  American Veterans, American Legion, Veterans of Foreign Wars, Paralyzed  Veterans of America, AMVETS, National Veterans Legal Services Program,  and state and county veterans service agencies.
As part of our review of the results of VA’s internal assessments of  regional offices’ compliance with Veterans Claims Assistance Act  requirements for obtaining military service records, we assessed the  reliability of fiscal year 2006 data compiled by VBA from its Systematic  Technical Accuracy Review (STAR) program for regional office decisions  involving compensation issues. In earlier GAO work on STAR data  reported for fiscal year 2004, we reported that regional offices had failed  to send any case files to the STAR unit for hundreds of cases randomly  selected for quality review, which meant the possibility existed that if the  STAR unit had actually been able to review the files for these cases, the  accuracy scores for some individual regional offices could have been  lower than those reported for fiscal year 2004. Subsequently, the STAR  unit began tracking the receipt of cases randomly selected for review. For  our current work, we followed up with the STAR unit to determine the  extent to which regional offices now send to the STAR unit all cases  selected for quality review. We obtained data from the STAR unit and  concluded that the numbers of cases requested, received, and reviewed for  the first half of fiscal year 2006 provided nationwide data that were  sufficiently reliable for our reporting purposes. Even so, the STAR unit did  not receive about 6 percent of the cases selected for review during the first  half of fiscal year 2006; therefore, because the STAR unit might have found  additional VCAA development errors if it had had the opportunity to  review these cases, the percentage of cases actually containing Veterans  Claims Assistance Act (VCAA) development errors may have been larger  than indicated by the fiscal year 2006 data reported by the STAR unit.
Also, as part of our review of VA’s internal assessments of regional offices’  compliance with VCAA requirements for obtaining military service  records, we assessed the reliability of data recorded in the Veterans  Appeals Control and Locator System (VACOLS) by the Board of Veterans’  Appeals on the results of its reviews of veterans’ appeals on compensation  decisions made by regional offices. We obtained data as of January 31,  2006, on all compensation cases decided by the board since November 1,  2004, when the board began recording in VACOLS whether its remands of  decisions to VBA for rework were due to regional office deficiencies. To  assess the reliability of the VACOLS data, we interviewed knowledgeable  board officials, performed electronic testing of pertinent VACOLS data  elements, and reviewed existing information about the data and the  system that produced them. We determined that the data were sufficiently  reliable for the purposes of this report. We analyzed these data to create  summary statistics on the disposition of compensation cases and issues  decided by the board.
section_title: Appendix II: Overview of Military Service Records
paragraphs: VBA’s regional offices face a complex task in obtaining veterans’ military  service records because (1) service records consist of numerous types of  records that can originate from numerous sources within or outside DOD,  (2) the process for collecting and storing service records has varied  substantially for different groups of veterans over time, (3) service records  cannot always be found at the expected storage locations, and (4) the  service records of many veterans were destroyed by a fire in 1973 at the  National Personnel Records Center, a primary repository for service  personnel and medical records.
subsections: section_title: Service Records Are Numerous and Can Originate from Numerous Sources
paragraphs: The cumulative service medical records and service personnel records of  individual service members contain numerous types of records that can  originate in varying organizations and geographic locations of DOD’s  activities as service members migrate from assignment to assignment  during their military service (see table 3).
section_title: Process for Collecting and Storing Service Records Varies Substantially for Different Groups of Veterans
paragraphs: Historically, when service members separated from active duty, all DOD  service branches forwarded all service medical records and service  personnel records to the National Personnel Records Center in St. Louis,  Missouri. However, beginning in the early 1990s, separation point military  installations began sending service medical records to VA’s Records  Management Center, also located in St. Louis. The timing of this  changeover varied among service branches, but as of May 1998, all  branches had begun sending service medical records to the VA Records  Management Center for service members who are discharged from active  duty and have no remaining military reserve or National Guard obligation  (see table 4, col. 2). Also, in 1996, the Navy became the first DOD service  branch to store service personnel records electronically in optically  imaged files, which permitted the Navy to discontinue sending these  records to the National Personnel Records Center. As of November 2005,  all DOD service branches were storing service personnel records  electronically and had discontinued sending such records to the National  Personnel Records Center (see table 4, col. 3).
When service members have military reserve or National Guard  obligations remaining at the time of their release from active duty, the  service branches may not route their service records in the same way that  they route the records of those who do not have such an obligation when  released from active duty. For service members who still have reserve or  guard obligations at the time of their release, the disposition of their  service records varies depending on their service branch, whether their  obligation is a reserve versus guard obligation, and whether or not they are  assigned to an active unit at the time of release from active duty.
VA and DOD jointly initiated a Benefits Delivery at Discharge program that  enables service members still on active duty to file disability compensation  claims within 6 months before separating from active military duty. Under  this program, VBA arranges for a physical examination of the claimant,  and the service branch provides a VBA liaison with a copy of the  claimant’s service medical records. The liaison sends these records to one  of the two VBA regional offices (Winston-Salem and Salt Lake City) that  process all claims filed under this program. The regional office prepares a  rating decision prior to the claimant’s discharge from active duty, and after  the claimant’s discharge, the service branch sends the regional office a  copy of the claimant’s DD Form 214 (Report of Release from Active  Military Service), and the regional office immediately authorizes benefits.  As of April 2005, 141 military installations worldwide were participating in  the Benefits Delivery at Discharge program, and in fiscal year 2004, and  VBA processed 39,000 claims under this program. Additionally, if a service  member not participating in this program submits a VA disability claim  form to his or her service branch before separating from active duty, the  service branch retains the claim form until the individual separates from  active duty and then forwards his or her claim form, DD Form 214, and  service medical records to the regional office having jurisdiction over the  individual’s permanent address.
section_title: Veterans’ Service Records Cannot Always Be Found at Expected Storage Locations
paragraphs: To request veterans’ service records, regional offices rely primarily on a  VBA system known as the Personnel Information Exchange System  (PIES). This system provides regional offices with a menu of record  request codes, each of which is defined in terms of the types of service  records and/or information being requested by the regional office. On  behalf of the regional offices that input such requests into the PIES  system, the VA Records Management Center prints and mails requests to  custodians of records maintained in paper form, and the PIES system  electronically routes requests to custodians of service personnel records  maintained in optically imaged files. However, for a variety of reasons, the  custodians whom regional offices expect to be in possession of requested  records cannot always provide the records (see fig. 1).
section_title: Fire in 1973 Destroyed the Military Service Records of Many Veterans
paragraphs: The service records of many older veterans were destroyed by a fire in  1973 at the National Personnel Records Center. The fire destroyed the  records of approximately 80 percent (16 million to 18 million) of the Army  veterans who served during November 1912 through January 1, 1960, and  the records of 75 percent of the Air Force veterans with surnames  Hubbard through Z who were discharged between September 25, 1947,  and January 1, 1964, and were not in a retired or reserve status at the time  of the fire. For some of these veterans, the National Personnel Records  Center has resources that can help reconstruct some of their service  medical information. For example, the center has Army morning (sick)  reports for November 1912 to December 1974 and Air Force morning  reports for September 1947 to June 1966. Also, in 1988, the National  Personnel Records Center obtained magnetic tapes containing limited  information extracted by the Surgeon General’s Office from about   10 million hospital admission records for veterans admitted to military  hospitals during 1942-1945 and 1950-1954.
Another alternative is for VA to ask the veteran’s service branch to search  sick logs, morning reports, and records of military organizations, hospitals,  and infirmaries. Other alternative sources for medical information can  include statements from service medical personnel; buddy certificates or  affidavits; state or local police accident reports; employment physical  examinations; medical evidence from hospitals, clinics, and private  physicians that may have treated the veteran during or soon after  separation; letters written by the veteran during service; photographs  taken during service; pharmacy prescription records; and insurance  examinations.
section_title: Appendix III: VA’s Disability Compensation Claims and Appeals Process
subsections: section_title: Regional office obtains evidence for claim
paragraphs: For each contested  issue, board makes  one of three  decisions, as shown  below (or)
Board denies the benefits  requested by the veteran (or)
VBA obtains more evidence  but denies the requested  benefits and resubmits the  contested issue to the  board for a final decision (or)
section_title: Appendix IV: Web Sites Listed in the PTSD Rating Job Aids Section of VBA’s Internal Network
subsections: section_title: Unit Citation and Campaign Participation Credit Register (January 1960- September 1987)
section_title: Appendix V: Types of Records Researched by DOD’s U.S. Army and Joint Services Records Research Center
section_title: Appendix VI: Comments from the Department of Veterans Affairs
section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: The following individuals made important contributions to the report:  Irene Chu, Assistant Director; Marta Chaffee; Martin Scire; Ira Spears;  Vanessa Taylor; and Walter Vance.