[House Hearing, 111 Congress]
[From the U.S. Government Publishing Office]
EXAMINING TRAINING REQUIREMENTS
OF VETERANS BENEFITS ADMINISTRATION
CLAIMS PROCESSING PERSONNEL
=======================================================================
HEARING
before the
SUBCOMMITTEE ON DISABILITY ASSISTANCE AND MEMORIAL AFFAIRS
of the
COMMITTEE ON VETERANS' AFFAIRS
U.S. HOUSE OF REPRESENTATIVES
ONE HUNDRED ELEVENTH CONGRESS
SECOND SESSION
__________
SEPTEMBER 16, 2010
__________
Serial No. 111-98
__________
Printed for the use of the Committee on Veterans' Affairs
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COMMITTEE ON VETERANS' AFFAIRS
BOB FILNER, California, Chairman
CORRINE BROWN, Florida STEVE BUYER, Indiana, Ranking
VIC SNYDER, Arkansas CLIFF STEARNS, Florida
MICHAEL H. MICHAUD, Maine JERRY MORAN, Kansas
STEPHANIE HERSETH SANDLIN, South HENRY E. BROWN, Jr., South
Dakota Carolina
HARRY E. MITCHELL, Arizona JEFF MILLER, Florida
JOHN J. HALL, New York JOHN BOOZMAN, Arkansas
DEBORAH L. HALVORSON, Illinois BRIAN P. BILBRAY, California
THOMAS S.P. PERRIELLO, Virginia DOUG LAMBORN, Colorado
HARRY TEAGUE, New Mexico GUS M. BILIRAKIS, Florida
CIRO D. RODRIGUEZ, Texas VERN BUCHANAN, Florida
JOE DONNELLY, Indiana DAVID P. ROE, Tennessee
JERRY McNERNEY, California
ZACHARY T. SPACE, Ohio
TIMOTHY J. WALZ, Minnesota
JOHN H. ADLER, New Jersey
ANN KIRKPATRICK, Arizona
GLENN C. NYE, Virginia
Malcom A. Shorter, Staff Director
______
SUBCOMMITTEE ON DISABILITY ASSISTANCE AND MEMORIAL AFFAIRS
JOHN J. HALL, New York, Chairman
DEBORAH L. HALVORSON, Illinois DOUG LAMBORN, Colorado, Ranking
JOE DONNELLY, Indiana JEFF MILLER, Florida
CIRO D. RODRIGUEZ, Texas BRIAN P. BILBRAY, California
ANN KIRKPATRICK, Arizona
Pursuant to clause 2(e)(4) of Rule XI of the Rules of the House, public
hearing records of the Committee on Veterans' Affairs are also
published in electronic form. The printed hearing record remains the
official version. Because electronic submissions are used to prepare
both printed and electronic versions of the hearing record, the process
of converting between various electronic formats may introduce
unintentional errors or omissions. Such occurrences are inherent in the
current publication process and should diminish as the process is
further refined.
C O N T E N T S
__________
September 16, 2010
Page
Examining Training Requirements of Veterans Benefits
Administration Claims Processing Personnel..................... 1
OPENING STATEMENTS
Chairman John J. Hall............................................ 1
Prepared statement of Chairman Hall.......................... 33
Hon. Doug Lamborn, Ranking Republican Member..................... 3
Prepared statement of Congressman Lamborn.................... 34
WITNESSES
U.S. Government Accountability Office, Daniel Bertoni, Director,
Education, Workforce, and Income Security...................... 4
Prepared statement of Mr. Bertoni............................ 35
U.S. Department of Veterans Affairs, Michael Cardarelli, Acting
Deputy Under Secretary for Benefits, Veterans Benefits
Administration................................................. 24
Prepared statement of Mr. Cardarelli......................... 56
______
American Federation of Government Employees (AFL-CIO), Jimmy F.
Sims, Jr., Shop Steward, Local 1738, and AFGE National Veterans
Affairs Council, and Rating Veterans Service Representative,
Winston-Salem, NC, Regional Office, Veterans Benefits
Administration................................................. 9
Prepared statement of Mr. Sims............................... 40
American Legion, Ian C. de Planque, Deputy Director, Veterans
Affairs and Rehabilitation Commission.......................... 16
Prepared statement of Mr. de Planque......................... 54
Disabled American Veterans, Jeffrey C. Hall, Assistant National
Legislative Director........................................... 11
Prepared statement of Mr. Hall............................... 42
Institute for Defense Analyses (IDA), David E. Hunter, Ph.D.,
Assistant Director, Cost Analysis and Research Division........ 14
Prepared statement of Dr. Hunter............................. 50
National Veterans Legal Services Program, Meg Bartley, Esq.,
Senior Staff Attorney.......................................... 13
Prepared statement of Ms. Bartley............................ 48
SUBMISSION FOR THE RECORD
Federal Bar Association, Carol Wild Scott, Chairman, Veterans Law
Section, statement............................................. 59
MATERIAL SUBMITTED FOR THE RECORD
Post-Hearing Questions and Responses for the Record:
Hon. John J. Hall, Chairman, Subcommittee on Disability
Assistance and Memorial Affairs, Committee on Veterans'
Affairs, to Daniel Bertoni, Director, Education,
Workforce, and Income Security Issues, U.S. Government
Accountability Office, letter dated October 6, 2010, and
response letter dated October 28, 2010................... 62
Hon. John J. Hall, Chairman, Subcommittee on Disability
Assistance and Memorial Affairs, Committee on Veterans'
Affairs, to Jimmy Sims, Jr., AFGE Local 1738 Shop
Steward, American Federation of Government Employees,
letter dated October 6, 2010, and AFGE responses......... 63
Hon. John J. Hall, Chairman, Subcommittee on Disability
Assistance and Memorial Affairs, Committee on Veterans'
Affairs, to David E. Hunter, Ph.D., Assistant Director,
Cost Analysis and Research Division, Institute for
Defense Analyses, letter dated October 6, 2010, and Dr.
Hunter's responses, dated November 5, 2010............... 68
Hon. John J. Hall, Chairman, Subcommittee on Disability
Assistance and Memorial Affairs, Committee on Veterans'
Affairs, to Michael Cardarelli, Acting Deputy Under
Secretary for Benefits, Veterans Benefits Administration,
U.S. Department of Veterans Affairs, letter dated October
6, 2010, and VA responses................................ 71
EXAMINING TRAINING REQUIREMENTS
OF VETERANS BENEFITS ADMINISTRATION
CLAIMS PROCESSING PERSONNEL
----------
THURSDAY, SEPTEMBER 16, 2010
U.S. House of Representatives,
Committee on Veterans' Affairs,
Subcommittee on Disability Assistance and Memorial Affairs,
Washington, DC.
The Subcommittee met, pursuant to notice, at 10:05 a.m., in
Room 334, Cannon House Office Building, Hon. John Hall
[Chairman of the Subcommittee] presiding.
Present: Representatives Hall, Donnelly, and Lamborn.
Mr. Hall of New York. Good morning, ladies and gentlemen.
Would everyone please rise for the Pledge of Allegiance.
[Pledge was taken.]
OPENING STATEMENT OF CHAIRMAN HALL
Mr. Hall of New York. Thank you. I am very grateful that
you have been able to join us today for our hearing entitled,
``Examining Training Requirements of Veterans Benefits
Administration Claims Processing Personnel.''
I think it is indisputable that quality training for
Veterans Benefit Administration (VBA) claims personnel is
critical for the U.S. Department of Veterans Affairs (VA) to
reach its goal of processing all claims within 125 days at a 98
percent accuracy rate and in reaching its overarching goal of
eliminating the backlog by 2015.
As of 2009, VBA received more than one million compensation
and pension (C&P) related claims annually. Over 200,000 of
these claims take longer than 4 months for VBA staff to fully
process, meaning that they are part of the backlog. Further, it
is estimated that approximately 20 percent of the claims
processed by VBA, as many as 200,000 are erroneous.
Also, according to information provided by the Board of
Veterans' Appeals in its annual report, 37 percent of all
appeals that it receives are returned to the VBA due to
avoidable errors. It should also be noted that the backlog
itself continues to grow.
In response, since 2007, Congress has appropriated more
than $750 million for VA to hire more than 10,000 new VBA
claims processors on an expedited hiring timetable. Recognizing
that the backlog is not just a ``people'' issue and that brute
force alone will not bring about transformation, Congress also
passed the Veterans Benefits Improvement Act of 2008, Public
Law 110-389, which included sweeping provisions to overhaul the
claims processing system including efforts to improve the
training of VBA claims personnel.
Recently, VA expanded the training requirements for claims
processing personnel. This is especially significant since 50
percent of the VA staff is considered new--that is with 2 years
or less of experience.
Today veteran service representatives (VSRs) and ratings
veteran service representatives (RVSRs) are required to
complete 85 hours of instruction annually, a 5-hour increase
over previous levels.
VA has also reimplemented and revamped its certification
testing program. I look forward to hearing more about that
today.
Congress also directed the U.S. Government Accountability
Office (GAO) to examine VA's training program for claims
processing personnel. GAO answered the call with two reports,
one in 2008 and one in 2010, which both assessed VBA's training
requirements and practices.
From these reports, we found that VBA claims processors may
be hindered from completing their training requirements in
order to meet their work production goals.
We also learned that VBA's training may not be sufficient
to equip VBA claims processors with the skills needed to help
them perform their duties.
Moreover, the GAO indicates that significant improvements
might be achieved by the VBA if it were to better monitor the
claims process, particularly during the claims developmental
stage, and employ appropriate training management and other
tools to provide timely correction of staff processing errors.
The Institute for Defense Analyses (IDA), based on its
research, has also issued findings relating to VBA's claims
processing related training, particularly as it pertains to
variances in the ratings between different regional offices
(ROs).
I look forward to hearing from both the GAO and IDA on
their findings.
Our job in our oversight capacity here in Congress includes
helping the VA to find solutions to these challenges that stand
in the way of veterans receiving the benefits they are due.
Today's hearing is designed to achieve this end by shining
greater light on the efficacy of the training and certification
of VBA claims processing personnel.
I look forward to the testimony of the veterans services
organizations and other stakeholders, many of whom for years
have offered recommendations for improving the training of VBA
claims processors, but with little avail.
Finally, I look forward to hearing feedback from the Acting
Deputy Under Secretary of Benefits on the critiques and
recommendations from the earlier witnesses and to get an action
plan for implementing and equipping VBA claims processing
personnel with the skills needed for the VA to ``break the back
of the backlog.''
Again, I reiterate that I strongly believe VBA's focus
should be on getting the claim right the first time, on
quality, not predominantly on production. I am disappointed
that the VA's recorded performance on training has not improved
significantly and I expect to hear specifics from VA on how it
will be significantly more effective in this area in the
future.
Veterans understand the necessity of proper training as
they have placed their lives in harm's way dependent upon the
training they and their brothers and sisters in arms received,
so they understand the importance of the training the
processors receive who decide their claims when they are
veterans.
Our mission today is to ensure that the VBA provides
meaningful and appropriate training and devotes the resources
that claims processing personnel need to perform their duties,
so that our veterans, their families, and survivors receive the
21st Century world-class service they deserve.
[The prepared statement of Chairman Hall appears on p. 33.]
Mr. Hall of New York. And I would now yield to Ranking
Member Doug Lamborn for his opening statement.
OPENING STATEMENT OF HON. DOUG LAMBORN
Mr. Lamborn. Thank you, Mr. Chairman. Thank you, Mr.
Chairman.
Mr. Hall of New York. You are welcome.
Mr. Lamborn. And welcome everyone to this hearing on
Veterans Benefits Administration training programs.
A quality training program is the key to any successful
organization, particularly one like VBA that must adhere to a
complex set of laws, regulations, and precedent decisions by
the U.S. Court of Appeals for Veterans Claims.
While these requirements pose a daunting challenge for
trainers, I want to emphasize my strong desire to ensure that a
comprehensive and substantive training program is employed at
all levels of VBA. And I know that this perspective is shared
by the Chairman, Representative Hall.
Over the past several years, Republican Members have
recommended substantial increases for training in our views and
estimates. We realize the importance proper training and
feedback have in production of quality rating decisions that
are fair and equitable to our veterans.
Throughout my tenure on this Committee, we have discussed a
number of problems within VBA that my colleagues on both sides
of the aisle and I recognize could be addressed through better
training.
VA training must be connected to its vision and mission and
VA managers need to be assured that if employees are pulled off
the floor for training, that it will result in long-term
benefits. There must be clear support from the top down in
order to conduct adequate training and acquire the expected
outcomes.
I look forward to hearing from our witnesses today. And I
thank you all for your participation.
Thank you, Mr. Chairman, and I yield back.
[The prepared statement of Congressman Lamborn appears on
p. 34.]
Mr. Hall of New York. Thank you, Mr. Lamborn.
I would ask you all to please turn off your cell phones,
and remind all panelists that your complete written statements
have been made a part of the hearing record. Please limit your
remarks so that we may have sufficient time to follow-up with
questions once everyone has had the opportunity to provide
their testimony.
Our first panel features Daniel Bertoni, Director of
Education, Workforce and Income Security with the Government
Accountability Office.
Mr. Bertoni, if you would join us at the witness table,
please. You have 5 minutes, but your written statement is in
the record, so feel free to improvise. You are now recognized
for 5 minutes.
STATEMENT OF DANIEL BERTONI, DIRECTOR, EDUCATION, WORKFORCE,
AND INCOME SECURITY, U.S. GOVERNMENT ACCOUNTABILITY OFFICE
Mr. Bertoni. Am I on? Mr. Chairman, Members of the
Subcommittee, good morning. I am pleased to discuss training
for Veterans Benefits Administration disability claims
processors.
For years, the claims process has been a subject of concern
due to long waits for decisions, large numbers of pending
claims, and problems with the accuracy and consistency of
decisions.
To help VBA manage increasing workloads, Congress has
provided additional funding over the last several years which
enabled the Agency to hire thousands of new staff. However,
more staff alone will not guarantee success. A robust training
program is needed to help new claims processors become fully
proficient and seasoned staff to maintain their knowledge and
skills over time.
In 2008, we noted that VBA's centralized training program
for new staff appeared well designed, but offered several
recommendations for further enhancing management of the program
in which the Agency concurred and has taken several actions.
In April 2010, we again reported on VBA's management and
oversight of its training, but in regard to more experienced
staff.
My remarks today will focus on experienced claims
processors' views regarding training and VBA's efforts to
monitor and assess that training.
In summary, experienced staff had concerns about the amount
of required training and their ability to meet those
requirements. Our survey showed that 60 percent found it
difficult to obtain 80 hours of annual training given their
workloads. About 50 percent of the supervisors thought that
only some or a few needed that amount to do their jobs
effectively.
Experienced staff also had mixed views on the training
received on specific topics with an estimated 47 and 42 percent
respectively noting that training was less than sufficient for
appeals and remands and special monthly compensation.
On the other hand, one-third reported receiving more than
enough training in records management, rating claims, and
calculating payments.
Experienced staff in general found certain training modes
more helpful than others with nearly all noting that on-the-job
training best suited their needs. Only 20 percent viewed VBA's
training performance support system, other online videos, or
satellite training as very helpful.
Moreover, an estimated 39 percent of respondents felt that
the training they received in the last 12 months was delivered
too late.
In regard to program management and oversight, we found
that the Agency delegated considerable authority for training
staff to its 57 regional offices and could do more to monitor
and assess training.
For example, VBA did not use its Web-based Learning
Management System (LMS) to monitor the regions, the specific
types of training completed by individual staff in the regions,
and could not ensure they received all required training.
In fact, our survey analysis showed that 24 percent of
staff who should have received mandatory training on spinal,
neck, and joint injuries never did.
In its comments to our report, VBA noted that it has begun
to electronically track the percentage of staff at each office
that are meeting annual training requirements.
We also reported that the Agency lacked controls to ensure
regional offices consistently define and record training. For
example, some offices allowed staff to count the time spent
reading Fast Letters as training while other offices did not.
At a minimum, this raised serious concerns about the
consistency and reliability of regional data.
And per our recommendation, the Agency is now developing
criteria as to what activities should and should not count
toward the completion of annual training.
And, finally, we reported that VBA had not systematically
assessed the appropriateness and consistency of regional office
training or collected feedback from experienced staff on the
training delivered.
We recommended that VA develop a strategy to assess the
content, mode, and timing of such training. The Agency has
developed such a strategy for national core technical training
and is exploring the feasibility of applying it to non-core and
locally developed regional training.
In conclusion, veterans who have been injured in service to
their country deserve timely, accurate, and consistent
disability decisions. And claims processors play a vital role
in responding to their needs. It is good news that the Agency
has a number of initiatives either planned or underway to
strengthen its training program and enhance service delivery.
However, going forward, we will continue to monitor and
assess its progress toward addressing our recommendations and
ensuring that both new and experienced staff are properly
supported in their efforts to serve the veteran community.
Mr. Chairman, this concludes my statement. I am happy to
answer any questions that you or other Members of the
Subcommittee may have. Thank you.
[The prepared statement of Mr. Bertoni appears on p. 35.]
Mr. Hall of New York. Thank you, Mr. Bertoni.
I will just recognize myself for a few questions and then
the Ranking Member.
In its 2008 report entitled, ``Increased Focus on
Evaluation and Accountability Would Enhance Training and
Performance Management for Claims Processors,'' the GAO found
that individual VBA personnel staff members faced no
consequences for failing to meet required training
specifications.
In your recent study, did you determine whether this issue
has been remedied or is there still a problem with
accountability?
Mr. Bertoni. I do not believe there has been a specific
policy change or at least at the time of our review, there was
not a specific policy change in terms of accountability.
At the tail end of our review in January of 2010, there was
a Fast Letter issued that talked about the requirement that
staff must now enter the fact that they have taken training
into the LMS. There would be an electronic query to supervisors
if that did not occur and some reference to either counseling
or reprimanding or perhaps adjusting the individual's workload
to make that training happen. But I do not know whether there
is any linkage to, say, performance rating or anything else.
Mr. Hall of New York. Comparing both the 2008 report with
your most recent 2010 report, it appears that the quantity of
training continues to pose a challenge for seasoned VBA claims
staff. According to both studies, claims processors reported
that the demands of their work production requirements often
prevent them from receiving mandatory training.
What has been the VA's response to this ongoing issue and
what measures, if any, do you recommend to remedy this problem?
Mr. Bertoni. I think up until very recently, the response
has been we established this 80-hour requirement. We believe it
is appropriate and we will continue to go that way.
But more recently, I believe there has been some outreach
and analysis to field staff and management to get a sense of
whether this is appropriate and whether it is doable under
current workloads.
And there have been some adjustments not in terms of the
ceiling but in terms of the curriculum. I think now they are
more training to the intermediate and targeting journey levels.
And I think that will go a long way towards making training
more relevant and processors being able to find training that
is relevant to their position.
I think there is an acknowledgment also that the workload
can distract from one's ability to do training. And I did see a
reference that now seasoned claims processors who teach or are
instructors can now apply up to 20 hours of that instructional
time to their Central Processing Unit requirements.
So I think short of changing the bar or lowering the bar,
there has been substantive examination of the content. And I
think that might alleviate some of the pressure in terms of
their ability to make that 80-hour requirement.
Mr. Hall of New York. Thank you, sir.
It seems that VBA fails to tie the training requirements to
its organizational goals for claims processing accuracy and
timeliness or even transformation efforts.
Can you provide us with any insight on how VA can close
this disconnect, that is to correlate training with more
accurate and quality claims processing outcomes?
Mr. Bertoni. I think in the 2008 report, we actually did
say that at least on paper in terms of design they were in
accordance with what we call generally accepted practices in
design of training programs in that there are goals for
timeliness, accuracy, and consistency. And the training that is
administered does get at those issues.
What we were concerned about was how they were doing the
training, was it appropriate, and how was it being evaluated so
that they could make adjustments to the training to make it the
best it could be and VA could more better target what they are
doing in training towards ultimate end goals.
And, yes, it appears that claims quality has gone down over
the last couple years. And we are concerned about that also.
Mr. Hall of New York. Regarding the quantity of training,
your 2010 report contained an interesting survey in which
experienced claims processors felt that they received too
little training on some topics and too much on others. A full
46 percent felt that they experienced problems completing the
training.
What has been the VA's reaction to the survey? Do you know
of any steps that have been taken to address this issue?
Mr. Bertoni. I do not know what they are doing specifically
with the survey results. But one thing that did stand out to me
was the statistic on appeals and remands. We appear to see a
real need amongst staff that they want more appeals and remands
training and also on the other side, we saw that they did not
feel the appeals and remands training was as effective as it
could be in helping them do their job.
And then you look at problematic areas in the claims
process that we do find a lot of issues with remanded cases. So
I think that it would behoove the Agency to really look at that
data and to look to what adjustments they might want to make in
their training to address the issues around appeals and
remands.
Mr. Hall of New York. Thank you, Mr. Bertoni. I have more
questions, which I will submit in writing to you.
And now I will recognize Ranking Member Lamborn.
Mr. Lamborn. Thank you, Mr. Chairman.
And thanks for being here, Mr. Bertoni.
Do you believe that 85 hours of training is an adequate
requirement for all employees or should this be reduced or
perhaps increased?
Mr. Bertoni. Again, I do not know and we have asked on
numerous occasions for the criteria or justification as to how
the Agency arrived at that, whether there was any other benefit
processing baseline that we could look to. We did not find
that.
So we really do not know the basis. I do know that in both
of our reviews there is the concern about the ability to reach
that bar. And, again, I think part of it comes down to what is
being offered and whether it is relevant and substantive.
I think for new claims processors, they will make that. The
training in the first couple years is very intense. It is after
you leave that environment of the challenge program where, I do
not want to say folks forget about you, but I think the
emphasis in the past has been, well, they are fine, you know,
they will just get by on refresher training.
I do not think that is the appropriate way to look at this.
I think you really need to look at a vigorous and invigorated
training program going forward for seasoned staff and it would
benefit the Agency to do so.
Mr. Lamborn. Okay. Thank you.
And I know I might be overlapping some with previous
questions and answers, but my last question is this. Could you
tell us what you think the VA can do to ensure that the correct
staff members are rewarded for exceptional performance and also
how we can assure that proper feedback is given to the staff
from their managers?
Mr. Bertoni. I am glad you revisited that section of the
2008 report. I was not quite sure if I was going to get
questions on that? But I can weigh in on that.
In 2008, we looked at the performance appraisal and
management system. And in our view, we were concerned that
although there were numerous categories to place people in
various performance buckets, it appeared that as designed, the
formula that was used, did not allow appropriate
differentiation in performance.
And because of the formula, you could have someone--they
would rate folks on, I believe, critical and noncritical
elements. And someone who scores outstanding in all critical
elements would, of course, get an outstanding rating. However,
if an individual rated less than outstanding in one of the
critical elements, say that person got a fully successful, that
would be enough to drop that person into the third category
which would be fully successful, bypassing the next category of
exceptional.
So in this case, you would have a very high performer
dropping into a bucket with some folks who perhaps were at the
very bottom end of fully successful performance but would be
rated the same.
So we felt there was room for the Agency to look at their
performance evaluation system, and determine whether they could
better differentiate between our highest performers.
Mr. Lamborn. Okay.
Mr. Bertoni. And, again, that backs into training. If you
know where your remedial needs are, you can design and target
your training to staffs' individual needs. And perhaps 85 hours
is not enough or is too much for some staff, but perhaps some
staff will need more. So it is a way to target your training
resources to people who need your help.
Mr. Lamborn. Thanks for your answers and for being here
today.
I yield back.
Mr. Hall of New York. Thank you, Mr. Lamborn.
Mr. Bertoni, just another question or two. Did GAO explore
the quality or adequacy of the training that the VBA
instructors receive? Does VBA have a formalized program for
training the trainers and are RO instructors required to
complete it?
Mr. Bertoni. We did not look at the train the trainer
program per se. We looked generally at their program. Just in
general, train the trainer programs make good sense. And also
if you give trainers an incentive to step up by allowing them
to apply what they are doing to their annual training hours, I
think everybody benefits. The Agency benefits from knowledge
transfer.
These supposedly are your best people. They are
knowledgeable. You have a vast number of new staff in the
Agency who could benefit from that. And the Agency will
benefit, I think, from good train the trainer programs. The
individual benefits, of course, because as you train, you get
better. You sharpen your skills and you also pick up a few
credit hours towards your national requirement.
We found it interesting that in our survey in 2010 that
many experienced staff really viewed on-the-job training as the
preferred mode. The question I have is, was that the default
choice? If they could not turn internally to the established
curriculum, were they turning towards peers and other on-the-
job tools to get what they need? I think that is a question
that VBA has to really think about.
Mr. Hall of New York. Well, thank you very much for your
work and your testimony and for being here today, Mr. Bertoni,
and you are now excused.
Mr. Bertoni. Thank you.
Mr. Hall of New York. Have a good day, sir.
I will call our next panel, please, which includes Jimmy
Sims, Jr., the RVSR and AFGE Local 1738 Steward, VBA Regional
Office, Winston-Salem, North Carolina, American Federation of
Government Employees (AFGE).
Jeffrey C. Hall from New York, Assistant National
Legislative Director, Disabled American Veterans (DAV),
welcome, sir.
Meg Bartley, Senior Staff Attorney, National Veterans Legal
Services Program (NVLSP); Dr. David Hunter, Assistant Director,
Cost Analysis and Research Division for the Institute for
Defense Analyses; and Ian C. de Planque, Deputy Director of the
National Veterans Affairs and Rehabilitation Commission of the
America Legion.
We are expecting votes to be called at any time. So what we
will do is we will try to get as much testimony as we can
before we have to recess for votes across the street. And then
we will come back and have questions.
Mr. Sims, your statement has been entered into the record.
You are now recognized for 5 minutes.
STATEMENTS OF JIMMY F. SIMS, JR., RATING VETERANS SERVICE
REPRESENTATIVE, WINSTON-SALEM, NC, REGIONAL OFFICE, VETERANS
BENEFITS ADMINISTRATION, AND SHOP STEWARD, LOCAL 1738, AMERICAN
FEDERATION OF GOVERNMENT EMPLOYEES (AFL-CIO), AND AFGE NATIONAL
VETERANS AFFAIRS COUNCIL; JEFFREY C. HALL, ASSISTANT NATIONAL
LEGISLATIVE DIRECTOR, DISABLED AMERICAN VETERANS; MEG BARTLEY,
ESQ., SENIOR STAFF ATTORNEY, NATIONAL VETERANS LEGAL SERVICES
PROGRAM; DAVID E. HUNTER, PH.D., ASSISTANT DIRECTOR, COST
ANALYSIS AND RESEARCH DIVISION, INSTITUTE FOR DEFENSE ANALYSES;
AND IAN C. DE PLANQUE, DEPUTY DIRECTOR, VETERANS AFFAIRS AND
REHABILITATION COMMISSION, AMERICAN LEGION
STATEMENT OF JIMMY F. SIMS, JR.
Mr. Sims. Thank you.
I thank Chairman Hall, Ranking Member Lamborn. I would like
to thank you for allowing me the opportunity to testify on
behalf of the American Federation of Government Employees and
the National VA Council.
Training has a direct impact on the VBA's ability to
process claims accurately and timely. Improving VBA's training
program is of utmost importance given the increased number of
new claims processors and projected increase over the next
year.
I would like to say at the outset that after many years of
excluding the input of AFGE members on training and testing
programs, we are beginning to see a change toward a more
collaborative effort.
I recently began working on a site team headed by the VBA's
Employee Development and Training Director, Terence Meehan,
which was commissioned to review the implementation and
compliance with phase three challenge training. Hopefully this
joint teamwork will not stop with challenge training and will
also look at the training programs for senior employees.
Why is VBA's mandatory annual training program deficient?
First, too much of the training is self-directed. Employees are
provided documents on the computer and expected to review,
interpret, and apply this information with no assistance from
subject matter experts.
While computer-based training is an effective tool for
providing training for a large audience, the computer-based
training should not be the primary method of training. There
must be more formal classroom training.
Second, VBA is facing a lack of qualified trainers. Many of
the employees placed in a training role have not had the
benefit of formal instructor training.
In my office, simply being promoted to a decision review
officer or a super senior VSR automatically qualifies you as a
trainer and you are thrust into the instructor role right away.
There is no program in place to validate the retention of
the newly learned material. Currently, VBA only tracks the
quantity of training versus the quality of training.
In addition, some topics identified in the mandatory
training such as how to write a clear and concise rating
decision are remedial training which is better focused on
employees within the first year of training. This training time
would be better spent on more complex concepts such as
evaluating blast injuries or debilitating diseases.
AFGE has also received reports by employees at other
regional offices of management's pressure to spend much less
time than officially allotted on training modules in an attempt
to increase productivity.
VBA allows regional offices to specify topics for 20 hours
of the mandatory training. This practice has evolved into
issues being identified during regular team meetings and
management directing employees to take training time for these
meetings.
The GAO reported an average of 46 percent of employees
indicated they would experience difficulty in completing this
training. I would dare say this percentage is greatly under-
reported based on experiences in my regional office.
Overall, employees report that the 85-hour requirement is
hard to achieve when faced with the dilemma of adequately
completing the training or meeting management's production
requirements.
The timing of training is also a problem. In my regional
office, we have experienced delays in delivery of the training.
We are still awaiting training directed by VBA on ischemic
heart disease, which is a presumptive disability associated
with the Agent Orange exposure.
VA must begin to invest the time and energy necessary to
meet the training needs of the employees. Otherwise, the Agency
is doomed to fail in our mission.
AFGE urges Congress to take the following actions:
Establish a team of subject matter experts to include
hands-on senior claims processors, AFGE, and veteran service
officers to annually review the training programs and make
recommendations for improvement; establish an effective
monitoring system for tracking compliance with training to
eliminate the incentives of managers who require employees to
shortcut the training to meet production; develop clear
guidelines on what should and should not be credited toward
training requirements; to establish consistency across the
regional offices; and, finally, VBA must start utilizing the
national Systematic Technical Accuracy Review (STAR) quality
review program to shape training around the areas where
employees are making the most errors.
Thank you for this opportunity to testify and I stand ready
to answer any questions you may have.
[The prepared statement of Mr. Sims appears on p. 40.]
Mr. Hall of New York. Thank you, Mr. Sims.
I am now going to call on the DAV witness, Jeffrey Hall,
who was the National Service Officer Supervisor in the New York
office for the last 6 years and has recently moved to DC.
We are not related, but it is my pleasure to recognize you
for 5 minutes of testimony.
STATEMENT OF JEFFREY C. HALL
Mr. Jeffrey Hall. Thank you, Mr. Chairman. Good morning to
you and Ranking Member Lamborn.
It is indeed a pleasure to appear before this Subcommittee
to discuss the training program and requirements for VBA claims
processors and why training is so important in reforming the
benefits claims process.
Mr. Chairman, while the growing backlog of pending claims
receives all the headlines, the backlog is actually not the
problem. It is just one symptom of a much larger problem, a
broken claims process.
Rather than focusing only on breaking the back of the
backlog of claims, VA must work to build a new claims process
that is centered around the idea of getting it right the first
time, which will require uncompromising emphasis on quality,
accuracy, consistency, and training.
Similar to VBA, DAV has an extensive training program for
our National Service Officers (NSOs). And I would like to offer
some insight as to the training that we provide versus that of
VBA.
VBA's training for new employees involves periods of
orientation and classroom instruction followed by on-the-job
training and increasing caseloads until they receive a full
caseload which is approximately 2 years from their hire date.
DAV's training program for new NSOs has a similar structure
and format. However, we emphasize academic foundation by
requiring college-level courses in anatomy and physiology,
medical terminology, and legal research and writing.
In addition to mandatory testing throughout their initial
training, NSOs must pass a comprehensive Web-based examination
for the entire 16-month training period.
Beyond VBA's initial training, experienced VSRs and RVSRs
are required to complete 85 hours of training annually. By
comparison, DAV's structure and continued training program is
required of all NSOs and managers.
Training is separated into two separate 16-month training
periods with monthly testing and aggregate testing at the
conclusion of each period. All NSOs and managers are
responsible for successfully completing the training and
testing. Training and testing are ongoing and repeated every 3
years for the duration of their careers.
Upon successful completion of the entire training
curriculum for the first time, NSOs earn 12 college credits
from the American Council on Education. This is a major
incentive to NSOs and one VBA may want to consider for its own
employees.
We are not suggesting that VBA match DAV's training program
nor adopt our curriculum verbatim. However, we do feel that it
is not possible for VBA claims processors to maximize their
potential or proficiency level without substantially increasing
the amount of training beyond the 85 hours currently required.
Even with this minimal training requirement, as we have
heard, GAO found that only one regional office actually met
their training requirement in 2009. And at nine regional
offices, less than 50 percent of VSRs and RVSRs met their
training goals.
GAO also reported that 46 percent of experienced claims
processors found it difficult to meet their annual training
requirement due to their increasing workload demands.
Mr. Chairman, from my personal experience over the past 17
years, VBA employees are motivated to learn. They want to do a
good job for veterans, but they are disillusioned by more
pressure being placed on meeting production goals than that of
quality, accuracy, and training.
VBA employees need regular training schedules and managers
must allow time for training. Also successful completion of the
training must be an absolute requirement for every regional
office while being a shared responsibility of every employee
and manager.
Just as VBA managers must provide employees with the time
for training, employees must faithfully complete that training.
Neither should be able or feel pressured to simply check the
box when it comes to training.
It is our understanding that VBA is administering some type
of certification examination for employees. However, the
examination being used seems to be for grade level increases
only and not for aptitude purposes.
A VSR must pass a certification examination to move, for
example, to the highest level. However, if they fail the
examination, they can still remain at their current grade level
albeit with no requirement to retake the exam or learn the
material.
An experienced VBA employee recently told me that the only
requirement for annual training is to simply attend, but there
is no tool such as testing to measure whether or not the
training is understood or the information being retained. In
fact, when he expressed his opinion about the need for testing,
he was actually ridiculed and he left the training feeling that
it was a waste of his time and merely fulfilling a requirement.
Regular testing, Mr. Chairman, should be a mandatory for
all VBA employees to include and must include coaches, Decision
Review Officers (DROs), and managers. Testing measures for
efficiency and knowledge and can identify subject matters or
competencies requiring additional training. Equally important,
testing can also aid in evaluating the effectiveness of
training programs and ascertain weaknesses in the claims
process.
Mr. Chairman, in closing, for the VA to truly reform the
claims process, it must make an earnest effort and invest the
time and resources towards getting it right the first time. And
training is an essential and core component of any reform.
This concludes my testimony. I will be happy to answer any
questions.
[The prepared statement of Mr. Hall appears on p. 42.]
Mr. Hall of New York. Thank you, Mr. Hall, and thank you
for your service to our veterans, especially those in New York
and in the Hudson Valley.
Ms. Bartley, you are recognized for 5 minutes.
STATEMENT OF MEG BARTLEY, ESQ.
Ms. Bartley. Chairman Hall and Ranking Member Lamborn and
Members of the Subcommittee, I am honored to provide this
testimony on behalf of National Veterans Legal Services
Program.
I and others at NVLSP read the GAO report on training of
claims processors. It would be duplicative at this time to
review the findings and recommendations, but the report was
very revealing.
In this testimony, I wanted to step back for a minute from
the details of the report and look broadly at what we see
happening at the VA ROs through some other lenses. These lenses
include talking to current VA employees at American Legion
quality reviews, talking with former VA employees, reviewing
files for cases on appeal to the Board, and reviewing files for
cases that are on appeal at the Veterans Court.
And based on those lenses, I wanted to just make a few
points, recommendations, and observations.
First it seems that many VA errors seem to be caused by the
perceived need to adjudicate claims quickly and not necessarily
by a lack of knowledge on the part of the VSRs and RVSRs. The
need to hurry and always hurry is a strong contributing factor
at the very least to work not being properly done.
The work is not brain surgery but neither is it, you know,
a one plus one equals two. There are complexities involved and
it takes a lot of time to do these claims. When employees do
not have that time, sometimes it is not a matter of how much
they know, they're not going to be doing a good job if they do
not have the time.
In our perspective, training is important, but time to do
the job well from the start is very important also. And the
VA's emphasis on production at all costs can hinder any kind of
training that has occurred.
The second point is that VA needs to, and I am just
reiterating what others have said here, needs to identify major
error patterns and work on them. There are common errors that
are repeated so often that they deserve to be the subject of
intense focus by the VA in training.
Some of the errors I have listed in my testimony and I will
just repeat a few here. Not providing a VA exam or medical
opinion where one was required or warranted under current law,
this could easily be a reason for one-quarter to one-third of
all remands, cases that keep going around the hamster wheel of
the VA, the Board, and the court.
So VA needs to identify these major error patterns and work
on them. It wastes tax dollars trying to fix these cases at
higher appeal levels. And those errors have to be strongly and
actively targeted preferably with interactive training where
trainers use actual files and scenarios to train on this issue.
One other point is that immediate supervisors of VSRs and
RVSRs should have technical experience. I know this was
addressed in the Veterans Benefits Improvement Act of 2008
requiring certification of employees or managers, but feedback
we received from VA ROs tells us this is still a problem.
If the manager does not have technical experience, that
really deteriorates the whole notion of training and of
quality. If you cannot ask your boss to answer your substantive
question about your work, there is something wrong.
Under-use of DROs as a training tool is also a problem for
some ROs. Let me say that some DROs do not appear to be real
highly skilled sometimes in decisions that I read, but
nevertheless one of the main reasons for the DRO program to
begin with was not only to lessen the appeal numbers but also
to use DROs as a tool to target issues that were being done
wrong by the RVSRs and to target poorly trained employees. And
the DRO knowledge base is not being used from feedback that we
get from employees at this time.
And, finally, the training attitude of some managers has to
change. The GAO report said that 50 percent thought training of
80 hours really was not necessary. This attitude should change.
The manager is seeing only the little picture of their regional
office, but that mentality really does hinder the VA in doing a
quality job.
Mr. Chairman, this completes my statement.
[The prepared statement of Ms. Bartley appears on p. 48.]
Mr. Hall of New York. Thank you, Ms. Bartley.
Let us see. Mr. Hunter, you are now recognized for 5
minutes.
STATEMENT OF DAVID E. HUNTER, PH.D.
Mr. Hunter. First, good morning. Mr. Chairman and Members
of the Subcommittee, I am pleased to come before you today to
discuss IDA's assessment of claims adjudication personnel
requirements, a study we performed for VBA in 2009.
In November of 2008, as a result of the Veterans Benefits
Improvement Act of 2008, the VA asked IDA to conduct an
assessment of the current personnel requirements of the VBA.
Given the topic of today's hearing, it is important to note
that the focus of our study was personnel requirements for VBA
claims adjudication positions.
IDA was not asked to analyze the adequacy of training
requirements nor did it do so. We did not make any
recommendations regarding training.
We did find that requirements for training are an important
factor in determining the VBA claims processing capacity,
however, as the balance of my testimony will discuss.
The results of our study in entirety have been documented
in IDA Paper P4471. Our analysis shows that for the rating
bundle, VBA claims processing capacity is currently limited by
the number of rating veteran service representatives or RVSRs.
Our model of the VBA claims processing capacity took into
account, among other factors, the number and experience levels
of claims adjudication personnel, particularly RVSRs.
Newly hired RVSRs are not as effective as fully trained
RVSRs. They spend a significant portion of their time in the
classroom and engaged in on-the-job training and they are
generally less proficient in the performance of their tasks.
We calculated effectiveness levels for less than fully
trained RVSRs based on the typical production goals used at the
regional offices. It takes 2 years for an RVSR to become 100
percent effective. For less experienced RVSRs, we assume that
for the first 6 months of employment they did not contribute to
claims production and they become incrementally more effective
from 6 months to 2 years.
We note in our report that VBA added over 600 RVSRs from
the beginning of fiscal year 2008 to April 2009, the last month
for which we had actual employment levels.
Due to the increasing productivity of these RVSRs as they
gain experience over time, we estimated that production would
grow by 29 percent from September 2009 levels without any
additional hiring.
There is a direct relationship between the number of
adjudication personnel and the number of completed claims.
Increases in completed claims do not necessarily translate into
a decline in the pending inventory, however, because the
pending inventory is influenced by both completed and received
claims.
In fiscal year 2008, completed rating claims exceeded
received rating claims for the first time since fiscal year
2003. The result was the number of pending rating claims which
had been increasing during the preceding several years
decreased slightly in fiscal year 2008.
Unfortunately, this trend in pending claims did not
continue. Our study accurately forecasted that completed claims
would increase further in fiscal year 2009 and 2010 as the
RVSRs that were hired in 2007 and 2008 became fully effective.
Claims received, however, increased even more rapidly and,
hence, pending claims increased even while VBA capacity
increased.
The number of received claims is difficult to predict. It
can change drastically from year to year due to changes in both
statute and in veterans' propensity to file claims. Any
substantive changes from historically observed behavior will
naturally have direct effects on the requirements for VBA
claims adjudication personnel.
Mr. Chairman, Members of the Subcommittee, that concludes
my remarks and I would be happy to answer any questions that
you have.
[The prepared statement of Dr. Hunter appears on p. 50.]
Mr. Hall of New York. Thank you, Dr. Hunter.
Mr. de Planque, welcome, and you have the floor for 5
minutes.
STATEMENT OF IAN C. DE PLANQUE
Mr. de Planque. Good morning, Mr. Chairman and Ranking
Member Lamborn. I would like to thank you on behalf of the
American Legion for the opportunity to talk about training
today.
This is a particularly opportune time to examine the
training process at VA owing largely to recent attention to VBA
operations and the growing backlog. There has been a boom in VA
hiring unseen in recent history.
With these growing numbers come greater challenges to VA.
Nearly half of the workforce processing claims has less than 3
years of experience. While this infusion of new energy and
resources has great potential to help VA manage their caseload
that includes over a million new filings every year, it will be
wasted if these employees cannot be properly trained and
brought up to speed to handle claims accurately and with the
timeliness to meet Secretary Shinseki's stated goals of 98
percent accuracy and no claim pending longer than 125 days.
In order to examine this, we want to look at three areas,
consistency, focus, and measurement of the training process.
The consistency issue has been highlighted by American
Legion visits, quality review visits. Over the last decade or
so, we have conducted between 40 and 50 of these quality review
visits in conjunction with NVLSP. They consist of a mix of
examination of recently adjudicated cases as well as in-depth
interviews with the staff of VA.
What we have noted overwhelmingly is inconsistency from
regional office to regional office. Mr. Bertoni from the GAO
recently mentioned Fast Letters. In some offices, the reading
of a Fast Letter is counted as training. In other offices, it
is not counted as training.
With most of the employees that we have discussed, a Fast
Letter from VA, a directive on how VA employees should be
operating, is circulated as an e-mail and they are told to read
it and if they have any questions, go to a supervisor.
That is not efficiently getting the training out to the
people. Regardless of the intention of Central Office, if they
cannot consistently enforce their training plan at the
individual regional offices, it will be ineffective.
In terms of focus, VA has a wealth of data that is out
there that can tell them where they need to focus their
training. We have mentioned these STAR reviews, internal
quality reviews, the DROs reviewing cases, the Board of
Veterans' Appeals reviewing cases and sending back their
regular remands.
We have just heard that the Board sends 37 percent of the
cases back as remands for avoidable errors. Those avoidable
errors should be captured and reinforced with employees so that
they are avoided in the future.
The American Legion has recommended in the past, and
continues to recommend, that STAR reviews, DRO decisions,
remands from the Board of Veterans' Appeals, remands from the
Veterans Court be captured and used as a focusing mechanism for
future training for VA employees.
Finally, I would like to look at the measurement section of
how VA measures the training. It does not matter if we are
talking about 45 hours of training, 85 hours of training, or
105 hours. If it is not effective training, it does not matter
how many hours they are doing.
We have just heard again from Mr. Sims of the AFGE
mentioning that training is tracked as a measure of quantity,
not quality. Where have we heard this before? This is a
consistent mantra within the VA. Whether they are doing four
claims a day without regard to whether you are doing them
correctly or whether you are meeting your 85 hours a year of
training, you are simply checking a box. You are not looking to
see that you are doing the job correctly.
And so that aspect of the training needs to be addressed
and it is difficult to say whether 85 hours is enough if you do
not know if it is the right kind of training. The kind of
training should be targeted, it should be consistently applied
to all of the employees, and there needs to be a better metric
to measure that training.
This concludes my statement and I would be happy to answer
any questions that you may have.
[The prepared statement of Mr. de Planque appears on p.
54.]
Mr. Hall of New York. Thank you, Mr. de Planque.
Thank you all for your testimony.
I will start by asking Mr. Sims, should experienced raters
who perform well in their performance ratings be allowed to
take less training and should VBA require more training for
those who score poorly on performance evaluations?
Mr. Sims. Chairman Hall, the aspect of senior rating
specialists who perform well receiving less training, I do not
believe that is an adequate way to approach training. Training
is necessary at all phases of our work because of the nature of
the work and the rapid changes that take place both in
legislation and in medical technology. It directly affects how
we do our job.
The targeting training for those who are performing poorly
is something that needs to be looked at. Saying that 85 hours
across the board is adequate for all personnel is not an
adequate way to look at training. Training needs to be focused
on the needs of the employee.
There are employees that may require a greater amount of
training to be focused because of their performance whereas
some employees may not need the same type of training, but
continual training is necessary in our position.
Mr. Hall of New York. Is there a way that VBA could better
tailor the training to produce better outcomes for employees
and for veterans given the disparity between how quickly
certain people learn or employees learn their training and they
take the material in and get it and are ready to go back to--it
would seem some people are ready to go to work using that new
information quicker than others. And I am just curious if you
think VBA should be trying to tailor its training requirements
depending on the outcome.
Mr. Sims. Well, the VBA is in one form tailoring the
training in the fact that there are specific topics that are
identified for intermediate level and journey level. The
problem is that the training topics that are identified are
set. And, unfortunately, there is not enough focus on the areas
where improvement is necessary.
We have a quality review program in place both locally and
nationally, but, unfortunately, the trends identified by those
reviews are not being targeted as the necessary training during
that period of time.
Even at our regional office, it was recommended that the
local quality reviews be looked at over the past 12 months to
identify specific trends and our local training be targeted on
those specific topics. And, unfortunately, that was met with
resistance.
And I believe that's also taking place on the national
level because of the additional work it may require to be able
to identify those specific trends and develop that training
specifically to address those needs.
Mr. Hall of New York. Mr. Hall, could you please elaborate
on the point in your testimony about the VA's failure to
implement certification testing for decision review officers
and supervisory personnel as is required in Public Law 110-389.
Mr. Jeffrey Hall. Actually, it was based off conversations
with VBA employees as an example indicating that certification
examinations, while it might be the intent of Public Law 110-
389, may not be what is actually being done in their estimation
because those certification examinations, in fact, are being
used at different regional offices for grade level increases as
an example and not really to test the proficiency from the 85
hours or training that they received through the year.
In their estimation, also in speaking with them, and really
from a personal experience level as a manager that had to take
training, deliver training, and develop training for all of my
employees, managers should never be exempt from a training
program. You cannot expect them to learn the material on their
own accord because of the complexities and nature of this
business. It is way too difficult.
But if you have managers that are exempt or not involved to
include decision review officers, if they are not part of the
training program and a testing or a certification examination,
then to me it is a failed experiment at the beginning.
Mr. Hall of New York. Given DAV's vast experience with
training its service officers, do you have any recommendations
for improving the challenge program and VA's overall training,
I am referring specifically to your point in your testimony
about the error trend analysis, and aggregating and analyzing
STAR and Inter-Rater Reliability (IRR) data?
Mr. Jeffrey Hall. All of those reviews are absolutely
important. If they do not collectively compile the data results
from each one of those sources, they just have a fragmented
database that they are drawing from.
As far as the challenge training, I am not really clear on
the specifics of what they undergo point for point in the
challenge training. I do talk to the VBA employees as an
example and many of them, some of which actually went through
DAV's training program. It will provide a comparison for me and
say that they are well advanced beyond what is being done at
the challenge training. Some also feel that when they reach
that level of challenge training that it might be well above
where they feel that they are ready.
As far as the data analysis portion of the question, I can
tell you whether it is the IRR or the STAR or coaches' reviews,
one thing that I have yet to see, at least in my personal
experiences, where one of the best sources of seeing how well
they are doing is a service organization.
We are a wealth of experience and expertise and we will
tell them exactly where the decision has gone wrong, the
quality of the decision, and things like that. Yet, they won't
ask for it. They simply wait for an appeal or a notice of
disagreement, something of that magnitude.
Mr. Hall of New York. Thank you.
Ms. Bartley, NVLSP has testified repeatedly that the
overemphasis on production by VBA often leads its claims
processing personnel to commit avoidable errors, which stem
from the work credit requirements.
Could you elaborate on your example in your testimony about
diabetes' secondary conditions, which constitute a large
portion of VA's current inventory and if work credits are not
assigned, how might VA count employee production and do you
think the training should be more vigorous and standardized
before production is counted?
Ms. Bartley. Yes. We have frequently, and I know that other
service organizations have frequently, made the point that an
emphasis on or overemphasis on production leads to avoidable
errors.
Well, what we see in quality reviews is that some things
that seem to be obvious are not caught by the rater. And as I
said in my testimony, you could attribute this to a lack of
knowledge or a lack of skill or you could on the other hand
attribute it to perhaps they were being rushed and they were in
a hurry and they knew that they had to get so many cases done
per week or per day and that that was the reason it was not
caught. And in many cases, it might be a combination of both
factors.
For something that seems fairly obvious, VA has trained
repeatedly on what the secondary conditions are for diabetes.
Right as soon as the condition diabetes came presumptive, they
issued a training letter that listed all of the secondary types
of issues that they would be facing, retinitis, neuropathy, et
cetera.
And so the fact that some of these are missed leads us to
believe that these are missed with some frequently as shown by
our quality reviews that are conducted for the American Legion.
The fact that these are missed really kind of puts you in a
quandary. And the fact that they have trained on it pretty
steadily makes us think that at least one factor here is indeed
the employees need to get their work done quickly, as I said.
As to what can be done about it or how VA could count work
differently, it is bothersome that for however many claims the
veteran has filed, the VA would only get one work credit for
doing that particular work for that veteran. And I think that
changing that, I am not an expert in, you know, counting or
managing a large organization, but it does seem that that is
the key factor here is the inability to take sufficient credit
for work done.
Mr. Hall of New York. Thank you.
I have run over time, so I am going to recognize Mr.
Lamborn for his questions.
Mr. Lamborn. Thank you.
And I have a question for Mr. Hall, not the Chairman, and
then a question or two for anyone on the panel.
Mr. Hall, how would you suggest that the VA create a level
of accountability in the VBA's training program since you
implied that you could find little or no evidence of any
existing accountability?
Mr. Jeffrey Hall. As far as VA's accountability, I mean, it
is a very difficult subject or topic because I understand with
AFGE and a lot of components that go into that. What we are
suggesting is a simple fact in DAV, we have the highest level
of accountability from the senior to the newest employee.
We follow that individual throughout their training and,
again, because we require our own managers who are delivering
the training, we hold them to the same accountability level.
Whether VA can actually achieve that same thing because with
our accountability we have things like performance reviews
which may affect salary increases and things like up to and
possibly including, possible termination of employment if they
are simply not being compliant or not meeting the training
requirements and things of that nature. Whether VA can do that
or not is really not for me to answer, I believe, but I can
tell you that I think the accountability simply is if you are
going to have testing and training for an employee, managers
must be held accountable to the same situation.
Mr. Lamborn. Okay. Thank you.
Now, for anyone else or you or anyone on this distinguished
panel, how well does the VA utilize feedback to ascertain
whether its training is effective and how might such a
measurement mechanism be instituted if it is not already in
place? Anyone care to take a stab at that?
Mr. Sims. Well, Ranking Member Lamborn, currently the
training that we receive in the field, each training program
through the learning management system has a survey that is
attached to it. That is how we certify whether or not we have
completed the training is we go in and complete the survey
attached to it.
The surveys identify whether or not the training, we felt
it was beneficial, whether we had problems completing the
training, whether there were specific issues that needed to be
addressed through the training that were not. There is a block
where we can put in suggestions that we have.
As to whether or not that information is being utilized,
that is a question that would be better posed to the VBA
counsel, our panel that is going to be here. We know we provide
the suggestions, but whether or not they are accepted, that is
something that is above us.
Mr. de Planque. One other thing I would like to note in
terms of a feedback mechanism, and both Mr. Sims and myself
touched on this and we have pointed this out a number of times,
there is a mechanism that is already in there.
If you look at the STAR reviews, if you look at internal
reviews, if you look at what the Board is remanding for or what
the court is remanding for, they are your common errors. They
are the things that you know that you need to work on. If you
are a third grader taking a math test and you miss all the
questions on fractions, you have to go back home and study
fractions so you do not fail that on the next test.
Mr. Lamborn. I remember that well.
Mr. de Planque. Yeah. That mechanism is already there. And
like I said, I know it was brought up there. This should be
used. It is a no-brainer. It is an easy mechanism that is
already there that can be captured and put into that training
that will help get rid of what the Board has been calling
avoidable errors.
Mr. Lamborn. Thank you.
For the sake of time, I will move on to the last question.
Once again, any one of you feel free to respond.
Does the VA track remand decisions for the purpose of
training development so that future remands of that type are
avoided?
Mr. Jeffrey Hall. In my opinion, they do not. They track it
simply for productivity or number sake, statistics, not for
remedial training, something that, you know, if we had 17
percent of our cases remanded back at this level, not in my
personal experience have I seen or had the discussion with any
senior VBA employee at any of those local regional offices that
would tell you, oh, yeah, we have a 17 percent remand rate and
we are training hard on those subjects. It is simply we have a
remand rate and we need to get these cases back up there.
Mr. Sims. And I can attest from my experience as a rating
specialist at our regional office, the only time I see anything
of a remand is when it is sent to me to deal with. There is no
discussion on the topics that come back on remand. There is no
identification of the trends in the remand and there is no
training that is done on the nature of the remands. It just
does not take place.
Ms. Bartley. And I just wanted to point out that with the
Appeals Management Center coming into existence several years
ago that we have heard complaints that, of course, the regional
offices are not getting the benefit of getting all of those
cases back and seeing actually what they did wrong the first
time.
Mr. de Planque. We think there could actually be an
excellent tool. If you are working in a regional office and you
get told you had 48 cases remanded this month because of
improper Veterans Claims Assistance Act (VCAA) letters, that is
a tool that tells you we need to have some more training on
VCAA letters. So it is a great tool. To the best of our
knowledge, we are not hearing that it is being utilized.
Mr. Lamborn. Okay. Once again, I want to thank you. I know
the Chairman agrees. You have been very good with the
information you provided. We appreciate it. And thank you for
being here.
And I yield back.
Mr. Hall of New York. Thank you, Mr. Lamborn.
I just have a couple more questions first of all for Dr.
Hunter.
You have noted that there are no nationwide rules for
training factors. Do you believe that implementing such
nationwide regulations would enhance accuracy and timeliness of
adjudicating claims?
Mr. Hunter. No. I would think that would not be helpful.
What we noticed is that these actually vary from individual to
individual. What we used in our study were averages.
So RVSRs typically take 2 years. There was no hard and fast
rule. So it varies not only from region to region but from
individual to individual within a regional office. So having a
standard for less than fully trained people to have one or two
weighted cases that they would have to do would likely not be
helpful for the goals you suggest.
Mr. Hall of New York. You also note in your 2009 report
that the ideal methodology for predicting personnel
requirements would be to simulate the processing stages for
each incoming claim and use statistical distributions to
estimate the time required at each stage, but that this data
does not exist.
Why is that the case and what would be necessary to acquire
this information?
Mr. Hunter. That is a really interesting question. One of
the problems you have at looking at the pending inventory of
claims are some are ready to rate and be done if there was
available RVSR hours. Others are not. They are somewhere in the
process either waiting for a medical exam or something else
that cannot be completed at that time.
So it is impossible to tell from the available data what
the limit is on the number of claims that are actually awaiting
a rating decision versus how many are stuck in the process due
to other parts of the requirements.
Knowing that and being able to track a claim through, you
would be able to figure out what the actual personnel
requirements were and what the actual minimum inventory you
could get and be able to suggest improvements to the process.
I think to implement that, you would have to do a data
collection effort. I do not think that data exists, so you have
to go through and actually track claims through the process to
see what fraction of them are waiting for various additional
evidence or doctors' exams before they can be declared ready to
rate.
Mr. Hall of New York. Based on your studies including the
IDA study on regional office variances from 2007, do you have
any recommendations on how VA might improve the quality and
accuracy of its production?
Mr. Hunter. Well, IDA is also working on an independent
assessment, the quality assurance program that is due next year
that will touch on that as well. But I can talk back to our
2007 study a little bit.
What we talked about was the accuracy would be improved and
the consistencies particularly if training was done the same
from when people started and then all periodic and recurring
training across all ROs.
Right now our experience was that it was being done
differently for raters of different experience and also
differently at each of the individual ROs, which was leading to
potential inconsistencies in rating decisions.
Mr. Hall of New York. Mr. de Planque, you stated that it is
essential to develop real benchmarks to illustrate whether
deficiencies in knowledge and expertise in the workforce are
being addressed.
Could you explain what type of benchmarks you would suggest
that would accurately address this issue?
Mr. de Planque. Well, I think the most obvious and glaring
benchmark that is out there is accuracy rate. When you see the
accuracy rate starting to go up, when you see it start to
approach that 98 percent goal, then you know that they are
training effectively. You know that you are eliminating the
previous errors and mistakes. I think that is a very obvious
one.
I think also we heard Mr. Hall from our panel discuss
testing as a feedback mechanism and understanding that you have
achieved the goal of training on that.
When we mentioned the example earlier of the Fast Letter
just being put out there, ask any questions if you have it, if
you have some kind of simple testing mechanism and not
something that is there to instill fear in employees about, oh,
I have a test and I am very upset, but a simple mechanism that
tells you did I learn the material, was this presented to me in
a way that I understand it. You need to have that mechanism
from the employees, and testing is one way to get it, that says
I understand what you are telling me, I understand what is
being presented to me. So the testing and also looking at the
accuracy rate, looking at it rising and not dropping as it has
been lately.
Mr. Hall of New York. Well, thank you very much, sir.
Thank you to all of our panelists, for your very helpful
testimony. And we have more questions that we might submit in
writing to you, but for now for the sake of time and knowing
that there are votes coming down the road, we will thank you
and excuse this panel and move on. So thank you all so much for
the work you are doing.
Let us call Michael Cardarelli, the Acting Deputy Under
Secretary for Benefits of the Veterans Benefits Administration,
U.S. Department of Veterans Affairs as our third panel.
He is joined by Diana M. Rubens, Associate Deputy Under
Secretary for Field Operations, the VBA, and Terence Meehan,
the Director of Employee Development and Training, the VBA, and
Danny Pummill of the VA, Deputy Director for Policy and
Procedures, Compensation and Pension Service (C&P) of the
Veterans Benefits Administration.
Welcome, and your full written statement is already made a
part of the record, as you know, so, Mr. Cardarelli, you have
the floor for 5 minutes.
STATEMENT OF MICHAEL CARDARELLI, ACTING DEPUTY UNDER SECRETARY
FOR BENEFITS, VETERANS BENEFITS ADMINISTRATION, U.S. DEPARTMENT
OF VETERANS AFFAIRS; ACCOMPANIED BY DIANA M. RUBENS, ASSOCIATE
DEPUTY UNDER SECRETARY FOR FIELD OPERATIONS, VETERANS BENEFITS
ADMINISTRATION, U.S. DEPARTMENT OF VETERANS AFFAIRS; TERENCE
MEEHAN, DIRECTOR OF EMPLOYEE DEVELOPMENT AND TRAINING, VETERANS
BENEFITS ADMINISTRATION, U.S. DEPARTMENT OF VETERANS AFFAIRS;
AND DANNY PUMMILL, DEPUTY DIRECTOR FOR POLICY AND PROCEDURES,
COMPENSATION AND PENSION SERVICE, VETERANS BENEFITS
ADMINISTRATION, U.S. DEPARTMENT OF VETERANS AFFAIRS
Mr. Cardarelli. Thank you, Mr. Chairman.
Mr. Chairman and Members of the Subcommittee, thank you for
the opportunity today to appear before the Subcommittee to
discuss employee training within VBA.
I am pleased to be accompanied by Diana Rubens, Associate
Deputy Under Secretary for Field Operations; Terence Meehan,
Director of Employee Development and Training; and Danny
Pummill, Deputy Director for Policy and Procedures for C&P
Service.
As you know, Secretary Shinseki set the goal of eliminating
the disability claims backlog by 2015 so no veteran has to wait
more than 125 days for a high-quality decision that meets a 98
percent accuracy level. This important goal is at the center of
our work as we collaborate across VA to improve the delivery of
benefits to our Nation's veterans.
VBA has been aggressively hiring claims processing staff
across the Nation since fiscal year 2007 and continues to hire
through fiscal year 2010. However, hiring more employees is not
a sufficient solution.
The need to better serve our veterans requires bold and
comprehensive business changes to transform VBA into a high
performing, 21st Century organization that provides the best
services available to our Nation's veterans and their families.
We are attacking the claims process and backlog through a
focused multi-prong approach. At its core, our approach relies
on changing our culture, reengineering current business
processes, and developing our infrastructure with technology
that supports a paperless claims environment.
Through VA, we are rededicating ourselves to the mission of
being advocates for our veterans. One of VBA's strategies to
improve and expand training available for our employees, we
focus on high quality timely and relevant training for both new
and experienced personnel.
VBA has developed and implemented a standardized training
curriculum, the challenge training program, for new claims
processing employees. The challenge program is a national
technical training curriculum that provides new employees with
the skills they need to function effectively in their positions
as veteran service representatives or rating veteran service
representatives.
Since fiscal year 2007, VBA has trained more than 7,200 new
VSRs and RVSRs including more than 2,000 in fiscal year 2010.
The challenge program is delivered in three phases. Phase
one is completion of knowledge-based prerequisite training at
home station using lectures, demonstrations of computer
applications, and team learning.
Phase two is centralized classroom training. Newly hired
VSRs and RVSRs attended 2\1/2\ weeks of resident training.
Centralized training provides hands-on training with computer
applications and advances the new employees through
progressively more challenging practice claims.
Phase three is completed at home stations lending lectures,
discussions, and Training and Performance Support System (TPSS)
training with experiential learning. Trainees work actual
veterans' cases under the guidance of experienced personnel.
Instructors in the third phase are experienced VSRs or RVSRs
with current knowledge of regulations and procedures.
VBA institutes continuous improvements to its training
program for experienced personnel. Beginning in fiscal year
2010, VBA designed national curricula to enhance quality in
claims processing through standardized training.
Topics in the national curricula were selected to address
national quality issues as determined through VBA's Systematic
Technical Accuracy Review or the STAR program.
In fiscal year 2010, VSRs and RVSRs are required to
complete a total of 85 hours of training including 40 hours
from the appropriate mandatory national technical curriculum,
20 hours of electives from a national technical curriculum of
additional topics, and 25 hours of station determined topics
that include courses required of all VA employees.
By August 31st, 73 percent of all VSRs and RVSRs had
exceeded the mandatory 85 hours of training and 80 percent were
on track to complete the requirement by the end of fiscal year
2010.
In fiscal year 2011, VBA is making additional improvements
in the training for experienced VSRs and RVSRs. The change will
give supervisors more latitude to tailor the annual training of
employees to better meet the emerging needs of individual
employees, their managers, and the RO in this transformational
environment.
VBA has improved its training oversight methods to increase
accountability. Managers at all levels are held accountable for
ensuring training requirements are met. The VA learning
management system provides a transparent view of each
employee's training achievements to managers and supervisors
from the team through the headquarters level.
In 2008, VBA created the position of training manager for
each RO. The training manager is responsible for local training
reviews as well as analyzing performance indicators to
determine local training needs and implementing the training
necessary to meet these needs.
In response to a GAO recommendation, VBA developed and
implemented a strategy for systematically assessing the
content, mode, and timing of training for experienced claims
processors. Training of claims processors has continuously
improved in VBA through ongoing evaluation of the training
program itself. VBA is also collecting and reviewing feedback
from staff to determine if the 85-hour training requirement is
appropriate for experienced VSRs and RVSRs.
In conclusion, since the Subcommittee's last hearing on VBA
training in 2008, VBA has improved instruction provided to new
claims processors, enhanced the relevancy and standardization
of training for experienced claims processors, and expanded
both oversight and evaluation of training programs.
VBA will continue its efforts to improve training and
ensure high quality decisions for our veterans in a timely
manner.
Mr. Chairman, this concludes my testimony. I will be happy
to respond to any questions that you or other Members of the
Subcommittee may have. Thank you.
[The prepared statement of Mr. Cardarelli appears on p.
56.]
Mr. Hall of New York. Thank you, sir.
I appreciate the effort that is being made by the Agency to
solve these problems that is kind of like a moving target as we
deal with the aging population of veterans from Vietnam, Korea,
World War II, and more recent veterans including those
returning from our current conflicts at the same time.
Congress is trying to do a responsible job of oversight and
give you the tools and the funding that the Agency and VBA and
the Veterans Health Administration need and also asking for
reports when we all know you are really, really busy without
coming here and reporting to us.
But thank you for being here and testifying and your
repeated and helpful testimony.
I am trying to get a full picture of the VBA personnel and
capacity. How many claims processing personnel does VBA
currently have and what is the number breakdown of the
positions and responsibility? For instance, the number of VSRs,
RVSRs, and DROs.
Mr. Cardarelli. Yes, sir. Overall, we have approximately
14,300.
Diana, if you want to go into specifics.
Ms. Rubens. Thank you.
Yes. The breakdown that we actually saw in Dr. Hunter's
testimony has increased. One of the key things I think
particularly, is that he reflected about 2,500 RVSRs. By the
end of this calendar year, it will be about 3,000.
We continue to evaluate the needs. Our RVSRs are our key
decision maker as it comes to those rating claims,
particularly, and so we will continue to evaluate whether that
number needs to increase further as we go through fiscal year
2011.
For our VSRs, we are in the 9,000 range. For our DROs, we
are at about 425 as of mid-summer and looking to increase that,
recognizing that they are our most skilled technicians,
particularly as we look at the need for succession planning.
We have been working very hard to make sure we are
increasing that number to prepare for the attrition we expect
to come in the next few years.
Mr. Hall of New York. Is there a quantitative empirical
relationship between VBA training requirements and national
claims processing goals such as on quality and accuracy and
what is the correlation between VBA training requirements and
VBA's national goals of 125 days, 98 percent accuracy, and 2015
for breaking the backlog?
Mr. Cardarelli. Yes, sir. There is a correlation. As you
aptly stated in your opening statement, our goal, one of the
things we strive to do is get the claim right the first time.
The two are intimately entwined.
As far as our training, the better trained that our
personnel are will enhance our timeliness and certainly enhance
our quality of what they actually do. Therefore, the two are
tied together, and they supplement each other.
Obviously we place a premium on our training in regards to
the 80 hours that we have; 40 hours that are dictated at a
national level, another 20 hours are from a menu of items that
comes from our national level, and then the final 25 hours
allow each RO to focus exclusively on those issues.
So we have a blend. What we are trying to do obviously is
set our employees up for success the first time, so that as
they review a case, they review it correctly and in a timely
manner.
Mr. Hall of New York. I have noticed during my tenure as
Chairman of this Subcommittee that VA sends out a number of
Fast Letters to the field. It actually notes that training has
still not occurred on rating eye disabilities for a schedule
change issued in February of 2009.
Given the number of eye injuries of our returning
servicemembers, I find this mystifying and disturbing.
How is training provided for recent changes in the law,
regulations, and statute? Is there regular training provided on
Fast Letters?
Mr. Cardarelli. Sir, our training and curriculum are
evolving. They change based upon the type of things that we are
seeing, the type of changes that are required, and where we
think emphasis needs to be.
We have 85 hours of training, but we constantly review that
and determine the right number of hours and the right number of
topics.
There was talk in earlier panels about the types of errors
seen, and we are focused on those. It is a constant review that
we do. There is a review that is done by the individuals as
they go through the training. They have a chance to provide
feedback such as: was the training helpful, worthwhile, what
other areas do you need to look at.
We are trying to have standardization through all 57 ROs as
much as possible, but we want to allow individual ROs to
address particular issues and be flexible enough so that as
changes come about in the law and procedure we have a chance to
put that training into our curricula.
Mr. Hall of New York. Thank you, sir.
Reviewing the materials that were sent over by VBA
outlining the content of the training modules, I came away with
concerns. I am not a training expert myself, but it seems that
there is not a lot of variety or breadth in the training topics
offered. I can see where more experienced personnel might find
it less than helpful.
In compliance with GAO's written recommendation, recent
recommendation, has VBA developed and implemented a written
strategy for systematically assessing the content, mode, and
timing of training experienced claims processors in the
regional offices and are there improvements planned or already
made? When indicated, how are these modules selected?
Mr. Cardarelli. Yes. In fact, we are working on a strategy
now. One of our focuses is to be able to do our basics
correctly. Sometimes that requires repetition. There is always
room for improvement. We know that. So we want to keep our
basic training doctrine consistent.
We have tried to involve the area directors and the RO
directors to ask: what is the feedback, what are the areas that
we are missing, what are the areas that we need to hit on that
we are not, in fact, hitting on.
You mentioned earlier that we are in a changing
environment. We are dealing with World War II era veterans and
Korea War veterans, but we are also dealing with the most
recent veterans from Afghanistan and Iraq. The types of claims
we are seeing are different. We need to make sure that we can
handle the other claims but also look at new situations as our
environment changes.
We have taken an effort here at the headquarters level to
make sure that we have standardized training, that we are
looking at all the different training modules that we have, and
that they are the appropriate ones in the appropriate place at
the appropriate time.
As I said earlier, it is evolving. It is something that
will change year to year. For example, in fiscal year 2011 we
brought people from the field in at all different levels to
look at the training, to look at the 40 hours, the 20 hours,
and the 25 hours, and ask, is this the right mix of things to
make us ultimately successful.
I cannot overemphasize, and I came from an environment
where training is critical to what we did, is that the better
trained that our employees are in doing different types of
work, we will set them up for future success and allow them to
be more effective as they do their job.
Mr. Hall of New York. When this training strategy is
complete, could you supply a copy to the Committee, please?
Mr. Cardarelli. Yes, sir.
[The VA subsequently provided the following information:]
VBA's written strategy for systematically assessing the
content, mode, and timing of training experienced claims
processors follow:
VBA implemented an evaluation process to gather feedback from
experienced claims processors regarding the usefulness,
relevance, and quality of training they receive. VBA fielded an
on-line evaluation tool in February 2010 to collect evaluations
submitted by C&P claims processors on the usefulness,
relevance, and quality of national training received in field
offices. With 25,614 anonymous responses since March 2010:
91 percent of respondents considered training at least
moderately useful;
91 percent of respondents considered training relevant to their
jobs;
88 percent of respondents are confident they can apply the
training to their jobs; and
91 percent of respondents considered worthwhile the requirement
they complete the training.
In FY 2010, C&P Service also examined this issue and
determined that at a minimum, half of the required annual
training hours would be dedicated to addressing national
quality trends. Upon review of local quality data and
discussions with regional office personnel, VBA increased the
hours dedicated to training on quality issues to a minimum of
60 hours for FY 2011. Forty hours of this training are
identified by specific required topics and assigned training
curriculum based on national quality trends and emerging
issues. Each regional office selects an additional 20 hours of
training based on local quality trends from curriculum
available on the C&P training Web site.
We are working to incorporate survey instruments into our
Learning Management System. This will allow supervisors to
monitor individual compliance with the completion of the
survey. This process is nearing completion and should be rolled
out by the second quarter FY 2011.
Training needs will continue to be reviewed periodically and
revised as necessary. Currently, the appropriateness of the
Core Technical Training Requirement courses is discussed at
both the annual Veterans Service Center Managers (VSCMs)
Conference and the annual Training Managers Conference. Monthly
calls are held with all VSCMs and local Training Managers
concerning changes in training policy.
Mr. Hall of New York. Thank you very much.
Many of the previous witnesses testified about premature
decision-making, particularly as it refers to underevaluation
of mental conditions and inferred conditions. They also
discussed VA's failure to aggregate and analyze data collected
from STAR and inter-rater reliability reviews to spot error
trends. The VA Office of Inspector General (OIG) has indicated
a similar finding in its findings in its regional office
reports.
How does VA identify major patterns of errors and generate
interactive trainings to end these patterns?
Mr. Cardarelli. Sir, actually, it is a decision process. It
is an ongoing process that is constantly changing. It is
constantly evolving, constantly occurring. What we want to do
is evaluate the information we are getting there from STAR and
the individual ROs, roll up categories of errors, categorize
them as much as possible, although some you may not be able to
categorize, and then start looking at the 80 hours of training.
We will address these issues, find the appropriate mix of
training, and adjust that based upon the types of errors we are
seeing.
It is a constant process, and we need to be vigilant here
at the leadership level to make sure this occurs every year.
Every year we are looking at the errors from the previous year,
and we can better adjust our training schedule, requirements,
and topics to address those issues.
Mr. Hall of New York. Do you know what the average tenure
of a VSR or RVSR is with the Agency?
Mr. Cardarelli. I do not know, sir. We can get that to you.
[The VA subsequently provided the following information:]
Tenure for VBA C&P & Education Service Employees in the 996 Series
----------------------------------------------------------------------------------------------------------------
Compensation & Pension Service # Education Service # and % of 0996
Tenure and % of 0996 workforce workforce
----------------------------------------------------------------------------------------------------------------
less than 1 year 868 or 8% 178 or 14%
----------------------------------------------------------------------------------------------------------------
1 4 years 3,658 or 34% 586 or 45%
----------------------------------------------------------------------------------------------------------------
5 9 years 2,376 or 22% 191 or 15%
----------------------------------------------------------------------------------------------------------------
10 14 years 1,266 or 12% 109 or 8%
----------------------------------------------------------------------------------------------------------------
15 19 years 848 or 8% 86 or 7%
----------------------------------------------------------------------------------------------------------------
20 24 years 823 or 8% 91 or 7%
----------------------------------------------------------------------------------------------------------------
25 29 years 442 or 4% 35 or 2%
----------------------------------------------------------------------------------------------------------------
30+ years 494 or 4% 35 or 2%
----------------------------------------------------------------------------------------------------------------
Total 10,775 Total 1,311
----------------------------------------------------------------------------------------------------------------
Total # of 0996 positions, VBA Wide = 12,086
Mr. Hall of New York. I am just curious if there is a
burnout factor, if we are bringing in new people and training
them, but also losing people who we might be able to hold onto
if their training and/or production pressure was mitigated
somehow.
Mr. Cardarelli. Yes, sir. Interesting point. I am sure
that, as in any organization, people doing the same job over
and over get very good at that job, but potentially get burned
out and less effective.
That is why we emphasize training at all levels, not only
for the newcomers, but for experienced RVSRs and VSRs. We keep
them fresh, motivated, and aware of the change in environment
because the way you did something 5 years ago may not be the
same way you do something today or, in the future.
As you are well aware, the VA is evolving. We are looking
at different ways of doing things and trying to get smarter,
more effective, and more efficient. Part of that requires
people to step away from the way they have been doing business
at all levels, at the new employee level, at mid-level
management, at senior management level.
There is a tendency to rely on what you did in the past to
be successful in the future, but that is not always the case.
Sometimes we have to look behind to say, what are we missing.
That is where our training becomes critical. There is a
training component here even, for our RO directors. We have two
conferences a year where we bring them all together and put out
from a strategic level, what we are trying to do overall, where
we are trying to take VA and VBA.
We recently had one in Louisville where we focused
exclusively on transformation. It was a chance to step back and
say, okay, look, do not worry about your day-to-day issues,
you're in a box right now. That is a concern because we are
actually doing business, but let us step back and project 5
years in the future, where do we want to be and how are we're
going to get there.
But there is also time set aside in both conferences where
the area directors have a chance to get their RO directors
together and basically say, okay, this is what is going on in
the eastern region, and this is what we need to focus on.
So you can see it is a constant training environment from
the most senior levels all the way down to the new employee.
Mr. Hall of New York. Will the Veterans Benefit Management
System (VBMS) be capable of identifying error trends and
providing timely training correction? If so, how so? And is the
development of VBMS on track?
Mr. Cardarelli. Sir, it is on track. We have a deliverable
in November. Fifteen November is the deliverable of the first
pilot. We expect to begin training on VBMS in May of 2012.
The initial plan is to train up to 300 cohorts from all the
ROs. They would then train each RO as we started to roll it
out.
Our intent is that with VBMS we would be able to roll up
different types of errors at the different locations so that we
can look at that data and then apportion our training resources
to actually address those.
Mr. Hall of New York. Thank you.
Just a couple more questions and then I have to run across
the street and cast some votes.
But given that the VA OIG found that the accuracy of
brokered claims is nearly 20 percent lower than national
accuracy, does VBA plan to offer additional training on
brokered claims or streamline the type of claims that may be
brokered? Is VA collecting empirical data on brokered claims as
suggested by GAO and other stakeholders? And if so, how does
this tie in with any needed corrective measures?
Ms. Rubens. Mr. Chairman, if I could address that. Yes, it
was very beneficial when our STAR folks began to look at
particularly the resource centers to evaluate exactly what the
quality errors were. That allowed us then to begin training
specifically to those within those resource centers to ensure
that those quality issues were addressed.
We will be using those resource centers and actually have
invested a great deal of brokering this year. I am sorry, not
brokering. We have invested a great deal of training in those
resource centers this year because they will be helping us work
the new Agent Orange presumptives that will fall under the
purview of the Nehmer decision.
So we are very focused on ensuring that any work that is
brokered is getting that same attention and that those folks
doing that work are getting that same and particularly focused
training as errors have been identified at the national level
in those individual offices.
Mr. Hall of New York. Thank you, Ms. Rubens.
Lastly, are you aware of when a permanent Under Secretary
for Benefits will be appointed? Where is the VA in that
process?
Mr. Cardarelli. Sir, I am not aware of that. I know there
were names that were sent to the White House and we are just
waiting for final decision.
Mr. Hall of New York. Okay. Well, thank you very much.
We do have some more questions that we will submit in
writing, but I have a minute and a half to go vote.
So thank you for the work you are doing for our veterans.
Thank you for testifying today.
Thanks to all our panelists.
I would like to remind Members they have 5 legislative days
to revise and extend their remarks. I will tell them that when
I see them across the street.
On behalf of the Subcommittee, I thank you all for
participating in this hearing. We greatly value your insight.
This hearing stands adjourned.
[Whereupon, at 11:39 a.m., the Subcommittee was adjourned.]
A P P E N D I X
----------
Prepared Statement Hon. John J. Hall, Chairman,
Subcommittee on Disability Assistance and Memorial Affairs
Good Morning Ladies and Gentleman. Would everyone please rise for
the Pledge of Allegiance? Flags are located at the front and back of
the room.
I am grateful that you have been able to join us for today's
hearing entitled, ``Examining Training Requirements of Veterans
Benefits Administration Claims Processing Personnel.''
I think it is indisputable that the quality of the training that
VBA claims processing personnel receives is critical for the Department
of Veterans Affairs' (VA) reaching its goal of processing all claims
within 125 days at 98 percent accuracy and in reaching its overarching
goal of eliminating the backlog by 2015. As of 2009, VBA received more
than 1 million compensation and pension related claims annually. Over
200,000 of these claims take longer than four months for VBA staff to
fully process, meaning that they are a part of the backlog. Further, it
is estimated that approximately 20 percent of the claims processed by
VBA, as many as 200,000, are erroneous. Also, according to information
provided by the Board of Veterans' Appeals in its annual report, 37
percent of all appeals that it receives are returned to the VBA due to
avoidable errors. It should also be noted that the backlog itself
continues to grow exponentially.
Since 2007, Congress has appropriated more than $750 million to VA
to hire over 10,000 new VBA claims processors on an expedited hiring
timetable. Recognizing that the backlog is not just a ``people'' issue
and that brute force alone will not bring about transformation,
Congress passed the Veterans' Benefits Improvement Act of 2008 (P.L.
110-389), which included sweeping provisions to overhaul the claims
processing system including efforts to improve the training of VBA
claims personnel. Recently VA expanded the training requirements for
each of its claims processors. Today, Veterans Service Representatives
(VSRs) and Ratings Veterans Service Representatives (RVSRs) are
required to complete 85 hours of instruction annually, a five-hour
increase over previous levels. VA has also re-implemented and revamped
its certification testing program and I look forward to hearing more
about that today.
Congress also directed the Government Accountability Office (GAO)
to examine VA's training program for claims processing personnel. GAO
answered the call with two reports, one in 2008 and one in 2010 that
assess VBA's training requirements and practices. From these reports,
we found that VBA claims processors may be hindered from completing
their training requirements in order to meet work production goals. We
also learned that VBA's training may not be sufficient to equip VBA
claims processors with the skills needed to help them perform their
duties. Moreover, the GAO indicates that significant improvements might
be achieved by VBA if it would monitor the claims process, particularly
during the claims developmental stages, and employ appropriate
training, management, and other tools to more timely correct staff
processing errors.
The Institute for Defense Analyses (IDA), based on its research has
also issued findings related to VBA's claims processing related
training, particularly as it pertains to rating variances between ROs.
I look forward to hearing from both the GAO and the IDA on their
findings.
The job of Congress in our oversight capacity is to help VA find
solutions to the challenges that stand in the way of veterans receiving
the benefits they are due. Today's hearing is designed to achieve this
end by shining greater light on the efficacy of VA's training and
certification of VBA claims processing personnel. I look forward to the
testimony of Veterans Service Organizations (VSOs) and other
stakeholders, many of whom for years have offered recommendations for
improving the training of VBA claims processors.
Finally, I look forward to hearing feedback from the Acting Deputy
Under Secretary for Benefits on the critiques and recommendations from
the earlier witnesses, and to get an action plan for equipping VBA
claims processing personnel with the skills needed for VA to ``break
the back of the backlog''.
As we all know, our Nation provides its military the very best
training and other resources needed to achieve its mission. Veterans
understand the necessity of proper training--as they have placed their
lives in harm's way depending upon the training they and their brothers
and sisters-at-arms received. Our mission today is to ensure that VBA
provides meaningful and appropriate training and resources that claims
processing personnel need to perform their duty so that our veterans,
their families, and survivors receive the 21st Century, world-class
service they deserve.
Thank you, I now yield to Ranking Member Lamborn for his opening
statement.
Prepared Statement Hon. Doug Lamborn,
Ranking Republican Member, Subcommittee on
Disability Assistance and Memorial Affairs
Thank you Mr. Chairman.
And welcome everyone, to this hearing on Veterans Business
Administration training programs.
A quality training program is the key to any successful
organization, particularly one like VBA that must adhere to such a
complex set of laws, regulations, and precedent decisions by the U.S.
Court of Appeals for Veterans Claims.
In addition to the aforementioned legal knowledge, a significant
portion of VBA employees must also have a fair understanding of medical
terminology and basic anatomy and physiology.
While these requirements pose a daunting challenge for trainers, I
want to emphasize my strong desire to ensure that a comprehensive and
substantive training program is employed at all levels of VBA.
Over the past several years, Republican members have recommended
substantial increases for training in our views and estimates.
We realize the importance proper training and feedback has in
production of quality rating decisions that are fair and equitable to
our veterans.
Throughout my tenure on this Committee, we have discussed a number
of problems within VBA that my colleagues on both sides of the aisle
and I recognize could be addressed through better training.
I believe that the VA's greatest challenge, the claims backlog, is
largely attributable to hasty decisions made without proper regard for
accuracy.
While the recent expansion of its workforce will certainly have a
positive impact, VA must ensure that newly hired claims workers receive
training that is commensurate with their responsibilities.
It is equally important that the results of the training are
evaluated.
Without feedback, VA may never know whether or not the training is
accomplishing its goal.
Any viable training program should be able to identify deficiencies
and demonstrate the intended and actual outcome of its curriculum.
VA training must be connected to its vision and mission, and VA
managers need to be assured that if employees are pulled off the floor
for training that it will result in long-term benefits.
I'm sure that with a growing number of pending claims, there is a
certain level of trepidation among managers that production will
decline and they will fall further behind if they have to conduct
training.
There must be clear support, from the top down, in order to conduct
adequate training and acquire the expected outcomes.
I look forward to hearing from our witnesses today, and I thank you
all for your participation
Thank you, I yield back.
Prepared Statement of Daniel Bertoni, Director, Education, Workforce,
and Income Security, U.S. Government Accountability Office
VETERANS' BENEFITS: Training for Experienced
Disability Claims Processors
GAO Highlights
Why GAO Did This Study
GAO was asked to present its views on the training requirements and
procedures for VA personnel responsible for processing compensation and
pension claims. This statement is based primarily upon an April 2010
GAO report on VA's training for experienced disability claims
processors (GAO-10-445) and includes information on actions VBA says it
has taken in response to our recommendations. This statement focuses on
(1) experienced disability claims processors' views regarding training,
and (2) VBA's efforts to monitor and assess training for experienced
disability claims processors.
What GAO Recommends
In its April report, GAO recommended that VBA (1) adopt procedures
for routinely monitoring and ensuring compliance with annual training
requirements, including more fully using its Web-based learning
management system to ensure training requirements are met, (2) develop
clear written guidance on the types of activities all regional offices
should and should not count toward completion of annual training
requirements, and (3) develop and implement a written strategy for
systematically assessing the appropriateness of the training regional
offices provide to experienced claims processors. VA concurred with
these recommendations and has taken some actions in response.
What GAO Found
Experienced claims processors had concerns about the amount of
training they were required to complete and their ability to meet that
requirement. In addition, they had mixed views on the amount of
training received on specific topics, the way in which training was
delivered and the timing of training. GAO's survey results indicated
that 60 percent of experienced claims processors found it difficult to
meet the 80 hour annual training requirement given their workload. In
addition, based on its survey, GAO estimates that 45 percent of
supervisors of experienced Rating Veterans Service Representatives
(RVSR) and 53 percent of supervisors of experienced Veterans Service
Representatives (VSR) thought that only some or few, if any, of the
experienced staff they supervise need 80 hours of training annually to
perform their job duties effectively.
Many experienced staff also thought they received too little
training on some topics and too much on others. For example, 47 percent
thought they received less training than needed in how to develop
appeals and remands and 34 percent thought they received more than
enough training on records management. Finally, opinions varied on how
helpful the various modes of training were. Nearly all claims
processors, in general, considered on-the-job experience to be the
method of training best suited to their needs. An estimated 39 percent
of all experienced claims processors, in general, felt that the
training they received was delivered too late, suggesting that regional
offices may not always deliver the training needed by experienced
claims processors in a timely manner.
According to Standards for Internal Control in the Federal
Government, Federal agencies must have control mechanisms in place to
help ensure that all employees receive appropriate and consistent
training. Under its current annual training requirements, VBA delegates
considerable responsibility for training experienced claims processors
to each of its 57 regional offices. In particular, regional offices are
responsible for ensuring that claims processors complete annual
training requirements. Each office also determines what topics are
covered for half of the required training hours, what material to
provide on each of these topics, and how and when the training should
occur. Regional offices also have considerable discretion in
determining what activities qualify as training. However, at the time
of GAO's review, VBA lacked controls to ensure that regional offices
deliver required training and record completed training in a consistent
manner, and did little to assess the appropriateness or consistency of
all training for experienced claims processors. During the course of
our review and in response to our recommendations, VBA has taken steps
to improve its monitoring and assessment of training. VBA reports that
they are developing guidance on what activities qualify as training,
have begun to require staff to complete course evaluations for some
training and are exploring the feasibility of requiring evaluations for
all training.
__________
Mr. Chairman and Members of the Subcommittee:
I am pleased to have the opportunity to comment on training for
Veterans Benefits Administration (VBA) disability claims processors. In
fiscal year 2009, the Department of Veterans Affairs (VA) paid about
$44 billion to about 4 million veterans and their survivors through its
disability compensation and pension programs. For years, the claims
process has been the subject of concern and attention by VA, the
Congress, and veterans service organizations due, in large part, to
long waits for decisions, large numbers of pending claims, and problems
with the consistency of decisions. To help VBA manage its increasing
workload and replace the growing number of experienced claims
processors who are retiring, the Congress provided funding which
enabled VBA to hire several thousand new staff from fiscal year 2005
through fiscal year 2010. However, more staff alone will not guarantee
effective disability claims processing. To ensure that decisions in
disability compensation and pension cases are accurate, consistent, and
timely, training must enable claims processors to become fully
proficient and maintain their knowledge and skills.
In 2008 we reported that VBA's centralized training for new claims
processors appeared well designed but that some claims processors had
raised concerns about implementation.\1\ VBA has since evaluated its
training for new claims processors and made changes based upon that
evaluation. In April 2010, we again reported on VBA's training as
mandated in the Veterans' Benefits Improvement Act of 2008.\2\ We
recommended improved monitoring of annual training requirements,
standardized recording of training taken, and a review of course
content and timing for experienced claims processors. My remarks today
will focus on (1) experienced disability claims processors' views
regarding training, and (2) VBA's efforts to monitor and assess their
training. This statement is drawn primarily from our April 2010 report,
where we obtained information on the training, experience, and views of
a nationally representative sample of claims processing staff. We also
interviewed VBA headquarters officials and managers and training
coordinators in four regional offices--Little Rock, Arkansas; Denver,
Colorado; St. Petersburg, Florida; and White River Junction, Vermont.
Our work was conducted 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 the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.
---------------------------------------------------------------------------
\1\ See GAO, Veterans' Benefits: Increased Focus on Evaluation and
Accountability Would Enhance Training and Performance Management for
Claims Processors, GAO-08-561 (Washington, D.C.: May 27, 2008).
\2\ See GAO, Veterans' Disability Benefits: Expanded Oversight
Would Improve Training for Experienced Claims Processors, GAO-10-445
(Washington, D.C.: April 30, 2010).
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Background
To process claims accurately, consistently, and in a timely manner,
Veterans Service Representatives (VSR) and Rating Veterans Service
Representatives (RVSR) must perform a complex set of tasks. When a
claim is received, a VSR reviews it and assists the veteran in
gathering the evidence, or documentation, needed to support it. The
RVSR then evaluates the evidence to determine whether the claimant's
medical condition(s) constitutes a disability, and assigns a disability
percentage rating which determines the amount of benefits the veteran
is eligible to receive. Finally a VSR calculates the amount of monthly
benefit payments. VSRs and RVSRs also perform follow-up reviews if, for
example, there is evidence a claimant's medical condition has changed,
or a court determines that a claim was incorrectly denied.
To ensure that VSRs and RVSRs develop and maintain the knowledge
and skills needed to process disability claims accurately,
consistently, and in a timely manner, VBA has established annual
training requirements and developed a structured training program,
called ``Challenge,'' for newly-hired or promoted claims processors.\3\
Beginning in fiscal year 2010, claims processors must receive 80 hours
of training annually in topics directly related to processing
disability claims.\4\ VBA requires that 40 of those hours be in topics
designated by VBA, 20 cover topics selected by each regional office
from a list of core technical training requirements (CTTR), and 20
cover topics determined by each regional office.\5\
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\3\ Challenge consists of a uniform curriculum that is implemented
in three phases: initial orientation training provided at a
participant's regional office, centralized classroom instruction
typically delivered at VBA's Training Academy in Baltimore, Md., and
comprehensive on-the-job and classroom training that new claims
processors receive at their regional offices.
\4\ The 80-hour annual training requirement is for RVSRs and VSRs
who have completed the Challenge training program and/or have been in
their position for six months.
\5\ At the time of our survey VBA did not designate the 40 hours of
required training.
---------------------------------------------------------------------------
In addition to its ``Challenge'' program and annual training
requirements, VBA issues ``Fast Letters,'' or memoranda on policy
changes, conducts telephone conferences, and develops ad hoc required
training on emerging issues to help ensure that disability claims
processors have the information they need to do their job. VBA issued
100 Fast Letters in calendar years 2008 and 2009, on topics ranging
from cost-of-living adjustments in disability benefits to rating the
effects of traumatic brain injury (TBI). Monthly or quarterly telephone
conferences with regional offices concentrate on claims processing
issues identified through VBA's quality reviews or on new management
priorities or initiatives that may affect how claims processors do
their jobs. VBA officials also told us the agency periodically requires
training on emerging topics such as rating post-traumatic stress
disorder (PTSD) and spinal, neck, and joint injuries.
Experienced Claims Processors Had Concerns With Various Aspects of the
Training They Received
Experienced staff responding to our survey expressed concerns with
the amount of training they were required to take and their ability to
meet those requirements. Based on the results of our survey of claims
processors, many believed that 80 training hours each year were too
many, particularly for experienced staff.\6\ An estimated 45 percent of
supervisors of experienced RVSRs and 53 percent of supervisors of
experienced VSRs thought that only some or few, if any, of the
experienced staff they supervise need 80 hours of training. Most of the
regional office officials we interviewed also said 80 hours are too
many for at least some experienced staff and one regional official told
us it would make sense to vary the required number of hours based on
the training needs of individual claims processors.\7\ In 2008 we
recommended that VBA collect and review feedback from staff to
determine if the 80-hour training requirement was appropriate for all
VSRs and RVSRs. VBA has not yet implemented this recommendation.
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\6\ Unless otherwise indicated, the margin of error for estimates
based on this survey cited in this report are within plus or minus 15
percentage points at the 95 percent confidence level.
\7\ An 80-hour annual training requirement may be appropriate for
some, in particular new staff. An estimated 70 percent (ranging from 52
to 84 percent at a 95 percent confidence level) of all supervisors of
new RVSRs and 62 percent of supervisors of new VSRs thought that all or
almost all of the new staff they supervise needed 80 hours of training.
---------------------------------------------------------------------------
Our survey results also indicated that it was challenging for many
experienced claims processors, in general, to meet the 80-hour annual
training requirement, given their workload. Sixty percent found it
somewhat or very difficult to meet the requirement. Moreover, 61
percent of experienced RVSRs' supervisors and 76 percent of experienced
VSRs' supervisors thought it was somewhat or very difficult for
experienced staff to complete 80 hours of training each year.
While many experienced claims processors thought that 80 hours of
training per year was too much and difficult to complete, they had
mixed views on the amount of training they received on specific topics.
For example, an estimated 47 percent thought they received less than
sufficient training in developing appeals and remands, and 42 percent
thought they received less than needed in how to rate claims involving
special monthly compensation. On the other hand, in each case, about
one-third thought they received more than enough training in records
management, rating disability compensation claims, and calculating
payment amounts based on disability ratings.
Experienced claims processors' views on the helpfulness of various
training modes and the timing of training also varied. Training for
disability claims processors can be delivered in a number of ways:
formal classroom training, online instruction, and video or satellite
conferences. Claims processors can access online training courses
through VBA's Training Performance Support System (TPSS), and learning
resources such as VBA training materials, published guidance, and
technical information are available to them on VBA's internal Web site.
Regional offices also provide claims processors with individual
coaching and mentoring, and may hold weekly meetings for claims
processing teams.
Based on our survey results, experienced claims processors, in
general, found certain training modes and learning resources more
helpful than others. Nearly all thought that on-the-job experience, to
a great or very great extent, helped them learn what they needed to
know to perform their jobs. However, only about 20 percent indicated
TPSS and other online training, and video or satellite training had, to
a great or very great extent, helped them become familiar with even the
basic information needed to handle claims.
Survey results also indicated that regional offices do not always
deliver necessary training in a timely manner. An estimated 39 percent
of all experienced claims processors felt that the formal training, in
general, they received in the last 12 months was delivered too late to
help them effectively perform their job duties. For example, although
the regulation governing ratings decisions on the effects of traumatic
brain injury (TBI) was changed in October 2008,\8\ one RVSR wrote in a
comment to the survey that, ``TBI training is not projected to come out
until [2010.]'' \9\ Another wrote that introductory leadership training
was not received until two years after a promotion to a supervisory
position.
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\8\ 73 Fed. Reg. 54,693 (September 23, 2008).
\9\ A presentation on TBI was available on VBA's Intranet site.
VBA Did Little To Systematically Monitor or Assess Training for
Experienced Claims Processors but Has Begun To Take Steps To Do
---------------------------------------------------------------------------
So
VBA headquarters does not ensure that experienced claims processors
receive all required training. It is important for Federal agencies to
have mechanisms in place to ensure their employees actually receive
required training and we have reported in the past that tracking the
actual receipt of required training calls for reliable data from a
comprehensive learning management system.\10\ While each regional
office is responsible for recording completed training hours for each
claims processor in VA's Web-based Learning Management System (LMS),
VBA officials told us that VBA headquarters did not use it to centrally
monitor the specific types of training individual claims processors
have completed. Based on our survey results, we found some claims
processors did not receive training they should have. An estimated 24
percent of all RVSRs with more than one year of experience, who should
have received mandatory training on rating spinal, neck, and joint
injuries, never did.\11\ To improve VBA headquarters' ability to
systematically monitor regional office compliance with its annual
training requirements, we recommended that it adopt procedures to
routinely do so, including more fully utilizing its LMS to ensure that
claims processors received required CTTR and ad hoc training on
emerging issues. In their comments to our report, VBA noted that it had
begun to use LMS to determine what percentage of claims processors at
each office were meeting annual training requirements. However, it is
not clear if they are tracking whether staff receive required CTTR
training or ad hoc training on emerging issues such as the training on
rating spinal, neck, and joint injuries.
---------------------------------------------------------------------------
\10\ See GAO, Human Capital: A Guide for Assessing Strategic
Training and Development Efforts in the Federal Government, GAO-04-546G
(Washington, D.C.: March 2004).
\11\ This training, delivered in September 2008, was undertaken to
clarify requirements resulting from DeLuca v. Brown, 8 Vet. App. 202
(1995), in which the court held that under Federal regulations defining
joint and spine impairment severity in terms of limits on range of
motion, VA claims adjudicators must consider whether range of motion is
further limited by factors such as pain and fatigue during ``flare-
ups'' or following repetitive use of the impaired joint or spine.
---------------------------------------------------------------------------
In addition, we found that VBA lacked controls to ensure that
regional offices record completed training in a consistent manner. Each
regional office has considerable discretion in determining what
activities qualify as training and we noted that they were not all
defining training consistently. For example, some regions counted the
time claims processors spent reading ``Fast Letters'' as training while
others did not. This raises questions about the reliability of the data
that regional offices enter into the LMS. We recommended that VBA
develop clear written guidance on the types of activities all regional
offices should and should not count toward completion of annual
training requirements. According to VBA, the agency is developing such
criteria and expects to complete this process by September 30, 2010.
VBA also has not systematically assessed the appropriateness or
consistency of training regional offices provide to experienced claims
processors. In prior work, we have noted that Federal agencies should
have mechanisms in place to ensure that training for employees is
appropriate and consistent.\12\ However, we found that VBA did little
to determine if all regional offices provide training to experienced
claims processors that (1) covers topics relevant to what they do; (2)
helps them do their job; (3) is delivered in the most useful and
efficient way; and (4) is provided when needed.
---------------------------------------------------------------------------
\12\ See GAO-04-546G.
---------------------------------------------------------------------------
In the past, VBA has evaluated some mandatory training to improve
the consistency of ratings, assessed training for newly-hired claims
processors, and solicited feedback from staff on TPSS. VBA officials
told us that teams from VBA headquarters also periodically visit
regional offices to monitor their compliance with VBA policies and
procedures. Since July 2009, such visits have included a training
specialist responsible for reviewing some aspects of training in the
regional office, such as training records and materials, and whether
new claims processors have completed the last phase of Challenge
Training at their regional office. Although examining some aspects of
training for claims processors during these visits may provide VBA with
some information on the appropriateness and consistency of training,
each office is only visited about once every three years.
Finally, VBA has not yet systematically collected feedback from
experienced claims processors on training received at the regional
offices even though feedback from training participants, supervisors,
instructors and other stakeholders can provide agencies with valuable
information to assess the appropriateness and consistency of their
training. VBA recently developed a training evaluation tool that all
VSRs and RVSRs are required to complete, but only for CTTR courses. As
a result, we recommended that VBA develop and implement a written
strategy to systematically assess the appropriateness (content, mode
and timing) of all training for experienced claims processors. Such a
strategy should include a standardized approach for obtaining feedback
from experienced claims processors and regional office managers and
training coordinators. VBA says it is assessing the feasibility of
requiring staff to complete an evaluation tool for all training and
expects to complete this assessment by September 30, 2010.
Concluding Observations
Veterans who have been injured in service to their country deserve
accurate and timely disability determinations. VBA claims processors
perform a vital role in helping the nation respond to the needs of
these veterans. Through its training program for claims processors, VBA
can ensure that they develop and maintain the skills required to do
their job efficiently and well. However, VBA could do more to monitor
the training received by experienced claims processors. VBA cannot be
sure all staff are receiving the type of training the agency believes
is essential for success on the job. Furthermore, there are questions
about the reliability of the training data regional offices record in
VA's LMS. VBA has indicated that they are developing criteria to define
the types of activities that should and should not count toward meeting
training requirements. However, it is yet to be seen if this will
result in consistent reporting of what counts as training by regional
offices.
Furthermore, according to our survey, both experienced claims
processors and their supervisors had a number of concerns regarding the
training that experienced claims processors receive. Thus, it is
important that VBA continue to explore options to assess the
appropriateness of the training provided to staff.
Mr. Chairman, this concludes my prepared statement. I would be
pleased to respond to any questions that you or other Members of the
Subcommittee may have. Thank you.
GAO Contact and Staff Acknowledgments
For further information about this testimony, please contact Daniel
Bertoni at (202) 512-7215 or [email protected]. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this testimony. In addition to the contact named
above, key contributors to this statement include Clarita Mrena, Martin
Scire, Regina Santucci and Susan Aschoff.
Related GAO Products
Veterans' Disability Benefits: Expanded Oversight Would Improve
Training for Experienced Claims Processors. GAO-10-445. Washington,
D.C.: April 30, 2010.
Veterans' Disability Benefits: Further Evaluation of Ongoing
Initiatives Could Help Identify Effective Approaches for Improving
Claims Processing. GAO-10-213. Washington, D.C.: January 29, 2010.
Veterans' Disability Benefits: Preliminary Findings on Claims
Processing Trends and Improvement Efforts. GAO-09-910T. Washington,
D.C.: July 29, 2009.
Veterans' Benefits: Increased Focus on Evaluation and
Accountability Would Enhance Training and Performance Management for
Claims Processors. GAO-08-561. Washington, D.C.: May 27, 2008.
Veterans' Benefits: Improvements Needed in VA's Training and
Performance Management Systems. GAO-08-1126T. Washington, D.C.:
September 18, 2008.
Veterans' Disability Benefits: Claims Processing Challenges
Persist, while VA Continues to Take Steps to Address Them. GAO-08-473T.
Washington, D.C.: February 14, 2008.
Veterans' Benefits: VA Needs Plan for Assessing Consistency of
Decisions. GAO-05-99. Washington, D.C.: November 19, 2004.
Human Capital: A Guide for Assessing Strategic Training and
Development Efforts in the Federal Government. GAO-04-546G. Washington,
D.C.: March 2004.
Veterans' Benefits: Improvements Needed in the Reporting and Use of
Data on the Accuracy of Disability Claims Decisions. GAO-03-1045.
Washington, D.C.: September 30, 2003.
Veterans' Benefits: Training for Claims Processors Needs
Evaluation. GAO-01-601. Washington, D.C.: May 31, 2001.
Prepared Statement of Jimmy F. Sims, Jr., Rating Veterans Service
Representative, Winston-Salem, NC, Regional Office, Veterans Benefits
Administration, and Shop Steward, Local 1738, American Federation of
Government Employees (AFL-CIO), and AFGE National Veterans Affairs
Council
Dear Chairman and Members of the Subcommittee:
Thank you for the opportunity to testify on behalf of AFGE and the
National VA Council regarding VBA training requirements for claims
processing personnel. Training is an issue of paramount importance
which has a direct impact on the VBA's ability to meet its operational
goals and mission. Effective training is an essential component of any
VBA effort to increase the timeliness, accuracy and consistency of
claims processing. Ultimately, a weak training program for claims
processing personnel is a disservice to veterans whose claims are
determined with greater delay and less accuracy.
Based on my experiences as a Rating Specialist and Shop Steward,
and a participant in several joint labor management committees, I
concur with GAO's findings in its April 2010 report of multiple
deficiencies in VBA's mandatory training program for experienced claims
processors. As discussed below, new employee training also suffers from
shortcuts and quality gaps.
I. Training for Experienced Claims Processors
Consistent with GAO's findings, the mandatory annual training
program at the Winston-Salem Regional Office (RO) is deficient in terms
of the amount of training provided, content of the curriculum and
timeliness.
Amount of Training Provided:
Currently, it is very difficult for employees to receive their full
85 hours of mandatory training, given the constant production pressures
they face. VBA mandates 85 hours of annual training for all claims
processing employees who have completed Challenge Training. Of these 85
hours of mandatory training, 40 hours are devoted to Core Technical
Training Requirement (CTTR) topics selected by VBA (covering 72 topics
for Veterans Service Representatives (VSR) and 47 topics for Rating
Specialists (RVSRs)) and 20 hours for topics selected by the Regional
office (RO) from the CTTR topics. The remaining 25 hours are topics
which the individual ROs elect to train on as well as ancillary
administrative requirements such as cyber security and ethics. In some
cases, training may also be provided at Team Meetings to cover issues
that have been identified during a Veteran Service Center Manager
conference call.
Curriculum Content:
The GAO survey found that an average of 46 percent of employees
experienced difficulties in completing this training. Based on my
experience, I would dare say this percentage is actually greater and
was merely under reported. Specifically when asked, a majority of
employees at my office report concerns on achieving the mandatory
training requirements when faced with increased workload and
production.
The current CTTR training which is mandated for Claims processors
is often times too remedial, specifically it focuses on issues such as
common law marriage for VSRs and building a glossary for RVSRs. The
majority of this CTTR training is conducted via self directed written
materials with no interaction with Subject Matter Experts (SME). The
employee merely completes the review of the information and certifies
through the Learning Management System (LMS) that the training was
completed. When faced with the dilemma of completing the training or
completing work to meet production requirements, employees feel
compelled to complete the additional production.
The RO based mandatory training program also fails to target
specific complex issues which are necessary for claims processors to
ensure accuracy of the work being produced. While continued training is
necessary to ensure the effectiveness of the workforce, the need for
training quality surpasses the quantity of training. The majority of
the issues I was tasked with this year were items which were more
appropriately identified for employees within the first two years of
employment such as how to write a clear and concise rating decision and
review of local quality findings, but omitting more complex issues such
as evaluating demyelinating diseases and residuals of blast injuries.
Too little classroom training:
Online training should not fully replace classroom training.
Currently, the majority of Core Technical Training Requirements
training is provided via self directed computer based materials with no
interaction with Subject Matter Experts. This requires the claims
processor to review, interpret and understand the material alone.
Validation of this training is also completed through LMS self-
certification.
Another troubling training shortcut is the use of emails to explain
complex new concepts, in lieu of more detailed, effective instruction.
AFGE members have reported that they have been asked to learn new
concepts via email with only a fraction of the excluded time actually
needed to effectively learn and accurately apply these training
materials.
Quality of Instruction:
This quality of training issue is further impacted by the limited
formal training provided to instructors. GAO found that only one in
four claims processors who participated in training had received formal
instructor training. This is true at the VARO Winston-Salem, as merely
being promoted to the Decision Review Officer or Super Senior VSR
position automatically requires performance as instructors.
Given the growing problem of inexperienced instructors to provide
training to claims processing personnel, it is all the more urgent that
instructors receive sufficient instructor development. Unfortunately,
at my RO, there is no Instructor training for employees who are thrust
into this position.
Timeliness of training:
Timing of training is not adequate to meet the demands of the work
performed. In some cases training has been delayed for months to years
following significant changes, and in some cases, no training was
received. This puts the claims processors, and veterans, at a
substantial disadvantage. With the changes in the presumptive
disabilities associated with Agent Orange exposure, VBA directed
ischemic heart disease training. To date, this training has not
occurred at my RO.
Another example pertains to the change in the schedule for rating
eye disabilities. That schedule was issued on February 13, 2009 but to
date, no formal training has been conducted at my RO.
II. New Employee Training
Since 2005, VBA has increased staffing by over 4,000 new
individuals to assist with the claims process. This enormous influx of
new employees makes it all the more critical that VBA improve both its
new employee training and ongoing training programs.
New employees participate in VBA's Challenge Training, which
consists of three phases. Phase 1 is based at the RO; for RVSRs the
focus is on introducing the employee to aspects of claims processes and
for VSRs, on the basics of the claims process and the programs
utilized. Phase 2 is centralized classroom training which focuses more
on the essential aspects of performing the assigned tasks.
Phase 3 is more topic focused and conducted at the individual
employee's station. Phase 3 involves working with live claims with half
of the day focused on training and the other half focused on
production. The bulk of new employee training is conducted during Phase
3 at the individual's station based on centralized curriculum
identified by VBA. (I am currently participating in a VBA Training Site
Visit Team commissioned by the Undersecretary for Benefits that is
focusing on implementation of and compliance with Phase 3 training; the
work of this group is still in the early stages.)
One of the most significant flaws in the Challenge Training program
is the absence of any system to effectively monitor the completion of
the two RO-based portions of the training (Phases 1 and 3). Prior to
participation in Centralized Phase 2, employees are required to
complete and certify that they have received specific training, but
many participants are not able to do so. Similarly, when they return
from centralized training, they are often unable to certify completion
of Phase 3 training.
As long as managers are under pressure to meet production quotas at
all costs, they will rush new employees who have not been adequately
trained into production. AFGE has received reports of new employees
processing cases independently only six weeks after returning from
Phase 2 classroom training. Managers exacerbate this by providing new
employees with a limited range of easier cases, depriving them of
valuable experience over the long run.
AFGE members also report problems with the curriculum in Phase 2.
First, time is wasted teaching them concepts that they already learned
in Phase 1. Second, the curriculum includes live cases that are out of
date, and therefore, have been decided incorrectly, yet they are still
used for new employee instruction.
Phase 3 training is designed to be instructor lead, and topic
specific. The problem lies within the certification and validation of
completion of the training. Too often, when new employees return to the
RO for Phase 3 training, they get too little supervision or face to
face training. Instead, they are left on their own to review complex
materials. More generally, over the years, VBA has significantly
reduced the amount of classroom training conducted at the ROs.
It is also troubling that often the cases processed by new
employees are not reviewed on a timely basis. AFGE members from other
ROs report that senior employees are regularly taken off production to
conduct these reviews and because of competing pressures, many new
employees have to wait three to four months to find out if they are
making accurate determinations.
Conclusion
If the VA is to become a model 21st century agency, then this must
begin at the base level with the training provided to the employees.
The Agency must alter the mindset, and begin to focus on the quality of
training, versus the quantity of training. Unless the agency is willing
to invest the time and energy to meet the needs of the employees, the
agency is doomed to fail in meeting our mission. AFGE offers the
following recommendations to the Subcommittee:
Establish performance measures and incentives to
ensure that managers avoid training shortcut in order to boost
production. I cannot recall a single instance of any VBA
manager who has ever been disciplined, demoted, or formally
reprimanded for failing to adequately train an employee.
Commission a group of Subject Matter Experts,
including front line employees, veterans' groups and other
stakeholders, to review all current training programs and
provide recommendations for improvement. (The team recently
commission by the VBA Undersecretary is only reviewing Phase 3
of the Challenge training program).
Develop a standardized plan to annually review and
update training topics to better reflect the trends in claims
processing.
Establish an effective monitoring system for tracking
compliance with training. The current LMS certification program
is faulty as self certification does not validate completion.
Develop clear guidelines on what should and should
not be credited toward training requirements. Frequently,
during team meetings at my RO, one issue is identified from a
recent Office of Field Operations or Veteran Service Center
Manager call and at the completion of the meeting, the
supervisor requires that the meeting be listed as training.
Thank you.
Prepared Statement of Jeffrey C. Hall, Assistant
National Legislative Director, Disabled American Veterans
Mr. Chairman and Members of the Subcommittee:
On behalf of the 1.2 million members of the Disabled American
Veterans (DAV), I am honored to appear before you today to discuss the
effectiveness of the Department of Veterans Affairs (VA) training
program for Veterans Benefits Administration (VBA) employees who
process disability claims.
In line with our congressional charter, DAV's mission to ``advance
the interests, and work for the betterment, of all wounded, injured,
and disabled American veterans'' is as vital today as it has been
throughout our 90 year history. In line with our core values of
``Service, Quality, Integrity and Leadership,'' I am pleased to offer
DAV's views regarding VBA's training program and its role in helping to
reform the benefits claims process.
Although this is my first time testifying before Congress, it is
not the first time that DAV has testified on the state of the VA
benefits claims processing system. As my colleagues have stated
countless times, but it bears repeating, the backlog of pending claims
is not actually the problem; it is only a symptom of the larger
problem: a broken veterans benefits claims processing system resulting
in too many veterans waiting too long for decisions on claims for
benefits that are too often decided incorrectly.
Unfortunately, the tremendous attention paid to the backlog and the
understandable tendency to focus only on the number of claims pending--
many estimates put it over 1 million in total--has led to an over-
emphasis on production to the detriment of quality and accuracy.
However, simply finding ways to increase production will result in more
claims being decided wrongly, which only leads to notices of
disagreement, appeals, remands and more appeals, further clogging up
the system and exacerbating the existing problems.
The only sensible and long term to way to reform this system is to
rebuild it in a way that focuses principally on getting claims done
right the first time. This will require VBA to invest sufficient time
and resources to build a new modern, paperless claims processing
system. Although this path could potentially result in longer
processing times during the transition and implementation of the new
claims system, with proper training and quality control, processing
times will shorten, error rates will drop, and the backlog will slowly
but steadily decline and eventually disappear. We urge this
Subcommittee to keep the pressure on VBA to stay true to this path and
remain focused on quality and accuracy, not just the backlog.
Mr. Chairman, over the past year, VBA has been moving in this
direction, launching dozens of new initiatives and pilot programs that
could help to modernize the claims process. The most important of these
is the Veterans Benefits Management System (VBMS), the new IT system
that will serve as the backbone of the VA claims process. VBA recently
announced that the first pilot of the VBMS will take place at the
Providence, Rhode Island Regional Office beginning this November.
While we applaud the continuing progress of this essential IT
system, and are pleased to see the first pilot is now scheduled, we
continue to be disappointed that no veterans service organization (VSO)
experts, nor any service officers from DAV or other VSOs, have been
involved in the development of this system. Since more than half of all
claims are represented by VSO service officers, we collectively offer a
wealth of expertise that is essential to finding long term solutions,
and we continue to stand ready to work with VBA in the further
development of this system.
VBA also has more than four dozen other pilots and initiatives
ongoing at various regional offices around the country. To fully
benefit from all this experimentation, VBA must develop and implement
an effective plan to analyze the results so that they can synthesize
the best practices into a new claims process. Most importantly, VBA
must resist the temptation to focus on those initiatives that provide
only short term production increases, rather than enhance accuracy and
quality, which must be one of the cornerstones of a 21st century claims
process.
One of the other cornerstones is proper training of employees and
managers involved in the processing of veterans claims for benefits.
Having just come from the field after 17 years of working for DAV as a
National Service Officer (NSO) and Supervisor in Louisville, Kentucky,
Chicago, Illinois and New York City, I have seen firsthand many of the
challenges facing VBA. I have been able to observe VBA's employees,
learn about their training programs and hear from them what they
believe works and what does not.
Having also had the benefit of DAV's extensive and life-long
training programs, I'd like to provide an overview of DAV's on-the-job
training program for new NSOs, and especially the Structured and
Continued Training (SCT) program that all NSO's must continue
throughout their careers at DAV. In our view, no other organization
places more emphasis on training and its vital role in quality and
accountability than DAV. While VBA and DAV necessarily have different
training programs designed to meet similar but distinct needs, we
believe there are lessons that could be applied from the DAV training
program which could strengthen VBA's training program, and ultimately
the claims process.
The training program in VBA is basically a three-stage system,
which requires new Veterans Service Representatives (VSRs) and Rating
Veterans Service Representatives (RVSRs) to complete orientation
training at their respective VA Regional Office (VARO). Next, they
participate in a two- to three-week centralized or ``Challenge''
training course at VA's training academy in Baltimore, Maryland, which
provides a basic introduction to job responsibilities. When they return
to their respective VARO, new VSRs and RVSRs spend several more months
in training, which includes completing a required curriculum by way of
online learning known as the Training and Performance Support System
(TPSS), as well as on-the-job training and/or instructor-led classroom
training. It is our understanding there are currently eleven training
modules in the TPSS, each consisting of multiple sections, and each
with some testing requirements. Subjects range from very general
orientation to more in-depth subjects such as how to utilize VBAs
computer-based programs, medical terminology, how to review and
interpret medical evidence, as well as understanding and applying the
law and regulations when evaluating evidence and rendering decisions.
The assignment of supervised, individual case review is introduced
later in the training program. While this initial training for new VSRs
and RVSRs provides a sound core of knowledge, there seems to be
imbalanced emphasis placed on production over training. DAV NSOs have
been told by many VBA employees that meeting production goals is the
primary focus, whereas training and quality is secondary. So, while we
feel VBA's training program for new employees is sound, and while
production is certainly important, productivity must not interfere with
the training of new employees who are still learning their job.
Once these individuals have successfully completed their initial
training, they begin their on-the-job-training (OJT) phase, in which
they will be moved into productive roles in developing and rating cases
with supervision. They will continue this OJT phase with mentoring and
supervision, slowly increasing the number and complexity of cases until
they are assigned a full case load approximately two years from their
hire date.
From that point forward, they will have the same training
requirements as all other experienced VSRs and RVSRs, which requires
all employees to complete 80 hours of training annually, along with an
additional 5 hours on VA's online Learning Management System (LMS) for
cyber security and ethics. VBA's training is broken down to 40 hours of
standardized training on VBA selected subjects and 40 hours of training
on subjects selected by the VARO from the Core Technical Training
Requirements (CTTR) and other subjects of their choosing.
In 2008, Congressed approved Public Law 110-389, the ``Veterans'
Benefits Improvement Act of 2008'', which required VBA to develop and
implement a certification examination for claims processors and
managers. Now codified, 38 U.S.C. Sec. 7732A states:
(a) DEVELOPMENT OF CERTIFICATION EXAMINATION.--(1) The
Secretary shall provide for an examination of appropriate
employees and managers of the Veterans Benefits Administration
who are responsible for processing claims for compensation and
pension benefits under the laws administered by the Secretary.
(2) In developing the examination required by paragraph (1),
the Secretary shall----
(A) consult with appropriate individuals or entities,
including examination development experts, interested
stakeholders, and employee representatives; and
(B) consider the data gathered and produced under section
7731(c)(3) of this title.
(b) EMPLOYEE AND MANAGER REQUIREMENT.--The Secretary shall
require appropriate employees and managers of the Veterans
Benefits Administration who are responsible for processing
claims for compensation and pension benefits under the laws
administered by the Secretary to take the examination provided
under subsection (a).
However, almost two years later, there are still gaps in the
implementation of this section. While tests have been developed and
piloted for VSRs and RVSRs, additional tests need to be developed and
deployed for Decision Review Officers (DROs) and supervisory personnel.
None of these certification tests are mandatory, nor are they done on a
continuing basis. It is our understanding that only when employees seek
to move up to the highest GS-level for their position are they required
to take and pass a one-time certification test. If they take but fail
the test, they can simply remain in their current position and GS
level. Moreover, VBA has no remedial training programs for employees
that fail certification tests, nor are they required to re-take the
test to show that they have mastered the skills and knowledge required
to do their job.
The Government Accountability Office (GAO) recently conducted a
study (GAO-10-445, April 2010) to determine the appropriateness of
training for experienced claims processors and the adequacy of VBA's
monitoring and assessment of such training. Of particular interest are
the GAO findings that experienced claims processors' had concerns with
the training received; specifically the hours, amount, helpfulness,
methods and timing of training. Likewise, as the GAO report points out,
there is very little done by VBA to ensure the required training is
completed or to assess the adequacy and consistency of the training,
nor is the VA's LMS being utilized to the fullest extent to properly
ascertain the total number of VSRs and RVSRs who have met the annual
training requirement. In fact, data received indicated a dismal outcome
of only one (1) VARO meeting the annual training requirement and nine
(9) other VARO's with less than half meeting the annual training
requirement. It is simply unacceptable to have only one VARO meeting
the simple requirement of ensuring that all employees complete 80 hours
of training. VBA must place greater emphasis on training by
implementing stricter monitoring mechanisms for all VAROs and ensure
that they are held accountable for failure to meet this minimal
standard.
Mr. Chairman, when DAV speaks about training, we do not do so just
as an interested stakeholder, but because DAV takes pride in the fact
that we have the foremost training program and the largest National
Service Officer program, representing almost 25 percent of all claims
before VA. In 88 offices throughout the United States and in Puerto
Rico, DAV employs a corps of approximately 250 NSOs who provide free
representation to veterans and their families with claims for benefits
from the VA, the Department of Defense and other government agencies.
Last year alone, DAV NSOs worked tirelessly on behalf of nearly a
quarter million veterans and their families in their claims before the
VA, obtaining nearly $4.5 billion in new and retroactive benefits.
DAV NSOs function as attorneys-in-fact, assisting veterans and
their families in filing claims for VA disability compensation and
pension; vocational rehabilitation and employment; education; home loan
guaranty; life insurance; death benefits; health care and much more.
Outside of the office, DAV NSOs provide free services, such as
information seminars, counseling and community outreach. NSOs also
represent veterans and active duty military personnel before Discharge
Review Boards, Boards for Correction of Military Records, Physical
Evaluation Boards and other official panels.
The expertise required for the outstanding assistance provided by
NSOs involves extensive training. It begins with a rigorous 16-month
on-the-job training program, which provides the foundation for new
trainees. Trainees are instructed by tenured supervisory NSOs with
subject matter expertise. Throughout their training, progress and
knowledge retention of the NSO is closely monitored through web-based
testing and monthly evaluations. In addition to the training received
in the office, NSO trainees must successfully complete academic
instruction in Anatomy & Physiology, Medical Terminology, Composition
and/or Legal Research & Writing, and Public Speaking, from an
accredited college or university. The National Service staff at the
National Service and Legislative Headquarters, administers and monitors
the program, as well as the instructor's behavior and the progress of
each NSO trainee.
Due to the intensity of the training in the first four months, NSOs
trainees are ready for an individual caseload in their fifth month and
must pass a comprehensive web-based examination every four months on
the topics covered from that given period; an all-inclusive web-based
examination for the entire training period is administered at the
conclusion of the 16th month.
Beyond their initial training, all NSOs participate in a
comprehensive SCT program designed to keep them up-to-date on changes
to the laws and regulations affecting veterans' benefits. NSOs are
required to pre-test and successfully complete 32 monthly training
modules with post-testing on each.
DAV training--which includes all NSOs, Supervisors and Area
Supervisors--is separated into two books, one for Adjudication and
Appeals, and the other for the Schedule for Rating Disabilities. Each
book contains 16 modules and NSOs are required to complete the workbook
research, questions, and case studies each month. Training utilizes
multi-media resources and is administered through an instructor-led
classroom environment and individual workbooks.
At the end of each month, NSOs must successfully pass web-based
testing in order to move forward in training. At the end of the 16
months a comprehensive 160 question web-based test must be passed in
order to move forward to the second 16-month training period, which is
delivered in the same manner as the first 16-month period. Once an
individual successfully completes the entire 32 months of training, not
only have NSOs gained a wealth of knowledge and become more proficient
in their duties, they earn 12 college credits provided through the
American Council on Education (ACE), which provides additional
incentive for successful completion. DAV is the only veterans service
organization to have a training program certified for college credit by
ACE.
DAV's SCT is ongoing and it will continue throughout an
individual's career at DAV. When an NSO completes the entire SCT
program a new training cycle begins again, but with changes, updates
and new information provided by DAV's national training staff. For
example, an experienced NSO with 15 years of service will have
completed the SCT training four times.
DAV's SCT program is effective because it provides in-depth review
of laws, regulations, VA M-21 and similar manuals, VA Fast Letters,
Board of Veterans' Appeals practices, as well as opinions of the VA
Office of the General Council and holdings from the U.S. Court of
Appeals for Veterans Claims. Moreover, the DAV SCT program delves
deeply into the VA Schedule for Rating Disabilities (VASRD) by
providing a meticulous breakdown of each anatomical system and
correlating diagnostic codes and ratings. When dealing with the
complexities of the VASRD, the SCTs accompanying CD-ROM collection,
Special Monthly Compensation ``slide rule'' and case studies prove to
be extremely useful throughout the NSOs career. In fact, there are many
outside DAV who have benefited from our SCT program; this includes
other VSOs and VA employees, as well as DoD Physical Evaluation Board
members, who have utilized our SCT materials to enhance their
knowledge.
DAV Recommendations for VBA's Continuing Training Program
Training Should Be Conducted at Regularly Scheduled Intervals in a
Structured Format
VBA's failure to meet the hourly training requirements for its
employees can be corrected by requiring greater structure to the
training program with regularly scheduled training. Adequate time for
training must be allowed in order for the employee to gain the maximum
benefit of the training and improve their overall knowledge and skill.
In order to accomplish this, VBA managers must ensure scheduled time
for training is in place and that employees attend training. VBA's
annual training should be structured and scheduled with consistency so
employees can plan and prepare for training.
Although training time for employees is excluded from the
calculation of their workload requirements and performance standards,
it is clear that the pressure to produce creates disincentives for
fully completing training. In GAO's survey for their report on
training, 60 percent of experienced claims processors found it
``difficult'' to meet their annual training requirement due to their
workload. VBA must find new ways to separate out time and space for
employees to assist them in meeting their training requirements.
VBA Should Significantly Increase the Total Annual Hour Requirement
for Continuing Training for All Employees
Given the complexities and duties of VSRs and RVSRs, more extensive
training is necessary in order to gain the appropriate level of
knowledge and skill to perform those duties with quality and accuracy.
DAVs SCT training program is continuously ongoing and provides a
constant learning environment for NSOs. Although NSOs are trained on
virtually the same subjects as VSRs and RVSRs, NSOs are required to
successfully complete 32 months of training about every three years, or
approximately 400 hours a year, nearly five times the amount of
training provided to VA claims processors. DAV also provides additional
training on new and emerging issues that is outside the curriculum of
the SCT training program, whereas VBA counts it as part of the 80-hour
requirement. Annual training should not include emerging topics; this
type of training should be provided separately and should vary each
year depending on the number and complexity of the new and emerging
issues.
We are not suggesting VBA match hour-for-hour DAV's training
program, nor adopt the content verbatim. However, it is not possible
for a claims processor to achieve the required proficiency level
without significantly increasing the amount and intensity of training
currently provided by VBA.
All VBA Employees, Coaches and Managers Must Undergo Regular
Testing to Measure Job Skills and Knowledge, as Well as the
Effectiveness of the Training
Mandatory, regular and continuing testing programs for all VBA
employees, supervisors and managers would serve several related
purposes:
It could be used to measure the proficiency and
knowledge required for promotion or be used as a factor in
determining other incentives.
It could be used to identify subject matters or
competencies that need required additional training of the
test-taker.
It could help evaluate the effectiveness of the
training programs; and
It could help identify weaknesses in the claims
process that may require systemic improvements.
VSRs and RVSRs are currently required to complete 80 hours of
annual training, but there is no testing to measure whether the
material was understood or is being retained. Attendance is the main
instrument used to verify if training is being completed, and even in
that minimal measure VBA is failing miserably.
VBA has begun administering certification examinations for some
employees; however, the examination is primarily being used for grade
level increases, not for proficiency purposes. For example, if a VSR
desires to elevate their grade level from a 10 to 11, they must pass a
certification examination; however, they may opt out of the examination
and remain at their current level. Conversely, if that same VSR fails
the certification examination, there is no penalty and they may remain
in their current position. A VBA employee also told DAV that a VSR
``work around'' to avoid taking a certification examination for a grade
level increase would be for a VSR to apply for an RVSR position; if
selected, the individual could be elevated from a grade level 10 to
grade level 11 without the requirement of a certification examination.
By comparison, DAV NSOs engaged in the SCT program are trained and
tested each month, concluding with a comprehensive 160 question web-
based test at the end of the SCT program. Likewise, NSO supervisors
have the flexibility to implement additional testing, which is often
the case depending on the complexity of the SCT material, or with
emerging topics, such as a particular CAVC case or VA Fast Letter.
DAV takes our commitment to disabled veterans, their families and
survivors very seriously; and in order to provide competent, proficient
representation, training is vital. Our goal is to deliver the most
relevant material and information to an individual, monitor their
progress through testing, and hold managers and NSOs accountable for
completing the training, while increasing their competency and
proficiency to perform their duties. We believe there is absolutely no
way for VBA to accurately assess its training or measure an
individual's knowledge, understanding or retention of the training
material without regular testing. It is important, however, that all
testing and certification be applied equally to both employees and to
the people who supervise and manage them.
VBA Must Aggregate the Results of All Employee Testing, Coaches
Reviews, Quality Assurance and Quality Control Programs and Regularly
Analyze This Data to Develop New Training Curriculum and Claims Process
Improvements
Training and quality control are interrelated and should be part of
a continuous improvement program, both for employees and for the claims
process itself. Quality control programs should identify areas and
subjects that require new or additional training for VBA's employees;
better training programs for employees and managers should improve the
overall quality of VBA's work.
VBA has mountains of data about the quality and accuracy of work
performed under the current system that comes from the Systematic
Technical Accuracy Review (STAR) program, ``coaches'' reviews of
employees, Inter-Rater Reliability (IRR) reviews and employee
certification testing. However, there is currently no process or system
that is capable of aggregating or analyzing this data to spot error
trends or breakdowns in the claims process that need improvement or
additional training of employees or managers. The new VBMS system
should include the capability to aggregate and analyze the data from
the results of all employee and manager training, testing, IRR, STAR
and Coaches reviews. Such analysis can then be used to modify training
programs and the claims process itself to reduce errors.
Training Must Be a Shared Responsibility of Both VBA Employees and
Managers, and VBA Must Provide Accountability and Incentives for
Successfully Completing Training
Successful completion of training must be an absolute requirement
for every VARO and must be a shared responsibility of both employees
and management. Managers must be held responsible for ensuring that
training is offered and completed by all of their employees. However it
is also the responsibility, as well as part of the performance
standard, for employees to complete their training requirements.
Managers must provide employees with the time to take training and
employees must fully and faithfully complete their training as offered.
Neither should be able or pressured to just ``check the box'' when it
comes to training.
Training is essential to the professional development of an
individual and tied directly to the quality of work they produce, as
well as the quantity they can accurately produce. In fact, a senior VA
official recently told DAV that new employees who just completed
training were receiving some of the highest marks for quality and
accuracy. One explanation is that new employees are more accountable
for the quality of their work because they are more closely reviewed,
have recently been trained and are up-to-date on the latest
information.
Mr. Chairman, DAV believes wholeheartedly in the vital role of
training and the primacy of quality over quantity. We believe the only
way that VBA can make any tangible and lasting gains towards decreasing
the backlog will be by producing better quality decisions the first
time. As we have said over and over again, the claims backlog is not
the problem; rather it is a symptom of a much larger problem: the
failure to accurately process claims. One of the keys to solving this
problem is training. VBA must undergo a cultural change that focuses on
the accountability of managers and employees to ensure the training is
being accomplished on time and with consistency.
At DAV, accountability for training and quality is present at every
level and tied directly to performance reviews and monetary increases
of employees as well as supervisors and managers. VA must infuse the
same level of accountability within its VAROs, and they will be most
successful if they adopt a ``carrot and stick'' approach which can be
done both through performance standards (``the stick'') and by linking
training requirements to advancement, bonuses and awards (``the
carrot''). This simple change could be a catalyst to producing better
quality decisions for veterans and their families. We urge VBA to be
firm in holding managers and employees to a much higher level of
accountability in ensuring that training requirements are being met.
Mr. Chairman, that concludes my testimony and I would be happy to
respond to any questions the Committee may have.
Prepared Statement of Meg Bartley, Esq., Senior
Staff Attorney, National Veterans Legal Services Program
Chairman Hall, Ranking Member Buyer, and Members of the
Subcommittee, I am honored to provide this testimony on behalf of the
National Veterans Legal Services Program (NVLSP).
NVLSP is a nonprofit veterans service organization founded in 1980
that has been assisting veterans and their advocates for thirty years.
We publish numerous advocacy materials, recruit and train volunteer
attorneys, train service officers from such veterans service
organizations as The American Legion and Military Order of the Purple
Heart in veterans benefits law, and conduct quality reviews of the VA
regional offices on behalf of The American Legion. NVLSP also
represents veterans and their families on claims for veterans benefits
before VA, the U.S. Court of Appeals for Veterans Claims (CAVC), and
other Federal courts.
Our testimony is primarily based on reviews of over a thousand VA
regional office decisions during our work with The American Legion
(Legion), for whom we conduct quality reviews of VA regional offices.
We have also spoken with current and former VA employees, including a
former senior VA manager who is now working as a service officer, and
with other veterans service officers. We also speak from the benefit of
having reviewed hundreds of VA claims files in connection with our
representation of veterans and their survivors at the Board and the
Court.
We acknowledge that there are many generally equally effective ways
to train VA adjudicators. Our intent is not to micromanage the Veterans
Benefits Administration (VBA) but to provide the subcommittee with
information and ideas concerning the training of VA's Claims Processing
personnel, so that those responsible for making decisions on benefit
claims learn to take appropriate actions to develop claims and make
legally correct and fair decisions, resolving all reasonable doubt in
favor of the veteran or claimant as required by law.
Our suggestions as to training are as follows:
First, many VA errors may be caused by the perceived
need to adjudicate quickly and not by lack of knowledge on the
part of raters. Investing taxpayer money in better VA training
programs may be a waste if VA management continues to
overemphasize production over quality.
Second, well-trained first-line supervisors are
needed throughout the system. When immediate supervisors don't
have sufficient technical experience and cannot answer the
questions of those they supervise, the quality of decisions
declines.
Third, the VA should make better use of decision
review officers' (DRO) experience to identify widespread
problems and poorly-trained employees.
Fourth, the VBA must develop and use a package of
trainings targeted to end the VA's most common error patterns.
There should be proactive interaction between management and
staff regarding these error patterns that are repeated over and
over in case after case.
Fifth, the VA must change the anti-training attitude
of some VA managers.
Finally, training modules should be retrofitted and
tailored to the experience level of the trainee.
1. Many VA Errors May Not Be Caused by a Lack of Effective
Training But by VA Management's Overemphasis on Production
We acknowledge that the VA is faced with a very difficult task.
Obviously, good training is essential if the VA wishes to produce a
quality product. However, our experience is that many VA errors seem to
be caused by the perceived need to adjudicate claims quickly and not by
an actual lack of knowledge. For example, one common VA error is that
conditions that appear to be secondary to service-connected type 2
diabetes are often not caught and rated. It is difficult to believe
that most VA raters do not know that diabetes can cause these common
secondary conditions. It is the opinion of NVLSP that because the extra
work that is required to generate a decision on secondary service
connection might not receive work credit, secondary service connection
issues remain unadjudicated.
2. Immediate Supervisors Should Have Technical Expertise
Immediate supervisors should have sufficient technical experience
to answer the questions of employees they supervise. For example, a
rater who inquires whether a VA examination is required in a particular
case should be able to rely on the knowledge and guidance of their
supervisor as to whether a VA exam is warranted. The supervisor should
be able to answer that question. If not, the rater may begin to believe
that technical expertise is unimportant, to cut corners, and to make
his or her decisions without adequate knowledge and direct supervision.
3. Use DROs To Identify Problem Areas and Poorly-Trained
Employees
There were originally two reasons for the DRO program. First, the
program was designed to give veterans de novo review and hopefully
reduce the number of appeals. Second, DROs were to identify problem
areas among decision makers and to identify poorly-trained employees.
This second reason for the DRO program could be a very effective
training tool. However, in the experience of NVLSP, in some ROs the DRO
knowledge base is not being used consistent with this original
objective. When a DRO decides upon de novo review to grant the benefit,
the DRO should be required or encouraged to use their special skills
and knowledge to explain their thought process to the rater so that
this type of error does not recur. These errors can be discussed in
trainings so that raters learn from DROS and DRO decisions and begin to
gain the knowledge base that sets DROs apart from and ahead of other VA
decision-makers.
4. Identify Major Error Patterns and Generate Interactive
Trainings To End These Error Patterns
There should be strong and focused interaction between management
and staff regarding error patterns that are repeated over and over in
case after case. The VBA must develop and use a package of trainings
targeted to put an end to common error patterns. This is absolutely
crucial--these errors ``muck up'' the VA adjudication system for years
on end, often require multiple appeals and multiple remands, waste
thousands of tax dollars, and frustrate many deserving veterans up
until the day of their death.
As the members of this subcommittee are aware, many veterans die
with their claims for VA benefits not finally decided. In many cases,
this occurs because the VA has failed to stem a tide of relatively
simple development errors. It has failed to properly identify these
errors and properly train employees to vigilantly guard against these
errors. For example, the VBA's Office of Performance Analysis and
Integrity releases data compiled from VACOLS regarding the reasons for
remand of claims from the BVA to the ROs or the AMC. Figures from the
first quarter of FY 2010 show that about 3,200 claims were remanded
because of problems with a VA medical examination or opinion; over
2,300 claims were remanded because the ROs failed to obtain all VA
medical records relevant to the appealed case; and over 1,100 claims
were remanded because a VA examination was not provided where
warranted. These cases all involve a premature decision--``premature''
meaning ``occurring before a state of readiness or maturity has
arrived.'' As noted earlier, this problem with ``premature'' VA
decisions may be partially caused by VA management's overemphasis on
production numbers--but whatever the cause, VA employees should be
trained to recognize and combat these errors.
In addition to the above errors, some of the major errors
identified by Legion quality review teams and review of files on appeal
include the failure to consider conditions secondary to type 2 diabetes
mellitus, the under-evaluation of mental disabilities, and the failure
to consider claims that should have been inferred. Testimony from other
veterans service organizations point out many methods that VBA can use
to compile a comprehensive list of common errors. As noted earlier,
some of these common errors may be caused by the VA's emphasis on
production and work credit over quality. Some may be caused by the
rater's or DROs' lack of understanding of legal requirements. In
particular, we find the large number of claims involving the under-
evaluation of mental disabilities striking and suggest that any list of
common errors include the under-evaluation of mental conditions.
5. Change the Anti-Training Attitude of Some Managers
Some VA managers see training requirements as just one more
impediment to meeting production numbers. These managers are not anti-
training so much as they are pro-production. Their perception is that
it is preferable to meet production goals than to take training
requirements seriously. Unfortunately, the attitude of such managers
could defeat even the most ambitious, perfect, and comprehensive
program of education and training. The cure for this problem attitude
has little to do with improving training. Instead, the VA management
must change its overemphasis on work credit and production and give
equal emphasis to quality, full development of evidence, and resolving
all reasonable doubt in favor of the veteran or claimant as required by
law.
6. Tailor Trainings to the Experience Level of the Trainees
A Government Accountability Office Report first released in April
2010 and revised in September 2010 recommended that the VA ``develop
and implement a written strategy for routinely assessing the
appropriateness of the training regional offices provide to experienced
claims processors.'' In its comments, the VA generally concurred with
GAO's conclusions and concurred with all of GAO's recommendations. It
goes without saying that trainees should receive training that is
commensurate to their level of experience, and we encourage the
subcommittee to ensure strong oversight of this area.
We are particularly concerned that the more experienced claims
processors continue to receive training at a level appropriate to their
expert knowledge, skills and abilities. With nearly one-half of the VA
workforce having less than three years of experience, providing high-
level training to experts might easily fall by the wayside. Those with
considerable expertise are perhaps the most valuable VA employees
because due to this expertise many veterans enjoy the benefit of quick
and correct decisions on their benefit claims. To prevent these more
experienced claims processors from gaining even greater knowledge would
be shameful. To allow them to stagnate or lose their edge due to
deficiencies in the training system would also be shameful. Therefore,
we encourage the subcommittee to ensure supervision and oversight in
this area.
I appreciate the opportunity to provide the Subcommittee with this
testimony and stand ready to answer any questions the members may have.
Thank you.
Prepared Statement of David E. Hunter, Ph.D.,
Assistant Director, Cost Analysis and Research Division,
Institute for Defense Analyses (IDA)
Mr. Chairman and Members of the Subcommittee, I am pleased to come
before you today to discuss IDA's Assessment of Claims Adjudication
Personnel Requirements, a study we performed for the Veterans Benefits
Administration (VBA) in 2009.
In November 2008, as a result of the Veterans Benefits Improvement
Act of 2008, the VA asked IDA to conduct an assessment of the current
personnel requirements of the VBA. The study is described in Section
104.b.2 of the Act as follows:
An assessment of the current personnel requirements of the
Veterans Benefits Administration, including an assessment of
the adequacy of the number of personnel assigned to each
regional office of the Administration for each type of claim
adjudication position.
Given the topic of today's hearing, it is important to note that
the focus of our study was personnel requirements for VBA claims
adjudication positions. IDA was not asked to analyze the adequacy of
training requirements, nor did it do so. We did not make any
recommendations regarding training. We did find that requirements for
training are an important factor in determining the VBA claims
processing capacity, however, as the balance of my testimony will
discuss.
My testimony today will describe the relevant results of the study,
with particular attention to the effect of the training requirements on
the VBA claims processing capacity. The results of our study, in
entirety, have been documented in IDA paper P-4471.
Our study considers the inventory of pending claims in the rating
bundle. (The ``rating bundle'' is composed of all disability
compensation and pension claims, and other claims that involve a rating
decision.) The future pending inventory will primarily be driven by two
top-level considerations:
The VBA's claims processing capacity; and
The number of new claims received each year.
Of these, the number of claims adjudication personnel will affect
only the VBA's capacity to process claims.
The three types of employees directly involved in claims
adjudication are:
Veterans Service Representatives (VSR),
Rating Veterans Service Representatives (RVSR), and
Decision Review Officers (DRO).
VSRs assemble the documentation submitted in support of claims in
the rating bundle and process claims that do not require a rating
decision; RVSRs evaluate and issue decisions on rating claims; and DROs
process veterans' appeals of VBA decisions, among other
responsibilities.
Figure 1 shows levels of VBA claims adjudication personnel by type
from FY 2000 to FY 2008. As the chart indicates, VBA personnel levels
have grown since FY 2006, after remaining essentially flat from the end
of FY 2002 to FY 2006.
Figure 1. VBA Claims Adjudication Personnel by Type, FY 2000-FY 2008
[GRAPHIC] [TIFF OMITTED] T1756.001
The graph shows that VSR levels started to increase at the end of
FY 2005, while RVSR levels started to increase during FY 2007. DRO
levels increased only slightly over this time period.
Claims in the rating bundle typically require actions from both
VSRs and RVSRs. DROs are primarily responsible for appeals. Our
analysis shows that there are sufficient VSR resources available, and
that, for the rating bundle, VBA claims processing capacity currently
is and for the next several years will be limited by the number of
RVSRs.
We developed a model of the VBA's claims processing capacity. We
took into account, among other factors, the number and experience level
of claims adjudication personnel, particularly RVSRs.
Newly hired RVSRs are not as effective as fully trained RVSRs. They
spend a significant portion of their time in the classroom and engaged
in on-the-job training, and they are generally less proficient in the
performance of their tasks. Based on typical production goals used at
the regional offices, we calculated effectiveness levels for less than
fully trained RVSRs. Nationally, the minimum daily quota for fully
effective RVSRs is 3.5 weighted claims, although some regional offices
have set higher production quotas. (A ``weighted claim'' is a metric
created by the VA to account for varying difficulty levels among
claims.)
Table 1 shows our estimates for employee effectiveness by
experience level. We used these values to calculate the number of fully
trained equivalent personnel, which we called Effective RVSRs.
Table 1. RVSR Training Factors
------------------------------------------------------------------------
Equivalent
RVSR Experience Production Goal Effectiveness
------------------------------------------------------------------------
0-6 months 0.0/3.5 0%
------------------------------------------------------------------------
7-12 months 1.0/3.5 29%
------------------------------------------------------------------------
1-2 years 2.2/3.5 63%
------------------------------------------------------------------------
2+ years 3.5/3.5 100%
------------------------------------------------------------------------
The results provided in our report were based on actual VBA
employment figures through April 2009 and used the VBA FY 2009 hiring
plan for May 2009 through September 2009. We note that the VBA added
over 600 RVSRs from the beginning of FY 2008 through April 2009, the
last month for which we had actual employment levels.
Our study forecasts future levels of fully trained equivalent
personnel under various hiring policies. The case presented in Figure 2
is a no-growth case, with future hiring limited to replacing attrition
starting in October 2009.
As this figure shows, even with no additional growth in the total
number of employees after September 2009, the number of Effective RVSRs
continues to grow in the near term due to the increasing productivity
of the recently hired personnel as they gain experience over time. We
estimated that the number of Effective RVSRs would grow by 29 percent
from September 2009 levels without any additional hiring.
Figure 2. Total and Effective RVSRs
[GRAPHIC] [TIFF OMITTED] T1756.002
There is a direct relationship between the number of adjudication
personnel and the number of completed claims. Increases in completed
claims do not necessarily translate into a decline in the pending
inventory, however, because pending inventory is influenced by both
completed and received claims. This point is not just of hypothetical
importance.
Figure 3 presents historical data on received, completed, and
pending claims. In FY 2008, completed rating claims exceeded received
rating claims for the first time since FY 2003. The result was that the
number of pending rating claims, which had increased during the
preceding several years, decreased slightly in FY 2008.
Figure 3. Received, Completed, and Pending Rating Claims, FY 2000-FY
2008
[GRAPHIC] [TIFF OMITTED] T1756.003
Unfortunately, this trend in pending claims did not continue. Our
study accurately forecasted that completed claims would increase
further in FY 2009 and FY 2010 as the RVSRs hired in FY 2007 and FY
2008 became fully effective. Claims received, however, increased even
more rapidly, and hence pending claims increased even while VBA
capacity increased.
The number of received claims is difficult to predict and can
change drastically from year to year due to changes both in statute and
in veterans' propensity to file claims. Any substantive changes from
historically observed behavior will naturally have direct effects on
the requirements for VBA claims adjudication personnel.
Mr. Chairman and Members of the Subcommittee, that concludes my
remarks. I would be happy to answer any questions.
Prepared Statement of Ian C. de Planque, Deputy Director,
Veterans Affairs and Rehabilitation Commission, American Legion
Mr. Chairman and Members of the Subcommittee:
I appreciate this opportunity to express the views of the 2.5
million members of The American Legion on the current state of training
at the Veterans Benefits Administration (VBA) of the Department of
Veterans Affairs (VA). Training is one of the most important aspects of
any plan for improvement in the VA at this time, especially in light of
the fact that nearly half the VA workforce has less than three years of
experience on the job. If VA is to achieve Secretary Shinseki's stated
goal of ``no claims pending longer than 125 days and an accuracy rate
of 98%'' then training is going to be one of the most important tools
to achieve that promise. If accuracy is to increase, and The American
Legion strongly believes that this component is essential to any reform
of VA, then the training must improve to bolster the workforce that has
grown so dramatically in recent years.
The American Legion has examined this problem through direct,
firsthand action in the Regional Offices (ROs), as a component of our
Quality Review visits of those Regional Offices. Furthermore, the
studies of the Government Accountability Office (GAO) in August of this
year, and others, have provided further insight that identifies some of
the problems faced by VA's training system as currently implemented.
In our Quality Review visits, as in our System Worth Saving visits
of the health care system, The American Legion has encountered one of
the greatest problems facing VA today--inconsistency. Simply put,
regardless of the intentions of Central Office, how programs are
implemented varies widely from region to region. Each individual RO
functions more like a semi-autonomous fiefdom, and little consistency
is apparent among the ROs as a whole.
This need for better oversight was confirmed not only by our in-
person site visits, but also in the findings of a GAO report entitled
``Veterans' Disability Benefits: Expanded Oversight Would Improve
Training for Experienced Claims Processors'' published just last month.
That testimony paints a picture of a ``one size fits all'' training
program that fails to meet the needs of more experienced processors. If
a reason were to be assigned to why the program is not meeting the
needs for this group of claims processors, The American Legion would
suggest that these needs are actually being met in offices where
training is a priority, and seriously addressed by those responsible to
make the training work. In other offices, where the training is planned
by individuals seeking merely to ``check a box,'' then the training
suffers and is poorly tailored to the needs of the employees. Again,
this all stems from inconsistent implementation within ROs that vary in
quality far too much from region to region.
Training is seldom viewed as a priority. All too often it falls far
behind the driving goal behind the majority of VA operations--the
endless march towards reaching production requirements. VA is so driven
by the need to churn out numbers by a dysfunctional work credit system,
that the time needed for training is simply not available. When faced
with the choices of not meeting production numbers and not adequately
meeting the training hour requirements, time and time again we see that
the individual offices choose to ensure that production numbers do not
drop. The vast majority of VA employees interviewed by The American
Legion over the past decade in Quality Review visits have continually
reinforced the frustration that meeting production numbers is the
single greatest factor in determining how they are able to do their
jobs.
Clearly, if VA is to adequately bring online their new and
inexperienced workforce in a manner that will enable them to process
claims without common errors, then training to eliminate those errors
must be an essential component of that plan. These simple, procedural
errors keep claims bouncing around the system through the appeals and
remand process; they must change this attitude to reflect a commitment
to appropriate and targeted training. Furthermore, they must ensure
that regardless of how strongly this new commitment is expressed by
Central Office, that implementation is enforced in the Regional
Offices. VA must strive to improve consistency and oversight to make
sure that their aims are being implemented equally from coast to coast.
GAO indicated that claims processors may not be getting the
training they need, even when they do receive training. Common
complaints included too little training on some topics, too much on
other topics. Specific topics such as Special Monthly Compensation
(SMC) where not enough training was received and Records Management as
a topic on which they received far too much training were identified.
The American Legion has found in our Quality Review visits that often
times the training is repetitive, dealing with the same topics year in
and year out, with little helpful additions. Simply put, the training
they are receiving does not match the target areas that are actually
needed. But how is VA to identify what areas are really needed by their
employees.
The American Legion has previously testified that there is a
mechanism already existing and waiting to be harnessed to just this
end. Annually, VA conducts their internal STAR review to identify
accuracy issues with individual work and identify problems that need to
be addressed by employees when they process claims incorrectly.
Furthermore, every day the Board of Veterans Appeals (BVA), the Court
of Appeals for Veterans Claims (CAVC) and the Appeals Management Center
(AMC) return hundreds of cases to lower jurisdictions after identifying
errors in the lower level of processing. This could even be said for
Decision Review Officer (DRO) examination of appeals, a process wherein
the most experienced claims workers in the ROs may review a veteran's
claim when that veteran elects to appeal the decision made on the
original claim. These decisions are made by better trained and more
experienced personnel, and can be a great tool in identifying common
errors.
VA could collect the aggregate data from STAR review, remands, and
overturned decisions of the higher authorities, compile them into
analytical reports, identifying common errors and trends would become
apparent; training programs could be implemented specifically targeting
the areas of greatest need.
For example, American Legion sampling of cases in Quality Review
visits indicates VA is having a problem rating mental health claims
consistently. This could be identified and turned into a training
program to increase consistency in these ratings. If VA is churning out
improper exams, or exams that inadequately address the proper
provisions for repetitive movement or other factors, then remedial
training on these exams would be necessary.
This could even be targeted to the regional level. Consistency
across regions does not have to mean the exact same training in each
office. However, each office has a robust plan that is targeting their
individual deficiencies and working to raise their accuracy rate. There
is a gold mine of data on the common errors available, and VA would be
foolish to ignore this valuable research tool to develop their training
plans on both a national and regional level.
Finally, it would be premature to discuss whether or not the
current 80-85 hours of required training is meeting the needs of the
employees, when it is being inconsistently implemented among the
regional offices. You cannot determine if 80, or 85, or 45 hours is the
``right'' amount of training until you can determine that it is
consistently implemented as the right kind of training.
This falls victim to the same fallacy that drives VA's production
goals. By evaluating success or failure solely on the ability to meet a
numerical benchmark, you fail to evaluate whether the quality component
is being met. VA needs a better mechanism. Simply punching a card for
80 hours of the same, lackluster and undirected training no better
serves the veterans of America than processing 4 claims a day with
little regard to whether or not they are done properly. Again, the
quality of the training must be of equal import to the quantity of
training.
It is essential to develop real benchmarks that illustrate not only
where VA is complying with the minimum number of hours of training
required, but also that this training is addressing the deficiencies in
knowledge and expertise so that it raises the skill level of the
workforce.
In summation, VA must implement a training program that is
universally consistent regardless of region, is targeted to areas of
need identified by common errors denoted in collected data from VA's
various internal mechanism for identifying mistakes and inaccuracy, and
finally evaluates the worth of the training not with mere numerical
benchmarks, but also accurately assesses and affirms that the overall
knowledge base of the employees is growing and that they are becoming
more proficient and adept at their jobs.
As previously stated, this is one of the most inexperienced
workforces that VA has ever fielded. Congress has admirably provided VA
with the resources to grow their workforce to meet the needs of a
caseload volume that exceeds a million new cases a year. Patience must
exist to some extent as new employees come up to speed. However, these
new employees, nearly a full half of VA's workforce, could not
underline the need for effective and robust training more clearly.
VA is building the core of their 21st Century operational structure
in this workforce and through other infrastructure means such as their
computer technology. The time to address these training issues is now,
at the ground floor level, not years down the road when the aggregate
effects of years of lackluster training and poorly targeted and
implemented plans have done their damage.
The American Legion stands ready to answer any questions of this
Subcommittee and thanks you again for this opportunity to provide
testimony on behalf of our members.
Prepared Statement of Michael Cardarelli,
Acting Deputy Under Secretary for Benefits, Veterans
Benefits Administration, U.S. Department of Veterans Affairs
Mr. Chairman and Members of the Subcommittee:
Thank you for the opportunity today to appear before the
Subcommittee to discuss employee training within the Veterans Benefits
Administration (VBA). I am pleased to be accompanied by Diana Rubens,
Associate Deputy Under Secretary for Field Operations; Terence Meehan,
Director of Employee Development and Training; and Danny Pummill,
Deputy Director for Policy and Procedures for the Compensation and
Pension (C&P) Service.
Breaking the Back of the Backlog
As you know, Secretary Shinseki set the goal of eliminating the
disability claims backlog by 2015 so no Veteran has to wait more than
125 days for a high quality decision that meets a 98 percent accuracy
level. This important goal is at the center of our work as we
collaborate across the Department of Veterans Affairs (VA) to improve
the delivery of benefits for our Nation's Veterans. We define the
``claims backlog'' as claims that have been pending in our inventory
longer than the 125-day goal. VA currently has approximately 530,000
pending disability claims, 37 percent of which have been pending longer
than 125 days and are therefore considered to be part of VA's claims
backlog. We are currently at 83.5 percent rating quality which is below
our fiscal year (FY) 2010 target of 90 percent.
VBA has been aggressively hiring claims processing staff across the
Nation since FY 2007, and continues to hire through FY 2010. However,
hiring more employees is not a sufficient solution. The need to better
serve our Veterans requires bold and comprehensive business changes to
transform VBA into a high-performing 21st Century organization that
provides the best services available to our Nation's Veterans and their
families. VBA's transformation strategy leverages the power of 21st
Century technologies applied to redesigned business processes. We are
examining our current processes to be more streamlined and Veteran-
focused. We are also applying technology improvements to the new
streamlined processes so that the overall service we provide is more
efficient and timely. We are using the knowledge, energy, and expertise
of our employees, other administrations in VA, Veterans Service
Organizations, Congress and the private and public sectors to bring to
bear ideas to accomplish this claims process transformation.
One of VBA's strategies is to improve and expand training available
to our employees. We focus on high-quality, timely, and relevant
training for both new and experienced personnel. To that end, VBA has
deployed training tools and centralized training programs to improve
standardization of training across all regional offices (ROs). My
testimony will address training of new and experienced employees who
process Veterans' claims. I will describe the training programs as well
as the methods of training evaluation and oversight VBA is using to
ensure employees are continuously prepared to accomplish their mission.
New Employee Training
VBA has developed and implemented a standardized training
curriculum, the Challenge training program, for new claims-processing
employees. The Challenge program is a national technical training
curriculum that provides new Veterans Service Center employees with the
skills they need to function effectively in their positions as Veterans
Service Representatives (VSRs) or Rating Veterans Service
Representatives (RVSRs). Since FY 2007, VBA has trained more than 7,200
new VSRs and RVSRs, including more than 2,000 in FY 2010.
The Challenge program is delivered in three phases. Phase 1 is
completion of knowledge-based prerequisite training at home stations
using lectures, demonstrations of computer applications, and team-
learning through VBA's Training and Performance Support Systems (TPSS).
Post-tests built into TPSS confirm that students have learned the
material.
Phase 2 is centralized classroom training. Newly hired VSRs and
RVSRs attend two-and-a-half weeks of resident training. These courses
are offered at the Veterans Benefits Academy in Baltimore, Maryland,
and selected VA regional offices when the volume of newly hired VSRs
and RVSRs exceeds the centralized training capacity. All training sites
use standardized curricula. Area offices recommend trained instructors
to VBA Headquarters where selections and instructional assignments are
made. The quality of the training is enhanced by using no greater than
an 8:1 student-to-instructor ratio. Centralized training provides
hands-on training with computer applications and advances the new
employees through progressively more challenging practice claims. All
new employees handle sample claims just as they will when they return
to their home stations.
Phase 3 is completed at home stations, blending lectures,
discussions, and TPSS training with experiential learning. Trainees
work actual Veterans' cases under the guidance of experienced
personnel. Instructors in the first two phases are subject matter
experts who have completed either an instructor development course
designed to provide platform-delivery skills or a TPSS Training
Coordinator course taught to effectively use team learning with
standardized lesson materials. Instructors in the third phase are
experienced VSRs or RVSRs with current knowledge of regulations and
procedures. Many of the Phase 3 instructors have also received formal
instructor training.
From FY 2008 through FY 2010, 1,642 VBA employees have attended a
VBA-sponsored instructor course. Our goal remains to provide every
field employee identified as a potential instructor an opportunity to
receive instruction on design and delivery of training.
Experienced Employee Training
In response to Government Accountability Office (GAO)
recommendations and internal evaluations, VBA instituted continuous
improvements to its program for training of experienced personnel.
Beginning in FY 2010, VBA designed national curricula to enhance
quality in claims processing through standardized training. Topics in
the national curricula were selected to address national quality issues
as determined through VBA's Systematic Technical Accuracy Review (STAR)
program.
The national curricula were used by ROs to deliver required
training for VBA employees based upon experience level. The
intermediate curriculum was used for employees with 6 to 24 months of
experience, and the advanced curriculum was used for employees with
more than 24 months of experience. Lesson materials supporting the
national curricula were published by the C&P Service to increase
standardization of training across all ROs.
In FY 2010, VSRs and RVSRs are required to complete a total of 85
hours of training, including 40 hours from the appropriate mandatory
national technical curriculum (intermediate or advanced), 20 hours of
electives from a national technical curriculum of additional topics,
and 25 hours of station-determined topics that included courses
required of all VA employees. By August 31, 73 percent of all VSRs and
RVSRs had exceeded the mandatory 85 hours of training, and 80 percent
were on track to complete the requirement by the end of FY 2010.
In FY 2011, VBA is making additional improvements in the training
for experienced VSRs and RVSRs. The change will give supervisors more
latitude to tailor the annual training of employees to better meet the
emerging needs of individual employees, their managers, and the RO in
this transformational environment. In FY 2011, experienced Veterans
VSRs and RVSRs will be required to complete 85 hours of training from
multiple curricula.
All VSRs and RVSRs will complete VA-mandated courses on an annual
or biennial basis to promote diversity and emphasize information
security awareness. They will be required to complete 40 hours from a
C&P Service technically-oriented curriculum that addresses national
quality concerns and regulation changes. They will also complete an
additional 40 hours from a combination of curricula depending upon the
needs of the RO and the developmental needs of individual employees.
For employees who require greater technical growth, some or all of
the 40 hours may be chosen from the C&P curriculum of technically
oriented ``elective'' courses. Employees who have mastered their trade,
exhibit high production and quality, and have expressed both the
potential and interest in personal growth may be ready for development
in skills that prepare them for higher levels of responsibility. For
employees with non-technical needs, such as critical thinking and
effective writing, courses will also be available through VA's new
``ADVANCE'' Program. The purpose of this program is to invest in
employee development, workforce engagement, and talent management. This
program will support the learning needs of a transformational
organization and includes courses such as critical thinking, effective
team operations, oral and written communications, and managing change
at the individual and group levels.
Training Oversight
VBA has improved its training oversight methods to increase
accountability. Managers at all levels are held accountable for
ensuring training requirements are met. The VA Learning Management
System (LMS) provides a transparent view of each employee's training
achievements to managers and supervisors from the team through the
Headquarters level. Using LMS, the Headquarters generates periodic
reports to indicate whether ROs are progressing satisfactorily to meet
published training requirements for VSRs and RVSRs. The reports are
shared within Headquarters and with RO leaders.
In 2008, VBA created the staff position of Training Manager for
each RO. The Training Manager is responsible for local training
reviews, as well as analyzing performance indicators to determine local
training needs and implementing the training necessary to meet those
needs. In each year since the positions were established, VBA has
provided multiple venues for collaboration of Training Managers with
Headquarters personnel and other Training Managers. The keystone is an
annual workshop for training and collaboration that is reinforced with
monthly telephonic meetings and on-line collaboration using social
networking tools.
Training Evaluation
In response to a GAO recommendation, VBA developed and implemented
a strategy for systematically assessing the content, mode, and timing
of training for experienced claims processors. Training of claims
processors is continuously improved in VBA through ongoing evaluation
of the training program itself.
During Challenge Phase 2 (centralized) training, Challenge students
provide anonymous evaluations, using a web-based tool, of each lesson
and the performance of their instructors, as well as the training
facilities and support. Evaluation feedback is reviewed daily by the
C&P Service training staff to facilitate rapid corrective actions if
participants or instructors need improvements.
Upon their return to home stations for Challenge Phase 3, employees
provide weekly evaluation of their continuing training. Employee
feedback is reviewed weekly by Headquarters personnel for potential
intervention if training is not proceeding successfully. Additionally,
VBA initiated a Challenge Phase 3 site-visit program to gather feedback
from participants and their managers about how that phase of Challenge
is being implemented.
VBA is also collecting and reviewing feedback from staff to
determine if the 85-hour training requirement is appropriate for
experienced VSRs and RVSRs. Similar to the feedback mechanism used with
employees in Challenge training, VBA is using a web-based evaluation
tool to gather feedback from experienced claims personnel regarding
their training. In more than 22,000 responses from experienced
personnel since initiating the evaluation in March 2010, VBA has
collected feedback on the usefulness, relevance, and quality of the
training received in their ROs using the national lesson materials.
Headquarters personnel who authored the training materials and RO
managers have direct access to the feedback and can quickly update
lesson materials and publish the changes.
VBA's formal training system, TPSS, has an integral feedback
mechanism to encourage users to recommend improvements, changes, and
corrections to lesson materials. Recommendations are screened routinely
and prioritized for incorporation into the life cycle project
management plans, with the goal of keeping all materials complete and
accurate.
Conclusion
Since the Subcommittee's last hearing on VBA training in 2008, VBA
has substantially and continuously improved the entry-level instruction
provided to our new claims processors. VBA has also taken many positive
actions to enhance the relevancy and standardization of training for
experienced claims processors. VBA expanded its training oversight and
implemented an evaluation program to increase quality and consistency
and support a continuing dedication to improving training. VBA has made
continuous efforts to improve training and ensure high quality
decisions for our Veterans in a timely manner.
Mr. Chairman, this concludes my testimony. I will be happy to
respond to any questions that you or other Members of the Subcommittee
may have.
Statement of Carol Wild Scott, Chairman,
Veterans Law Section, Federal Bar Association
Congressman Filner, Congressman Buyer and Members of the Committee:
Thank you for the opportunity to present this statement on behalf
of the Veterans Law Section on behalf of the Federal Bar Association.
The Federal Bar Association is the foremost national association of
private sector and government lawyers engaged in the practice of law
before the Federal courts and Federal agencies. Sixteen thousand
members belong to the Federal Bar Association. The Veterans Law Section
(``VLS'') is comprised of lawyers who are associated with all aspects
of veterans and military law. The comments herein are exclusively those
of the Veterans Law Section and do not necessarily reflect the views or
official position of the entire Association.
The growing backlog of veterans' disability claims pending before
the Department of Veterans Affairs and the U.S. Court of Appeals for
Veteran Claims has been the subject of numerous written submissions,
testimony and commentaries. The Claims Summit in March and a further
hearing before the House Committee on Veterans' Affairs in June all
addressed the same issues--what is wrong with the claims process and
how can it be fixed? Several facts are inescapable. The backlog is out
of control, symptomatic of a process out of control. The operative term
is ``control.'' There is as much need for vertical accountability in
the area of training as in administration of the Veterans Benefits
Administration.
The problems
The statistics from the Board and the CAVC give a strong indication
that there are and will continue to be serious training issues in both
the rating and appeals process. CAVC routinely remands 70-80 percent of
the cases coming before it. Another 5 percent are reversed and then
remanded. The Court agrees with the Board only 20-25 percent of the
time, according to Judge Kasold's testimony of May 2009. Even if one
attributes a portion of the remands to philosophical differences
between the Board and the Court, a 70-80 percent remand rate is
strongly indicative of a significant level of error in the proceedings
below. In a system in which the Board has claimed an accuracy rate of
in excess of 90 percent, there is clearly a disconnect. Similarly, the
Board, in FY 2009 either remanded or allowed 61 percent of the 48,800
appeals in which they made decisions, thus finding that the Regional
Office decision was correct in only 39 percent of the cases.
This level of error is strongly suggestive of serious training
deficiencies from the Benefits Academy to the continuing education
which every rating employee is required to receive annually. Training
issues were addressed in the April, 2010 GAO study, ``Veterans
Disability Benefits, Expanded Oversight Would Improve Training for
Experienced Claims Processors.'' GAO determined that the VBA delegates
a considerable amount of control to the individual Regional Offices,
while providing a fairly standardized curriculum for about half of the
required eighty hours of annual training. They found that a majority of
the experienced personnel (over two years experience) had difficulty
meeting the eighty hours of required training with their workload
requirements.
Because of the uniform level of subject matter addressed in the
training, many of the rating personnel either felt that they did not
need it or the training did not meet their specific needs. Two examples
were identified by personnel as inadequate: case management and special
monthly compensation. Clearly ``one size fits all'' does not fit within
the context of continuing education, which is what the requirement of
yearly training is intended to be. Rating employees have expressed the
need for additional education in the rating for TBI. Decisions from the
Court and the Board demonstrate a significant error rate with PTSD and
toxic exposures. The conclusion was that the training component of VBA
lacked controls to ensure the content and quality of the eighty hours
of instruction required annually and thus did not meet the standards
cited. In the area of training as well as in administration, it is
essential to have a vertical chain of command with accountability for
the quality of instruction, content and availability of information to
every rating employee.
In a sense, a well-trained cadre is a happier cadre. There are very
few in the VBA who do not do the best job they can to ensure that the
veteran is allocated appropriate compensation for the harm suffered.
There have been numerous complaints reflected in IG reports and
Congressional testimony to the effect that poor training and lack of
experience on the part of supervisory and executive personnel has
affected morale in the workplace. Education and testing for leadership
skills to develop a well trained, qualified cadre of supervisory and
executive personnel is essential to the maintenance of the high
standards required across the board. Inadequate training has apparently
led to the early dismissal of some of the new hires, thus reducing the
number of new rating personnel when the real problem was lack of
adequate training.
Some suggested solutions
VLS recommends that vertical accountability be established with a
directorate of training within the Office of the Secretary, as a
separate entity. Within this entity should be located the Academy and
under the Academy a vertically organized network of adult education
specialists with expertise in education, medical issues and regulatory
process. The Director of the Academy should be directly accountable to
the Secretary.
VLS encourages VBA to re-examine the curriculum and the
qualifications of the instructors at the Academy, with the result that
specific protocols be in place for appointment as an instructor. We
also urge that advances in adult education methodology and recruitment
of experts and consultants external to VA be utilized. The statistics
indicate that the instructional and training entities have become
cocooned, such that too often errors are repeated through instruction.
The Academy should be the focal point and resource for all instruction
agency-wide.
VLS encourages education and testing for leadership skills to
develop a well trained, qualified cadre of supervisory and executive
personnel, which would have a significant, positive effect on employee
morale. Supervisory personnel lacking knowledge of ``what they do'' has
been noted in earlier hearings and reports as sources of low morale in
the workplace. Supervisory personnel should receive continuing
education in regulatory and case law developments as do the rating
personnel along with leadership and administrative skills. The
institution of results-oriented performance protocols rather than the
``work credit'' system should apply equally to supervisory and
executive personnel and rating personnel. The quality of the decisions
in the Regional Office should be the measure of performance.
VLS recommends that should the POD modality be adopted (and
continues to recommend that this be the case) that it include a full-
time training coordinator situated in each Regional Office reporting
directly to the Director of Training. The primary duty would be
monitoring on-site, the training needs and requirements, setting a
curriculum consistent with those universal to the agency, and ensuring
that instruction and Q&A are available consistently to the individual
employee. Additionally, on-site proficiency testing is then available
for VSRs ready for promotion to RVSRs and RVSRs aspiring to the
position of DRO. (The exam certifying the DRO should equate with the
Agent's exam and re-certification should be required bi-annually to
ensure currency with case law and regulatory changes.) Uniformity in
the programs across all the ROs is critical, with standardized
performance objectives and outcomes. Innovations in the field of adult
education and the use of outside consultants as advisors in the
development and evaluation of educational and training programs should
also be utilized.
VLS recommends that training programs be thoroughly evaluated for
accuracy and thoroughness by resources both internal and external to
VA. A complex array of disabilities affect the veteran population
residual from Vietnam, the Gulf War, and OIF/OEF. Rating employees have
expressed the need for instruction in TBIs, and a significant error
rate has been found with PTSD and herbicide exposure. VBA must ensure
that the medical instruction blocs meet the needs of the demographics
of the veteran population. The medical issues of exposure to toxins
from Vietnam, the Gulf War and the burn pits in Iraq along with the
sequelae of TBI and multiple amputations must be included as these
affect multiple body systems and may lie latent for years before
becoming symptomatic (such as hepatitis C). Medical training is
critical, as it is necessary to orient lay personnel to the vastly
complex array of medical issues inherent in the average claim for
compensation arising from conflicts of the last three decades.
VLS recognizes the complex issues presented by rapid acquisition of
new personnel and the necessity of providing adequate, but concentrated
training to these employees. The Agency can ill afford to discharge new
hires as the result of inadequate training. The utilization of every
resource both in and outside of VA is required, thus VLS strongly
recommends the establishment of training protocols that also utilize
resources and expertise external to VA with instructors selected
through a certification process and recruited from the Veterans Law Bar
as ``Visiting Professors.'' Similarly, recruitment of ``Visiting
Professors'' from entities experienced in educating laity in medical
issues, protocols and processes should be implemented. Efforts such as
these ensure dissemination of information which is accurately
consistent with current case law, regulatory developments and
appropriate medical knowledge.
We thank the Committee for the opportunity to share the foregoing
views and recommendations. We must all take whatever actions are
necessary to make as whole as we can, without regard for ethnicity, the
men and women who have put their lives on the line in order that we may
have the luxury of this discussion. We owe them not only treatment of
wounds seen and unseen but as much restoration of their quality of life
as is humanly possible. With now over a million pending claims, it
matters not who represents whom, or on whose shoulders the blame
properly lies. Only through thorough and accurate education as well as
closely monitored implementation of the material learned will the
quality of claims process improve. Until the quality of performance
attains the level that precludes innumerable remands the backlog will
persist. Increasing the quality of education and training and rewarding
adequately the performance that implements it is the challenge VA now
faces. The views expressed herein are solely those of the Veterans Law
Section and not necessarily those of the entire Association.
Respectfully submitted.
MATERIAL SUBMITTED FOR THE RECORD
Committee on Veterans' Affairs
Subcommittee on Disability Assistance and Memorial Affairs
Washington, DC.
October 6, 2010
Daniel Bertoni
Director, Education, Workforce, and Income Security Issues
U.S. Government Accountability Office
441 G. Street NW
Washington, DC 20548
Dear Mr. Bertoni:
Thank you for testifying at the House Committee on Veterans'
Affairs' Subcommittee on Disability Assistance and Memorial Affairs'
oversight hearing on, ``Examining the Training Requirements of Veterans
Benefits Administration Claims Processing Personnel,'' held on
September 16, 2010. I would greatly appreciate if you would provide
answers to the enclosed follow-up hearing questions by Tuesday,
November 9, 2010.
In an effort to reduce printing costs, the Committee on Veterans'
Affairs, in cooperation with the Joint Committee on Printing, is
implementing some formatting changes for material for all full
committee and subcommittee hearings. Therefore, it would be appreciated
if you could provide your answers consecutively on letter size paper,
single-spaced. In addition, please restate the question in its entirety
before the answer.
Due to the delay in receiving mail, please provide your responses
to Cecilia Thomas by fax at (202) 226-4691. If you have any questions,
please call (202) 225-9164.
Sincerely,
John J. Hall
Chairman
__________
U.S. Government Accountability Office
Washington, DC.
October 28, 2010
The Honorable John J. Hall
Chairman
Subcommittee on Disability Assistance and Memorial Affairs
Committee on Veterans' Affairs
U.S. House of Representatives
Washington, DC 20515
The enclosed information responds to the post-hearing questions in
your letter of October 6, 2010, concerning testimony before the
Subcommittee on September 16, 2010, on the Veterans Benefit
Administration's (VBA) training for disability claims processors. If
you have any questions or would like to discuss this information,
please contact me at (202) 512-7215.
Sincerely yours,
Daniel Bertoni, Director
Education, Workforce, and Income Security Issues
Enclosure
This enclosure details Chairman Hall's questions and our response,
which supplement information in our testimony before your Committee,
Veterans' Benefits: Training for Experienced Claims Processors (GAO-10-
1029T, Washington, D.C. September 16, 2010).
__________
Questions for the Record, Honorable John J. Hall, Chairman,
Subcommittee on Disability Assistance and
Memorial Affairs, Committee on Veterans' Affairs,
U.S. House of Representatives
Question 1: Has the Government Accountability Office (GAO)
conducted any evaluations or assessments of the Veterans Benefit
Administration (VBA) certification testing program?
Response: The Government Accountability Office has not conducted
any evaluations or assessments of the VBA's certification testing
program. However, as part of our ongoing review of the VBA's Decision
Review Officer (DRO) program we will be obtaining the opinions of VBA
regional office managers and DROs about the effectiveness of the
recently implemented DRO certification exam in assessing Decision
Review Officers' ability to do their jobs.
Question 1(a): If so, please elaborate on this program and whether
your assessment showed any connection between test results and the
quantity or quality of training.
Response: Our review of the DRO program is in process. The final
report will contain the results of the limited assessment of the DRO
certification exam included in this review.
Question 1(b): If GAO has not studied this issue, has it considered
doing so in the future?
Response: Currently, we have no other plans to study the VBA's
certification testing program. We are available, at your convenience,
to discuss additional work GAO could do in this area.
Committee on Veterans' Affairs
Subcommittee on Disability Assistance and Memorial Affairs
Washington, DC.
October 6, 2010
Jimmy Sims, Jr.
AFGE Local 1738 Steward
c/o John Gage
American Federation of Government Employees
80 F Street, NW
Washington, DC 20001
Dear Mr. Sims:
Thank you for testifying at the House Committee on Veterans'
Affairs' Subcommittee on Disability Assistance and Memorial Affairs'
oversight hearing on, ``Examining the Training Requirements of Veterans
Benefits Administration Claims Processing Personnel,'' held on
September 16, 2010. I would greatly appreciate if you would provide
answers to the enclosed follow-up hearing questions by Tuesday,
November 9, 2010.
In an effort to reduce printing costs, the Committee on Veterans'
Affairs, in cooperation with the Joint Committee on Printing, is
implementing some formatting changes for material for all full
committee and subcommittee hearings. Therefore, it would be appreciated
if you could provide your answers consecutively on letter size paper,
single-spaced. In addition, please restate the question in its entirety
before the answer.
Due to the delay in receiving mail, please provide your responses
to Cecilia Thomas by fax at (202) 226-4691. If you have any questions,
please call (202) 225-9164.
Sincerely,
John J. Hall
Chairman
__________
QUESTIONS FROM THE COMMITTEE ON VETERANS' AFFAIRS
DISABILITY ASSISTANCE AND MEMORIAL AFFAIRS SUBCOMMITTEE HEARING
``Examining the Training Requirements of Veterans
Benefits Administration Claims Processing Personnel''
September 16, 2010
Question 1: AFGE has testified repeatedly that the over-emphasis on
production deadlines by the Veterans Benefit Administration (VBA) often
hinders claims processors from completing training requirements and
ultimately leads to avoidable claims processing errors. What
recommendations does AFGE have for incentivizing prompt yet quality
performance by VBA claims processors?
Response: VBA's current focus on production capacity drives the
claims process. Employees are driven to produce numbers versus
producing quality. Current VBA Director's Performance Standards drive
this process in the field. These standards are focused on increasing
the number of claims produced which in turn reduces the Average Days
Pending (ADP), Average Days to Completion (ADC) and Average Awaiting
Development Time (ADT). These cycle times are not focused on the
quality of the work performed, but the quantity of the work performed.
While the overwhelming statements from the claimants are ``I just
want a decision'' it is incumbent on the VBA to ensure that the
decision rendered is accurate. By continuing to focus all metrics on
the amount of work produced, there is an increasing gap between the
amount of cases produced and the quality of these cases.
VBA must begin to change the focus of the production standards from
the amount of work produced, to the correctness of the work produced.
Incentive awards need to be focused on meeting and maintaining a metric
of quality versus meeting and exceeding a production number.
Question 1(a): If VBA's work credit system is not working, what
other approach would AFGE recommend for motivating VBA staff to meet
production goals?
Response: In the Center for Naval Analysis study conducted pursuant
to Section 226 of Public Law 110-389, it was recommended that a study
be conducted to determine the time required to perform each action at a
specific level of quality (Time-Motion study). This study would require
the incorporation of the differing levels of experience to determine
the amounts of time required to achieve the specified level of quality.
The current work credit system does not adequately account for the
effect of experience on quality and productivity. The current work
credit system is a cookie cutter approach based on anticipated
Journeyman level experience. VBA has been transitioning to a work
credit system which allows crediting for the claims process only when
specific milestones are met. This system does not take into
consideration the full level of work required during the life cycle of
a claim, nor does it provide consideration for the quality of work
associated with the experience level of the claims processor. This
manner of crediting work only drives employees to take shortcuts in the
process, reducing the quality of the work performed, in order to
achieve the milestones whereby credit for work may be taken.
In order to adequately address this need to motivate employees to
meet production goals while achieving specific quality levels, there
needs to be an adequate consideration of the time required in the
process.
A scientific evaluation of the claims process, such as the time-
motion study recommended by CNA, is essential to development of an
effective motivating system to meet the needs of the Agency while
meeting those of our claimants.
Question 1(b): Should VBA reward staff for completing required
training or meeting work quality benchmarks?
Response: VBA's current award system places greater emphasis on
increasing productivity. Many stations provide bonuses only for
employees whose productivity exceeds the required production standards
by a percentage from 20 to 50 percent, while only requiring achievement
of the minimum quality standard.
The ability for increasing productivity while maintaining a
specific level of quality should be commended. However, increases in
quality and productivity should generate greater rewards.
The Fiscal Year 2010 national quality target for VBA claims
processing was set at 90 percent. The end of year quality for Rating
was measured at 83.8 percent. Quality for development of claims is not
measured independently. Authorization of the awards was measured at
96.1 percent which exceeded the 90 percent target.
Prior VBA production standards did not consider training as an
element for evaluating performance. The VBA production standards for
the Veterans Service Representatives (VSR) which were implemented in FY
10 include Training as a Critical Element thereby tying the completion
of training to a satisfactory performance level. Proposals for changes
to the performance standards for Rating Veterans Service
Representatives (RVSR) and Decision Review Officers (DRO) have included
Training as a critical element. While this creates a mandate to
complete training in order to be rated fully successful, there is no
incentive to go beyond the required training of 85 hours. At the same
time, there continues to be a serious problem with the quality of
training, because of an overreliance on online training instead of
classroom training, and the lack of experience and expertise of
trainers.
As experience and quality are closely related to training, it would
be to the Agency's benefit to develop incentives for increased quality
and completion of additional training.
Question 1(c): Should VBA provide its staff with adequate time to
complete required training and ensure that the training is both timely
and targeted to their needs before enforcing strict claims processing
production quotas?
Response: In order to effectively measure an employee's
performance, there must be certainty that employees have received the
training required to accomplish the task set before them. In the
current VBA performance standard structure, employees are immediately
held to a production standard upon completion of a minimum training
program. This immediate requirement of production standards results in
a decrease in the time spent on learning and retaining the information
necessary to accurately and efficiently complete the claims process.
As VBA has reported in prior testimonies, it takes an average of
two years to adequately learn the tasks associated with the positions
in the claims process.
A moratorium on production standards during this two year period
would increase the knowledge and experience level of all claims
processors as it would allow for increased focus on obtaining quality
work versus quantity of work.
Continued training beyond the initial two year training period
should be focused on meeting the needs of the claims processors. The
current continued training (Core Technical Training Requirements) is a
one-size-fits all system. Knowledge and experience are individualized
aspects; training should likewise be individualized to address the gaps
in this knowledge base. While training programs may never be able to
address all types of claims encountered by claims processors during
their tenure, training programs should be better tailored to encompass
a greater range of issues.
Upon completion of the 2 year training program, a more
individualized training program should be developed in consultation
with the immediate supervisor and the quality review specialist
reviewing the work of the claims processor.
This individualized training program would then be re-evaluated at
the end of each year to better focus on the areas of improvement needed
to be made.
Question 2: Are VBA claims processors and their managers penalized
if training requirements are not met? Are both rewarded for meeting
annual training requirements?
Response: Under the current performance standard system in place
for VSRs, the assignment of a fully successful evaluation is predicated
upon completion of all assigned training. The performance standard
system for RVSRs and DROs does not include training completion as a
critical element. As such, there is currently no incentive in place for
employees other than VSRs to complete training requirements.
Unfortunately, AFGE is not afforded information on the reward and
punishment programs which VBA has instituted for management officials.
Therefore, we are unable to comment on the repercussions of failure of
management or their assigned employees to meet mandatory training
requirements.
The performance standard system for RVSRs and DROs should include
training completion as a critical element.
Question 3: What are your specific assessments of VBA's classroom
versus online training and do you believe there is a proper mix of each
one in order to ensure high quality delivery of training?
Response: As a Journeyman Rating Veteran Service Representative, I
have participated in the training in a classroom and online setting.
The current classroom training programs are adversely impacted by VBA's
lack of qualified and trained instructors. In the field stations,
employees are selected for training, not based on past ability or
experience, but by their relationship with management. There is a
significant disparity in the quality of the classroom training provided
by station, as well as by which individual is conducting the training.
Online training programs are centrally created, thus ensuring the
level of quality of the information presented. However, the shift
toward more online training means that employees are left on their own
to review and interpret a significant portion of the curriculum. There
is currently no measurement in place to determine if the information
presented is understood or retained. The structure of the management
staff eliminated the need to be a Subject Matter Expert over the area
of supervision. Thus employees with questions have no supervisor to
whom they can turn. Employees are left to either form their own
interpretation or to seek out assistance from other employees thus
impacting their ability to meet mandatory production requirements.
The current training delivery process needs to be revamped so that
the quality of training takes priority over expedience.
Question 3(a): What is AFGE's assessment of the Training
Performance Support System (TPSS)?
Response: TPSS is again a centrally designed computer based
training program which requires individual employees to review and in
many cases interpret and apply information presented on their own.
While this training system has a built in system of testing the
understanding and retention of information, the utilization of this
system is inadequate. VBA has data which reports the failure of
stations to comply with the requirements associated with TPSS during
the initial training of new employees.
Management should more closely monitor utilization of the TPSS
training program.
Question 4: How often are VBA claims processors briefed or provided
feedback on the quality of their work?
Response: As a Journeyman RVSR I am only provided feedback on cases
in which there is an error of omission or commission. RVSRs are
continually provided feedback during the initial stages of training
leading up to the release to single signature authority. Following this
release to single signature authority, feedback is provided only in
cases containing an error or minimally during performance meetings with
supervisors.
Question 4(a): Are VBA claims processors required to complete
additional training based upon poor work quality according to the
Systematic Technical Accuracy Review (STAR) quality ratings?
Response: The current VBA claims processor training at VARO Winston
Salem is not tailored to effectively utilize findings of the STAR
process. Training at this facility is a ``one size fits all'' approach
which does not take into consideration the knowledge gaps of employees.
When AFGE recommended that quality data for the past 12 month period be
reviewed for determination of trends and/or gaps in training,
management's response was that this would be too time consuming.
VBA's STAR review program is designed to be a training tool which
can identify the training needs of individuals as well as stations.
Data generated by the STAR review program should be used to
identify training needs of individual employees and stations.
Question 4(b): Does AFGE think that the quality of VBA claims
processing could be improved by dedicating more resources to retaining
experienced claims personnel?
Response: The current rate of attrition of VBA is a direct outcome
of ineffective training programs as well as the ever increasing
performance standards and complexity of the work required.
Experienced claims processing personnel are necessary if VBA
intends to reach the projected goals of ``No claim over 125 days old''
and ``98 percent quality.''
Experience lends itself to speed and quality of work produced.
Senior managers at VARO Winston Salem have been heard making the
statement: ``Any employee can be replaced, if they unable to do the job
assigned get rid of them and get someone in here that will work.''
Unfortunately, this attitude permeates management at VARO Winston
Salem, and it causes employees to face the realization that management
does not see them as a vital resource. That attitude by management
results in a decrease in morale and a desire to do only that which is
required to maintain employment, thereby, resulting in lesser
performance of the station as a whole and decrease in service to the
claimants. As the VARO Winston Salem is in the forefront of National
initiatives, this predicament affects more than the veterans and
dependents of North Carolina. Until management begins to change this
perception of the employees, there will continue to be large numbers of
senior employees who elect to leave the VA for employment opportunities
with other agencies and the private sector.
Management should change its perception of front line employees.
The Agency may also wish to consider retention bonuses for high
performing employees with greater than five years of experience within
their field.
Question 5: The Committee understands that VBA was slated to end
its contract with Human Resources Research Organization (HumRRO) on
September 22, 2010. What are AFGE's thoughts on VBA's certification and
testing program?
Response: The current VBA certification testing program does not
accurately reflect the ability of employees to perform the daily
functions required by their positions. Under the Claims Processing
Improvement staffing model, VSRs were specialized and worked only in
one aspect of the claims process. The certification testing for VSRs is
designed to take into consideration all phases of the claims process.
Testing VSRs on job functions that have not been part of their work
requirements inaccurately reflects the knowledge and experience of the
employee.
The current Certification examinations evaluate only the Journeyman
VSR; RVSR testing evaluates the level of knowledge at completion of
training as well as at the Journeyman level.
The approach of evaluating the level of knowledge at completion of
training should be implemented for both VSR and RVSR.
Question 5(a): Do deficiencies in training impact the results of
these tests?
Response: As stated, the current certification testing does not
accurately reflect an employee's knowledge and experience in the
performance of the claims process. This directly reflects deficiencies
in the claims processor training program currently utilized by VBA.
More specifically, much of the certification examination focuses on the
employee's ability to look up information in the reference material
versus the employee's understanding of the material being tested. As is
evident by the low pass rates of claims processors, employees are not
receiving adequate training to be able to meet the expectations of
management.
While AFGE does not support the concept of training employees to
merely pass an examination, we do support the training of employees in
such a fashion that the ability to pass the examination would be
inherent in the completion of this training. Management must review the
past certification testing and identify the areas of lowest
performance, and tailor the training to address these deficiencies.
Question 5(b): Have the certification process deficiencies been
corrected? Please elaborate.
Response: The deficiencies of the certification program have not
been properly identified by management. Based on past performance of
the employees, management has returned to the question banks and
reformulated questions. By this, management has been tailoring the
questions to meet the knowledge base of the employees versus tailoring
the training to address the deficiencies of the employee's knowledge.
Question 5(c): Is the VBA complying with certification requirements
as mandated in P.L. 110-389?
Response: Section 225 established the requirement for VBA to
provide for examination of employees and managers responsible for
processing VA compensation and pension benefit claims. This also
directed the Comptroller General to evaluate these training programs
and provide reports to Congress.
These examination processes have continued to be delayed in
implementation. There have been pilot testing of certification
examination of managers and Decision Review Officers, but
implementation of a standard testing has not been made.
Certification of the training of RVSRs has been implemented and is
mandatory for newly hired RVSRs. However, certification of Journeyman
RVSRs is only minimally being performed with no requirement of these
employees to certify.
VSR certification examination is linked directly to promotion to
the GS-11 level and is not performing the function of validating
training. There is no certification test required upon completion of
the initial training program as with RVSRs.
Decision Review Officers certification examination is not utilized
in the validation of the employees' ability to perform the functions of
this position. As with the VSR certification examination, employees
should certify prior to promotion to the DRO position.
As management continues to stress actions of management which are
provided for under 5 U.S.C. 7106(a) are outside of the Union's right to
know. Management has stressed that examination of management is outside
of their obligation to negotiate. As such, AFGE has limited information
on the certification program implemented for management. AFGE is only
aware of a pilot having been performed, but the implementation of a
standard certification program is not known.
Based on the limitations of the information provided in association
with the certification requirements, it would have to be determined
that VBA has failed in the requirements to meet the statutory
requirements as implemented by PL 110-389.
Question 6: What steps should VA take to improve its overall
training and testing program for VBA claims processors, managers, and
trainers?
Response: First, VBA must ensure that employees utilized in the
training programs have been adequately trained for providing training.
As was reported in the GAO report, only 1 in 4 trainers have received
formal training.
Second, VBA must begin to utilize the data available through the
STAR system to tailor training to address the deficiencies in knowledge
base of the employees.
Third, VBA must tailor the certification examinations to accurately
measure knowledge and experience, and utilize the results of past
examinations to tailor training to address the deficiencies as
identified through the results of the examinations.
Fourth, VBA must ensure that certification examinations are
properly administered during the life cycle of the claims processors.
By this, it is imperative that VBA certify the training of the
employees at completion of the initial training of the personnel, and
again at the Journeyman level. VBA must also ensure the certification
of DROs prior to promotion to this position.
Fifth, VBA must comply with the statutory requirement for
management certification. Management's current view is that it does not
have to comply with this requirement. More specifically, management
refuses to provide AFGE with results from management certification
exams. This attitude directly impacts the employees who serve under
them. AFGE needs these test results to ensure that all employees are
receiving adequate supervision. Employees who serve under certified
managers have the benefit of knowing their supervisors have proven
their knowledge and ability to perform the requirements of the claims
process. This affords employees greater comfort when dealing with their
managers on issues that arise during the claims process.
Finally, VBA must begin to increase the involvement of AFGE in the
development and implementation of the training programs in the initial
training phase as well as the continued training of claims processing
personnel. Until Management and Labor begin to collaboratively address
issues as directed by E.O. 13522--Creating Labor-Management Forums to
Improve Delivery of Government Services, the training program will
continue to flounder in mediocrity and fail to effectively address the
needs of the Agency and employees.
Committee on Veterans' Affairs
Subcommittee on Disability Assistance and Memorial Affairs
Washington, DC.
October 6, 2010
David E. Hunter, Ph.D.
Assistant Director, Cost Analysis and Research Division
Institute for Defense Analyses
4850 Mark Center Drive
Alexandria, VA, 22311
Dear Mr. Hunter:
Thank you for testifying at the House Committee on Veterans'
Affairs' Subcommittee on Disability Assistance and Memorial Affairs'
oversight hearing on, ``Examining the Training Requirements of Veterans
Benefits Administration Claims Processing Personnel,'' held on
September 16, 2010. I would greatly appreciate if you would provide
answers to the enclosed follow-up hearing questions by Tuesday,
November 9, 2010.
In an effort to reduce printing costs, the Committee on Veterans'
Affairs, in cooperation with the Joint Committee on Printing, is
implementing some formatting changes for material for all full
committee and subcommittee hearings. Therefore, it would be appreciated
if you could provide your answers consecutively on letter size paper,
single-spaced. In addition, please restate the question in its entirety
before the answer.
Due to the delay in receiving mail, please provide your responses
to Cecilia Thomas by fax at (202) 226-4691. If you have any questions,
please call (202) 225-9164.
Sincerely,
John J. Hall
Chairman
__________
November 5, 2010
INSTITUTE FOR DEFENSE ANALYSES (IDA) RESPONSES TO
QUESTIONS FROM THE COMMITTEE ON VETERANS' AFFAIRS
DISABILITY ASSISTANCE AND MEMORIAL AFFAIRS
SUBCOMMITTEE HEARING:
``Examining the Training Requirements of Veterans Benefits
Administration Claims Processing Personnel'' held on September 16, 2010
Question 1: In your testimony, you noted that there are no
nationwide rules for training factors. Do you believe that implementing
such nationwide regulations would enhance accuracy and timeliness of
adjudicated claims? Please elaborate.
Response: Our study did not address the effect of training
protocols on accuracy or timeliness of claims adjudication. The
training factors referred to in our report are a modeling tool used to
estimate the relative effectiveness of employees with different levels
of experience. We do not believe that accuracy or timeliness of claims
adjudication would be enhanced by instituting nationwide training
factors.
In our study, we note that in order to accurately forecast the
productivity of a particular staffing level, we must account for the
experience levels of the employees. Newly hired employees are not as
effective as fully trained employees. They spend a significant portion
of their time in classroom and on-the-job training, and are generally
less proficient in the performance of their tasks.
The metric we called training factors was developed to estimate the
relative claims processing effectiveness for different levels of
trainees. Rating Veteran Service Representatives (RVSRs) with at least
2 years of experience are considered in our model to be fully trained
and fully effective and are assigned a training factor of 100 percent.
Less experienced RVSRs are assigned a training factor less than 100
percent. In our model, RVSRs with less than 6 months experience are
assigned a training factor of 0 percent, those with 6-12 months
experience are assigned a training factor of 29 percent; and those with
1-2 years experience are assigned a training factor of 63 percent.
These training factors represent our estimate of the relative
claims production capabilities of each group of employees. They are
averages derived from typical production goals used at regional offices
for trainees. The actual production goals for individual trainees are
at the discretion of regional office management and are largely based
on demonstrated performance. Regulating training factors nationwide
would not be an effective tool to improve either the accuracy or
timeliness of adjudication claims.
Question 2: Based on what has actually happened in terms of growth
in the Veterans Benefits Administration's (VBA) inventory and in its
significant increase in hiring since your 2009 study, do you have any
new forecasts on VBA's production capacity?
Response: The IDA Assessment of Claims Adjudication Personnel
Requirements for the Veterans Benefits Administration was completed in
September 2009. We have not been asked, nor have we performed any
additional forecasts since the completion of the study.
It is important to note that there is a lag between the time VA
hires new raters and the time when they become fully effective. We
found the lag to be about two years. Thus, the effect on capacity of
raters hired in FY10 will not be fully felt until FY12.
It also should be noted that these projections of increases in
rating capacity are based on the assumption that the RVSRs are fully
utilized for claims processing. This assumption, though true during the
time of our study, may not continue to hold in the future. In
particular, RVSRs may not be fully utilized if there are insufficient
claims ready to rate. This could be due to a number of factors, such as
claims awaiting doctors' exams or service records, or a deficiency in
the number of Veteran Service Representatives (VSR) available to
prepare claims for rating. If this becomes the case, additional RVSRs
will not translate into increases in claims processing.
As noted in our report, a better methodology for predicting claims
processing personnel requirements (and the resulting production
capacity) is to model the flow of claims through the claims
adjudication process in a discrete event simulation model. Such a model
would simulate each of the processing stages (triage, VSR processing,
waiting for evidence, RVSR processing, promulgation, etc.) for
individual claims and use statistical distributions to estimate the
time required at each stage by claim type. To perform such an analysis,
the data required to develop the statistical distributions would have
to be collected over time. Such a data collection effort was not
possible in the time frame provided for this study.
The simulation approach would provide additional insight into the
process that the current modeling does not allow. For example,
bottlenecks in the claims production process could be easily
identified, allowing Department of Veterans Affairs (VA) leadership's
improvement efforts to be focused on the areas most likely to improve
the system. Additionally, the effect of potential solutions could be
tested and evaluated in the model prior to real world implementation.
These are just a few of the advantages that simulation, with the
appropriate input data, can offer the VBA.
Question 3: Based on your studies, including the Institute for
Defense Analyses study on Regional Office variances from 2007, do you
have any recommendations that you can offer on how VA might improve the
quality and accuracy of its production?
Response: Specific recommendations for improving quality and
accuracy of production were not made in any of our previous studies. We
are currently conducting a 3-year independent assessment of the VA's
Quality Assurance Program, in response to Section 224.c.1-2 of the
Veterans Benefits Improvement Act of 2008 (PL 110-389). The final
report from this study is due to Congress in October 2011.
Question 4: In your studies, what deficiencies did you find in the
Department of Veterans Affairs' (VA) claims processing paradigm, the
Claims Processing Initiative (CPI) model, that would best improve
accuracy, consistency, and help VA to get the claim right the first
time?
Response: IDA has not been asked to perform any studies that
directly analyze the CPI model. Therefore, we are not in a position to
comment on any deficiencies in the CPI model.
Question 5: You stated that Decision Review Officers (DROs) are
considered fully effective at the start of their terms. However, your
2009 study projected that the efficiency of DROs are not expected to
grow in the near future. Based upon this assessment, do you recommend
that VBA offer DROs additional specialized training to help them become
more efficient?
Response: DROs are senior personnel usually hired from the pool of
experienced RVSRs. In our study, we assumed that, unlike VSRs and
RVSRs, DROs are not required to undergo a lengthy training process. We
consider all DROs to be equally effective--a DRO with 1 year of DRO
experience is considered as effective as a DRO with 15 years
experience. For this reason, we do not consider DRO experience levels
when projecting their claims production capacity.
Our projection of DRO capacity showed no increases in the future
due to our modeling assumption of no future growth in the number of
DROs. Rather than specialized training, to increase the DRO claims
processing capacity, we concluded that an increase in the total number
of DROs is required.
Committee on Veterans' Affairs
Subcommittee on Disability Assistance and Memorial Affairs
Washington, DC.
October 6, 2010
Michael Cardarelli
Acting Deputy Under Secretary of Benefits
Veterans Benefits Administration
U.S. Department of Veterans Affairs
810 Vermont Avenue, NW
Washington, DC 20420
Dear Mr. Cardarelli:
Thank you for testifying at the House Committee on Veterans'
Affairs' Subcommittee on Disability Assistance and Memorial Affairs'
oversight hearing on, ``Examining the Training Requirements of Veterans
Benefits Administration Claims Processing Personnel,'' held on
September 16, 2010. I would greatly appreciate if you would provide
answers to the enclosed follow-up hearing questions by Tuesday,
November 9, 2010.
In an effort to reduce printing costs, the Committee on Veterans'
Affairs, in cooperation with the Joint Committee on Printing, is
implementing some formatting changes for material for all full
committee and subcommittee hearings. Therefore, it would be appreciated
if you could provide your answers consecutively on letter size paper,
single-spaced. In addition, please restate the question in its entirety
before the answer.
Due to the delay in receiving mail, please provide your responses
to Cecilia Thomas by fax at (202) 226-4691. If you have any questions,
please call (202) 225-9164.
Sincerely,
John J. Hall
Chairman
__________
Questions for the Record, The Honorable John J. Hall, Subcommittee on
Disability Assistance and Memorial Affairs, House Committee on
Veterans'
Affairs, ``Hearing on Examining the Training Requirements of Veterans
Benefits Administration Claims Processing Personnel,'' September 16,
2010
Question 1: I understand that the Veterans Benefit Administration
(VBA) employs approximately 14,000 claims processors, how many claims
processing managers and trainers are on VBA's staff?
Response: VBA currently has 732 claims processing managers. From FY
2008 through FY 2010, 1,642 VBA employees have attended a VBA-sponsored
instructor course. Our goal remains to provide every field employee
identified as a potential instructor an opportunity to receive
instruction on design and delivery of training.
Question 1(a): What is the manager to claims processor ratio
nationally?
Response: There is one claims processing manager for approximately
every 19 claims processors.
Question 1(b): List the descriptions of all claims processing staff
members and the total number of employees designated in each position
(e.g., number of VSRs, RVSRs, and Decision Review Officers (DROs)).
Response: As of November 5, 2010, VBA had 7,748 Veterans service
representatives (VSRs), 2,734 rating Veterans service representatives
(RVSRs), and 536 decision review officers (DROs). VSRs develop for
evidence and process compensation awards. RVSRs determine whether a
claimed disability is service connected and, if so, what amount of
compensation is appropriate based on rating schedule regulations. DROs
review and attempt to resolve appealed decisions.
Question 2: The Committee staff has reviewed the training
requirements for VBA claims processors. Does VBA have similar training
requirements for its claims processing managers and supervisors? Please
detail the training program for VBA claims processing managers and
supervisors.
Response: VBA has a standardized National Training Curriculum for
its claims processing managers and its supervisors. Additionally, we
are currently utilizing the FY 2009 Veterans Benefits Administration
Core Technical Training Requirements (CTTR) for VBA Managers and
Supervisors. Regional office directors and assistant directors have an
80-hour annual training requirement, while training managers and
support services division chiefs have an annual requirement of 40
hours. The division chief, assistant division chiefs, coaches and
assistant coaches have a 16-hour annual training requirement. Stations
are not limited to the minimum required number of hours and can always
provide any additional training they feel is pertinent for enhanced job
performance. For the purpose of the National Training Requirement, both
new and experienced supervisors must select topics from the VBA
National Training Curriculum list to complete their minimum
requirements.
Question 3: What is the training regimen for VBA trainers? How are
they selected and is there a dedicated cadre of training personnel?
Response: The training regimen for VBA trainers includes at least
one of four VBA-funded venues for employees selected to be trainers:
1. Up to 180 employees annually attend VBA's one-week
Instructor Development Course at the Veterans Benefits Academy
in Baltimore, Maryland, where they learn characteristics of
adult learners, principles of training development, and
presentation skills. Each course participant presents three
lessons as practical application and has an opportunity to
receive constructive feedback from the course instructors and
other class participants. The feedback includes a videotape of
their presentations to reinforce feedback. The Instructor
Development Course is used to prepare employees as instructors
for Challenge Centralized Training, which is entry-level
training to teach VSRs and RVSRs the basic skills of their
jobs.
2. Up to 300 employees annually attend VBA's Basic Instructor
Clinics delivered at their regional offices. Basic Instructor
Clinics provide an eight-hour block of instruction focused on
creating learning objectives, techniques for interaction, and
training evaluation and presenting training content. Basic
Instructor Clinics are used to prepare employees to deliver
instructor-led training within the regional offices to both new
and experienced employees.
3. Up to 120 employees annually attend VBA's Training and
Performance Support System (TPSS) Training Coordinators Course.
In this ten-day course, participants learn how to guide new
employees in the use of VBA's TPSS using cooperative learning
with teams of new employees. The Training Coordinators Course
is used to provide each regional office with employees who are
familiar with the TPSS training materials, how to effectively
employ cooperative learning with small teams, and how to record
students' successful practical applications in the learning
management system.
4. In addition to the instructor courses, trainers selected to
deliver claims processor training to new employees as part of
Challenge Centralized Training also receive curriculum-specific
instructor standardization training so they understand how to
effectively use the training materials and practice cases
developed for centralized training.
Regional office directors select VBA trainers and nominate them for
courses listed above. Trainers are selected based upon expertise in
their jobs and willingness to teach others. Employees who learn
instructional skills through one of VBA's courses often use those
skills to present classes to experienced personnel within the regional
offices.
VBA does not have a dedicated cadre of instructors for teaching
claims processors. VBA uses employees who are engaged daily in the
business of processing Veterans' claims and are current in practices
and procedures. VBA uses the dedicated staff of the Compensation and
Pension (C&P) Service to provide Challenge instructor standardization
training, and to oversee Challenge classroom instruction. VBA also has
a full-time staff to operate its major training facility at the
Veterans Benefits Academy.
Question 3(a): How many employees are VBA trainers generally
required to train?
Response: The number of employees that VBA trainers are generally
required to train varies based on the method of instruction and the
type of student population.
Instructors of new claims processors in Challenge Centralized
Training typically teach at a ratio of seven students to each
instructor. Using this student-to-instructor ratio, teams of three to
six instructors are assigned to classes of eighteen to forty students.
With multiple instructors, students have easy access to expert
assistance and quick review of their performance in classroom
exercises.
Training of new employees using TPSS is normally performed in teams
of three students with a TPSS Training Coordinator as the instructor/
facilitator. Depending upon other job tasking and the number of new
employees enrolled in TPSS, Training Coordinators may guide multiple
teams simultaneously through TPSS lessons.
Training of experienced personnel occurs in both small and large
groups depending upon the topic, the population being trained, and the
method of instruction selected by the regional office. Consequently, a
single instructor may lecture 20-30 employees simultaneously or may
instruct a group of less than ten employees when high levels of
interactivity are necessary, such as teaching the use of computer
applications or teaching with practical applications to reinforce
learning.
Question 4: Is there a quantitative/empirical relationship between
VBA training requirements and national claims processing goals, such as
on quality and accuracy? Please elaborate.
Response: VBA does not have data on quantitative or empirical
comparisons between training requirements and specific results
pertaining to national goals for quality and accuracy. VBA considers
various elements when determining training requirements, and quality is
our primary objective in these decisions. Data from the previous fiscal
year on national quality drives the topics to be considered when
identifying training requirements. Information derived from reviewing
quality data for regional offices and discussions with training
managers are also taken into consideration. The primary focus is to
ensure the correct training is being administered from both the
national perspective as well as what is applicable for each individual
office.
In conjunction with reviewing quality data, compliance with
mandated training is reviewed utilizing Learning Management System
(LMS) Learning History reports. During the past year, evaluation tools
were established to obtain feedback from the regional office employees.
These evaluations are being reviewed to identify any potential training
trends that may be hampering effective instruction and subsequent
claims processing quality.
VBA strives to recruit and select candidates for claims processor
positions that meet the experience, knowledge, skill, and ability
requirements necessary to successfully perform in these positions. VBA
makes every effort to provide employees with the opportunity to develop
and demonstrate their proficiency. VBA's comprehensive national
training plan is designed to continually build upon previous knowledge
and provide new training for legislative changes and improvements in
our business processes. The combination of recurring training and
technological improvements will result in a streamlined process that is
more efficient, timely, and accurate.
Question 4(a): What is the correlation between the VBA training
requirements and VBA's national goals of processing claims within 125
days with 98 percent accuracy and breaking the back of the backlog by
2015?
Response: Ongoing training improvements and Systematic Technical
Accuracy Review (STAR) will help VBA reach Secretary Shinseki's goals
of eliminating the disability claims backlog by 2015 and of processing
disability claims so no Veteran has to wait more than 125 days for a
quality claims decision (98 percent accuracy rate).
VBA is taking steps to improve training for claims processing staff
through a comprehensive national training program. This training
program includes pre-requisite, centralized, and home-station training
phases. The integration of a national training program has resulted in
standardized training modules for all phases of claims processing.
Additionally, VBA created training modules for recurring training for
journey-level claim processors. This national training program will
allow VBA to increase both accuracy and production as employees
continue to increase their individual knowledge and proficiency.
The primary mission of C&P's STAR program is to address quality
issues. The C&P Training Staff analyzes error trends and incorporates
them in the Core Technical Training Requirements (CTTR) mandatory
topics for regional offices.
Question 5: Are VBA claims processors, and their managers,
penalized if annual training requirements are not met? How are these
training requirements enforced? Conversely, are there any incentives
for completion?
Response: VBA's managers are responsible for ensuring that the
minimum requirement of 85 hours per year is met by claims processors.
Training requirements were recently written into VSR Performance Plans,
and VBA plans to incorporate training requirements into other claims-
processor performance plans.
VBA has improved its training oversight methods to increase
accountability. Managers at all levels are held accountable for their
subordinates' training requirements. If employees do not meet the
requirement of 85 hours per year, it is reflected in both the managers'
and employees' performance evaluations. In 2008, VBA created the
position of Training Manager for each regional office. The Training
Manager uses LMS to track training and ensure each regional office is
compliant with requirements. Training Managers work with regional
office management to supervise the completion of training. While there
are currently no national incentives in place to motivate employees to
complete training requirements, completion of the mandatory training is
required for each claims processor. Failure to complete required
training is reflected in both the manager's and the employee's year-end
performance.
For employees who seek to increase their knowledge and develop
additional non-technical skills, courses are now available through the
VA's new ``ADVANCE'' program. This program supports the development of
employees in areas such as critical thinking, effective team
operations, written communications, and change management.
Question 6: Many of the hearing witnesses testified about premature
decision-making, particularly the under-evaluation of mental conditions
and inferred conditions, contributing to VBA's high claims processing
error rate. They also discussed VA's failure to identify error trends
by aggregating and analyzing data collected from Systematic Technical
Accuracy Review (STAR) and Inter-Rater Reliability Reviews. The VA
Office of Inspector General (OIG) has indicated similar findings in its
Regional Office Reports. As such, what steps is VBA taking to address
these critiques by identifying major error patterns and generating
interactive trainings to end these error patterns?
Response: VBA identifies major error patterns through a rigorous
quality assurance program managed by the C&P STAR staff in
collaboration with the C&P Training Staff. Analysis of STAR error
trends led to the inclusion of mandatory training topics in the CTTR
for the regional offices for FY 2011. The C&P Service Training Staff
uses the results from these types of studies and a monthly analysis of
error patterns identified by national accuracy reviews to generate
interactive training lessons for claims processors.
For example, in October 2009, a new training lesson was created on
the topic of establishing service connection for Posttraumatic Stress
Disorder and Other Mental Disorders. Additionally, a new training
lesson on Inferred Issues was posted to the C&P Service Training
intranet site in December 2009. These courses are mandatory lessons
that must be completed as part of the CTTR hours for RVSRs.
Question 7: Several hearing witnesses have testified about how the
VBA's over-emphasis on production deadlines, manifested in work-credit
performance requirements, often hinders claims processors from
completing training requirements and ultimately leads to avoidable
claims processing errors. How does VA plan to address this concern?
Response: Employee training is a top priority for VBA. Each year,
VBA sets a requirement for training hours to be completed with relevant
training materials specific to that employee's job. Regional office
directors are held accountable if their employees do not reach the
annual content and hour requirements. Failure to complete required
training is reflected in year-end performance appraisals for both the
regional office management staff and the employees.
Question 7(a): Is the VBA exploring additional mechanisms for
incentivizing prompt yet quality performance by VBA claims processors?
Response: VBA is constantly striving to improve our quality and
timeliness to better serve our Veterans. In addition to work standards
that mandate an employee to perform at set levels of both quality and
production, VBA has several award programs at a National level to
recognize employees providing outstanding service within their regional
offices. Some of the awards VBA currently provides are: Special
Contribution Awards, On-the-Spot Awards, and Quality Step Increases
(QSI). Regional offices currently provide Special Contribution Awards
to employees who have contributed to the goals and mission of the
regional office above the standard level required by their position.
On-the-Spot awards are given to recognize exceptional courtesy and
responsiveness that results in high quality service to Veterans. A QSI
is an increase in an employee's basic rate of pay, which can be
provided to an employee in recognition of excellence in performance
during the last appraisal year.
A recent example of a new mechanism created to inspire prompt and
quality work is the ``Who's Who'' list, which recognizes VSRs and RVSRs
that obtain an outstanding level of both quality and production. This
incentive program will both motivate employees that are not meeting
their current goals as well as reward employees that are providing
outstanding service to Veterans.
Question 8: VA currently has over 30 claims processing related
pilots underway. Is VBA seeking to harness best practices from these
pilots by offering its claims processing staff training based upon the
lessons learned from these studies?
Response: VBA is capturing the best practices gleaned from our
claims processing initiatives. Many of VBA's claims processing
initiatives are still in the pilot phase; however, based on their
initial success, VBA nationally implemented five of these initiatives.
For nationally implemented initiatives, we provided comprehensive
training to our claims processing staff based on the lessons learned
during each initiative's pilot phase. We conducted the training using a
variety of methods, including live meetings, teleconferences, and
written instruction.
As we continue with our pilots, we recognize the importance of
capturing critical techniques and processes for inclusion in our
training program. VBA leadership and regional office management
continue to ensure all personnel have sufficient knowledge of
performance expectations stemming from each initiative; associated
training, tools, and resources; and proper oversight to ensure
successful transformation. VBA's training curriculum is continuously
updated to incorporate legislative and regulatory changes as well as
new initiatives and technological advances. We currently require at
least 85 hours of refresher training annually for experienced
employees. Ongoing training is essential to maintain a high performing
workforce.
Question 8(a): While I am excited by the innovative thinking, I am
concerned about whether these pilots are leading to improvements in
quality and consistency of the claims process. What is VA's strategic
plan for utilizing the lessons from these studies to improve training,
if any?
Response: VBA's Strategic Plan for FY 2010-2014 states that, ``VA
will recruit, hire, train, develop, and retain a diverse VA workforce
to meet current and future needs and challenges.'' VBA invests a
tremendous amount of resources to ensure its employees are well trained
and able to provide the best service possible to Veterans. Part of our
strategic planning for the initiatives is the requirement to capture
the critical lessons learned during the pilot phase to help improve
VBA's training programs. It is especially critical to capture the
lessons learned for pilots identified for national implementation; VBA
ensures the initial lessons are captured in subsequent training for the
field.
Prior to the national deployment of these pilots, we completed a
comprehensive training program to ensure our claims processing staff
fully understood the new process or capability being fielded and the
value it added to their work. This training incorporated the lessons
learned from the pilot phase. For example, in coordination with VHA, we
recently fielded three Disability Benefits Questionnaires. Working
collaboratively with the Veterans Health Administration (VHA), we
developed a comprehensive training plan, to include a short video, and
over a period of several weeks, presented the training to both VHA and
VBA staff. This is just one example of the importance we place on
training our staff to ensure we meet the Secretary's quality goal for
2015.
Question 9: What efforts are being undertaken by VBA to determine
the types of activities all regional offices should and should not
count toward completion of annual training requirements?
Response: A Fast Letter addressing training requirements for FY
2011 is expected to be released to the field by December 1, 2010. VBA
has mandated that 85 hours will be dedicated to training each VSR/RVSR.
Forty of these hours have topics and specific training material
identified which will address new guidance to the field and national
quality issues. This block of training is referred to as mandated
training. The remaining 45 hours are split, with 20 hours of electives
from a national technical curriculum of additional topics addressing
the station's quality and 25 hours of station-determined topics that
included courses required of all VA employees. For technical training
to count toward the employee's annual requirements, the training must
have utilized lesson material available on the C&P training Web site
and must be documented in LMS.
Question 10: When will the VBA's Veterans Benefits Management
System (VBMS) be fully and formally launched?
Question 10(a): Upon its launch, will VBMS be capable of
identifying error trends and providing timely notice to managers of
need for corrective training correction, and if so, how? Is the
development of VBMS on track?
Response: The development of VBMS is on track, and we will have a
monitoring process in place to be able to identify trends and provide
feedback to managers.
In FY 2010, the VBMS initiative began with development of the
Virtual Regional Office (VRO). The VRO concept involved subject matter
experts (SMEs) working with a vendor to develop business requirements
and detailed specifications. The vendor used the input from SMEs to
create a graphical user interface, which became a means of validating
the requirements as well as building the front-end interface for the
business user.
VA will deploy the first iteration of VBMS software for testing at
a site, the Providence Regional Office, in November 2010. Claims
processors at the Pilot I site will use the new software to validate
and harden the business requirements, as well as to generate new
business requirements for future software releases. Pilot 1 will
utilize a new electronic claims repository and scanning solution, as
well as new claims processing software, which will integrate with
existing core business applications (VETSNET) that support claims
processing.
VBMS will be released incrementally through three pilots prior to
nationwide deployment of full system capabilities. This iterative
approach will allow claims processors to provide real-time input into
the development of the application, as well as improved business
processes. The use of Agile development will enable VBA to respond
rapidly to new requirements, such as those captured from nationwide
initiatives. VBMS will help VA eliminate many errors caused today as a
result of the dependence on paper moving through the claims process.
Additionally, VBMS, once fully developed, will provide managers the
information needed to identify trends and areas where additional focus,
business process improvement, and training may be needed to improve
service delivery to Veterans.
Question 11: What training is provided to the VBA's fiduciary
division personnel? Is it structured like the VBA's Training and
Performance Support System (TPSS), how is it different, how is it the
same? What is being done to integrate this business function in VBA
performance and accountability metrics?
Response: National training for the fiduciary program was developed
and implemented beginning in March 2010. This training is comprehensive
and provides 36 hours of on-site instruction to all positions within
the fiduciary activity staff. Thus far, on-site training by
Headquarters' staff has been conducted at 13 regional offices and the
fiduciary hub. A TPSS module currently exists for the position of field
examiner, and a TPSS module is being developed for the legal instrument
examiner position, with implementation anticipated in FY 2011.
VBA's fiduciary program has also enhanced its internal Web site to
include training materials. National teleconferences are held monthly
to provide training and disseminate information on areas requiring
attention as identified by program staff.
The C&P Fiduciary Staff conducted a Fiduciary Manager's Training
Conference in June 2010 to provide in-depth training on workload
management, misuse of funds, accounting follow-up, field examinations,
surety bonds, and other fiduciary topics. A similar conference is
scheduled for April 2011 to address these and other topics with the
field examiners.
Question 12: The Committee understands that VBA was slated to end
its contract with Human Resources Research Organization (HumRRO) on
September 22, 2010. Did this contract end, and if so, what has been the
impact of this change? What services did HumRRO offer?
Response: The contract with HumRRO ended, and a new contract
commenced with Camber Corporation on September 27, 2010. An initial
meeting was held on October 6, 2010 with VBA management, VBA
contracting staff, and Camber's team assigned to work on this contract.
The only significant impact from changing contractors is the time
limit in administering the first Skills Certification Test. The
contractor is allowed 180 days to deliver the first task,
administration of the RVSR Skills Certification Test. C&P has stressed
to Camber that the RVSR Skills Certification Test is a priority due to
the requirements of administering the four Skills Certification Tests
by the end of FY 2011.
Question 12(a): Has VA fully undertaken the certification
requirements as outlined in P.L. 110-389? Please elaborate.
Response: VA continues to follow the requirements outlined in PL
110-389, by administering tests for each position handling a Veteran's
claim. Currently, we have skills certifications for VSRs, Pension
Management Center VSRs, basic RVSRs, journey RVSRs, DROs and coaches.
We have also informed Camber of the possibilities for additional skills
certification tests for other positions, which may come about during
the contract period, September 27, 2010 through September 26, 2015.
Question 13: How do the VBA training requirements affect the
certification testing outcomes for VSRs and RVSRs? Do they help with
success/failure rates? Are there any correlations? When will VA
implement testing of DROs and claims processing supervisory staff?
Response: VBA training increases success rates on skills
certification tests because it provides the required skills, knowledge,
and abilities for each participant to successfully pass his or her
certification test. A Skills Certification Readiness Guide is available
on the training Web site, which references such as regulations,
directives, and job aids to review in preparation. Under the newly
awarded contract, Camber will prepare an on-line preparatory tool,
which will provide access to information about certification testing
and an application that facilitates preparation by permitting practice
with items similar to those on the test. This Web site will be
accessible within VBA.
The Skills Certification Operational Test for supervisory VSRs
(coach level) and DROs has been completed. Testing was held on January
13, 2010 for coaches and June 16, 2010 for DROs. Both tests are
considered fully implemented, and VBA plans to offer each test twice a
year.
Question 14: The VA OIG has noted in many of its Regional Office
(RO) Inspection Reports, most recently in the Nashville Inspection
Report, that VA should have a more objective, systematic, and
disciplined approach to rotating personnel under the CPI model. The
VBA's current CPI implementation plan indicates that VBA personnel
should be rotated to handle peak workloads (i.e., where experienced
VSRs will rotate from specialized teams to another) at least once every
2 years. As such, what is VBA doing to ensure that this rotation occurs
in all ROs so that VBA personnel can maintain and improve their skills
for optimal claims processing competency?
Response: The Claims Processing Initiative (CPI) model is directed
by VBA manual M21-1MR, Part III, subpart i chapter 1. All regional
offices follow this model unless a deviation is approved as outlined in
VBA Letter 20-04-29. Overall, control and timely claims processing are
considered first before rotation of VSRs. Local management has
discretion on actual rotational schedules. The procedures governing the
VSR Certification Test encourages rotation and cross training of
employees. Regional offices also incorporate local special missions and
emerging national concerns when determining employee rotations. VBA is
continually reviewing workload-management processes to identify best
practices and determine if adjustments to the CPI model will result in
increased quality and productivity.
Question 15: The Institute for Defense Analyses (IDA) notes in its
2009 Report (P-4471) that VBA developed a Capacity Model in 1998-1999
to determine the VBA's claims production capacity. Would you elaborate
on the inputs in this model and how it determines employee
effectiveness? Has it changed or been updated since 1998/99 (e.g.,
experience vs. equivalent effectiveness)?
Response: The Capacity Model was developed in 1998 and 1999. The
model compared expected man-hours with estimated available man-hours,
and if the latter exceeded the former, there was enough capacity to
cover the work. It assumed all fully trained employees were available
to work 1,502 hours per fiscal year and incorporated time for standard
leave, administrative absences, training, and development. RVSRs and
VSRs were considered fully trained after two years and one year of
employment, respectively.
Since the initial tasking in September 1998, the model has changed.
It initially forecasted the number of Veterans submitting and
resubmitting disability compensation claims over six future fiscal
years. The updates to the model forecasted claims received, completed,
and pending over a seven-year time period. With a July 2005 update, the
name of the model changed to Workload Forecasting Model and added the
capability to display yearly forecasts as well as monthly levels. The
last follow-on task to the VBA Workload Forecasting Model by IDA was
delivered in June 2007. It added features to print from the
application, calculate full-time FTE needed to complete a user-
specified number of claims, forecast for average days pending and
average days to complete, determine employee effectiveness, and explore
new performance metrics for VBA.
Question 16: What guidance does VBA offer its claims processing
supervisors to ensure that ROs record training activities consistently
in the VA Learning Management System (LMS) so that LMS-collected data
is reliable?
Response: To ensure that regional offices record training
activities consistently in the LMS, VBA guidance to supervisors in FY
2011 specifies hourly training requirements for claims processors and
lists of topics to be trained within the hourly training requirements.
The guidance includes the LMS item numbers for recording training
completions and directs the use of standardized training materials
published by C&P Service.
Question 17: The Government Accountability Office (GAO) indicated
in its testimony that VBA claims processing training quality has
declined over the past 2 years. How did VBA determine the number of
hours required for its claims processing personnel? Has VBA assessed
the adequacy, appropriateness, and efficiency of this requirement? If
so, what where the results?
Response: VBA has established total training hour requirements
based on historical experience. Training needs are reviewed
periodically and revised as necessary. While VBA has not specifically
assessed whether 85 hours (the actual requirement) is the optimum
amount of training time, recent evaluations by field office personnel
indicate the training that claims processors are now receiving is
useful, relevant, and worthwhile.
GAO recommended VBA implement an evaluation process to gather
feedback from experienced claims processors regarding the usefulness,
relevance, and quality of training they receive. VBA fielded an on-line
evaluation tool in February 2010 to collect evaluations submitted by
C&P claims processors on the usefulness, relevance, and quality of
national training received in field offices.
With 25,614 anonymous responses since March 2010:
91 percent of respondents considered training at
least moderately useful
91 percent of respondents considered training
relevant to their jobs
88 percent of respondents are confident they can
apply the training to their jobs
91 percent of respondents considered worthwhile the
requirement that they complete the training
Beginning in FY 2011, regional offices must dedicate a minimum of
60 hours of the required annual training hours to addressing national
quality error trends. Forty hours of this training are identified by
specific required topics and assigned training curriculum based on
national quality trends and emerging issues. Each regional office
selects an additional 20 hours of training based on local quality
trends from curriculum available on the C&P training Web site.
In FY 2010, C&P Service addressed this issue by determining that at
a minimum, half of the required annual training hours would be
dedicated to addressing national quality trends. Upon review of local
quality data and discussions with regional office personnel, VBA
increased the hours dedicated to training on quality issues to a
minimum of 60 hours for FY 2011. Forty hours of this training are
identified by specific required topics and assigned training curriculum
based on national quality trends and emerging issues. Each regional
office selects an additional 20 hours of training based on local
quality trends from curriculum available on the C&P training Web site.
Question 18: GAO surveys indicated a real need amongst staff for
more effective training on appeals and remands. What is the VBA doing
to meet this need?
Response: C&P Service's Training Staff is implementing a new
curriculum for appeals and remands. This curriculum is being developed
in collaboration with members of the Board of Veterans' Appeals and
will provide a range of technical lessons that can be utilized by any
member of the appeals team. A sample of regional offices was contacted
to accomplish a needs assessment, and the C&P Training Staff is
creating an appeals curriculum based on their feedback. As lesson
material is completed, it will be accessible for all regional offices
on the C&P Training Web site.
The C&P Training Staff also formed a subcommittee to provide
recommendations on courses to be reformatted in our Training and
Performance Support System and Electronic Performance Support System
learning tools. The staff decided that certain lessons may need to be
offered in more that one format, such as self-instructed and in person.
A standard evaluation form is being developed, and C&P Staff will
consolidate the responses and communicate the results to the regional
offices. These results, in conjunction with national quality errors,
will have an impact on our selection of the appeals topics as well as
any needed technical updates to the material.
Question 19: Do Fast Letters count as training in all 57 ROs? How
does VA get the latest information to all of its VBA field offices?
Response: During FY 2010, training on fast letters counted if the
training was recorded with sign-in sheets. During FY 2011, fast letters
that have associated facilitated training sessions will be released
with an assigned LMS number. These fast letters are reflected as
acceptable training on the C&P Training Web site under the mandatory
training curriculum. Determination of which fast letters count towards
training will be based on meeting the requirements defined by the soon-
to-be-released Standard Operating Procedure for VBA National C&P
Curriculum.
In addition to fast letters, VBA shares information with regional
offices through other venues such as weekly conference calls with
Regional Office Directors and management staff, monthly Training
Manager and Training Coordinator calls, and Veteran Service Center
Manager calls.