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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

March 2011: 

DOD and VA Health Care: 

Federal Recovery Coordination Program Continues to Expand but Faces 
Significant Challenges: 

GAO-11-250: 

GAO Highlights: 

Highlights of GAO-11-250, a report to congressional requesters. 

Why GAO Did This Study: 

In 2007, following reports of poor case management for outpatients at 
Walter Reed Army Medical Center, the Departments of Defense (DOD) and 
Veterans Affairs (VA) jointly developed the Federal Recovery 
Coordination Program (FRCP) to coordinate the clinical and nonclinical 
services needed by severely wounded, ill, and injured servicemembers 
and veterans. The FRCP, which continues to expand, is administered by 
VA, and the care coordinators, called Federal Recovery Coordinators 
(FRC), are VA employees. This report examines (1) whether 
servicemembers and veterans who need FRCP services are being 
identified and enrolled in the program, (2) staffing challenges 
confronting the FRCP, and (3) challenges facing the FRCP in its 
efforts to coordinate care for enrollees. GAO reviewed FRCP policies 
and procedures and conducted over 170 interviews of FRCP officials, 
FRCs, headquarters officials and staff of DOD and VA case management 
programs, and staff at medical facilities where FRCs are located. 

What GAO Found: 

It is unclear whether all individuals who could benefit from the FRCP’
s care coordination services are being identified and enrolled in the 
program. Because neither DOD nor VA medical and benefits information 
systems classify servicemembers and veterans as “severely wounded, 
ill, and injured,” FRCs cannot readily identify potential enrollees 
using existing data sources. Instead, the program must rely on 
referrals to identify eligible individuals. Once these individuals are 
identified, FRCs must evaluate them and make their enrollment 
determinations—a process that involves considerable judgment by FRCs 
because of broad criteria. However, FRCP leadership does not 
systematically review FRCs’ enrollment decisions, and as a result, 
program officials cannot ensure that referred individuals who could 
benefit from the program are enrolled and, conversely, that the 
individuals who are not enrolled are referred to other programs. 

The FRCP faces challenges in determining staffing needs, including 
managing FRCs’ caseloads and deciding when VA should hire additional 
FRCs and where to place them. According to the FRCP Executive 
Director, appropriately balanced caseloads (size and mix) are 
difficult to determine because there are no comparable criteria 
against which to base caseloads for this program because of its unique 
care coordination activities. The program has taken other steps to 
manage FRCs’ caseloads, including the use of an informal FRC-to-
enrollee ratio. Because these methods have some limitations, the FRCP 
is developing a customized workload assessment tool to help balance 
the size and mix of FRCs’ caseloads but has not determined when this 
tool will be completed. In addition, the FRCP has not clearly defined 
or documented the processes for making staffing decisions in FRCP 
policies or procedures. As a result, it is difficult to determine how 
staffing decisions are made, or how this process could be sustained 
during a change in leadership. Finally, the FRCP’s basis for placing 
FRCs at DOD and VA facilities has changed over time, and the program 
lacks a clear and consistent rationale for making these decisions, 
which would help ensure that FRCs are located where they could provide 
maximum benefit to current and potential enrollees. 

A key challenge facing the FRCP concerns limitations on sharing 
information needed to coordinate services for enrollees, who may be 
enrolled in multiple DOD and VA case management programs. These 
limitations are often blamed for duplication of services and enrollee 
confusion, prompting two military wounded warrior programs to cease 
making referrals to the FRCP. One such limitation existed because VA 
had not completed public disclosure actions necessary to enable the 
sharing of information from the FRCP’s information system. In January 
2011, VA completed the process needed to resolve this issue. In 
addition, incompatibility among information systems used by different 
case management programs limits data sharing. Although the ultimate 
solution to information system incompatibility is beyond the capacity 
of the FRCP to resolve, the program has initiated an effort to improve 
information exchange. 

What GAO Recommends: 

GAO recommends that VA direct the FRCP Executive Director to establish 
systematic oversight of enrollment decisions, complete development of 
a workload assessment tool, document staffing decisions, and develop 
and document a rationale for FRC placement. GAO received comments from 
DOD and VA; VA concurred with GAO’s recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-11-250] or key 
components. For more information, contact Randall B. Williamson at 
(202) 512-7114 or williamsonr@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Problems Identifying Potential Enrollees and Reviewing Enrollment 
Decisions Make It Unclear Whether Those Needing FRCP Services Are 
Enrolled: 

The FRCP Faces Challenges in Determining Staffing Needs and Has Not 
Clearly Defined or Documented Its Processes for Managing FRCs' 
Caseloads, Making Staffing Decisions, and Placing FRCs: 

The FRCP Faces Challenges That Limit Its Ability to Coordinate Care 
but Is Taking Steps to Address Them: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: The Use of Software to Analyze Testimonial Evidence: 

Appendix II: Comments from the Department of Defense: 

Appendix III: Comments from the Department of Veterans Affairs: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Demographic Information of Federal Recovery Coordination 
Program (FRCP) Enrollees as a Percentage of FRCP Enrollment, September 
2010: 

Table 2: Description of Selected Federal Recovery Coordinator (FRC) 
Activities: 

Table 3: Diagnoses of Federal Recovery Coordination Program (FRCP) 
Enrollees, September 2010: 

Table 4: Characteristics of Major Department of Defense (DOD) and 
Department of Veterans Affairs (VA) Programs for Seriously and 
Severely Wounded Servicemembers and Veterans: 

Figure: 

Figure 1: Location and Number of Federal Recovery Coordinators (FRC), 
September 2010: 

Abbreviations: 

DOD: Department of Defense: 

FRC: Federal Recovery Coordinator: 

FRCP: Federal Recovery Coordination Program: 

OEF: Operation Enduring Freedom: 

OIF: Operation Iraqi Freedom: 

VA: Department of Veterans Affairs: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

March 23, 2011: 

Congressional Requesters: 

In 2007, in response to critical media reports of deficiencies in the 
provision of outpatient services at Walter Reed Army Medical Center, 
various review groups investigated the challenges that the Departments 
of Defense (DOD) and Veterans Affairs (VA) faced in providing care to 
recovering servicemembers. The review groups cited common areas of 
concern, including case management, which helps ensure continuity of 
care by coordinating services from multiple providers and guiding 
transitions between providers or agencies or back to the civilian 
community. One of these review groups, the President's Commission on 
Care for America's Returning Wounded Warriors--commonly referred to as 
the Dole-Shalala Commission--issued a report[Footnote 1] that noted 
that while the military services did provide case management, some 
servicemembers were being assigned multiple case managers, having no 
single person to monitor and coordinate their activities, which often 
resulted in confusion, redundancy, and delay. To address these 
shortcomings, the commission recommended strengthening the continuity 
of care for recovering servicemembers through the use of 
individualized recovery plans that would be developed and monitored by 
skilled recovery coordinators who would have the ability to operate 
across departments. In response, the joint DOD and VA Wounded, Ill, 
and Injured Senior Oversight Committee (Senior Oversight Committee) 
developed the Federal Recovery Coordination Program (FRCP) to assist 
severely wounded Operation Enduring Freedom (OEF) and Operation Iraqi 
Freedom (OIF) servicemembers, veterans, and their families with access 
to care, services, and benefits.[Footnote 2] The FRCP was envisioned 
to serve severely wounded, ill, or injured servicemembers and 
veterans,[Footnote 3] including those who had suffered traumatic brain 
injuries, amputations, burns, spinal cord injuries, visual impairment, 
and post-traumatic stress disorder. (In this report, we use "severely 
wounded" to denote severely wounded, ill, and injured servicemembers 
and veterans, as appropriate.) According to VA officials, the number 
of severely wounded servicemembers in the OEF/OIF conflicts is not 
known with certainty because "severely wounded" is not a categorical 
designation used by DOD or VA medical or benefits programs. Estimates 
of the size of the severely wounded population vary, depending on 
definitions and methodology. 

Although the FRCP is the first care coordination program jointly 
developed by DOD and VA, it is but one of several recently introduced 
or revised programs intended to improve the continuity of care for 
wounded servicemembers and veterans. Other programs include the 
wounded warrior programs operated by the military services;[Footnote 
4] VA's OEF/OIF Care Management Program; and DOD's Recovery 
Coordination Program, which is separately implemented and managed by 
each military service. However, the FRCP was intended to complement 
rather than duplicate the efforts of clinical and nonclinical case 
management programs in both DOD and VA through the use of senior-level 
coordinators called Federal Recovery Coordinators (FRC). Unlike case 
managers, FRCs are intended to be care coordinators whose planning, 
coordination, monitoring, and problem-resolution activities encompass 
both health services and benefits provided through DOD, VA, other 
federal agencies, states, and the private sector. Care coordination 
programs[Footnote 5] are typically more comprehensive in scope than 
clinical or nonclinical case management programs, and care 
coordinators, such as FRCs, may serve as a link between multiple case 
managers. The FRCs strive to work with each enrollee to create a 
comprehensive Federal Individual Recovery Plan to identify his or her 
goals and subsequently to coordinate and monitor the clinical and 
nonclinical services needed to achieve the enrollee's goals-- 
interacting with the enrollee for a lifetime if necessary. The FRCP is 
administered by VA, and the FRCs are VA employees. 

An evaluation of the FRCP during the program's initial implementation 
phase identified a number of challenges facing the program, including 
the determination of appropriate staffing levels for FRCs.[Footnote 6] 
This evaluation noted that staffing levels were difficult to 
determine, given the absence of a widely accepted estimate of the size 
of the severely wounded population. In addition, the FRCs' 
unprecedented care coordination role and work activities meant that it 
was not known how many FRCs would be required to address the needs of 
enrollees. This evaluation also noted that the program should consider 
future FRC placement in response to the expected increase in the 
number of enrollees, who could be located in different parts of the 
country. 

Since beginning operation in January 2008, the FRCP has grown 
considerably, but the program experienced turmoil in its early stages. 
At the time of the program's introduction, eight FRCs were placed at 
three military treatment facilities--Walter Reed Army Medical Center, 
National Naval Medical Center, and Brooke Army Medical Center. 
However, within the first 7 months of its implementation, six of the 
original eight FRCs left the program, VA moved oversight of the 
program directly under the VA Secretary, and the FRCP Executive 
Director was replaced in July 2008. Under the new Executive Director, 
the FRCP enlarged its staff, increased the number of enrollees, and 
expanded the number of locations where FRCs are assigned. As of 
September 2010, the program employed 20 FRCs, who were serving about 
600 servicemembers and veterans. These FRCs were located at six 
military treatment facilities, three VA medical centers, and the 
headquarters of one military service's wounded warrior program. While 
the FRCs are physically located at certain facilities, their enrollees 
are scattered throughout the country and may not be receiving care at 
the facility where their assigned FRC is located. 

Our review of the FRCP is one in a series of engagements focused on 
the continuity of care for recovering servicemembers and veterans, 
which resulted from requests from multiple congressional requesters. 
In light of continued concerns about DOD's and VA's efforts to support 
servicemembers and veterans, this report examines (1) whether 
servicemembers and veterans who need FRCP services are being 
identified and enrolled in the program, (2) staffing challenges 
confronting the FRCP, and (3) the challenges facing the FRCP in its 
efforts to coordinate care for severely wounded servicemembers and 
veterans. 

To address these objectives, we conducted more than 170 interviews of 
the following groups: FRCs; FRCP leadership, which includes the 
Executive Director, the Deputy Director for Health, and the Deputy 
Director for Benefits; leadership officials with DOD and VA case 
management programs (collectively referred to as program officials), 
including leadership officials from each military service's wounded 
warrior program; and medical facility directors and staff at DOD and 
VA medical facilities (referred to as medical facility staff). We 
interviewed the FRCs individually to learn about challenges they have 
encountered, using comprehensive interviews of the 15 FRCs who were 
working in the FRCP in or before December 2009 and limited interviews 
of the 5 FRCs who were hired in January 2010. To develop an 
understanding about how clinical and nonclinical officials and staff 
interact with the FRCs, we conducted site visits and telephone 
interviews with program officials at DOD and VA headquarters and 
medical facility staff at the DOD and VA medical facilities where FRCs 
are located. These facilities included Walter Reed Army Medical 
Center; National Naval Medical Center; Brooke Army Medical Center; 
Naval Medical Center-San Diego; Naval Hospital Camp Pendleton; 
Eisenhower Army Medical Center; and the VA medical centers in Houston, 
Texas; Providence, Rhode Island; and Tampa, Florida. In addition, we 
visited three VA medical centers with which FRCs have significant 
interaction--the facilities in Richmond, Virginia; Augusta, Georgia; 
and San Diego, California. We performed content analysis of the 
qualitative information obtained from the FRCs, DOD and VA program 
officials, and medical facility staff by grouping their responses by 
topic and then identifying response patterns. Content analysis of 
qualitative information obtained from DOD and VA program officials and 
medical facility staff was conducted using a software 
package,[Footnote 7] which enabled us to analyze responses to specific 
interview topics for a large number of interviews. (See app. I for a 
discussion of how we used the software package.) However, the results 
from our site visits and interviews cannot be generalized because 
while all DOD and VA facilities could potentially interact with FRCs, 
our review focused on facilities where FRCs are located as well as 
some facilities where FRCs have significant interaction. In addition, 
we obtained and reviewed documentation related to the FRCP, including 
VA's October 2009 handbook on care management of OEF and OIF Veterans; 
the FRCP Standard Operating Procedures; the FRCP fiscal year 2010 
operating plan; and draft FRCP procedures, such as the VA handbook on 
the FRCP. 

We conducted this performance audit from September 2009 through March 
2011 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. 

Background: 

Servicemembers wounded in recent conflicts are surviving injuries that 
would have been fatal in past conflicts, in part because of advanced 
protective equipment and medical treatment. However, the severity of 
their injuries can result in a lengthy transition from patient status 
back to active duty or to veteran status. Most severely wounded 
servicemembers from the conflicts in Iraq and Afghanistan initially 
are evacuated to Landstuhl Regional Medical Center in Germany for 
treatment. From there, they are usually transported to military 
treatment facilities in the United States, with most of the severely 
wounded admitted to Walter Reed Army Medical Center, the National 
Naval Medical Center, or Brooke Army Medical Center. 

Acute medical treatment and stabilization is the first of three phases 
in the "continuum of care" experienced by severely wounded 
servicemembers. The second phase of the continuum is rehabilitation at 
a DOD, VA, or civilian facility. (The recovery needs of some 
servicemembers receiving rehabilitation may require their return to a 
medical center for acute medical care, such as surgical procedures.) 
The third phase of the continuum is reintegration--either return to 
active duty or to the civilian community as a veteran, where they may 
receive health care from DOD, VA, or civilian providers. 

FRCP Enrollees: 

From January 2008--when FRCP enrollment began--through September 2010, 
the FRCP provided services to a total of 1,268 servicemembers and 
veterans.[Footnote 8] As of September 2010, the program had 607 active 
enrollees, ranging in age from 19 to 61 years, with a median age of 27 
years. About half of the enrollees were or had been married. Fifty- 
eight percent had designated another person as his or her primary 
caregiver, and 38 percent had delegated legal authority to another 
person. (See table 1 for additional demographic information about 
current FRCP enrollees.) 

Table 1: Demographic Information of Federal Recovery Coordination 
Program (FRCP) Enrollees as a Percentage of FRCP Enrollment, September 
2010: 

Enrollee's branch of service: 
Army; 56 percent; 
Marines; 29 percent; 
Navy; 9 percent; 
Air Force; 6 percent; 
Coast Guard; Less than 1 percent. 

Duty status: 
Active duty; 57 percent; 
Veteran; 43 percent. 

Gender: 
Male; 94 percent; 
Female; 6 percent. 

Treatment status: 
Outpatient; 77 percent; 
Inpatient; 23 percent. 

Source: GAO analysis of FRCP data. 

Note: Totals may not equal 100 percent because of rounding. 

[End of table] 

FRC Activities: 

FRCs are senior-level registered nurses and licensed social workers 
whose principal role is to coordinate services with case managers 
rather than provide services directly to enrollees. FRCs are expected 
to serve as the single point of contact for the enrollees and their 
families and to assist the enrollees in a number of ways. FRCP care 
coordination guidelines identify FRC activities, which are outlined in 
table 2. 

Table 2: Description of Selected Federal Recovery Coordinator (FRC) 
Activities: 

Activity: Referral; 
Description: Receiving notification of or identifying potential 
Federal Recovery Coordination Program (FRCP) enrollees and contacting 
them. 

Activity: Evaluation; 
Description: Conducting an evaluation of need and whether the 
servicemember or veteran meets FRCP eligibility criteria; 
individuals who are referred to but not enrolled into the FRCP may be 
counseled about alternative sources of support ("redirected") or 
provided with short-term services to address a specific issue (an 
"assist"). 

Activity: Enrollment; 
Description: Determining that a servicemember or veteran meets 
eligibility criteria and would benefit from care coordination, and 
enrolling that individual in the FRCP. 

Activity: Creation of Federal Individual Recovery Plan; 
Description: Developing an individualized plan for each FRCP enrollee. 

Activity: Documentation; 
Description: Entering enrollee information and Federal Individual 
Recovery Plan into the FRCP data management system, known as the 
Veterans Tracking Application; 
FRCs use the Veterans Tracking Application to record subsequent 
actions taken on an enrollee's behalf. 

Activity: Communication; 
Description: Contacting enrollee or family at least every 30 days, 
unless otherwise negotiated. 

Activity: Coordination; 
Description: Identifying, communicating with, and coordinating with 
providers and case managers from federal, state, local, and private 
organizations, based on the needs of enrollees. 

Activity: Monitoring; 
Description: Monitoring the enrollee and goal achievement as contained 
in the Federal Individual Recovery Plan; 
modifying the Federal Individual Recovery Plan over time in response 
to enrollee's changing needs. 

Activity: Deactivation; 
Description: Changing enrollment status to "inactive" in the event 
that an enrollee dies, no longer needs or desires assistance, or is 
nonresponsive to FRC communications; 
otherwise, care coordination may continue over an enrollee's lifetime. 

Source: FRCP handbook (in draft). 

[End of table] 

According to FRCP policy, the FRC's primary responsibility is to 
develop and monitor progress of each enrollee as detailed in that 
person's Federal Individual Recovery Plan, which is created and 
implemented by the FRC with input from the enrollee and his or her 
family and clinical team. This plan is to be a comprehensive, client- 
centered plan that sets individualized goals for recovery and is 
intended to guide and support the enrollee through the continuum of 
care. FRCs update Federal Individual Recovery Plans to reflect 
changing conditions or enrollee goals. 

Based on their diagnoses and other factors, enrollees are likely to 
require a complex array of clinical and nonclinical services from 
multiple providers and facilities. (See table 3.) In providing care 
coordination services, the FRC may engage with an enrollee's health 
care providers, other care coordinators, and case managers, such as 
those with the military services' wounded warrior programs. As care 
coordinators, FRCs are generally not expected to directly provide the 
services needed by enrollees. However, FRCs may provide services 
directly to enrollees in certain situations, such as when they cannot 
determine whether a case manager has taken care of an issue for an 
FRCP enrollee, when asked to resolve complex problems, or when making 
complicated arrangements, for example, identifying and arranging 
admission to a substance abuse treatment program for a veteran who was 
beginning to develop violent behaviors and had refused to complete a 
VA drug rehabilitation treatment program. 

Table 3: Diagnoses of Federal Recovery Coordination Program (FRCP) 
Enrollees, September 2010: 

Diagnoses: Traumatic brain injury; 
Percentage of enrollees: 54%. 

Diagnoses: Psychological diagnosis; 
Percentage of enrollees: 43%. 

Diagnoses: Orthopedic injury; 
Percentage of enrollees: 25%. 

Diagnoses: Amputation; 
Percentage of enrollees: 20%. 

Diagnoses: Spinal cord injury; 
Percentage of enrollees: 19%. 

Diagnoses: Vision loss; 
Percentage of enrollees: 15%. 

Diagnoses: Medical diagnosis[A]; 
Percentage of enrollees: 13%. 

Diagnoses: Burn; 
Percentage of enrollees: 9%. 

Diagnoses: Chest injury; 
Percentage of enrollees: 9%. 

Diagnoses: Hearing loss; 
Percentage of enrollees: 9%. 

Diagnoses: Intra-abdominal injury; 
Percentage of enrollees: 9%. 

Diagnoses: Other[B]; 
Percentage of enrollees: 25%. 

Source: GAO analysis of FRCP data. 

Note: These diagnoses may not represent each enrollee's primary 
medical diagnosis. Additionally, approximately 70 percent of FRCP 
enrollees have more than one diagnosis. 

[A] "Medical diagnosis" includes diagnoses such as stroke, heart 
attack, and cancer. 

[B] "Other" includes diagnoses not otherwise covered in the table, 
such as anoxic brain injury and inhalation injury. 

[End of table] 

Problems Identifying Potential Enrollees and Reviewing Enrollment 
Decisions Make It Unclear Whether Those Needing FRCP Services Are 
Enrolled: 

It is unclear whether all of the eligible "severely wounded, ill, and 
injured" servicemembers and veterans who could benefit from the FRCP 
are being enrolled in the program. The FRCP cannot readily identify 
these individuals because the "severely wounded, ill, and injured" 
classification is not captured in existing data sources. Additionally, 
the program's broad eligibility criteria cannot be used systematically 
to identify potentially eligible servicemembers and veterans. Instead, 
the FRCP must rely on referrals from others to identify these 
individuals, although the program has also taken steps to identify 
potential enrollees through the FRCs' efforts at medical facilities 
and through a "look back" initiative to identify eligible veterans who 
were wounded prior to program implementation. In addition, the FRCs 
must exercise judgment in applying the program's criteria for 
enrollment determinations, and FRCP leadership does not systematically 
review these decisions to ensure that these criteria are applied 
appropriately so that referred individuals who could benefit from the 
program are enrolled, and that individuals who could be served by less 
intensive services are referred to other programs. 

The FRCP's Potential Enrollee Population Cannot Be Readily Identified 
from Existing Data Sources, but the FRCP Has Taken a Number of Steps 
to Identify Potentially Eligible Individuals: 

FRCP officials have experienced difficulties in identifying the 
potentially eligible population of "severely wounded, ill, or injured" 
servicemembers and veterans, and as a result, it is unclear whether 
all of these individuals who could benefit from care coordination 
services are enrolled in the program. The Senior Oversight Committee, 
which created the FRCP, developed a three-level care categorization 
system to differentiate the population of wounded servicemembers and 
veterans for different programs based on the severity of their 
conditions. In this system, 

* Category 1 servicemembers are those with mild wounds, illnesses, or 
injuries who are expected to return to duty in less than 180 days; 

* Category 2 servicemembers are those with serious wounds, illnesses, 
or injuries who are unlikely to return to duty in less than 180 days 
and possibly may be medically separated from the military; and: 

* Category 3 servicemembers are severely wounded, ill, or injured 
individuals whose medical conditions are highly likely to prevent 
their return to duty and also likely to result in medical separation 
from the military. 

Individuals who fall under category 3 may be considered for enrollment 
into the FRCP, while individuals falling under categories 1 or 2 may 
qualify for other types of programs. However, according to the FRCP 
Executive Director, these are administrative categories that are not 
captured in existing VA or DOD medical or benefits data systems or 
included in medical or benefits records. As a result, the FRCP cannot 
use this classification to systematically identify the population of 
potentially eligible severely wounded servicemembers and veterans 
using available data sources. In addition, the FRCP Executive Director 
and FRCs told us that the broad eligibility criteria developed for the 
FRCP must be used on a case-by-case basis to identify potentially 
eligible individuals for the program because these criteria require 
some judgment. Therefore, the criteria cannot be used systematically 
to identify the program's potentially eligible population. These 
criteria include both specific medical diagnoses and requirements that 
are somewhat subjective, such as whether an individual may benefit 
from a recovery plan. To decide whether potential enrollees may 
benefit from a recovery plan, FRCs reported that they evaluate the 
complexity of a situation by examining issues such as future medical 
needs, family dynamics, and any financial or legal problems--
information that is not readily available in any one data source. 

As a result, to identify potentially eligible individuals, the FRCP 
relies on referrals from others, including program officials and 
medical facility staff. Sources of referrals include, for example, 
wounded warrior program staff, Recovery Care Coordinators, and 
clinical treatment teams. Of the program officials and medical 
facility staff we spoke with who discussed referrals, more than half 
(25 of 47) had made a referral to the program. However, more than half 
(15 of 27) of the program officials and medical facility staff we 
interviewed who responded to questions on eligibility also felt that 
the FRCP eligibility criteria were unclear.[Footnote 9] In addition to 
relying on referrals, the FRCs also take steps to identify potential 
enrollees. Some FRCs stated that they review their facility's list of 
incoming severely wounded servicemembers and attend weekly 
multidisciplinary team meetings where hospital officials and medical 
staff discuss severely wounded patients' cases. 

In an attempt to ensure that eligible veterans who were wounded prior 
to the program's inception are enrolled in the program, the FRCP 
conducted a "look back" initiative in May 2010. Because no single data 
source contains sufficient information, the FRCP Executive Director 
told us that she combined five DOD and VA data sets and used multiple 
"proxy" factors to narrow the data from 40,000 veterans' records to 
the final list of potentially eligible veterans. For example, the 
Veterans Benefits Administration's 100 percent disability compensation 
list and medical diagnostic codes were used to help identify this 
population. Based on this analysis, the FRCP Executive Director 
reported that the program contacted approximately 300 potential 
enrollees to determine whether they could benefit from an FRC's 
assistance. As a result, 35 of those severely wounded veterans will be 
further evaluated for potential enrollment. 

According to the FRCP Executive Director, this analysis was 
prioritized to focus on severely wounded veterans who were most likely 
to need FRC assistance. The Executive Director told us that, as a 
result, the list was not comprehensive--for example, the program did 
not contact veterans who were already enrolled in VA's OEF/OIF Care 
Management Program under the assumption that they were already 
receiving adequate case management. Additionally, the FRCP Executive 
Director told us that identifying 35 veterans indicated that the FRCP 
is not reaching all potentially eligible veterans through its normal 
referral process or that information about the program is not reaching 
severely wounded veterans. The FRCP Executive Director added that once 
it is complete, this effort will be assessed to determine whether 
another "look back" is needed, but as of February 2011, leadership 
officials had not yet determined whether they would conduct a 
subsequent "look back." 

Enrollment Decisions Require FRC Judgment, and FRCP Leadership Does 
Not Systematically Review These Decisions to Ensure That Referred 
Individuals Who Could Benefit Are Enrolled: 

Following the identification of potentially eligible servicemembers 
and veterans, FRCs use a more thorough application of the program's 
eligibility criteria to evaluate these individuals for enrollment. The 
eligibility criteria are broad and require FRCs to exercise judgment 
with their enrollment decisions. However, FRCP leadership does not 
systematically review these decisions to ensure that referred 
individuals who could benefit from the program are enrolled while 
those requiring less intensive services are referred to other programs. 

Eligibility criteria for the program--developed by the Senior 
Oversight Committee--specify that enrollees: 

* be receiving acute care in a military treatment facility; 

* be diagnosed or referred for one or more of the following: spinal 
cord injury, burns, amputation, visual impairment, traumatic brain 
injury, or post-traumatic stress disorder; 

* be considered at risk for psychosocial complication; or: 

* may benefit from a recovery plan. 

Because some of these criteria are subjective, particularly whether an 
individual is at risk for psychosocial complications or would benefit 
from a recovery plan, the FRCs must use their judgment when deciding 
whether an individual should be enrolled in the program. According to 
the FRCP Executive Director, the program's criteria are intended to 
provide guidance for the FRCs, giving them the flexibility to enroll 
severely wounded servicemembers and veterans, rather than being 
restrictive. The Executive Director added that FRCs strive to enroll 
severely wounded servicemembers and veterans in cases where having an 
FRC can add value to existing case management efforts. 

To evaluate servicemembers and veterans for program eligibility, FRCs 
must make subjective assessments of the impact their care coordination 
efforts could have on potential enrollees. This involves FRCs making 
assessments of the severity of potential enrollees' medical conditions 
to determine future medical needs--such as rehabilitation--and 
nonmedical issues--such as caregiver status. FRCs obtain information 
from a number of sources, including DOD and VA medical records, as 
well as records from private sector providers. They may also discuss 
potential enrollees' situations with members of multidisciplinary 
teams providing medical treatment, family members, and the potential 
enrollees. At the end of the evaluation period, the FRC will consider 
a potential enrollee's need for care coordination based on the 
collected information and determine whether the individual should be 
enrolled in the program, provided temporary assistance, or referred to 
another program. 

While it is necessary for FRCs to use their judgment in making 
enrollment decisions, the FRCP does not systematically review the 
factors and reasons for enrolling, providing temporary assistance, or 
referring potentially eligible servicemembers and veterans to other 
programs. Systematic review could involve the use of a defined 
protocol for the review of eligibility decisions made by FRCs. 
According to federal internal control standards,[Footnote 10] agencies 
should establish ongoing internal control activities to provide 
reasonable assurance that decisions are consistent with applicable 
criteria--in this case, criteria designed to ensure that those in need 
of care coordination services are enrolled in the program. While the 
FRCs indicate in their data management system--the Veterans Tracking 
Application--whether they decided to enroll an individual, FRCP 
leadership told us they do not require that the FRCs record the 
factors they considered to support this decision. Additionally, FRCP 
leadership told us that while they closely review all enrollment 
decisions made by new FRCs, they do not perform similar reviews of 
decisions made by more experienced FRCs. Instead, FRCP leadership and 
experienced FRCs discuss the FRCs' recommended actions on newly 
referred individuals as part of weekly telephone conversations. 
However, FRCP officials acknowledged that these discussions with the 
FRCs may not be comprehensive and that there is no section in the 
Veterans Tracking Application dedicated to recording these 
discussions. Without specific documentation of the factors the FRCs 
considered when making their enrollment decisions and absent internal 
controls and systematic oversight of much of the enrollment process, 
it is difficult to determine whether severely wounded servicemembers 
and veterans who are referred and could benefit from the program are 
actually enrolled and severely wounded servicemembers and veterans who 
could be served by less intensive services are referred to other 
programs. Additionally, this issue could become even more problematic 
as the program's enrollment continues to increase and FRCP leadership 
has to review more enrollment decisions. 

The FRCP Faces Challenges in Determining Staffing Needs and Has Not 
Clearly Defined or Documented Its Processes for Managing FRCs' 
Caseloads, Making Staffing Decisions, and Placing FRCs: 

Several challenges confront the FRCP in determining staffing needs for 
the program, including how to manage FRCs' caseloads, deciding when VA 
should hire FRCs, and determining where to place them in the field to 
best serve current and potential enrollees. The FRCP has not 
established a formal caseload size for FRCs because there are no 
comparable criteria upon which to determine caseload size because of 
the program's unique care coordination activities. Also, while 
establishing an appropriate caseload size for FRCs may help FRCP 
leadership determine how many FRCs VA should hire, it remains 
difficult for FRCP leadership to determine when VA should hire FRCs. 
Finally, the FRCP lacks a clear and consistent rationale for making 
decisions about where to place FRCs in the field. 

FRCs Have Expressed Concerns about Heavy Caseloads, and the FRCP Is 
Developing a Workload Assessment Tool That Should Help Address This 
Concern: 

The FRCs we spoke with expressed concerns about the high number of 
enrollees assigned to them and cited the need for improved caseload 
management. Specifically, 11 of the 15 FRCs we interviewed[Footnote 
11] identified inadequate caseload management as a concern. Eight of 
these FRCs expressed concerns about the large number of cases assigned 
to them. As of September 30, 2010, FRCs' caseloads ranged from 25 to 
48, with two-thirds of the FRCs (10 of 15) having caseloads that 
exceeded the informal target ratio of 1 FRC for every 30 enrollees 
established by the FRCP Executive Director to manage FRC caseloads. 
Some FRCs told us that the large number of cases required them to work 
long hours and sometimes forced them to limit the amount of time that 
they could devote to an enrollee. In addition, more than half of the 
FRCs (8 of 15) expressed concerns that FRCP leadership does not 
adequately account for the services required by existing enrollees in 
their caseloads when assigning new cases. For example, one FRC told us 
that the types of cases assigned to her were stressful. She indicated 
that she had been assigned two enrollees with terminal conditions 
because she was skilled at managing the issues related to these types 
of cases, but she is now reluctant to take another terminally ill 
enrollee because it is emotionally draining to deal with end-of-life 
issues. However, an FRCP leadership official told us that FRCs have 
the flexibility to forward a referral to the FRCP central office for 
assignment to another FRC as a means of managing their existing 
caseloads. 

According to the FRCP Executive Director, an appropriate caseload is 
difficult to determine because care coordination is a new type of 
function, and there are no comparable criteria against which to 
measure and base caseload size for this program because of its unique 
activities. Additionally, the FRCs' caseloads are dynamic in that the 
needs of each enrollee differ and may change over time. For example, 
out of a caseload of 30 clients, 5 may need intensive crisis 
management, while the remaining 25 enrollees may only need periodic 
contact or limited services. However, as noted by FRCP leadership and 
some FRCs, the needs of these enrollees, and consequently, the time 
required of an FRC, may change as enrollees move through different 
stages of the continuum of care. 

As a means of managing FRCs' caseloads, the FRCP Executive Director 
cited two actions in particular that FRCP leadership uses to assess 
and manage FRC caseloads. 

* FRCP leadership uses an informal FRC-to-enrollee target ratio of 1 
to 30 (with a targeted range of 25 to 35 enrollees per FRC), which is 
based on the FRCP Executive Director's experience in managing the 
program over time. 

* Weekly telephone calls with each FRC are used by FRCP leadership to 
discuss issues related to their assigned cases and to gauge workload 
burden. 

The FRCP Executive Director told us that the program is developing a 
customized workload assessment tool to help balance FRCs' caseloads--
in other words, to ensure that an FRC's caseload mix is manageable. 
The objective of the workload assessment tool is to identify specific 
enrollee characteristics, such as medical diagnosis, and to correlate 
each characteristic with the amount of time an FRC would be required 
to spend on addressing issues related to it. One method being 
considered is the assignment of a point value to each identified 
enrollee characteristic. Adding up the number of points for the 
characteristics of all enrollees in an FRC's caseload would provide an 
estimate of that FRC's workload burden. However, according to the FRCP 
Executive Director, the development of such a tool has been difficult, 
primarily because the enrollee characteristics that existing workload 
assessment tools use to determine how much time it takes to address an 
issue are not relevant to the care coordination activities that FRCs 
perform. As a result, program leadership continues to consider 
different methods of assessing FRCs' workloads, including measurement 
tools that have already been validated for other purposes, to identify 
a method that could potentially be relevant for the program. The FRCP 
Executive Director is uncertain how long it will take to develop a 
workload assessment tool and has not established timelines to complete 
this effort. Without a workload assessment tool, the program does not 
have the data it needs to develop a more comprehensive caseload 
management strategy and to better determine appropriate caseload size 
for FRCs. 

FRCP Staffing Decisions Are Based on Ongoing Program Monitoring 
Efforts, but This Process Has Not Been Clearly Defined or Documented: 

While establishing appropriate FRC caseloads should help FRCP 
leadership better determine how many FRCs VA should hire, determining 
when VA should hire FRCs has been another staffing challenge. 
Currently, the FRCP Executive Director's decisions about when VA 
should hire FRCs are based on various ongoing monitoring efforts. The 
FRCP Executive Director told us that staffing decisions regarding FRCs 
are difficult to make because the FRCP cannot predict the number of 
potentially eligible servicemembers and veterans, which is affected by 
the OEF/OIF conflicts. In the absence of being able to project the 
number of potentially eligible servicemembers and veterans, the FRCP 
Executive Director said she uses other methods to predict future 
trends and guide the staffing process. One method involves monitoring 
FRCs' workloads as an indicator that workload levels are increasing 
and new FRCs are needed. In this regard, the FRCP Executive Director 
told us that FRCP leadership conducts weekly telephone calls with each 
FRC to discuss issues related to their caseloads. The FRCP Executive 
Director told us that another method she uses to predict staffing 
needs is through the analysis of the number of new referrals and 
enrollment rates in the program, which she uses to create a quarterly 
report that highlights the projected number of FRCs that the program 
may need. For example, the average number of new referrals grew from 
25 a month in 2008 to 35 a month in 2009. VA hired five FRCs in 
January 2010 in part because of this increase in the number of 
referrals and the expected resulting increase in the number of 
enrolled servicemembers and veterans. The FRCP Executive Director told 
us that the referral data collected in 2010 show that the number of 
new referrals continued to increase and averaged 50 a month, which 
indicates a continuing need for more FRCs. According to the FRCP 
Executive Director, she routinely shares this information with the 
Secretary of Veterans Affairs as advance notice that a request for 
additional FRCs may be forthcoming because it takes about 6 months for 
VA to hire a new FRC. The FRCP Executive Director told us that the 
program's ongoing monitoring efforts are the most logical approach for 
determining when and how many FRCs VA should hire in the absence of 
knowing the number of potentially eligible servicemembers and veterans. 

While these methods appear to be reasonable given the lack of overall 
data on the numbers of severely wounded servicemembers and veterans, 
the staffing process is not well documented. Internal control 
standards applicable to all federal agencies state that an agency 
should effectively communicate its policies and procedures by 
providing clear documentation that is readily available for 
examination. Consistent with this internal control standard, we would 
expect the FRCP to have documented procedures outlining its process 
for making staffing decisions. FRCP leadership documented staffing 
projections for fiscal year 2010 in the program's annual operating 
plan, citing that ongoing analysis of referrals and enrollment rates 
was important in making those projections. However, the process used 
by program leadership--specifically how the referral and enrollment 
data are used in making staffing decisions--has not been clearly 
defined or documented in the operating plan or any of the other 
program policies or procedures. By documenting this information, the 
FRCP would have greater assurance that the process developed by the 
current leadership will be maintained during management changes. 

The FRCP Lacks a Clear and Consistent Rationale for Making FRC 
Placement Decisions: 

Deciding where to place FRCs to best serve current and potential 
enrollees' needs is another key staffing issue, despite the fact that 
FRCs often coordinate services for enrollees who are located 
throughout the country and may not be receiving care at the facility 
where their assigned FRC is located. The FRCP's basis for making 
decisions about where to place FRCs has varied over time, and the 
program currently lacks a clear and consistent rationale for making 
FRC placement decisions. As of September 2010, 20 FRCs were located at 
10 facilities. (See figure 1.) 

Figure 1: Location and Number of Federal Recovery Coordinators (FRC), 
September 2010: 

[Refer to PDF for image: illustrated U.S. map] 

Locations of the following are depicted on the map: 

Military treatment facility: 
Brooke Army Medical Center, Texas (4 FRCs); 
Dwight D. Eisenhower Army Medical Center (2 FRCs); 
National Naval Medical Center, Maryland (3 FRCs); 
Naval Hospital Camp Pendleton, California (1 FRC); 
Naval Medical Center San Diego, California (3 FRCs); 
Walter Reed Army Medical Center, District of Columbia (3 FRCs) 

VA medical center: 
Michael E. DeBakey VA Medical Center, Texas (1 FRC); 
Providence VA Medical Center, Rhode Island (1 FRC); 
Tampa Polytrauma Rehabilitation Center, Florida (1 FRC). 

Wounded warrior program: 
U.S. Special Operations Command, Florida (1 FRC). 

Source: GAO, based on Federal Recovery Coordination Program data. 

[End of figure] 

When the FRCP began operating in 2008, eight FRCs were placed at the 
three military treatment facilities where the majority of severely 
wounded servicemembers were receiving treatment. According to the FRCP 
Executive Director, the placement of FRCs at military treatment 
facilities helped with the identification of servicemembers who could 
benefit from FRCP services. In addition, some FRCs told us that being 
located at the military treatment facilities allowed them to develop 
relationships with the enrollees, their families, and the case 
managers who would be providing direct services to the enrollees. 
However, as the program expanded, placement of some FRCs was not based 
on a rationale or an analysis of where FRCs could provide the maximum 
benefit to severely wounded servicemembers and veterans. For example, 
some DOD and VA officials we spoke with expressed concerns about the 
FRCP's placement decisions, particularly the placement of FRCs at 
facilities that do not treat a large population of severely wounded 
servicemembers or veterans. DOD officials told us that it was not 
clear why there were FRCs assigned to a military treatment facility 
that typically does not treat severely wounded servicemembers. 
Similarly, a VA medical center official stated that it was unclear why 
FRCs were initially placed at two VA medical centers that had few FRCP 
enrollees being treated there, rather than at VA medical centers where 
a significant number of severely wounded veterans may be receiving 
treatment. There was no official FRCP documentation that explained the 
basis for these decisions, which were made by FRCP officials who are 
no longer with the program. 

After the FRCP leadership changed in July 2008, decisions to place 
FRCs have been based on several factors. According to the FRCP 
Executive Director, some placement decisions focused on ensuring that 
enough FRCs were in place to meet the demands of the FRCP workload by 
replacing FRCs who had left the program and by adding FRCs at 
facilities where only one FRC was located. She explained that where 
possible, it is helpful to have at least two FRCs at each facility so 
that there can be backup support, particularly for administrative 
purposes such as coverage, when an FRC is on leave. However, the FRCP 
Executive Director told us that more recently--from March 2010 through 
September 2010--FRC placement decisions have primarily been based on 
requests or recommendations from DOD and VA officials. For example, in 
June 2010, the FRCP relocated an FRC to a military wounded warrior 
program headquarters facility in response to a request from the 
program's director. FRCP officials have also decided to place some new 
FRCs at two VA medical centers where servicemembers and veterans with 
polytrauma injuries receive care, based on recommendations from DOD 
and VA officials. 

The FRCP Executive Director explained that the FRCP had not 
established a systematic rationale for FRC placement because the 
program initially lacked the data upon which to base these 
determinations. Additionally, she told us that every placement of an 
FRC at a VA or DOD facility is a negotiation and depends on the 
facility's ability to accommodate an FRC, including the provision of 
work space and equipment. However, she told us that she and other FRCP 
leadership officials have begun to think about how to improve the 
FRCP's process for deciding where to place FRCs. In August 2010, the 
FRCP Executive Director explained that a planned update of the 
Veterans Tracking Application would collect additional information 
that would allow FRCP officials to identify the location of 
individuals who refer potential enrollees.[Footnote 12] She 
anticipates being able to use these data to identify the locations and 
facilities where the most referrals are being made. According to the 
FRCP Executive Director, this information along with other factors, 
such as placement recommendations from DOD and VA officials, could be 
used in making future placement decisions. However, as of December 
2010, she had not established a specific time frame for this effort. 
Developing a clear and consistent rationale for placing FRCs, which 
includes a systematic analysis of program data, should help ensure 
that FRCs are located where they could provide the maximum benefit to 
current and potential enrollees. 

The FRCP Faces Challenges That Limit Its Ability to Coordinate Care 
but Is Taking Steps to Address Them: 

FRCs and others identified challenges that can limit the FRCP's 
efforts to coordinate the services needed by severely wounded 
servicemembers and veterans. One challenge involves limitations on the 
FRCP's ability to share information with the large number of programs 
that provide care coordination and case management services to wounded 
servicemembers and veterans. These limitations--which are the result 
of restrictions on the disclosure of enrollee information and data 
systems' incompatibility--have sometimes resulted in confusion and the 
duplication of services for enrollees. Efforts by the FRCP to improve 
information sharing are ongoing. Another challenge is that FRCs often 
have difficulty obtaining resources from the facilities at which they 
are located--such as telephones, computers, and private office space-- 
that they need to perform their care coordination activities, 
including communicating with enrollees across the country. This can 
affect the quality of services to enrollees, and the FRCP is working 
to resolve these logistical issues. 

Coordination among the FRCP and DOD and VA Case Management Programs Is 
Impeded by Limitations on Their Ability to Share Information, and 
Efforts to Address These Limitations Are Ongoing: 

Coordination among DOD and VA programs that provide care coordination 
and case management is difficult because of the large number of such 
programs that exist to address the needs of wounded servicemembers and 
veterans and the limitations in the ability of these programs to share 
information. Although these programs vary in terms of the severity of 
the injuries among the servicemembers or veterans they serve and the 
specific types of services they coordinate, many programs have similar 
functions. (See table 4.) 

Table 4: Characteristics of Major Department of Defense (DOD) and 
Department of Veterans Affairs (VA) Programs for Seriously and 
Severely Wounded Servicemembers and Veterans: 

Program: VA/DOD Federal Recovery Coordination Program (FRCP); 
Severity of enrollees' injuries[A]: Severe; 
Title of care coordinator or case manager: Federal Recovery 
Coordinator (FRC); 
Involvement in the continuum of care: Acute care: [Check]; 
Involvement in the continuum of care: Rehab: [Check]; 
Involvement in the continuum of care: Reintegration: [Check]; 
Involvement in the continuum of care: Lifetime follow-up: [Check]; 
Type of services provided: Clinical: [Check]; 
Type of services provided: Nonclinical: [Check]; 
Type of services provided: Recovery plan: [Check]. 

Program: DOD Recovery Coordination Program; 
Severity of enrollees' injuries[A]: Serious; 
Title of care coordinator or case manager: Recovery Care Coordinator; 
Involvement in the continuum of care: Acute care: [Check]; 
Involvement in the continuum of care: Rehab: [Check]; 
Involvement in the continuum of care: Reintegration: [Check]; 
Involvement in the continuum of care: Lifetime follow-up: [Check]; 
Type of services provided: Clinical: [Empty]; 
Type of services provided: Nonclinical: [Check]; 
Type of services provided: Recovery plan: [Check]. 

Program: Army Warrior Transition Units; 
Severity of enrollees' injuries[A]: Serious to severe; 
Title of care coordinator or case manager: Triad of nurse case 
manager, squad leader, and physician; 
Involvement in the continuum of care: Acute care: [Check]; 
Involvement in the continuum of care: Rehab: [Check]; 
Involvement in the continuum of care: Reintegration: [Check]; 
Involvement in the continuum of care: Lifetime follow-up: [Empty]; 
Type of services provided: Clinical: [Check]; 
Type of services provided: Nonclinical: [Check]; 
Type of services provided: Recovery plan: [Check]. 

Program: Military wounded warrior programs[B,C]; 
Severity of enrollees' injuries[A]: Serious to severe; 
Title of care coordinator or case manager: Case manager or Advocate 
(title varies by service); 
Involvement in the continuum of care: Acute care: [Check]; 
Involvement in the continuum of care: Rehab: [Check]; 
Involvement in the continuum of care: Reintegration: [Check]; 
Involvement in the continuum of care: Lifetime follow-up: [Empty]; 
Type of services provided: Clinical: [Check]; 
Type of services provided: Nonclinical: [Check]; 
Type of services provided: Recovery plan: [Check]. 

Program: VA OEF/OIF Care Management Program[D]; 
Severity of enrollees' injuries[A]: Mild to severe; 
Title of care coordinator or case manager: Case manager, Transition 
Patient Advocate[E]; 
Involvement in the continuum of care: Acute care: [F]; 
Involvement in the continuum of care: Rehab: [Check]; 
Involvement in the continuum of care: Reintegration: [Check]; 
Involvement in the continuum of care: Lifetime follow-up: [Check]; 
Type of services provided: Clinical: [Check]; 
Type of services provided: Nonclinical: [Check]; 
Type of services provided: Recovery plan: [Check]. 

Program: VA Spinal Cord Injury and Disorders Program; 
Severity of enrollees' injuries[A]: Mild to severe; 
Title of care coordinator or case manager: Nurse, social worker; 
Involvement in the continuum of care: Acute care: [Check]; 
Involvement in the continuum of care: Rehab: [Check]; 
Involvement in the continuum of care: Reintegration: [Check]; 
Involvement in the continuum of care: Lifetime follow-up: [Check]; 
Type of services provided: Clinical: [Check]; 
Type of services provided: Nonclinical: [Check]; 
Type of services provided: Recovery plan: [Check]. 

Program: VA Polytrauma System of Care; 
Severity of enrollees' injuries[A]: Serious to severe; 
Title of care coordinator or case manager: Social work and nurse case 
managers; 
Involvement in the continuum of care: Acute care: [F]; 
Involvement in the continuum of care: Rehab: [Check]; 
Involvement in the continuum of care: Reintegration: [Check]; 
Involvement in the continuum of care: Lifetime follow-up: [Check]; 
Type of services provided: Clinical: [Check]; 
Type of services provided: Nonclinical: [Check]; 
Type of services provided: Recovery plan: [Check]. 

Source: GAO analysis of DOD and VA program information. 

Note: The characteristics listed in this table are general 
characteristics of each program; individual circumstances may affect 
the enrollees served and services provided by specific programs. 

[A] For the purposes of this table, we have categorized the severity 
of enrollees' injuries according to the injury categories established 
by the DOD and VA Wounded, Ill, and Injured Senior Oversight 
Committee. Servicemembers with mild wounds, illness, or injury are 
expected to return to duty in less than 180 days; those with serious 
wounds, illness, or injury are unlikely to return to duty in less than 
180 days and possibly may be medically separated from the military; 
and those who are severely wounded, ill, or injured are highly 
unlikely to return to duty and also likely to medically separate from 
the military. These categories are not necessarily used by the 
programs themselves. 

[B] The military wounded warrior programs are the Army Wounded Warrior 
Program, Marine Wounded Warrior Regiment, Navy Safe Harbor, Air Force 
Warrior and Survivor Care Program, and Special Operations Command's 
Care Coalition. 

[C] An FRC placed at Special Operations Command's Care Coalition 
headquarters coordinates clinical and nonclinical care for Care 
Coalition and other FRCP enrollees. 

[D] OEF/OIF refers to Operation Enduring Freedom and Operation Iraqi 
Freedom. 

[E] An OEF/OIF care manager supervises the case managers and 
transition patient advocates and may also maintain a caseload of 
wounded veterans. 

[F] According to VA, in some instances, patients are transferred to VA 
medical facilities while still in the acute phase of the care 
continuum and may receive services from VA care management or 
polytrauma program staff. 

[End of table] 

Many recovering servicemembers and veterans are enrolled in more than 
one program. For example, in September 2010, approximately 84 percent 
of FRCP enrollees were also enrolled in a military service wounded 
warrior program. According to one FRC, his enrollees have, on average, 
eight case managers who are affiliated with different programs. 
Individuals enrolled in multiple programs may have recovery plans or 
goals that have been developed by different programs. Moreover, some 
case managers of other programs consider themselves to be the single 
point of contact for their enrollees, even those enrolled in the FRCP. 
Because the majority of FRCP enrollees are enrolled in more than one 
program, there is a high likelihood that without adequate information 
exchange and coordination, FRCs and case managers could duplicate one 
another's efforts, confuse enrollees and families, waste resources, or 
mistakenly believe that someone else has taken care of a task for an 
enrollee. The extent of overlap and the lack of information sharing by 
the FRCP have prompted some programs to limit FRCs' involvement with 
servicemembers when they are receiving initial medical treatment at a 
military treatment facility. At two of the military treatment 
facilities we visited, for example, a military program serving wounded 
servicemembers delays referrals to the FRCP until a servicemember 
approaches the point when he or she is preparing to transition to 
another facility or VA. 

Information Disclosure Requirements Limited the FRCP's Information 
Sharing with DOD's Wounded Warrior Programs: 

Prior to January 2011, VA had not completed public disclosure actions 
necessary to enable the sharing of information from the Veterans 
Tracking Application, the information system used by the FRCP that 
contains each enrollee's personal information and Federal Individual 
Recovery Plan. As a result, VA management had advised the FRCP that 
the program could not provide staff of non-VA programs (such as those 
affiliated with DOD) with its enrollees' personally identifiable 
information, such as names, addresses, Social Security numbers, and 
details of Federal Individual Recovery Plans.[Footnote 13] 
Specifically, VA had not completed the System of Records Notification 
process for the Veterans Tracking Application, a process required by 
the Privacy Act of 1974[Footnote 14] that requires federal agencies to 
publish in the Federal Register a notice of the existence, purpose, 
and routine uses of every "system of records" that contains 
information that may be linked to individuals.[Footnote 15] 

Although this limitation did not prevent FRCs from performing their 
care coordination responsibilities, it has been a source of 
frustration for others. Specifically, officials of several of DOD's 
wounded warrior programs contend that the inability to receive 
enrollment information from the FRCP has caused difficulties. The 
director of one program, for example, told us that not having the 
names of servicemembers enrolled in the FRCP resulted in a situation 
in which an FRC and a wounded warrior program Recovery Care 
Coordinator were not aware that the other was involved in coordinating 
care for the same servicemember and had unknowingly established 
conflicting recovery goals for this individual. In this case, a 
servicemember with multiple amputations was advised by his FRC to 
separate from the military in order to receive needed services from 
VA, whereas his Recovery Care Coordinator set a goal of remaining on 
active duty.[Footnote 16] These conflicting goals caused considerable 
confusion for this servicemember and his family. Furthermore, 
leadership officials of two of the military services' wounded warrior 
programs told us that they have instructed their staff not to make 
referrals to the FRCP to avoid confusion and potential duplication of 
activities, citing issues associated with information sharing. 

In August 2010, prompted by the FRCP, VA initiated the public- 
disclosure process to facilitate information sharing. In December 
2010, VA published a notice in the Federal Register that describes the 
compilation of information in the Veterans Tracking Application and 
routine uses of that information.[Footnote 17] VA received no comments 
on the notice during the public comment period, which ended on January 
10, 2011. The new system of records became effective on that date and 
the FRCP was able to share certain enrollee information, such as the 
names of enrollees, with DOD programs. 

DOD and VA Data System Incompatibility Impedes Information Sharing 
among the FRCP and DOD's Wounded Warrior Programs: 

Another factor that limits information sharing is the inability of the 
information systems used by the FRCP, the DOD Recovery Coordination 
Program, and the five military services' wounded warrior programs to 
exchange information directly with one another. As a result, FRCs 
cannot readily access information from data systems used by case 
management programs about their enrollees and information about an 
individual cannot be easily transferred among systems. To help address 
this issue, the FRCP has spearheaded an effort, known as the 
Information Sharing Initiative, to identify an approach for the direct 
exchange of information between DOD and VA care coordination and case 
management information systems in the future. The FRCP Executive 
Director explained that this initiative primarily includes identifying 
the data that need to be exchanged as well as identifying the data 
systems where these data originate and subsequently developing a 
technical solution to electronically exchange this information. 
Further, she noted that the Information Sharing Initiative is a 
grassroots effort and that work on the initiative has been performed 
by DOD and VA employees in addition to their normal duties, making a 
completion date difficult to estimate. An official from the 
Interagency Program Office, which oversees major information 
technology initiatives jointly undertaken by DOD and VA, said that the 
Information Sharing Initiative was a well-considered initial step but 
notes that the ultimate goal of direct information exchange among 
programs' information systems faces daunting challenges, such as 
resolving conflicting DOD and VA policies pertaining to information 
exchange. We have previously reported on DOD's and VA's efforts to 
electronically exchange health care information, including the 
departments' progress toward increasing their capabilities to share 
medical and nonmedical history and physical exam data.[Footnote 18] We 
have found that despite the departments' progress, their efforts to 
meet clinicians' evolving needs to exchange health information and to 
create a single lifetime electronic record for each servicemember, 
which is intended to streamline the transition of electronic records 
between the two departments, are ongoing. 

Recognizing that these limitations on information sharing exist, the 
FRCP is also taking steps to emphasize FRCs' principal role of 
coordinating with case managers rather than providing services to 
enrollees themselves, which should help prevent unintentional 
duplication of effort. Because FRCs may provide a direct service in 
some instances, proper information sharing is necessary so that staff 
from multiple programs may not unknowingly perform the same task for 
an enrollee. For example, an FRC told us that in one instance there 
were five case managers working on the same life insurance issue for 
an individual. According to the FRCP Executive Director, the Federal 
Individual Recovery Plan process has been improved to encourage 
coordination by FRCs and also to reinforce their primary role as care 
coordinators. To accomplish these objectives, in January 2011 the FRCP 
upgraded the Veterans Tracking Application, in which Federal 
Individual Recovery Plans are maintained, by adding a record of the 
names of the case managers who are responsible for completing 
activities linked to enrollees' planning goals. In addition, the 
Veterans Tracking Application began displaying indicators to inform 
each FRC about the completion status of every goal-related activity 
planned for each enrollee, based on the completion dates that the FRCs 
put into the system. The FRCP Executive Director believes that such an 
indicator system, when linked to the names of the case managers who 
are responsible for completing the activities, will reinforce the 
FRCs' care coordination role by encouraging them to actively follow up 
with others on the status of individual tasks rather than taking on 
these tasks themselves. 

FRCs Face Difficulties in Obtaining Access to Equipment, Technology 
Support, and Work Space at Their Medical Facilities, but FRCP 
Leadership Is Taking Steps to Remedy These Issues: 

FRCs and others identified several types of logistical problems that 
have affected the FRCs' ability to carry out their responsibilities in 
dealing with FRCP enrollees and coordinating with wounded warrior 
programs. These issues center around three specific areas: provision 
of equipment (such as computers, printers, landline telephones, and 
BlackBerrys), technology support (such as equipment maintenance, 
software upgrades, and systems security), and private work space at 
the medical facilities. 

* Provision of equipment. Most of the FRCs' work is done using 
computers, accessing data management systems, and communicating with 
enrollees and DOD and VA facility staff by e-mail and phone. However, 
about half of the FRCs told us that they have been hindered in their 
ability to perform their care coordination responsibilities by the 
lack of appropriate technology resources at the facilities at which 
they work. Some FRCs expressed frustration with delays in obtaining 
appropriate computer or communications equipment when they first 
reported to their facilities, and this experience was echoed by nearly 
all of the FRCs hired in January 2010. For example, one FRC said she 
waited more than 6 weeks at the facility to receive a DOD computer and 
landline telephone. Another FRC reported that he has found that e-mail 
is an effective mode of communication with enrollees with traumatic 
brain injuries because he can provide detailed instructions to them, 
but when he was hired he did not receive a DOD computer and a landline 
telephone with long-distance calling capability for 8 months. 
Consequently, he had to resort to mailing letters and brochures to 
current and potential enrollees. 

* Technology support. In addition to the lack of equipment, some FRCs 
cited the lack of technology support as a factor that hindered their 
care coordination activities. Technological support includes functions 
such as connectivity to information systems, installing security 
systems, and equipment upgrading and repair. An FRCP deputy director 
told us that the lack of such support is often experienced by new 
FRCs, but it is also an ongoing issue for many, especially after a 
facility computer system is upgraded and the FRCs' equipment becomes 
incompatible. Additionally, several FRCs have had difficulty with 
their BlackBerrys, either because the facility was unable to install a 
security patch needed to access e-mails or because poor reception made 
the device unusable. Some FRCs also reported their inability to access 
DOD medical records (although this issue is beyond the scope of a 
single program to address)--for example, FRCs located at VA medical 
centers must ask FRCs at military treatment facilities to access 
enrollees' DOD records and then fax them to the FRCs at the VA medical 
centers. Finally, FRCP officials noted that equipment repair has been 
a problem for some FRCs--one FRC told us that she had to use a 
malfunctioning laptop computer issued to her by the local VA medical 
center for 8 months. 

* Work space. Some FRCs noted that they had been assigned work space 
at the facility that was unsuitable for conducting sensitive 
conversations with enrollees, family members, and coworkers. At a 
major medical center, we observed that FRCs were located in tightly 
spaced cubicles that allowed nearby staff to easily overhear their 
conversations. A recently transferred FRC told us that when she 
arrived at her new medical center, she found that she had no office 
and had been located in an open room that serves as the call center 
for triage nurses. Lacking the privacy needed to make confidential 
calls to her enrollees, this FRC resorted to making sensitive phone 
calls from her car in the parking lot. At another treatment facility, 
an FRC who shared an office with staff from another program had to 
take phone calls with enrollees in the stairwell in order to have 
privacy. Finally, two recently hired FRCs were not only placed in the 
same office but also had to share the same desk. 

The provision of equipment, technology support, and work space is 
covered by memoranda of agreement between the FRCP and the DOD and VA 
facilities where FRCs are located. However, an FRCP deputy director 
told us that obtaining compliance with the memoranda of agreement at 
some facilities is an ongoing challenge and that equipment maintenance 
and systems upgrades are persistent issues for all FRCs. In some 
instances, after FRCs had made repeated requests for needed resources 
without result, the FRCP Executive Director intervened with medical 
center officials or through the Senior Oversight Committee to obtain a 
resolution. A leadership official for a wounded warrior program told 
us that some military medical centers have difficulty satisfying 
requests for equipment and space from programs such as the FRCP 
because these facilities house and support various DOD and VA support 
programs and all make requests for resources. This official pointed 
out that at one military treatment facility, a military case manager 
was relocated in order to make an office available to an FRC. An FRCP 
deputy director added that given the frequent turnover of military 
staff, medical center officials are sometimes unaware that their 
facility is responsible for providing resources and services to FRCs. 

FRCP officials reviewed existing memoranda of agreement between the 
FRCP and DOD and VA medical facilities to determine where improvements 
could be made to ensure that the FRCs have the tools and privacy 
required to do their work. The program has developed three new 
templates for memoranda of agreement that will be used when FRCs are 
located in new settings: one each for military treatment facilities, 
VA medical centers where servicemembers and veterans with polytrauma 
injuries receive care, and military wounded warrior programs. These 
new memoranda are more detailed than the previous versions, and they 
identify who is responsible for providing specific resources and 
services. The FRCP is using the revised agreements in its negotiations 
for logistical support for newly placed FRCs at two VA medical centers 
and with the Special Operations Command wounded warrior program. 
Following implementation of the new memoranda of agreement, the FRCP 
plans to revise existing agreements to make them consistent with the 
newer versions, but no specific timetable has been established to 
complete these revisions. 

Conclusions: 

Since its inception, the FRCP has increased the number of enrollees, 
enlarged its staff considerably, and expanded the number of locations 
where FRCs are assigned. However, the program faces significant 
challenges as it matures. As the first joint care coordination program 
for DOD and VA, the FRCP represents a new paradigm in patient support 
for the departments. Because of its unprecedented nature, the program 
cannot refer to preexisting data or policies and procedures to manage 
the program, and as a result, FRCP leadership had to develop 
management processes as the program was being implemented and has 
largely relied on informal processes to oversee and manage key aspects 
of the program. However, now that the program has been operating for 
several years and continues to grow, it has become apparent that the 
program would benefit from more definitive management processes to 
strengthen program oversight and decision making. 

While the program has overcome some early setbacks and has established 
processes related to enrollment and staffing, these processes are not 
clearly documented or systematic. Because enrollment decisions are not 
well documented or systematically reviewed by FRCP leadership, it is 
unclear whether referred servicemembers and veterans who need FRC 
services are being enrolled in the program. Additionally, as the 
number of individuals enrolled in the program steadily increases, it 
will be important for the FRCP to appropriately balance FRCs' workload 
to ensure that enrollees receive the services they need and to prevent 
FRC burnout. While program leadership recognizes this issue and is 
developing a customized workload tool, there is no firm timeline for 
the completion of this effort. The FRCP also needs clearly documented 
processes and criteria for guiding staffing and placement decisions. 
Without this, it will be difficult to provide continuity to subsequent 
program leadership and to place FRCs where they would best serve the 
needs of current and future enrollees. 

Some of the daunting challenges facing FRCs and the program are beyond 
the capability of the program's leadership to resolve. The exchange of 
information among DOD and VA data systems, in particular, has been a 
long-standing issue and will require interdepartmental action. 
Similarly, the duplication of effort resulting from the proliferation 
and overlap of DOD and VA programs that support recovering 
servicemembers and veterans can best be resolved through 
interdepartmental coordination and action. 

Recommendations for Executive Action: 

We recommend that the Secretary of Veterans Affairs direct the 
Executive Director of the FRCP to take four actions: 

1. Ensure that referred servicemembers and veterans who need FRC 
services are enrolled in the program by establishing adequate internal 
controls regarding the FRCs' enrollment decisions. To accomplish this, 
the FRCP leadership should: 

* require FRCs to record in the Veterans Tracking Application the 
factors they consider in making an enrollment decision, 

* develop and implement a methodology and protocol for assessing the 
appropriateness of enrollment decisions, and: 

* refine the methodology as needed. 

2. Complete development of the FRCP's workload assessment tool that 
will enable the program to assess the complexity of services needed by 
enrollees and the amount of time required to provide services to 
improve the management of FRCs' caseloads. 

3. Clearly define and document the FRCP's decision-making process for 
determining when and how many FRCs VA should hire to ensure that 
subsequent FRCP leadership can understand the methods currently used 
to make staffing decisions. 

4. Develop and document a clear rationale for the placement of FRCs, 
which should include a systematic analysis of data, such as referral 
locations, to ensure that future FRC placement decisions are strategic 
in providing maximum benefit for the program's population. 

Agency Comments and Our Evaluation: 

DOD and VA each provided comments on a draft of this report. In its 
comments, DOD stated that it continues to work with VA to fully 
integrate their efforts and to increase collaboration between the two 
departments. (DOD's comments are reprinted in appendix II.) In its 
comments, VA stated that it generally agrees with GAO's conclusions 
and concurs with our recommendations to the Secretary. (VA's comments 
are reprinted in appendix III.) VA's responses to each of our 
recommendations are as follows: 

* To ensure that referred servicemembers and veterans who need FRC 
services are enrolled in the program, VA indicated that the FRCP will 
document decisions and factors used to assess a potential enrollee's 
eligibility for the program. In addition, the program will establish 
clear documentation requirements according to a defined protocol 
within the program's data management system. 

* To complete the development of the FRCP's workload assessment tool, 
VA indicated that the FRCP will continue field-testing a new 
assessment tool, which will require at least a year to complete. 

* To document the decision-making process for determining when and how 
many FRCs VA should hire, VA stated that the FRCP will clearly 
document the current process used for making staffing decisions. In 
addition, the staffing processes and plans will be updated annually in 
the FRCP business operation planning document. 

* To develop and document a clear rationale for the placement of FRCs, 
VA indicated that the FRCP will develop an FRC placement strategy 
based upon a systematic analysis of data over the next 6 months. This 
process will be documented and updated annually in the FRCP business 
operation planning document. 

VA provided an additional comment regarding the progress made toward 
the exchange of data between VA and DOD's wounded warrior information 
systems. VA stated that it anticipates that an initial set of data 
will be available for exchange between VA and DOD by the end of fiscal 
year 2011. The departments plan to expand the exchange of data to 
support improved collaboration on care plans in fiscal year 2012. 

We are sending copies of this report to the Secretary of Defense and 
the Secretary of Veterans Affairs and other interested parties. The 
report also is available at no charge on the GAO Web site at 
[hyperlink, http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202) 512-7114 or williamsonr@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. Key contributors to this 
report are listed in appendix IV. 

Signed by: 

Randall B. Williamson: 
Director, Health Care: 

List of Requesters: 

The Honorable John F. Tierney: 
Ranking Member: 
Subcommittee on National Security, Homeland Defense and Foreign 
Operations: 
Committee on Oversight and Government Reform: 
House of Representatives: 

The Honorable Kirsten Gillibrand: 
United States Senate: 

The Honorable Jason Altmire: 
House of Representatives: 

The Honorable Bruce Braley: 
House of Representatives: 

The Honorable Kathy Castor: 
House of Representatives: 

The Honorable Yvette Clarke: 
House of Representatives: 

The Honorable Steve Cohen: 
House of Representatives: 

The Honorable Joe Courtney: 
House of Representatives: 

The Honorable Joe Donnelly: 
House of Representatives: 

The Honorable Keith Ellison: 
House of Representatives: 

The Honorable Gabrielle Giffords: 
House of Representatives: 

The Honorable Mazie Hirono: 
House of Representatives: 

The Honorable Hank Johnson: 
House of Representatives: 

The Honorable David Loebsack: 
House of Representatives: 

The Honorable Jerry McNerney: 
House of Representatives: 

The Honorable Chris Murphy: 
House of Representatives: 

The Honorable Ed Perlmutter: 
House of Representatives: 

The Honorable John Sarbanes: 
House of Representatives: 

The Honorable Heath Shuler: 
House of Representatives: 

The Honorable Albio Sires: 
House of Representatives: 

The Honorable Betty Sutton: 
House of Representatives: 

The Honorable Tim Walz: 
House of Representatives: 

The Honorable Peter Welch: 
House of Representatives: 

The Honorable John Yarmuth: 
House of Representatives: 

[End of section] 

Appendix I: The Use of Software to Analyze Testimonial Evidence: 

To conduct a content analysis of our interviews with program officials 
and medical facility staff, we used a qualitative data analysis 
software package. The software facilitated our analysis of over 150 of 
the 170 interviews we conducted and helped us to identify and quantify 
interviewees' responses on various topics. The program's coding 
capabilities allowed us to group our interviewees' responses into 
categories. It also provided a centralized location where all of our 
documents could be reviewed and analyzed. 

We took a number of steps to ensure that our analysis was 
methodologically sound. First, we defined categories to organize the 
views of the Department of Defense and the Department of Veterans 
Affairs program officials and medical facility staff by specific 
topics, including the Federal Recovery Coordination Program's (FRCP) 
eligibility criteria, the interviewees' interactions with the Federal 
Recovery Coordinators (FRC), overlap and duplication of activities 
among the FRCP and the case management programs with which the FRCs 
interacted, knowledge of the FRC role, and challenges faced by the 
FRCs. These categories were chosen based on themes we heard during our 
interviews with the program officials and medical facility staff. We 
conducted an intercoder reliability check to ensure the accuracy of 
the category definitions. To do this, two analysts coded a sample of 
15 interviews into the categories. A methodologist compared the 
analyses to determine where inconsistencies occurred and, as a result, 
what categories needed more specific definitions. 

Once the category definitions were finalized, the same two analysts 
divided the categories among them and coded their categories for all 
of the interview documents. When the coding was completed, both 
analysts reviewed every code made by the other analyst and indicated 
whether they agreed or disagreed with the code. Changes were then made 
accordingly. We subsequently analyzed the interviewees' responses 
based on the defined categories. This analysis allowed us to quantify 
interviewees' responses within each category. 

[End of section] 

Appendix II: Comments from the Department of Defense: 

Office Of The Under Secretary Of Defense: 
Personnel And	Readiness: 
4000 Defense Pentagon: 
Washington, D.C. 20301-4000: 

March 4, 2011: 

Mr. Randall Williamson: 
Director, Health Care: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Williamson: 

This is the Department of Defense (DoD) response to the Government 
Accountability Office (GAO) Draft Report, GAO 11-250, "DOD and VA Care 
Healthcare: Federal Recovery Coordination Program Continues to Expand, 
but Faces Significant Challenges," dated February 2, 2011 (GAO Code 
290804). 

While there were no specific recommendations with regards to DoD, GAO 
requested that comments be provided. The following comments are 
provided by the Department: DoD and VA continue to work together to 
fully integrate their efforts and to increase collaboration between 
the two departments. To that end, a Joint DoD/VA Committee has been 
formed to study how to combine or integrate recovery care coordination 
efforts for wounded, ill, and injured Service members, Veterans and 
their families. 

The Department appreciates the opportunity to review and comment on 
the draft report. 

Sincerely, 

Signed by: 

John R. Campbell: 
Deputy Assistant Secretary of Defense for Wounded Warrior Care and 
Transition Policy: 

[End of section] 

Appendix III: Comments from the Department of Veterans Affairs: 

Department Of Veterans Affairs: 
Washington DC 20420: 

March 7, 2011: 

Mr. Randall B. Williamson: 
Director, Health Care: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Williamson: 

The Department of Veterans Affairs (VA) has reviewed the Government
Accountability Office's (GAO) draft report, "DOD and VA Health Care: 
Federal Recovery Coordination Program Continues to Expand, but Faces 
Significant Challenges" (GAO-11-250) and generally agrees with GAO's 
conclusions and concurs with GAO's recommendations to the Department. 

The enclosure specifically addresses GAO's recommendations and 
provides additional and technical comments to the report. VA 
appreciates the opportunity to comment on your draft report. 

Sincerely, 

Signed by: 

John R.	Gingrich: 
Chief of Staff: 

Enclosure: 

[End of letter] 

Enclosure: 

Department of Veterans Affairs (VA) Comments to Government 
Accountability Office (GAO) Draft Report DOD and VA Health Care: 
Federal Recovery Coordination Program (FRCP) Continues to Expand, but 
Faces Significant Challenges (GAO-11-250): 

GAO Recommendation: We recommend that the Secretary of VA direct the 
Executive Director of the FRC to take four actions: 

Recommendation 1: ensure that referred servicemembers and veterans who 
need FRC services are enrolled in the program by establishing adequate 
internal controls regarding the FRCs' enrollment decisions. To 
accomplish this, the FRCP leadership should: 

*	Require FRCs to record in the Veteran's Tracking Application the 
factors they consider in making an enrollment decision; and; 

*	Develop and implement a methodology and protocol for assessing the 
appropriateness of enrollment decisions; and; 

*	Refine the methodology as needed. 

VA Response: Concur. As pointed out by GAO, evaluation of potential 
FRCP clients is based on an assessment of the individual's medical and 
non-medical needs and requirements in order to recover, rehabilitate, 
and reintegrate to the maximum extent possible. A key feature of this 
process is the clinical experience of the FRCs and their clinical 
judgment of whether or not an individual would benefit from care 
coordination. 

While many of these decisions are discussed routinely with management, 
improved documentation of the decision factors is required. FRCP will 
establish clear documentation requirements, according to a defined 
protocol, within the program's data management system as a permanent 
solution. The defined protocol will be developed in concert with the 
service intensity measurement tool (GAO Recommendation 2 below). In 
the short-term, the program will implement an immediate requirement 
that all FRCs discuss each enrollment decision with management. 

It is the highest priority of FRCP to ensure that all severely 
wounded, ill and injured Servicemembers and Veterans who would benefit 
from care coordination are enrolled. While the program will ensure 
that adequate internal controls exist for enrolling individuals into 
FRCP, the program cannot ensure that all potentially eligible 
individuals are referred to FRCP. FRCP, as currently structured, is a 
voluntary referral program and, as such, relies on the identification 
and referral of those who might benefit from FRCP services by others 
(case managers, Command, Wounded Warrior Programs, etc.). The terms 
"catastrophic" and "severely", often used to describe the wounded, ill 
or injured population who should be referred to FRCP, are 
administrative in nature and whose meaning is left to interpretation. 
To date, the program has relied on outreach activities and 
demonstrated outcomes to inform the referral process. 

Recommendation 2: complete development of its workload assessment tool 
that will enable the program to assess the complexity of services 
needed by enrollees and the amount of time required to provide 
services to improve the management of FRCs' caseloads. 

VA Response: Concur. Determining the right caseload for each FRC is a 
strategic goal for FRCP. Because care coordination is a relatively new 
concept, particularly as implemented across and within Federal 
agencies, no clear guidelines or intensity measurement tools exist to 
accurately determine caseloads. This is a labor intensive task that 
requires tool development and testing, along with validity and 
reliability assessments. FRCP is in the process of field testing a new 
service intensity measurement tool that will likely need refinement 
and additional testing. We believe that this iterative process will 
require at least a year to complete. 

Recommendation 3: clearly define and document the FRCP's decision-making
process for determining when and how many FRCs VA should hire to 
ensure that subsequent FRCP leadership can understand the methods 
currently used to make hiring decision. 

VA Response: Concur. FRCP will more clearly document the current 
process used for staffing decisions. The process will be revised when 
the service intensity measurement tool is in place. Staffing processes 
and plans will be updated annually in the FRCP business operation 
planning document. 

Recommendation 4: develop and document a clear rationale for the 
placement of FRCs, which should include a systematic analysis of data, 
such as referral locations, to ensure that future FRC placement 
decisions are strategic in providing maximum benefit for the program's 
population. 

VA Response: Concur. FRCP will develop a FRC placement strategy based 
upon a systematic analysis of data over the next six months. This 
process will be documented and updated annually in the FRCP business 
operation planning document. 

Additional Comment: 

Since the time of this report, significant progress has been made 
toward a live exchange of data between VA and DoD wounded warrior 
information systems as part of the Information Sharing Initiative. 
Leveraging existing VA-DoD data exchange mechanisms, it is anticipated 
that an initial set of data around the case/care managers assigned to 
an individual Servicemember or Veteran will be available for exchange 
by the end of Fiscal 2011.	It is anticipated that this mechanism will 
provide the ability to accommodate IT systems that are not directly 
compatible. Additional data to support improved collaboration on care 
plans is planned for exchange in Fiscal 2012. 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Randall B. Williamson, (202) 512-7114 or williamsonr@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Bonnie Anderson, Assistant 
Director; Susannah Bloch; Frederick Caison; Elizabeth Conklin; Cynthia 
Gilbert; Deitra Lee; Lisa Motley; Kristina Martin; Steven Putansu; and 
Suzanne Worth made key contributions to this report. 

[End of section] 

Footnotes: 

[1] President's Commission on Care for America's Returning Wounded 
Warriors, Serve, Support, Simplify (July 2007). 

[2] OEF, which began in October 2001, supports combat operations in 
Afghanistan and other locations, and OIF, which began in March 2003, 
supports combat operations in Iraq and other locations. Since 
September 1, 2010, OIF is referred to as Operation New Dawn. 

[3] The FRCP defines severely wounded, ill, and injured individuals as 
those who, because of their physiological or psychological disease or 
condition, or a mental disorder, require ongoing medical care, exhibit 
impaired ability to function independently in their community, are 
vulnerable and whose personal safety is highly at risk, and require 
informal and formal support for maintenance of health and safety. 

[4] The military wounded warrior programs are the Army Wounded Warrior 
Program, Marine Wounded Warrior Regiment, Navy Safe Harbor, Air Force 
Warrior and Survivor Care Program, and Special Operations Command's 
Care Coalition. 

[5] According to the National Coalition on Care Coordination, care 
coordination is a client-centered, assessment-based interdisciplinary 
approach to integrating health care and social support services in 
which an individual's needs and preferences are assessed, a 
comprehensive care plan is developed, and services are managed and 
monitored by an identified care coordinator. 

[6] Booz Allen Hamilton, Federal Recovery Coordination Program, Draft 
Program Evaluation Report for Phase I: November 2007 - April 2008 
(McLean, Va.: 2008). 

[7] We used a data analysis computer software package designed to 
organize and analyze complex nonnumerical or unstructured data. 

[8] In addition to active enrollees in the FRCP, this number includes 
individuals who were evaluated for the program but were not enrolled 
(in which case the FRCs provided temporary assistance to the 
individual, redirected the individual to another program, or both) and 
enrollees who were deactivated from the program because they could not 
be contacted, no longer required FRCP services, or had died. 

[9] The denominators for these numbers are different because not all 
of the program officials and medical facility staff we interviewed 
responded to every question. 

[10] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[11] This information was obtained from comprehensive interviews with 
the 15 FRCs who were working in the FRCP in or before December 2009. 

[12] In January 2011, the Veterans Tracking Application was 
successfully upgraded to be able to collect location information, 
according to an FRCP official. 

[13] FRCs would be able to provide this information to staff of non-VA 
programs if they obtain the enrollees' written permission. However, 
FRCP officials stated that because it is not feasible to obtain such 
permission from each enrollee for logistical reasons, this procedure 
has not been introduced. 

[14] See 5 U.S.C. § 552a(e)(4). 

[15] The Privacy Act defines a "system of records" as a group of any 
records under the control of any federal agency from which information 
is retrieved by the name of the individual or by some identifying 
number, symbol, or personal identifier assigned to the individual. 5 
U.S.C. § 552a(a)(5). A "routine use" is a disclosure of a record for a 
purpose that is compatible with the purpose for which it was 
collected. 5 U.S.C. § 552a(a)(7). 

[16] With the assistance of prosthetic devices, some amputees are able 
to return to active duty status. 

[17] 75 Fed. Reg. 76,784 (Dec. 9, 2010). 

[18] For additional information, see GAO, Electronic Health Records: 
DOD and VA Interoperability Efforts Are Ongoing; Program Office Needs 
to Implement Recommended Improvements, [hyperlink, 
http://www.gao.gov/products/GAO-10-332] (Washington, D.C.: Jan. 28, 
2010), and Electronic Health Records: DOD and VA Efforts to Achieve 
Full Interoperability Are Ongoing; Program Office Management Needs 
Improvement, [hyperlink, http://www.gao.gov/products/GAO-09-775] 
(Washington, D.C.: July 28, 2009). 

[End of section] 

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