VA Vocational Rehabilitation and Employment Program: Independent Living Services and Supports Require Stronger Oversight
Published: 2013-11-13T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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 from fiscal years 2008 to 2011, most were male Vietnam era veterans in their 50s or 60s. The most prevalent disabilities among these veterans were post-traumatic stress disorder and tinnitus ("ringing in the ears"). GAO's review of 182 IL cases from fiscal year 2008 shows that VR&E provided a range of IL benefits to veterans; the most common benefits being counseling services and computers. Less common benefits included gym memberships, camping equipment, and a boat. GAO estimates 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.
About 89 percent of fiscal year 2008 IL veterans were considered by VR&E to be "rehabilitated" by the end of fiscal year 2011; that is, generally, to have completed their IL plans. These plans identify each veteran's independent living goals and the benefits VR&E will provide. The remaining 11 percent of cases were either closed for various reasons, such as the veteran declined benefits, or were still active. Rehabilitation rates across regions varied from 49 to 100 percent, and regions with larger IL caseloads generally rehabilitated a greater percentage of IL veterans. On average, IL plans nationwide were completed in 384 days; however, completion times varied by region, from 150 to 895 days.
GAO identified four key areas where VR&E's oversight was limited. 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. This has resulted in delayed benefits or VR&E providing the benefits instead of VHA. Second, VR&E does not systematically 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, VR&E's policies for approving IL expenditures may not be appropriate as regions were permitted to purchase a range of items without Central Office approval, some of which were costly or questionable. In one case GAO reviewed, Central Office review was not required for expenditures of $17,500 for a boat, motor, trailer, and the boat's shipping, among other items. Finally, VR&E's case management system does not collect information on IL costs and the types of benefits purchased. VR&E also lacks accurate data on the number of IL veterans served. While the law currently allows up to 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. Since veterans can have more than one IL plan in a fiscal year, one veteran could be counted multiple times towards the cap. VA plans to make modifications to its case management system to address this, but officials noted that it could take up to 3 years to obtain funding for this project.
section_title: What GAO Found
paragraphs: The IL track--one of five tracks within VA's VR&E program--provides a range of non-employment related benefits to help veterans with service-connected disabilities live more 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. This testimony is based on GAO's report issued in June 2013, and describes (1) the characteristics of veterans in the IL track, and the types and costs of benefits 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.
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, procedures, studies, and other documentation.
section_title: What GAO Recommends
paragraphs: In its June 2013 report, GAO recommended 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 agreed with these recommendations.

section_title: Letter
paragraphs: I am pleased to discuss our recent work on the Department of Veterans  Affairs’ (VA) Vocational Rehabilitation and Employment Program’s  (VR&E) Independent Living (IL) “track.” The IL track is one of five tracks  administered by VR&E and provides non-employment related benefits— such as counseling and assistive devices—to help veterans with service- connected disabilities live more independently when employment is not a  feasible goal. In fiscal year 2011, almost 3,000 veterans nationwide were  served through VR&E’s IL track.
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.” areas. In general, timeframes for IL plans may not exceed 24 months,  except under certain circumstances. Under VA regulations, VR&E may  declare a veteran successfully “rehabilitated” when all goals in their IL  plan have been achieved, or if they meet other conditions. Therefore,  “rehabilitation” does not necessarily mean that the veteran’s disabilities  have improved, but rather that the goals developed in their IL plan to  facilitate independence have been met. When veterans are not  successfully rehabilitated, their case may be closed as “discontinued.”  VR&E can also temporarily “interrupt” a veteran’s case when  circumstances arise that affect the provision of the goods and services.  Because there is no statutory limit on the number of IL plans a veteran  can have, officials told us that veterans can reapply to the VR&E program  at any time and start another IL plan. However, unlike VR&E’s four  employment-related tracks, the number of veterans who can be admitted  into the IL track annually is limited by the law. While this number has  increased over the years, the cap was set at 2,600 veterans in fiscal year  2011, and 2,700 in fiscal year 2012.
My remarks today are based on our report, which was released on June  7, 2013, and describes (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 obtain this  information, 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. We  also interviewed VA officials and veteran service organizations, and  visited VA regional offices in San Diego, California; Atlanta, Georgia;  Detroit, Michigan; Philadelphia, Pennsylvania; and the District of  Columbia. In addition, we analyzed VA administrative data and used  statistical models to determine any differences in rehabilitation times.  Moreover, we reviewed the case files of a random, generalizable sample  of 182 veterans who were assigned to the IL track at some point during  fiscal year 2008. We conducted this work 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. A more detailed explanation of our methodology is available in  our report.
subsections: section_title: The IL Track Mainly Serves Older Veterans and Provides a Wide Variety of Benefits
paragraphs: From fiscal years 2008 through 2011, the typical participant in the IL track  was a male Vietnam-era veteran. Of the 9,215 veterans who entered the  IL track in these years, most (67 percent) were male and 50 years old or  older. Most women in the IL track were in their 40s or 50s. Most of the  9,215 IL track veterans served in the Vietnam War; relatively few served  in the Global War on Terrorism as part of Operation Enduring Freedom or  Operation Iraqi Freedom.veterans served in the U.S. Army, and less than 1 percent served in the  National Guard or Reserves. More than three-quarters of IL track  veterans had a combined service-connected disability rating of at least 60   In addition, most (60 percent) IL track  percent, and 34 percent had a disability rating of 100 percent. 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.
Furthermore, 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, from individual counseling and the  installation of ramps to a boat, camping gear, and computers. The most  common type of goods or services were related to counseling, education  and training, and computer and camera equipment. For all veterans who  entered the IL track in fiscal year 2008, we estimated that VR&E  purchased a total of almost $14 million in goods and services. The  average spent per IL track case that year was nearly $6,000.
section_title: Most Veterans Were “Rehabilitated” but within Varying Time Frames
paragraphs: We found that most (about 89 percent) of IL track veterans who began  only one plan during fiscal year 2008 were classified by VR&E as  “rehabilitated”—i.e., successfully reaching and maintaining the goals  identified in their IL plan—by the end of fiscal year 2011. At the same  time, about 11 percent of cases were either “discontinued”—i.e., closed  by VR&E because the rehabilitation goals in the veteran’s IL plan were  not completed—or were still active cases. Of the IL cases that had been  discontinued, the reasons included the veteran declining benefits, not  responding to VA’s attempts to contact them, worsening medical  conditions, and death. We also found that some IL plans were easier to  close as rehabilitated than others, due to the varied nature and  complexity of IL plans, which are based on veterans’ individual disabilities  and needs. For example, one IL plan we reviewed for a veteran with  rheumatoid arthritis only called for the purchase and installation of eight  door levers and a grab rail for the bathtub to facilitate his independence.  However, another IL plan 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.
While the overall IL rehabilitation rate nationwide was 89 percent for  veterans who started an IL plan in fiscal year 2008, the rate varied by  regional office, from 49 to 100 percent. About two-thirds of regional  offices rehabilitated 80 percent or more of their 2008 IL track veterans by  the end of fiscal year 2011. 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.
Furthermore, in fiscal year 2008 IL veterans nationwide completed their IL  plans in an average of 384 days (about 13 months); however, we found  that the length of time to rehabilitate these veterans varied by regional  office from a low of 150 days at the St. Paul Regional Office to a high of   At most regional offices (49  895 days at the Roanoke Regional Office. of 53), however, the average number of days to complete veterans’ IL  plans ranged from 226 to 621 days (8 to 21 months). To control for  various factors that could influence rehabilitation time frames, 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.model show differences across regional offices in the amount of time it  takes for veterans to become rehabilitated based on caseload. More  specifically, the chance of rehabilitation within 2 years was less than 50  percent at 4 offices, between 50 and 90 percent at 18 offices, and 90   The results of our  percent or higher at 16 offices. Veterans served by regional offices with  large IL caseloads generally had a higher probability of completing an IL  plan more quickly than a veteran served by an office with a small IL  caseload (see fig 1).
section_title: VR&E Exercises Limited Oversight of the IL Track
paragraphs: We identified four key areas where VR&E’s oversight of the IL track was  limited: (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.
subsections: section_title: Regional Offices May Not Be Complying with VR&E Case Management Requirements
paragraphs: Certain VR&E case management requirements were not being met by  some regional offices. For example, based on our review of VR&E’s site  visit monitoring reports, we found that some Vocational Rehabilitation  Counselors (VRCs) were not fulfilling VR&E’s requirement to meet in- person each month with IL track veterans to monitor progress in  completing their IL plans. VRCs told us that this requirement is a  challenge due to the size of their caseloads and the distances that they  may have to travel to meet with veterans. Furthermore, while VR&E and  the Veterans Health Administration (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.  Several VRCs in the regions we interviewed indicated that when they  refer IL track cases to VHA physicians, the physicians do not respond or  they respond too late. As a result, services for IL track veterans are  delayed or purchased by VR&E instead of VHA. In our review of 182 IL  track case records, we found some instances where VR&E purchased  goods and services that appear to be medically related, such as ramps  and grab bars, which could have been provided by VHA. In response, we  recommended VA explore options for enhancing coordination to ensure IL  track veterans’ needs are met by VHA, when appropriate, in a timely  manner. VA concurred and stated that it was piloting an automated  referral system that would allow VR&E staff to make referrals to VHA  providers and check on their status electronically.
section_title: VR&E Does Not Systematically Monitor Variation in IL Caseload and Benefits Provided
paragraphs: VR&E does not systematically monitor variation in IL track caseload size  and benefits across its regional offices. We found that the total IL track  caseload for fiscal years 2008 through 2011 ranged from over 900 cases  in the Montgomery, Alabama Regional Office to 4 cases in the  Wilmington, Delaware Regional Office. In addition, we found that some  regions developed IL plans that addressed a broad range of needs while  others elected to develop more focused plans that provided fewer  benefits to achieve VR&E’s rehabilitation goal. VR&E has relied on the  information provided through its general quality assurance (QA)  activities and a series of periodic ad hoc studies to oversee the  administration of the IL track. Because these activities are limited in  scope, frequency, and how the information is used, we noted that they  may not ensure consistent administration of the IL track across regions. In  response, VR&E officials commented that QA results are analyzed to  determine trends, and make decisions about training content and  frequency.
section_title: VR&E’s Policy for Approving IL Track Expenditures May Not Be Adequate
paragraphs: VR&E’s current policy for approving IL track expenditures may not be  adequate, considering the broad discretion VR&E provides to regions in  determining and purchasing goods and services. 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’s written policy and guidance do not explicitly require this  for all IL expenditures. Thus, regional offices have the ability 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  costly. (See table 1 for the level of approval required for IL expenditures.)  In one case we reviewed, VR&E Central Office approval was not required  for the purchase of a boat, motor, trailer, and the boat’s shipping cost,  among other items, totaling about $17,500. In another case we reviewed,  VR&E Central Office was not required to approve total expenditures of  $18,829 for a riding lawn mower—which VR&E’s current policy  prohibits—and other IL goods and services including a bed, bed frame,  desktop computer, and woodworking equipment. Without appropriate  approval levels, VR&E’s IL track may be vulnerable to potential fraud,   In our report, we recommended that VA reassess  waste, and abuse.and consider enhancing its current policy concerning the required level of  approval for IL track expenditures. VA concurred with our  recommendation and said it will use the results of an internal study to  determine if changes are needed to its existing cost-review policies or  procedures. VA stated that any necessary changes should be  implemented by March 2014.
VR&E’s case management system—commonly referred to as  —does not collect or report critical program management  “CWINRS”information that would help the agency in its oversight responsibilities.  More specifically, this system does not collect and maintain information  on:
Costs of IL goods and service purchased: The system does not collect  information on the total amount of funds VR&E expends on IL  benefits. VR&E aggregates costs across all its tracks, despite VA’s  managerial cost accounting policies that require the costs of products  and services to be captured for management purposes. Federal  financial accounting standards also recommend that costs of  programs be measured and reported. According to VA officials, cost  information is not collected on the IL track alone because they view  the five tracks within VR&E as a single program with the same  overarching goal—to help veterans achieve their employment goals.  We previously reported on this issue in 2009. At that time, we found  that VR&E’s five tracks do not share the same overarching goal.  Therefore, we concluded that VR&E should not combine track  information.
Types of IL benefits provided: The 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. 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 “IL supplies,” without any  further details. In addition, we found that controls for data entry were  not adequate to ensure that all important data were recorded. 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.
Number of IL veterans served: The system does not provide VR&E  with the information it needs 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, as of 2012, was set at  2,700. In analyzing VR&E’s administrative data, we found that  VR&E counts the number of IL plans developed annually rather than  the number of individual veterans admitted to the track. Because  multiple IL plans can be developed for an individual veteran during the  same fiscal year, veterans with multiple plans may be counted more  than once toward the statutory cap. As a result, VR&E lacks complete  information on the number of veterans it is serving through the IL track  at any given time—information it could use to better manage staff,  workloads, and program resources, and ensure that it can effectively  manage its cap.
Similar to our report’s findings, VR&E’s 2012 evaluation of CWINRS has  shown that the system limits VR&E’s oversight abilities and does not  capture all important data elements to support the agency’s “evolving  business needs.”that the new system modifications will enable them to individually track  veterans served through the IL track. However, we found that the  CWINRS redesign will not enable VR&E to obtain data on IL track  expenditures or the types of goods and services provided. At the time of  our review, no specific time frames were provided for the CWINRS  redesign, but officials noted it could take up to 3 years to obtain funding  for this effort. In our report, we recommended that VA implement an  oversight approach that enables VR&E to better ensure consistent  administration of the IL track across regions. This approach would include  ensuring that CWINRS (1) tracks the types of goods and services  provided and their costs, (2) accounts for the number of IL track veterans  being served, and (3) contains stronger data entry controls. VA concurred  with our recommendation and stated that discussions of system  enhancements and the development of ad hoc reports are ongoing. The  agency also will be considering a new oversight approach as part of an  internal study.
Officials told us that they plan to modify CWINRS, and  In conclusion, strengthening oversight of VR&E’s IL track is imperative  given the wide range of goods and services that can be provided under  the law to help veterans with service-connected disabilities improve their  ability to live independently when employment is not feasible. More  attention at the national level can help ensure that IL track case  management requirements are met, the track is administered consistently  across regions, expenditures for goods and services are appropriate, and  critical information is collected and used to ensure veterans’ IL needs are  sufficiently addressed.
Chairman Flores, Ranking Member Takano, and Members of the  Subcommittee, this concludes my prepared remarks. I would be happy to  answer any questions that you or other members of the subcommittee  may have.
section_title: Contacts and Staff Acknowledgments
paragraphs: For further information regarding this testimony, please contact Daniel  Bertoni at (202) 512-7215, or at bertonid@gao.gov. Contact points for our  Office of Congressional Relations and Public Affairs may be found on the  last page of this statement. Individuals who made key contributions to this  testimony include Clarita Mrena (Assistant Director), James Bennett,  David Chrisinger, David Forgosh, Mitch Karpman, Sheila McCoy, James  Rebbe, Martin Scire, Ryan Siegel, Almeta Spencer, Jeff Tessin, Jack  Warner, and Ashanta Williams.
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