Veterans' Benefits: More Transparency Needed to Improve Oversight of VBA's Compensation and Pension Staffing Levels
Published: 2004-11-15T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Chairman and Ranking Minority Member, Senate Committee on Veterans' Affairs, asked GAO to assist the committee in its oversight of the Veterans Benefits Administration's (VBA) disability compensation and pension programs. This report examines (1) VBA's determination and justification of claims processing staffing levels, and the role of productivity in such determinations, and (2) VBA's projections of future claims workload and complexity.
section_title: What GAO Found
paragraphs: VBA's fiscal year 2005 budget justification did not clearly explain how the agency would achieve the productivity improvements needed to meet its compensation and pension claims processing performance goals with fewer employees. According to VBA officials, productivity improvements, workload changes, and employee attrition were considered in developing its fiscal year 2005 budget request. While some of these factors were identified in VBA's budget justification, they were not linked to the requested full-time equivalent (FTE) employment levels. Also, VBA's justification did not specifically address its claims processing productivity or how much VBA planned to improve productivity. Finally, VBA does not explain the impacts of VBA budgetary decisions on long-term productivity. VBA officials identified information technology improvements and training programs that could help improve productivity but have been delayed because VBA shifted funding from these initiatives to support higher staffing levels. This was done to help meet VBA's shorter-term goal to improve claims decision timeliness, in particular the Secretary of Veterans Affairs' goal to reduce decision time for rating-related claims to an average of 100 days. More transparent budget justifications would better inform congressional oversight of VBA by making it easier to evaluate whether the agency's budget requests reflect the resources, particularly staffing, needed to achieve expected performance. V BA estimated the number of claims it expects to receive (receipts) in fiscal year 2005 based on historical workload trends, with adjustments for factors that could affect future receipts, notably the impact of legislation allowing some military retirees to concurrently receive Department of Veterans Affairs (VA) disability compensation and military retirement pay. The accuracy of VBA's projections of rating-related receipts for fiscal years 2000 through 2004 was mixed, varying from underprojecting by about 11 percent to overprojecting by about 19 percent. Actual receipts in fiscal year 2004 exceeded VBA's projections. Meanwhile, VBA did not project claims complexity in its fiscal year 2005 budget justification and did not explain how it expected claims complexity to affect its productivity and requested staffing levels. A claim's complexity can be affected by many factors, such as the number and types of disabilities claimed. VBA's budget justification could be improved if the agency explained how changes in complexity affect workload and staffing requirements.

section_title: Letter
paragraphs: In fiscal years 1998 through 2003, the Veterans Benefits Administration  (VBA) added significant numbers of employees to process veterans’  disability compensation and pension benefit claims. With these additional  employees, VBA significantly increased its production of rating-related  claims decisions in fiscal years 2002 and 2003, and this increase in turn  reduced the agency’s claims inventory and led to improved decision  timeliness. Also, according to VBA, these employees’ increased  proficiency, due to experience and training, will lessen the impact of  attrition of its most experienced employees. In its fiscal year 2004 and  2005 budget justifications, VBA requested funding to support lower  staffing levels than in fiscal year 2003 while maintaining ambitious  performance goals, in particular the Secretary of Veterans Affairs’ goal to  complete rating-related decisions within an average of 100 days.
At your request, we reviewed the basis for the agency’s estimation of its  disability compensation and pension claims processing staffing needs and  workload levels. Specifically, we assessed how VBA (1) determined and  justified its staffing requests for fiscal year 2005, including the extent to  which productivity was considered, and (2) projected the volume and  complexity of future workloads.
We focused our review on VBA’s fiscal year 2005 budget justification to the  Congress, specifically the request for funding of compensation and  pension administration. We also reviewed VBA’s budget justifications for  fiscal years 2000 through 2004 to compare the fiscal year 2005 justification  with previous justifications, identify trends in requested and actual  funding and staffing, and obtain background information on specific  management initiatives and workload trends. We discussed VBA’s fiscal  year 2005 budget and staffing estimates with VBA officials. To review  VBA’s estimation of the number of claims it expects to receive (receipts)  in fiscal year 2005, we interviewed VBA officials and reviewed records of  how they developed the receipts estimates for its fiscal year 2005 budget  justification. To assess the accuracy of VBA’s estimates, we compared  original estimates with actual rating-related receipts for fiscal years 2000  through 2004. We also interviewed VBA and Institute for Defense Analyses  (IDA) officials and reviewed documentation on the IDA receipt projection  model. Finally, we interviewed VBA officials on the agency’s capability to  measure disabilities per claim. We assessed the reliability of VBA’s  workload data and found it adequate for purposes of this report. For  additional scope and methodology information, including data reliability,  see appendix I. We conducted our review from April through September  2004, in accordance with generally accepted government auditing  standards.
subsections: section_title: Background
paragraphs: When a veteran submits a claim for disability benefits to a VBA regional  office, Veterans Service Center staff process the claim in accordance with  VBA regulations, policies, procedures, and guidance. A Veterans Service  Representative (VSR) in a Pre-Determination Team develops the claim;  that is, assists the claimant in obtaining sufficient evidence to decide the  claim. The claim then goes to a Rating Team, where a Rating Veterans  Service Representative (also known as a Rating Specialist) makes a  decision on the claim, based on the available evidence and VBA’s criteria  for benefit entitlement. VSRs also perform a number of other duties,  including establishing claims files, authorizing payments to beneficiaries  and generating notification letters to claimants, conducting in-person and  telephone contacts with veterans and other claimants, and assisting in the  processing of appeals of claims decisions.
VBA’s administrative costs, including personnel costs, are funded through  VA’s General Operating Expenses account. VBA, as part of VA’s annual  budget justification, asks for specific amounts for each of its programs,  including compensation and pension programs. Funding is requested to  support an estimated full-time equivalent (FTE) employment level. In  fiscal year 2003, VBA spent about $878 million to administer its  compensation and pension programs. This funding included support for  about 9,350 FTEs.
From fiscal year 1998 through 2003, staffing levels for VBA’s compensation  and pension programs increased significantly, particularly for staff who  process compensation and pension claims at VBA’s 57 regional offices, as  shown in figure 1 below. In fiscal year 1998, VBA had 6,770 compensation  and pension FTEs; by fiscal year 2003, employment had increased by  about 38 percent to 9,352 FTEs. Compensation and pension FTE levels  rose by about 900 in fiscal years 2001 and 2002. Staffing levels increased  because VBA hired hundreds of new rating specialists and VSRs in  anticipation of a large number of future retirements. Also, these additional  staff helped VBA respond to a sharp drop in the production of rating- related claims decisions in fiscal year 2001. In fiscal year 2002, these  decisions rose from about 481,000 to about 797,000, and to about 827,000  in fiscal year 2003.
In fiscal year 2003, VBA’s 57 regional offices received about 735,000 rating- related claims from veterans and their families for disability benefits. This  included about 167,000 original claims for compensation of service- connected disabilities (injuries or diseases incurred or aggravated while  on active military duty) and about 434,000 reopened compensation claims.  In addition, about 90,000 original and reopened claims were filed for  pensions for wartime veterans who have low incomes and are  permanently and totally disabled for reasons not service-connected and  for their survivors. In addition, VBA received about 28,000 original claims  for dependency and indemnity compensation by deceased veterans’  spouses, children, and parents and to survivors of service members who  died on active duty.
section_title: VBA’s Budget Justification Did Not Clearly Explain the Basis for Its Fiscal Year 2005 Compensation and Pension Staffing Estimates
paragraphs: VBA officials stated that productivity improvements, workload changes,  and attrition of experienced claims processing staff are considered  throughout the annual budget process. However, VBA’s budget  justification did not clearly explain how these factors affected its request.  Early in this process, the Compensation and Pension Service makes a  budget request that is reviewed by VBA’s Office of Resource Management,  under the direction of VBA’s Chief Financial Officer and becomes part of  VBA’s total request. VBA’s request eventually becomes part of VA’s overall  budget request, which is submitted to the Office of Management and  Budget (OMB) for review.
VBA’s fiscal year 2005 budget justification identified a number of  initiatives and projections that could affect its staffing levels. For example,  implementing specialized claims processing teams in VBA’s regional  offices and consolidating pension maintenance work at three regional  offices could affect staffing levels. Also, VBA projected it would receive  more disability compensation claims than in previous years, based on such  factors as the enactment of concurrent receipt legislation in 2003.  Specifically, the fiscal year 2005 budget justification stated that VBA  expected to receive about 65,000 claims because of the enactment of  legislation that allows military retirees with service-connected disabilities  rated at 50 percent or higher to receive both VA disability compensation  and military retirement pay. VBA officials said that this estimate was  included in their negotiations with OMB. Further, VBA noted that it  expects many experienced claims processing staff to leave VBA over the  next several years.
Despite identifying these factors in its 2005 budget justification, VBA does  not specify how such initiatives and projections will affect the number of  employees it needs to meet its claims processing performance goals. For  example, VBA projected that in fiscal year 2005, the number of original  and reopened compensation claims receipts would increase by about 15  and 10 percent respectively from its fiscal year 2004 estimates, and that  original and reopened pension receipts would decrease by about  2 percent. However, VBA did not specifically identify how these  anticipated workload trends had affected its requested staffing levels or its  expected improvements in productivity. VBA’s reduced staffing request  was consistent with OMB guidance to agencies to assume increased  productivity in their budget requests—for example, to do the same amount  of work with fewer employees. However, the budget justification does not  describe how its FTE staffing requirements are linked to the specific  initiatives and projections that could affect these needs.
Also, VBA’s fiscal 2005 budget justification provides no specific  information on its compensation and pension claims processing  productivity or on its planned improvements in productivity. VBA  expressed confidence that it can improve productivity enough to meet its  claims processing goals for fiscal year 2005 with fewer employees, despite  a projected increase in the workload of compensation claims. To achieve  expected improvements in timeliness and accuracy with fewer employees,  while receiving more claims for disability compensation, VBA’s claims  processing operations will need to become more productive. However, the  budget justification included no measurement of productivity, nor did it  identify how it planned to achieve the needed productivity improvements.
Finally, VBA’s fiscal year 2005 budget justification does not explicitly show  the impact of budget decisions to shift funding away from initiatives that  could improve productivity; such decisions were based on VBA’s emphasis  on meeting the Secretary’s 100-day timeliness goal for deciding rating- related claims. According to VBA officials, in fiscal years 2002 and 2003,  nonpayroll funds were shifted to help fund increased FTE employment  levels in VBA regional office Veterans Service Centers, which are  responsible for processing compensation and pension claims. This was  done to increase the number of rating-related claims being decided and to  meet the Secretary’s fiscal year 2003 goals for improving timeliness and  reducing the backlog of undecided claims. For example, VBA used  nonpayroll funds to help support about 300 more FTEs than it had  originally requested for fiscal year 2002, and about 400 more FTEs than it  had originally requested for fiscal year 2003. Specifically, in fiscal year  2002, VBA requested funding for 7,351 compensation and pension FTEs  but reported that it actually used 7,663, and in fiscal year 2003, VBA  originally requested funding for 7,532 FTEs but reported that it actually  used 7,936. According to VBA officials, nonpayroll funds were shifted to  help pay increased payroll costs associated with this higher FTE level. In  addition, the fiscal year 2003 budget request assumed a 2003 pay raise of  2.6 percent, but the actual pay raise was 3.1 percent. VBA’s fiscal year 2004  and 2005 budgets reflect continued efforts to support as many FTEs as  possible through reductions in nonpayroll funding to continue to support  improvements in claims processing timeliness.
VBA officials identified training and information technology initiatives that  have been delayed because of these cuts in nonpayroll funds. These  include delays in developing new Training and Performance Support  Systems (TPSS) modules and in updating existing TPSS modules to reflect  changes in laws, regulations, and procedures. According to its fiscal year  2005 budget justification, VBA is relying on TPSS to improve productivity  by helping new claims processing employees develop needed proficiency  more quickly and by helping experienced employees maintain their  proficiency. Delays in the progress of TPSS implementation could affect  VBA’s productivity, because existing modules may not be as useful as  revised modules could be, and advanced modules may continue to be  unavailable. VBA requested about $2.6 million for TPSS implementation in  fiscal year 2005, including funding to update some existing modules.  However, VBA did not explain the impact of delays in developing new  training modules and updating existing modules.
Another delayed initiative that could improve productivity is Virtual VA.  This initiative involves the scanning of paper records into electronic  claims folders. VBA expects efficiency and timeliness to improve when  Virtual VA is fully implemented, in part because electronic claims folders  could be transferred among regional offices more quickly. VBA has  implemented Virtual VA at its three Pension Maintenance Centers.  However, VBA requested fiscal year 2005 funding only to maintain the  existing Virtual VA program and anticipates that funding will not be  available to expand the program beyond the Pension Maintenance  Centers. VBA’s justification stated that full implementation of Virtual VA  would help improve claim processing and identified the need for  additional staff to convert existing paper claims files to electronic format,  such as for document preparation and scanning. However, VBA did not  request these additional staffing resources and did not explain why. The  budget justification stated that VBA expected no improvements in  performance because of implementation of Virtual VA at regional offices in  fiscal year 2005, but it did not identify how much productivity would be  forgone because of VBA’s decision to delay Virtual VA implementation.
The Congress relies on the budget justification as VBA’s statement of how  it plans to spend the funds it requested. The House and Senate  Appropriations Committees have noted that VA’s budget justification  represents the agency’s budget plan. VA’s authorizing committees also  rely on VBA’s budget justification in conducting their oversight. In  February 2004, both the Senate and House Veterans’ Affairs Committees  held hearings on VA’s fiscal year 2005 budget request. Each committee  then recommended funding levels to its respective Budget Committee. The  Appropriations Committees also conduct oversight of VA through the  annual budget process. Congressional oversight could be enhanced if  VBA’s budget justifications were more transparent.
section_title: VBA Projected Claims Workload Is Based on Historical Trends and Other Factors but VBA Did Not Project Claims Complexity
paragraphs: VBA estimated the number of rating-related claims it would receive in  fiscal year 2005 based on historical trends and judgments about the likely  impacts of various factors on receipts, but it did not project claims  complexity, such as average disabilities per claim. For example, VBA  expected an increase in the number of claims received based on the  enactment of legislation allowing some military retirees to receive both  military retirement pay and VA disability compensation. Also, VBA  officials stated that they factored in the return of veterans from operations  in Iraq and Afghanistan, but they were unclear as to how many claims VBA  expected to receive from these veterans.
Previous VBA projections have been mixed in their accuracy. For fiscal  years 2000 through 2004, VBA’s projections of rating-related claims  receipts varied from an underprojection of about 11 percent to an  overprojection of about 19 percent, as shown in table 1.
In its fiscal year 2004 budget justification, VBA projected that it would  receive an average of about 57,300 rating-related claims per month. For its  fiscal year 2005 budget justification, VBA revised its fiscal year 2004  projection to an average of about 63,900 receipts, based on actual receipts  for October and November 2003. VBA’s revised projection underprojected  by only about 0.5 percent; actual fiscal year 2004 receipts averaged about  64,300 per month.
VBA is working to improve its ability to project its rating claims workload  by more accurately estimating the number of such claims it will receive. In  June 2000, VBA received the first version of a model for forecasting  original and reopened compensation claims receipts, developed under  contract by the Institute for Defense Analyses. This model factored into its  projections the changing size and demographics of the veteran population.  Specifically, the model used historical claim submission data and  projections of the veteran population to project VBA’s future workload.  Although the model was updated in June 2002, its usefulness is limited by  several factors. For example, it projects only original and reopened  compensation claims and relies on outdated veteran population data.  According to a VBA official, VBA’s workload projections for its budget  justifications were not based on this model, but the results of the model  were used to check VBA’s projections. An expanded model with more  recent information is scheduled to be delivered in December 2004. The  expanded model will project workload for more types of claims, including  all rating-related claims, and will be updated to reflect the 2000 Census.
VBA did not project the complexity of its rating-related claims in its fiscal  year 2005 budget submission and did not explain the impact of complexity  on productivity and requested staffing levels. VBA has noted that disability  compensation claims have become more complex because veterans are  claiming more service-connected disabilities per claim, and VBA must  make a decision whether each disability is service-connected. Meanwhile,  the Congress and VA have established presumptions of compensation and  pension eligibility that can make some claims less complex. For example,  the Congress and VA have identified several types of disabilities (such as  type II diabetes) as service-connected based on the presumption that  veterans who served in Vietnam were exposed to Agent Orange. Claims  based on these disabilities can be simpler to decide because less evidence  is needed to prove service connection. VBA did not specifically explain the  impact of claims complexity on productivity and staff requirements.
VBA provided some data on average number of disabilities for completed  compensation claims in its fiscal year 2005 budget justification. However,  these data were based on incomplete information. The average number of  disabilities per claim was based on calendar years 1998 through 2001 data  on completed claims from VBA’s software application for preparing rating  decisions, Rating Board Automation (RBA). According to a VBA official,  the RBA data were incomplete because data on many rating decisions  were not transmitted to VBA’s central database for analysis. For example,  according to a VBA official, employees who were working from home did  not always upload rating information from computer disks into RBA and  send the data to VBA’s central database. Also, because making corrections  to a rating once it had been entered into the central database was  cumbersome, corrections were not always made to the incorrect  information that had been entered in the database. VBA began  implementing a new rating decision preparation package (RBA 2000) in  October 2000. While VBA officials stated that RBA 2000 provides more  complete data on rating decisions, it cannot provide data by the end  product code, which VBA uses to identify types of claims (for example,  original and reopened compensation claims). VBA officials suggested that,  in the future, it could measure issues per claim through its new claims  development software application, MAP-D. VBA is not planning to provide  information on disabilities per claim in its fiscal year 2006 budget  justification.
section_title: Conclusions
paragraphs: It is difficult to determine whether VBA’s confidence that it can meet its  key fiscal year 2005 claims processing goals is well founded because its  budget justification lacks sufficient information to make such an  assessment. VBA set ambitious goals for providing veterans and their  families with more timely decisions. At the same time, VBA expects the  volume of incoming rating-related claims to increase and to lose  experienced claims processing staff to attrition. Nonetheless, VBA  requested a reduction in claims processing staff in fiscal year 2005, on top  of a decrease in fiscal year 2004. VBA’s budget justification does not  clearly explain how its estimated staffing requirements will be affected by  its proposed initiatives to improve efficiency and accuracy, projected  increases in compensation claims, and staff attrition.
To achieve its goals in the face of increasing workloads and decreased  staffing, VBA will have to rely on productivity improvements. However, its  budget justification does not provide information on VBA’s claims  processing productivity or how much VBA expects to improve  productivity. Consequently, it is difficult to determine if VBA can achieve  the productivity improvements it needs or determine how these  improvements will be achieved. While VBA’s budget assumes improved  productivity, the agency has made budget decisions to delay initiatives  that could help improve productivity, in order to protect funding for  claims processing staff to help meet its top short-term priority—improving  timeliness. Its budget justification could have provided more information  on the impacts of decisions to delay these initiatives. Further, VBA’s  budget justification did not clearly explain the effects on productivity of  claims complexity, such as changes in the average number of disabilities  per claim. Consequently, the effect of complexity on VBA’s workload and  staffing requirements is unclear. A more transparent budget justification  would better inform the Congress’ oversight of VBA, by making it easier to  evaluate whether the agency’s administrative budget requests adequately  reflect the resources, particularly staff, needed to achieve expected  performance.
section_title: Recommendation
paragraphs: To assist the Congress in its oversight of VBA’s compensation and pension  claims processing operations, we recommend that the Secretary of  Veterans Affairs direct the Under Secretary for Benefits to prepare the  following information and work with the Committees on Veterans’ Affairs  and the Appropriations Subcommittees on Veterans Affairs, Housing and  Urban Development, and Independent Agencies on how best to make it  available for their use:    explanation of the expected impact of specific initiatives and changes  in incoming claims workload on requested staffing levels;  information on claims processing productivity, including how VBA  plans to improve productivity; and    explanation of how claims complexity is expected to change and the  impact of these changes on productivity and requested staffing levels.
section_title: Agency Comments and Our Response
paragraphs: In its written comments on a draft of this report (see app. II), VA  concurred with our recommendation.  VA noted that VBA will work  closely with VA's Office of Budget, OMB, and congressional authorizing  and appropriating committees and subcommittees to ensure that  appropriate supporting information is included in its future budget  justifications.
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 or Irene Chu, Assistant Director, at (202) 512-7102. In  addition to those named, Amy Buck, Denise Fantone, Martin Scire,  Greg Whitney, and Gregory Wilmoth made key contributions to this report.
section_title: Appendix I: Scope and Methodology
paragraphs: To assess how the Veterans Benefits Administration (VBA) determined  and justified its staffing requests, we focused on VBA’s fiscal year 2005  budget justification to the Congress: specifically, its requests for  discretionary administrative funding for VBA’s compensation and pension  programs. We also reviewed VBA’s budget justifications for fiscal years  2000 through 2004 to identify funding and staffing trends and obtain  background information on specific management initiatives and workload  trends. We reviewed Office of Management and Budget guidance to  agencies on how to prepare their fiscal year 2005 budget requests. In  particular, we reviewed guidance on information to be included in budget  requests, estimating staffing levels, and the budget formulation process. In  addition, we interviewed VBA officials to identify the role of productivity  and workload factors in VBA’s internal budget process and to discuss the  fiscal year 2005 request. Specifically, we interviewed VBA officials  responsible for compensation and pension programs, resource  management, and field operations. In some instances, we relied on  testimonial evidence from our interviews, along with written responses to  detailed questions.
To review VBA’s fiscal year 2005 receipts projections, we interviewed  Compensation and Pension Service officials responsible for these  estimates. We obtained records showing the workload data used to  estimate receipts for fiscal years 2004 and 2005 as well as the adjustments  VBA made to historical trends in developing its estimates. To assess the  accuracy of receipts estimates for fiscal years 2000 through 2004, we  reviewed VBA’s budget justifications for those fiscal years. For fiscal years  2000 through 2003 we compared initial estimates of rating-related claims  for each fiscal year with actual VBA-wide receipts reported in VBA’s  budget justifications. We focused on rating-related claims because they  represent the types of claims VBA uses to develop key performance  measures, such as timeliness (average days to complete rating-related  claims). For fiscal year 2004, we compared VBA’s estimate in its budget  justification with VBA’s Distribution of Operational Resources (DOOR)  report of receipts for the fiscal year.
In addition, we reviewed documentation of the Institute for Defense  Analyses (IDA) receipt estimation model and discussed the model with  IDA and Compensation and Pension Service officials. Because VBA did not  use this model to develop the compensation claims receipt estimates in its  fiscal year 2004 and 2005 budget justifications, we did not conduct a  detailed analysis of the model. In our discussions, IDA officials identified  improvements in its model, such as projecting receipts for additional types  of claims and using updated population data.
We assessed the reliability of end product data in VBA’s Benefits Delivery  Network (BDN). The end product code is a key data element because it  identifies the type of claim. VBA’s DOOR reports aggregate workload data  from the BDN by end product. We reviewed 1997 and 1998 Department of  Veterans Affairs (VA) Inspector General reports that identified significant  control deficiencies in BDN, leading to questionable reliability of workload  and timeliness data. We reviewed VBA’s system for identifying potentially  erroneous end product transactions that might lead to inaccurate  workload data. VBA adopted this system in response to the Inspector  General’s findings. We interviewed the VBA official responsible for  sampling transactions to identify questionable end product instances— where a regional office may have improperly taken credit for completing a  claim or for completing a claim in less time than was actually required. For  example, this sample is designed to identify when a regional office has  taken credit for more than one decision on the same claim, leading to  overcounting of decision production. We also reviewed sample data from  fiscal year 1999 through the second quarter of 2004.
We also reviewed how VBA’s Systematic Technical Accuracy Review  (STAR) program identifies questionable and erroneous end product codes.  If a STAR reviewer determines that the end product code for a randomly  sampled claim file is questionable or erroneous, the claim will be removed  from the STAR sample and be replaced by another claim with the same  end product code. For example, if a claim is identified as completed in  BDN but no decision has been made on the claim, the claim is removed  from the STAR sample. We interviewed a VBA official responsible for  STAR and reviewed data on claims removed from the STAR sample in  fiscal year 2003 and the first half of fiscal year 2004.
We determined that VBA’s end product data are sufficiently reliable for the  purposes of this report, which focuses on VBA-wide data. For example,  VBA’s sampling shows a decline in questionable end product codes from  the second quarter of fiscal year 2003 to the second quarter of fiscal year  2004, from about 5.2 percent to 2.8 percent. However, we are aware that  BDN is an aging information system. In its October 2001 report, VA’s  Claims Processing Task Force noted this and recommended that VBA  maintain BDN until the replacement VETSNET system is fully  implemented. However, VBA officials stated that VBA was not planning to  make significant investments in maintaining BDN because it will be  replaced.
We interviewed VBA officials about the reliability of its Rating Board  Automation (RBA) system as a source of data on average disabilities per  claim. These officials noted that many rating decisions were not included  in the RBA data used in VBA’s fiscal year 2005 budget justification. On the  basis of this, we determined that the data on average disabilities per  compensation claim in VBA’s budget justification were not reliable, and  we do not use the data in our report. Finally, we did not assess the  reliability of the full-time equivalent data VA reported in its budget  submissions.
section_title: Appendix II: Comments from the Secretary of Veterans Affairs