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					                            Proposal by
                    Veterans for Common Sense


                                      to


      Place Veterans Benefits Administration Claims
  Adjudication Staff at All Veterans Health Administration
                          Facilities




                                October 19, 2009




Contact Information:
Veterans for Common Sense
Post Office Box 77304
Washington, DC 20013
Phone: (202) 558-4553
E-Mail: Paul@VeteransForCommonSense.org
Web Site: www.VeteransForCommonSense.org
  Veterans for Common Sense: Bring VBA Services to Our Veterans


         Bring VBA Services to Our Veterans and Families
October 19, 2009 – Veterans for Common Sense (VCS) believes the Veterans Benefits
Administration (VBA) should significantly increase the number of VBA offices in each
state in order to provide friendly face-to-face assistance for our Veterans and their
families with the fastest access to important documents and VBA decision makers.
Using a carefully designed plan, VBA facilities of differing sizes can be opened over
several years throughout the United States that will finally bring VBA services to our
Veterans and families. After full implementation, this policy can result in a “win-win” for
both Veterans and VBA by streamlining the process and improving Veteran-VBA
relations.

VCS has provided this information to the Presidential Transition Team in 2008, and to
the Department of Veterans Affairs’ Advisory Committee on Disability Compensation in
2009.


Issues Facing Veterans
VBA maintains 58 regional offices, usually one per state, to provide non-medical
benefits assistance to 23 million Veterans and their families. VBA is frequently seen as
an isolated and inaccessible agency because nearly all communication between VBA
and Veterans remains through the mail through impersonal, complicated, and quasi-
legal letters.

A single VBA regional office far away often prevents our Veterans and their families
from obtaining friendly face-to-face assistance from VBA, submitting documents to VBA
in a timely manner, and promptly scheduling required medical examinations.

The centralization of work at a few VBA regional offices, with promises of economies of
scale and expertise, has not resolved VBA’s ever-increasing claims backlog, according
to several recent government investigations.

The inventory of incomplete claims of all types still under review continues escalating
sharply, especially at the Board of Veterans Appeals (BVA), where it is nearly 200,000,
and the average wait time for a decision is four years.

In December 2008, a total of 809,000 Veterans’ claims of all types were backlogged,
including appealed claims. As of September 2009, the backlog grew to more than
956,000. In December 2008, on average, Veterans waited more than six months for an
initial benefit decision from VBA. The average wait is improving slightly, but not
significantly, and now stands at less than six months in August 2009.




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  Veterans for Common Sense: Bring VBA Services to Our Veterans


Based on these significant systemic challenges, a new approach to improve how
Veterans access VBA is urgently needed.


Restructuring Proposal for VBA
VBA should gradually increase the number of VBA offices in each state in order to
provide face-to-face assistance for our Veterans and their families with the fastest
access to important documents. Using a carefully designed plan, VBA facilities of
differing sizes can be opened over several years at these locations:

1. Existing Veterans Health Administration (VHA) facilities, including Medical Centers,
Outpatient Clinics, and Community Based Outpatient Clinics

2. Existing VHA Vet Centers operated by Readjustment Counseling Service

3. Existing Department of Defense military installations, including facilities for active
duty as well as National Guard and Reserve

4. Other population centers identified by VA without an existing VHA or DoD facility.
VBA can use the already scheduled opening of new or larger VHA facilities to test this
restructuring proposal of adding more full-time VBA claim processing staff at VHA
facilities.


Precedent for Restructuring VBA
There are three historical precedents for restructuring VBA facilities and significantly
expanding outreach.

First, during the Clinton Administration, VA Under Secretary for Health Ken Kizer
successfully revolutionized the delivery of healthcare to our Nation’s Veterans by
opening hundreds of local VA healthcare facilities. Instead of a single urban-based
medical center focused heavily on in-patient care, Kizer envisioned and implemented a
new system to improve access for Veterans by opening more than 800 community
based outpatient clinics located in suburban and rural areas.

We propose a similar structural overhaul of VBA so all VA services can be brought to as
many Veterans as possible. This would replace the existing consolidated single
regional office in each state that is often highly resistant to change due to size and
complexity. If the Kizer model worked for VHA, then decentralization should be tried for
VBA.

Second, the Social Security Administration operates 1,400 offices providing face-to-face
benefits assistance. In a manner similar to SSA, Veterans should be allowed to retain



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  Veterans for Common Sense: Bring VBA Services to Our Veterans


counsel at meetings and have access to in-person due process at the local level without
travelling hundreds of miles. Quality and timeliness are superior at SSA than VBA, and
customer relations have significantly improved at SSA since the number of field offices
expanded.

Third, during and after World War II, VA placed employees aboard troop ships returning
to the U.S. in order to brief soon-to-be Veterans about transition issues such as
healthcare, disability benefits, home loan guaranty programs, and educational
assistance under the highly popular GI Bill. The earlier our soon-to-be Veterans learn
about and focus upon VA’s wide array of highly successful readjustment programs, then
the earlier and more successful their reintegration into society may be.


Resolving VBA’s Serious Systemic Problems
This proposal assists with resolving two key problems VBA faces when processing
Veterans’ disability compensation and pension claims as well as applications for other
benefits, such as home loan guaranty, education benefits, vocational rehabilitation, and
life insurance. In addition to a complex and often adversarial process, VBA’s two main
time-consuming problems are gathering evidence and completing medical exams in a
timely manner.

First, gathering evidence from the military and the Veteran is the most time-consuming
part of the process (averaging nearly five months). The one positive exception is active
duty service members who process their claim using the Benefits Delivery at Discharge
(BDD) program, which has an average processing time of 55 days. This proposal
expands BDD by placing full-time, permanent VA resources for all VA benefits at nearly
every military point of discharge.

In a related manner, VHA uses an easy one-page healthcare enrollment form. VBA
should consider streamlining the current 23-page disability compensation claim form to
one or two pages for use at BDD locations where most military service and military
medical records are easily available. We believe it is unreasonable to ask Veterans
with traumatic brain injury (TBI), post traumatic stress disorder (PTSD), or other serious
medical conditions to complete such a lengthy form when the military already
possesses the information the VA seeks. This is why we also support President
Obama’s efforts to create a single medical record for each service member that can be
used by both DoD and VA.

Second, another step in the claim process that increases delays remains the difficulty
obtaining a prompt appointment for a Compensation and Pension (C&P) medical exam.
This proposal brings VBA benefits staff alongside VHA medical staff to assist our
Veterans with “one-stop shopping” for nearly all VA services, including C&P exams.




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  Veterans for Common Sense: Bring VBA Services to Our Veterans


“One VA” is what our Veterans expect, as few are aware of the difference between VBA
and VHA and the delays caused by transferring large amounts of paper records through
the mail among VBA, VHA, Veterans, and Veterans’ advocates assisting Veterans.

In a related manner, we also support the universal implementation of pre- and post-
deployment medical exams so that the new single medical record contains complete
and consistent facts that can be relied upon by both VHA and VBA. Mandatory medical
examinations, required under the Force Health Protection Law of 1998 (PL 105-85),
also reduce stigma for mental health conditions such as TBI and PTSD by eliminating
the current practice of forcing service members to self-identify, often in military
formation, that they want mental healthcare.


Conclusion
Our goal is to restructure VBA so the agency becomes more Veteran-focused and
Veteran-friendly by opening more VBA offices so our Veterans have greater and faster
access to important records as well as VBA decision makers. Restructuring VBA also
includes providing sufficient space for veterans’ advocates, including state, county, and
city agencies as well veteran service organizations.

We can measure the performance of this proposal by monitoring the time VA takes to
gather records, set up claim exam appointments, and process claims accurately. We
can also measure success by monitoring the amount of lost records. VBA can also
conduct surveys of Veterans’ opinions about VBA’s reformed claim system.

Today, the sole remaining challenge to fixing VBA's enormous systemic problems and
restructuring VBA remains the urgent need for new leadership that can recognize the
challenges and then quickly act with strong pro-Veteran vision and advocacy.


This article was originally provided to Presidential Transition Team on December 6,
2008. This memo was updated on September 14, 2009, and provided to VA’s Advisory
Committee on Disability Compensation.




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