VA Needs Plan for Assessing Consistency of Decisions
GAO-05-99: Published: Nov 19, 2004. Publicly Released: Nov 19, 2004.
In the past, we have reported concerns about possible inconsistencies in the disability decisions made by the 57 regional offices of the Department of Veterans Affairs (VA). In 2002, we reported that VA did not systematically assess the consistency of decision making for any specific impairments included in veterans' disability claims. We recommended that VA conduct such assessments to help reduce any unacceptable variations that VA might find among regional offices. VA agreed that decision-making consistency is an important goal and concurred in principle with our recommendation. However, VA did not discuss how it would measure consistency. In January 2003, in part because of concerns about consistency, we designated VA's disability program, along with other federal disability programs, as high-risk. In fiscal year 2005, VA estimates it will pay about $25 billion in disability compensation benefits to about 2.7 million disabled veterans. In this context, we determined (1) the actions that VA has taken to assess the consistency of regional office decisions on disability compensation claims and (2) the extent to which VA program data can be used to measure the consistency of decision making among regional offices.
In summary, we found that VA still does not systematically assess decision-making consistency among the 57 regional offices. We also found that data contained in VA's Benefits Delivery Network system, which was designed for the purpose of paying benefits, do not provide a reliable basis for identifying indications of possible decision-making inconsistencies among regional offices. However, according to VA officials, as of October 2004, a newly-implemented nationwide information system (known as RBA 2000) could provide VA such an opportunity if the system proves over time to reliably collect data needed to determine each regional office's denial rates and average disability ratings for specific impairments. VA will need to collect several years of data with RBA 2000 in order to have sufficient data to reliably identify indications of impairment-specific inconsistencies among regional offices. Still, even if the RBA 2000 system permits VA to identify indications of such inconsistencies, VA will need to systematically study and determine the extent and causes of such inconsistencies and identify ways to reduce any variations among regional offices that VA may consider unacceptable.
Recommendation for Executive Action
Status: Closed - Implemented
Comments: VA concurred with GAO's recommendation and began a project in early 2005 to study variances in rating decisions on disability claims for hearing loss, knee conditions, and post-traumatic stress disorder (PTSD). In March 2005, VBA tasked a group of regional office subject matter experts with devising tools for reviewing variances. VBA validated these tools in April 2005 and assigned a group of 10 subject matter experts to review a total of 1,750 regional office decisions. Also, each subject matter expert was required to rate three cases for each of the three conditions under review. VBA completed its analysis of the study data in August 2005. Based on the study results, VBA is developing a schedule for future studies of specific ratable conditions as well as periodic follow-up studies of previously studied conditions.
Recommendation: The Secretary of Veterans Affairs should develop a plan, and include it in VA's annual performance plan, that contains a detailed description of how VA will (1) use data gathered through the new RBA 2000 system to identify indications of possible inconsistencies among regional offices in the award and denial of disability compensation benefits for specific impairments and (2) conduct systematic studies of consistency for specific impairments for which RBA 2000 data reveal indications of possible decision-making inconsistencies among regional offices.
Agency Affected: Department of Veterans Affairs