VHA recommends that all veterans who receive VHA services be screened for HIV as part of routine medical care, including those who do not think they are at risk for acquiring the virus. The aim is to ensure that veterans who are infected with the virus can be diagnosed as early as possible, receive life-saving care, and avoid passing the virus on to others. VHA has made earlier diagnosis of HIV a priority for the agency and established certain requirements for VAMC providers that aim to achieve early diagnoses and rapid linkages to HIV care for veterans. HIV screening at VAMCs involves three stages, and related VHA policy sets forth providers’ requirements related to each of these stages. (See fig 1.) Stage one: providing HIV tests to consenting veterans. A provider in a primary care clinic, a specialty care setting (such as an infectious disease clinic), or other outpatient setting (such as a women’s health clinic) offers a voluntary HIV test to an eligible veteran. In accordance with Centers for Disease Control and Prevention (CDC) recommendations, VHA policy requires providers to offer a one-time test to all veterans; annual tests to veterans with known higher risk factors for acquiring the virus, such as injection drug use; and tests every 3 months to veterans with known higher risk factors who are prescribed preventive medication known as pre-exposure prophylaxis (PrEP). Once a provider obtains consent from the veteran to be tested for HIV, the provider initiates an HIV test order with the laboratory. Although VHA policy previously required that providers document that they obtained veterans’ verbal consent to be tested for HIV, as of April 2019, providers must obtain, but no longer need to document, such consent. In addition, under VHA policy, providers must order the most current CDC- recommended HIV test (which detects HIV antigens and antibodies) when clinically indicated, and laboratories must follow the CDC-recommended HIV testing algorithm (see text box). A blood sample is collected from the veteran, and the laboratory processes the HIV test. Officials from the five selected VAMCs reported using information technology solutions and other strategies to facilitate each of the three stages of HIV screening: providing HIV tests to consenting veterans (stage one), communicating HIV test results to veterans (stage two), and linking HIV-positive veterans to care (stage three). Officials from multiple VAMCs in our review stated their providers use information technology solutions, such as clinical reminders, to fulfill their requirements related to the first stage of HIV screening: offering HIV tests to veterans, obtaining veterans’ verbal consent to be tested, and ordering the most current recommended HIV test. Offering HIV tests to veterans. Officials from three VAMCs in our review told us that providers often use clinical reminders that were developed and implemented by the VAMC or associated VISN to prompt them to offer HIV tests to veterans. (See fig. 2.) According to these officials, clinical reminders are used to prompt providers to offer a one-time HIV test to veterans who have not been tested. They can also be used to facilitate providers’ identification of veterans who are at higher risk for acquiring HIV and subsequently prompt them to offer these veterans an HIV test on an annual, rather than a one-time, basis. For example, officials at two of these three VAMCs indicated that the reminders include prompts for determining if veterans are at higher risk of acquiring HIV or fields to document identified risk factors. One of these officials told us that the recurrence of these clinical reminders can subsequently be increased or decreased to prompt providers to offer an HIV test to veterans who are at higher risk of acquiring HIV on a more or less frequent basis, depending on the risk factors identified over time. Obtaining veterans’ verbal consent to be tested. According to officials from the three VAMCs that discussed the use of clinical reminders, this technology prompts providers to obtain veterans’ verbal consent to be tested for HIV before ordering tests. Further, the reminders give providers a way to document that consent was obtained. For example, officials at one of the three VAMCs stated that providers can access the laboratory menu, which they use to order an HIV test, through the clinical reminder. The officials stated that providers must either (a) document that they obtained veterans’ verbal consent within the clinical reminder before accessing the menu, or (b) document that verbal consent was obtained once they have accessed the menu. Ordering recommended HIV tests. Officials from four of the VAMCs in our review reported that the facilities’ laboratory menus are designed to make it easier for providers to order the most current CDC-recommended HIV test. For example, officials from two VAMCs told us that the most current CDC-recommended HIV test is either the first result that appears when searching for an HIV test within the laboratory menu or the first HIV test that appears within a list of different types of HIV tests. According to officials from another VAMC, the facility’s laboratory menu includes a prompt that explains that an HIV viral load test (a test that is primarily used to monitor an active HIV infection) is not recommended solely to be used for diagnostic purposes if a provider attempts to order such a test for this purpose. Officials at each of the five VAMCs in our review told us that staff contact veterans to schedule non-routine, in-person appointments within the 7 day time frame to inform them that they have tested positive for HIV. According to officials at four VAMCs, staff first place phone calls to veterans and request that the veterans schedule face-to-face visits with providers. Officials at two VAMCs explained that providers attempt to inform veterans of positive HIV test results in person given the sensitive nature of the diagnosis, as recommended by VHA policy. If staff cannot reach the veterans by phone, officials at these two VAMCs indicated that they send letters to the veterans asking them to contact their providers to obtain their test results. Further, officials at three VAMCs stated that staff send letters to veterans to inform them of negative HIV test results within the required 14 day time frame. Officials from all five VAMCs in our review also reported using various, additional approaches to communicating negative HIV test results to veterans, including notifying them by phone, informing them of test results during face-to-face visits, or uploading test results into veterans’ personal electronic health records (EHR). In addition, all five VAMCs in our review have developed protocols to prevent delays in the communication of positive HIV test results to veterans when the provider who ordered the test is unavailable. These protocols are generally outlined in facility-specific policies, which we reviewed, that require that a designee communicate positive HIV test results to veterans in lieu of the ordering provider. According to officials at three VAMCs, these protocols apply when the ordering provider is unavailable for a certain number of consecutive days (typically 3 days). Officials told us that if the designee is not available, their facility’s protocol requires that VAMC leadership (such as the Chief of Medicine) communicate the results to the veteran. Officials from all five VAMCs in our review indicated that providers may refer eligible HIV-positive veterans to care within the community to ensure that treatment occurs in a timely manner. According to officials at two of these VAMCs, these referrals are often made based upon veterans’ preferences or primary care providers’ comfort levels in providing HIV care to veterans who are also eligible for community care. An official at another of these VAMCs told us that eligible veterans who live further distances from the VAMC may ask to be referred to community care. According to officials from multiple VAMCs in our review, providers may also use telecommunications to provide HIV care to veterans. For example, officials from two VAMCs told us that their facilities offer telehealth consultations with an infectious disease provider to veterans who live outside the city in which the VAMC is located or who otherwise find it inconvenient to be seen in-person by an infectious disease provider at the facility. Telehealth allows infectious disease providers to care for veterans who would otherwise receive HIV care from primary care providers or in the community. Officials at another VAMC reported that infectious disease providers are available via cell phone or Skype (software that can be used to make one-to-one or group voice or video- based calls from a cell phone or computer) to assist primary care providers who assume responsibility for veterans’ HIV care. VHA facilitates monitoring of the first stage of HIV screening by providing information to VAMCs that include data on the number of veterans who have been tested for the viral infection. While VHA does not collect data on the timeliness with which HIV test results are communicated to veterans, data resulting from VHA’s monitoring of the communication of other test results may indicate whether veterans are informed of HIV test results within recommended time frames. However, HIV lead clinicians may not be aware that they have access to this information. VHA does not currently monitor whether veterans who test positive for HIV are linked to care within recommended time frames; however, VHA has taken steps to collect and disseminate data that can be used to monitor this stage of screening. According to HHRC officials, the office collects and disseminates annual and biannual data to each VAMC’s HIV lead clinician on the offering of HIV tests to veterans. (See table 2 for information related to VHA’s monitoring activities.) This includes data on (1) the number of veterans who are eligible to receive one-time HIV tests, as well as the number of eligible veterans who were tested, for each VAMC and VISN; and (2) the number of veterans who are prescribed PrEP who are tested for HIV every 3 months to document that they are still HIV negative as recommended by the CDC. HHRC officials told us that they share the one-time testing rate data with HIV lead clinicians on an annual basis, and that these clinicians can use the data to calculate their VAMCs’ one- time HIV test rates and, subsequently, compare their rates regionally or to VAMCs that offer the same complexity of services. According to HHRC officials, they upload these data to an internal data sharing website and notify HIV lead clinicians that the data are available via email and during regularly scheduled conference calls that facilitate the discussion of issues related to HIV screening. HHRC officials also told us that VHA uses the same method to share with HIV lead clinicians on a biannual basis data on the HIV test rate for veterans who are prescribed PrEP. VISNs and VAMCs have used VHA’s data on the offering of HIV tests to veterans to support local efforts to improve HIV screening. For example, HHRC officials told us that VISNs have used data on the number of veterans who are eligible to receive one-time HIV tests, and who were tested, to support applications for VHA-sponsored grants intended to improve the offering of such tests to homeless veterans. Officials from four VAMCs in our review told us that they have used these data to identify the need to increase testing, which led to the implementation of new strategies, such as clinical reminders that prompt providers to offer one-time and risk-based HIV tests to veterans. While VHA recently monitored the documentation of verbal consent by collecting data that VAMCs used to make related improvements, such monitoring is no longer needed due to a change in VHA policy. Between fiscal years 2013 and 2016, NCEHC (the VHA office responsible for VHA’s policy on informed consent) oversaw a system-wide review that led to improvements in the number of VAMC providers that documented in veterans’ medical records that they obtained veterans’ verbal consent to be tested for HIV. In 2019, VHA amended its policy and no longer requires providers to document that they obtained verbal consent. In addition, VHA recently monitored VAMC laboratory protocols for HIV testing, but HHRC noted that this monitoring is no longer needed, because the recommended testing technologies have been implemented. In 2018, VHA conducted a one-time review of VAMC laboratory protocols to ensure that CDC recommendations for the use of HIV tests were followed at each VAMC, such as recommendations related to the type of HIV test that providers should order for diagnostic purposes. VAMCs were required to submit verification to VHA showing that their laboratories had implemented the most current CDC-recommended testing technologies. According to HHRC officials, this provided assurance that providers were ordering the most current CDC-recommended HIV test and that laboratories were following the CDC-recommended HIV testing algorithm. VHA’s Director of Pathology and Laboratory Medicine Service reviewed the verification submitted by each VAMC, and VAMCs were required to develop action plans to address any identified deficiencies. As of August 7, 2018, VHA found that all VAMCs were following CDC’s recommendations related to the availability and use of HIV tests. According to HHRC officials, VHA does not need to continue its monitoring effort in this area, since the implementation of recommended testing technologies by VAMCs was a one-time effort. Further, officials from the five VAMCs in our review told us that the VAMCs were using the CDC-recommended HIV test, and nothing inconsistent came to our attention during our medical records review. OPC and RAPID (the VHA offices responsible for VHA’s policy on the communication of test results and related performance measurement) make data available to VAMC staff that may indicate the timeliness with which HIV test results are communicated to veterans. OPC and RAPID publish a quarterly report on the timeliness with which results from the eight tests that are included in its review of veterans’ medical records are communicated to veterans at each VAMC. While HIV tests are not one of the eight tests included in the OPC and RAPID review, VAMC officials we interviewed told us that VAMC procedures for communicating results are generally the same for all tests. OPC officials stated that VAMC officials could use the data to identify needed performance improvement efforts related to the communication of test results. OPC officials added that while it is not the primary goal of the OPC and RAPID review, data on the eight tests included in the review may serve as a sample, providing some indication as to whether VAMC procedures promote the timely communication of results of any test to veterans. Although OPC and RAPID publish a quarterly report on the timeliness of communicating test results, HIV lead clinicians may not be aware they have access to this information. OPC and RAPID officials told us that VAMC staff responsible for serving as liaisons for OPC’s medical records review are notified by RAPID via email of the report’s availability. RAPID officials added that any VAMC staff may opt in to the email group that officials use to notify liaisons that the timeliness data have been published. HIV lead clinicians we interviewed reported that they did not know that they can opt in to this email group. According to RAPID officials, the main mechanism for making VAMC staff aware that they can join this email group is through their VAMC colleagues. VHA has not taken steps to more systematically communicate the availability of these timeliness data to all VAMC staff (including HIV lead clinicians). Standards for internal control in the federal government require that agencies communicate necessary information throughout all agency reporting lines to achieve the agencies’ objectives and respond to identified risk. VHA policy requires that HIV lead clinicians serve as VAMC points of contact on HIV testing, diagnosis, and care, which may include monitoring HIV care. An HIV lead clinician we interviewed also noted that these data could be used as an indicator as to whether HIV test results are being communicated to veterans in a timely manner. Further, having these data could help staff determine if delays in communicating test results pose risks to the timely completion of HIV screening, such as whether veterans who test positive for HIV are linked to care for their diagnosis as expeditiously as possible. If there are unnecessary delays in communicating positive HIV test results to veterans, providers may be at risk of delaying the start of needed HIV treatment. According to VHA policy, and confirmed by RAPID officials, the timely communication of test results to veterans is essential for high quality care, and the timely follow- up of positive test results may help veterans achieve favorable health outcomes. Linking Veterans to Preventive Care for Human Immunodeficiency Virus (HIV) In addition to linking veterans who test positive for HIV to care for their diagnosis, Department of Veterans Affairs (VA) medical centers link veterans who test negative for HIV to preventive care. The use of preventive medication, or pre-exposure prophylaxis (PrEP), reduces the risk of acquiring HIV in adults. Officials from VA’s HIV, Hepatitis, and Related Conditions Programs (HHRC) told us that they implemented a PrEP quality improvement initiative in September 2016, which focuses on increasing the use of PrEP among veterans who live in areas of the country with a higher prevalence of HIV compared to the national average. HHRC officials told us that the initiative focuses on providing high quality care to veterans in accordance with current recommendations on the use of PrEP. For example, the Centers for Disease Control and Prevention (CDC) has recommended that providers prescribe PrEP medications to individuals who test negative for HIV within one week of documenting the test result. HHRC officials told us that they monitor the time frames in which veterans are prescribed PrEP medication by collecting data on a biannual basis on the date on which veterans’ blood was drawn for the purposes of conducting an HIV test and the date on which veterans’ were prescribed the medication. HHRC officials told us that these data are disseminated to VA medical center staff responsible for improving HIV screening to improve the appropriate use of PrEP as needed. source of information to determine whether veterans are linked to care specifically for their HIV diagnosis within the recommended time frame. According to officials, the data tool was implemented in October 2018, and as of early November 2019, they were in the process of building the capacity to generate a report based on these data showing the time frames in which veterans are linked to HIV care. HHRC officials initially indicated that they expected to begin monitoring linkage to HIV care in August or September 2019, but they were not able to do so for various reasons. According to HHRC officials, the process of building the new data tool and the capacity to generate a report has been lengthy due to competing priorities related to VHA’s ongoing development of a new EHR system. These officials added that they have been simultaneously focused on implementing required improvements in the diagnosis and treatment of veterans with Hepatitis C. According to officials, the time frame to develop the new data tool and report has been extended due to these competing priorities. HHRC officials told us that once monitoring begins, they will report on the number of veterans who are linked to HIV care within the recommended 30-day time frame for each VAMC on an annual basis, retroactive to fiscal year 2018. According to HHRC officials, the data will be disseminated by publishing them on an internal data sharing website that each VAMC’s HIV lead clinician can access. The officials explained that these clinicians will be notified when the data have been published via email and during regularly scheduled conference calls with HHRC. HHRC officials also told us that the data may be used to inform any needed improvements in the timeliness of linking newly diagnosed veterans to HIV care. Standards for internal control in the federal government require that agencies perform ongoing monitoring activities and evaluate results to remediate any identified deficiencies on a timely basis. VHA policy requires that HHRC develop data reports for monitoring the quality of HIV care that are to be disseminated to the VISNs or VAMCs, among other entities and individuals, and lead VHA efforts toward meeting the NHAS’s recommendations. However, until HHRC disseminates data on the timeliness with which veterans are linked to HIV care, VAMCs are limited in their ability to identify any delays and take the necessary steps to ensure that this occurs within recommended time frames, now and in the future. In our nongeneralizable review of the 38 medical records for veterans who tested positive for HIV, we observed some instances of delay. Specifically, we found that six veterans were first seen by an infectious disease provider, who typically treats HIV, more than 30 days after being informed of their positive test results. We were unable to identify a documented explanation in the six medical records for why linkages to care exceeded 30 days. Delays in linking veterans to HIV care can increase the risk that veterans are not promptly beginning treatment to help achieve favorable health outcomes. According to the 2015 NHAS, evidence shows that earlier treatment reduces the risk that an individual with HIV will develop AIDS or transmit the virus to others. Veterans who are voluntarily tested for HIV at VAMCs, informed of positive HIV test results in a timely manner, and expeditiously linked to care before their infections progress further have improved health outcomes, a longer life expectancy, and a reduced risk of transmitting the virus to, for example, a sexual partner. VHA has monitored the provision of HIV tests to veterans and reported related improvements resulting from these monitoring efforts, ensuring that, for example, veterans are receiving the most current CDC-recommended test. However, VHA’s dissemination of data on the time frames in which test results are communicated to veterans and monitoring of the time frames in which HIV-positive veterans are linked to care specific to their diagnosis needs improvement. We are making the following two recommendations to VA: The Under Secretary for Health should take steps to improve communication to VAMC staff (including HIV lead clinicians) about the availability of data on the time frames in which test results are communicated to veterans. (Recommendation 1) The Under Secretary for Health should disseminate data to HIV lead clinicians on the extent to which veterans who test positive for HIV are linked to care within recommended time frames. (Recommendation 2) We provided a draft of this report to VA for review and comment. In its written comments, which are reproduced in appendix I, VA concurred with our recommendations. VA stated that it will communicate to VAMC staff, including HIV lead clinicians, how providers may be notified when the data on the time frames in which test results are communicated to veterans have been published. Further, VA stated that HIV test results will be added to the OPC and RAPID quarterly review of such time frames beginning in the second quarter of fiscal year 2020. VA also indicated that as of December 2019, the agency began annual monitoring of whether veterans are linked to HIV care within recommended time frames and will notify HIV lead clinicians of the availability of the data during conference calls scheduled to take place in January and March 2020. We are sending copies of this report to the appropriate congressional committees and the Secretary of Veterans Affairs. In addition, this report is available at no charge on the GAO website at https://www.gao.gov. If you or your staff have any questions about this report, please contact me at (202) 512-7114 or at DraperD@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix II. In addition to the contact named above, Hernán Bozzolo (Assistant Director), Karen Belli (Analyst-in-Charge), Hannah Grow, Cathy Hamann, and Tatyana Walker made key contributions to this report. Also contributing were Jacquelyn Hamilton, Diona Martyn, and Vikki Porter.

Summary: VHA is the largest single provider of medical care to HIV infected individuals in the nation. In 2018, VAMCs tested approximately 240,000 veterans for HIV and provided HIV care to over 31,000 veterans. Early diagnosis and timely treatment is important for achieving favorable health outcomes and reducing the risk of transmitting the virus to others. The accompanying Joint Explanatory Statement for the Consolidated Appropriations Act, 2018 included a provision for GAO to examine how VAMCs have implemented VHA's HIV screening policy. This report examines (1) approaches that selected VAMCs use to facilitate HIV screening, and (2) the extent to which VHA monitors HIV screening. GAO analyzed VHA documents, including VHA directives and a nongeneralizable sample of 103 veterans' medical records, to understand how providers made decisions and documented actions related to HIV screening. GAO also interviewed VHA and VAMC officials, the latter from five facilities selected based on factors such as the range of HIV prevalence rates. Officials from five selected Department of Veterans Affairs (VA) medical centers (VAMC) reported using various approaches to facilitate human immunodeficiency virus (HIV) screening, which involves three stages. For example, for the first stage of HIV screening (providing HIV tests to consenting veterans), officials told GAO that VAMCs use information technology solutions, such as clinical reminders that prompt providers to offer HIV tests to veterans who have not been tested. These clinical reminders can also prompt providers to offer an HIV test on a repeated, rather than a one-time, basis to veterans with known higher risk factors for acquiring HIV. The Veterans Health Administration (VHA) monitors the first stage of HIV screening by collecting and disseminating data that VAMCs can use to calculate and, if necessary, improve facility HIV testing rates. VHA also collects data on the time frames in which results for eight types of tests are communicated to veterans; these data could indicate how timely test results are being communicated generally (stage two of HIV screening). However, VHA has not effectively communicated the availability of these data to HIV lead clinicians. In addition, VHA does not currently monitor whether VAMCs link veterans who test positive for HIV to care in a timely manner (stage three of HIV screening). VHA officials indicated that they are in the process of building the capacity to collect and disseminate to HIV lead clinicians data on the number of veterans at each VAMC who are linked to HIV care within 30 days, as recommended. However, the time frames for completing these efforts have been extended due to competing priorities, such as implementing required improvements in the diagnosis and treatment of veterans with Hepatitis C. Until VHA improves VAMC staff's access to, or provides them with, these data, it increases its risk that HIV-positive veterans do not receive timely treatment. Such treatment can improve veterans' health outcomes and prevent the transmission of the virus to others. VA should (1) improve communication regarding the availability of data on the timeliness with which test results are communicated to veterans, and (2) disseminate data to HIV lead clinicians on the timeliness with which veterans are linked to HIV care. VA concurred with GAO's recommendations.