Department Of Veterans Affairs Office Inspector General Audit The VA Regional Office, Wilmington, Delaware; Rpt #12 04328 VAOIG 12 211

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VA Office of Inspector General
OFFICE OF AUDITS AND EVALUATIONS
Inspection of
VA Regional Office
Wilmington, Delaware
June 11, 2013
12-04328-211
ACRONYMS AND ABBREVIATIONS
OIG Office of Inspector General
QRT Quality Review Team
RVSR Rating Veterans Service Representative
SAO Systematic Analysis of Operations
TBI Traumatic Brain Injury
VARO Veterans Affairs Regional Office
VBA Veterans Benefits Administration
VSC Veterans Service Center
To Report Suspected Wrongdoing in VA Programs and Operations:
Telephone: 1-800-488-8244
Email: vaoighotline@va.gov
(Hotline Information: http://www.va.gov/oig/contacts/hotline.asp)
Report Highlights: Inspection of VA
Regional Office Wilmington, DE
Why We Did This Review not provide adequate outreach to homeless
veterans in their area of jurisdiction.
The Veterans Benefits Administration
(VBA) has 56 VA Regional Offices
(VAROs) and 1 Veterans Service Center
nationwide that process disability claims and
provide a range of services to veterans. We
evaluated the Wilmington VARO to see how
well it accomplishes this mission.
What We Found
Overall, VARO staff did not accurately
process 17 (50 percent) of 34 disability
claims we reviewed. We sampled claims
that we considered to be at higher risk of
processing errors, thus these results do not
represent the overall accuracy of disability
claims processing at this VARO. Claims
processing that lacks compliance with VBA
procedures can result in the risk of paying
inaccurate and unnecessary financial
benefits.
Specifically, 17 of 30 temporary 100 percent
disability evaluations we reviewed were
inaccurate. Generally, errors in processing
the temporary evaluations occurred because
VARO staff did not input suspense diaries
or take timely actions to schedule medical
reexaminations or reduce benefits as
appropriate. All four traumatic brain injury
claims that VARO staff completed from
April through June 2012 were correctly
processed.
Management ensured Systematic Analyses
of Operations were complete and timely.
However, staff did not always annotate Gulf
War veterans’ entitlement to mental health
care on decision documents. Staff also did
What We Recommend
The VARO Director should develop and
implement a plan to ensure staff input
suspense diaries, schedule medical
reexaminations, and follow up to reduce
benefits for temporary 100 percent disability
evaluations when appropriate. The Director
should ensure staff review the temporary
100 percent disability evaluations to
determine if reexaminations are required for
those claims not reviewed as part of the OIG
statistical sample. Management should also
implement a plan to provide outreach to
homeless shelters and service providers.
Agency Comments
The VARO Director concurred with our
recommendations. Management’s planned
actions are responsive and we will follow up
as required.
LINDA A. HALLIDAY
Assistant Inspector General
for Audits and Evaluations
i
TABLE OF CONTENTS
Introduction......................................................................................................................................1
Results and Recommendations ........................................................................................................2
I. Disability Claims Processing ...............................................................................................2
Finding 1 Wilmington VARO Could Improve Disability Claims Processing
Accuracy .........................................................................................................2
Recommendations...........................................................................................6
II. Management Controls ..........................................................................................................7
III. Eligibility Determinations ....................................................................................................8
Finding 2 Gulf War Veterans Did Not Always Receive Entitlement Decisions
for Mental Health Treatment ..........................................................................8
IV. Public Contact ......................................................................................................................9
Finding 3 Oversight of the Homeless Veterans Outreach Program Needs
Improvement ...................................................................................................9
Recommendation ..........................................................................................10
Appendix A VARO Profile and Scope of Inspection ........................................................11
Appendix B Inspection Summary .....................................................................................13
Appendix C VARO Director’s Comments........................................................................14
Appendix D Office of Inspector General Contact and Staff Acknowledgments ..............15
Appendix E Report Distribution .......................................................................................17
ii
Inspection of VARO Wilmington, DE
Objective
Scope of
Inspection
Other
Information
INTRODUCTION
The Benefits Inspection Program is part of the Office of Inspector General’s
(OIG) efforts to ensure our Nation’s veterans receive timely and accurate
benefits and services. The Benefits Inspection Division contributes to
improved management of benefits processing activities and veterans’
services by conducting onsite inspections at VA Regional Offices (VAROs).
These independent inspections provide recurring oversight focused on
disability compensation claims processing and performance of Veterans
Service Center (VSC) operations. The objectives of the inspections are to:
Evaluate how well VAROs are accomplishing their mission of providing
veterans with access to high-quality benefits and services.
Determine whether management controls ensure compliance with VA
regulations and policies; assist management in achieving program goals;
and minimize the risk of fraud, waste, and other abuses.
Identify and report systemic trends in VARO operations.
In addition to this oversight, inspections may examine issues or allegations
referred by VA employees, members of Congress, or other stakeholders.
In November 2012, we inspected the Wilmington VARO. The inspection
focused on the following four protocol areas: disability claims processing,
management controls, eligibility determinations, and public contact. Within
these areas, we examined five operational activities: temporary 100 percent
disability evaluations, traumatic brain injury (TBI) claims, Systematic
Analysis of Operations (SAOs), Gulf War veterans’ entitlement to mental
health treatment, and the homeless veterans outreach program.
We reviewed 30 (34 percent) of 87 rating decisions where VARO staff
granted temporary 100 percent disability evaluations for at least 18 months,
This is generally the longest period a temporary 100 percent disability
evaluation may be assigned without review, according to Veterans Benefits
Administration (VBA) policy. We examined all four disability claims
related to traumatic brain injury (TBI) that VARO staff completed during the
period April through June 2012.
Appendix A includes details on the VARO and the scope of our
inspection.
Appendix B outlines criteria we used to evaluate each operational
activity and a summary of our inspection results.
Appendix C provides the VARO Director’s comments on a draft of this
report.
VA Office of Inspector General 1
Inspection of VARO Wilmington, DE
RESULTS AND RECOMMENDATIONS
I. Disability Claims Processing
The OIG Benefits Inspection team focused on accuracy in processing claims
related to temporary 100 percent disability evaluations and TBI. We
evaluated these claims processing issues and assessed their impact on
veterans’ benefits.
Finding 1 Wilmington VARO Could Improve Disability Claims Processing
Accuracy
Claims The Wilmington VARO did not consistently process temporary 100 percent
Processing disability cases accurately. The four TBI claims completed and available for
A
ccurac
y
our inspectors to review were processed accurately. Overall, VARO staff
incorrectly processed 17 of the total 34 disability claims we sampled. The
inaccurate processing of the temporary 100 percent disability cases resulted
in 179 improper monthly payments to 10 veterans totaling $297,289 from
February 2009 until the time of our inspection.
We sampled claims related only to specific conditions that we considered at
higher risk of processing errors. As a result, the errors identified do not
represent the universe of disability claims processed at this VARO. As
reported by VBA’s Systematic Technical Accuracy Review program as of
July 2012, the overall accuracy of the VARO’s compensation rating-related
decisions was 75.2 percent—11.8 percentage points below VBA’s
FY 2012 target of 87 percent. This program information was not reviewed
during the scope of this inspection.
The following table reflects the errors affecting, and those with the potential
to affect, veterans’ benefits processed at the Wilmington VARO.
Table 1 Wilmington VARO Disability Claims Processing Accuracy
Type of Claim Reviewed
Claims Inaccurately Processed
Affecting
Veterans’
Benefits
Potential To
Affect Veterans’
Benefits Total
Temporary 100 Percent
Disability Evaluations 30 10 7 17
Traumatic Brain Injury
Claims 4 0 0 0
Total 34 10 7 17
Source: VA OIG analysis of VBA’s temporary 100 percent disability evaluations paid
at least 18 months or longer and TBI disability claims completed in the third quarter
FY 2012
VA Office of Inspector General 2
Inspection of VARO Wilmington, DE
Temporary
100 Percent
Disability
Evaluations
VARO staff incorrectly processed 17 of 30 temporary 100 percent disability
evaluations we reviewed. VBA policy requires a temporary 100 percent
disability evaluation for a service-connected disability following a veteran’s
surgery or when specific treatment is needed. At the end of a mandated period
of convalescence or treatment, VARO staff must request a follow-up medical
examination to help determine whether to continue the veteran’s 100 percent
disability evaluation.
For temporary 100 percent disability evaluations, including confirmed and
continued evaluations where rating decisions do not change veterans’
payment amounts, VSC staff must input suspense diaries in VBA’s
electronic system. Wilmington had five errors where suspense diaries were
not established. A suspense diary is a processing command that establishes a
date when VSC staff must schedule a reexamination. As a suspense diary
matures, the electronic system generates a reminder to alert VSC staff to
schedule the reexamination.
Without effective management of these temporary ratings, VBA is at risk of
paying inaccurate financial benefits. Available medical evidence showed
10 of the 17 processing errors we identified affected veterans’ benefits. The
processing inaccuracies resulted in 179 improper monthly payments totaling
$297,289 from as early as February 2009 until the time of our inspection.
Details on the most significant overpayment and underpayment follow.
A Rating Veterans Service Representative (RVSR) correctly assigned an
evaluation of 100 percent for a veteran’s laryngeal cancer and annotated
the need for a routine future examination in July 2008; however, VSC
staff did not input a suspense diary in the electronic system as required;
therefore, a reminder notification to schedule the reexamination did not
generate. VA treatment reports showed the veteran’s cancer was no
longer active so a reduction in benefits should have occurred in
April 2009. As a result, VA overpaid the veteran $110,662 over a period
of 3 years and 7 months.
An RVSR did not establish entitlement to a special monthly
compensation based on loss of use of a creative organ due to prostate
cancer, as required. As a result, VA underpaid the veteran $3,777 over a
period of 3 years and 3 months.
The remaining 7 of the total 17 errors had the potential to affect veterans’
benefits. We could not determine whether the evaluations would have
continued because the veterans’ claims folders did not contain the medical
examination reports needed to evaluate each case. In cases where routine
future medical reexaminations were not scheduled as required, claims
processing delays ranged from approximately 9 months to 8 years and
2 months. An average of approximately 3 years elapsed from the time staff
VA Office of Inspector General 3
Inspection of VARO Wilmington, DE
should have scheduled these medical reexaminations until the date of our
inspection.
Summaries of the 17 total errors we identified follow.
Five errors occurred when staff did not establish suspense diaries in the
electronic record; thereby, removing the possibility that staff would
receive reminder notifications to schedule medical reexaminations.
Five errors occurred when staff did not timely reduce benefits after
notifying veterans of the intent to do so. On average approximately
1 year and 3 months elapsed from the time staff should have reduced
benefits until the date of our inspection and ranged from 1 month to
3 years and 9 months. As a result, veterans’ claims were not effectively
managed.
Two errors occurred when RVSRs did not establish entitlement to special
monthly compensation for a medical condition secondary to service
connected prostate cancer.
Two errors occurred when RVSRs entered incorrect routine future
examination dates on the rating decision code sheet. The dates entered
by RVSRs extended temporary 100 percent disability evaluations beyond
the required reexaminations dates by 1 and 10 years, respectively. The
temporary 100 percent disability evaluations may have continued
uninterrupted until the erroneous reexamination dates and resulted in
inaccurate benefits payments, had we not identified these cases for
review during our inspection.
One error occurred when staff did not schedule a medical reexamination
in November 2004 as requested by an RVSR. A review of the claims
folder showed the veterans’ reexamination date was entered correctly in
the electronic system; however, the paper reminder notification to
schedule the reexamination was not in the claims folder nor did staff
schedule the reexamination.
One error occurred when an RVSR entered an incorrect code related to a
special monthly compensation benefit for a veteran. In this case, staff
entered an incorrect code which resulted in incorrect payments to the
veteran.
One error occurred when an RVSR did not grant entitlement to
Dependents’ Educational Assistance in March 2011 despite medical
evidence of a disability considered by VBA to be permanently and totally
disabling.
In November 2009, VBA provided guidance reminding VARO staff about
the need to input suspense diaries to the electronic record as reminders to
schedule medical reexaminations. However, VARO managers had no
oversight procedure in place to ensure VSC staff established suspense diaries
VA Office of Inspector General 4
Inspection of VARO Wilmington, DE
A
ctions Taken
in Response to
Prior Audit
Report
TBI Claims
and scheduled reexaminations timely, nor did they ensure staff complied
with established procedures to reduce benefits when appropriate. Temporary
100 percent disability evaluations could have continued uninterrupted over
the veterans’ lifetimes if we had not identified the need for VARO staff to
take actions to schedule reexaminations.
In response to a recommendation in our national report, Audit of 100 Percent
Disability Evaluations (Report No. 09-03359-71, January 24, 2011), the
Acting Under Secretary for Benefits agreed to review all temporary
100 percent disability evaluations and ensure each had a future examination
date entered in the electronic record. Our report stated, “If VBA does not
take timely corrective action, they will overpay veterans a projected
$1.1 billion over the next 5 years.” The then Acting Under Secretary for
Benefits stated in response to our audit report that the target completion date
for the national review would be September 30, 2011.
VBA did not provide each VARO with a list of temporary 100 percent
disability evaluations for review until September 2011. VBA subsequently
extended the national review deadline to December 31, 2011, and then again
to June 30, 2012. At the time of our inspection, VBA was working to
complete this national review requirement, but extended the deadline again
to December 31, 2012. We are concerned about the lack of urgency in
completing this review, which is critical to minimize the financial risks of
making inaccurate benefits payments.
During our 2012 inspection, we followed up on VBA’s national review of its
temporary 100 percent disability evaluation processing. We sampled
40 cases from the lists of cases needing corrective actions that VBA had
provided to the Wilmington VARO for review. We determined VARO staff
accurately reported actions, such as inputting suspense diaries or taking
actions to schedule reexaminations, on all 40 cases we reviewed. However,
in comparing VBA’s national review lists with our data on temporary
100 percent disability evaluations, we found five cases involving prostate
cancer or non-Hodgkin’s lymphoma that VBA had not identified. We could
not determine why these cases were not identified by VBA; however, we will
continue monitoring this situation as VBA works to complete its national
review.
The Department of Defense and VBA commonly define a TBI as a
traumatically induced structural injury or a physiological disruption of brain
function caused by an external force. The major residual disabilities of TBI
fall into three main categories—physical, cognitive, and behavioral. VBA
policy requires staff to evaluate these residual disabilities.
In response to a recommendation in our annual report, Systemic Issues
Reported During Inspections at VA Regional Offices (Report
No. 11-00510-167, May 18, 2011), VBA agreed to develop and implement a
VA Office of Inspector General 5
Inspection of VARO Wilmington, DE
Follow Up to
Prior VA OIG
Inspection
Management
Comments
strategy for ensuring the accuracy of TBI claims decisions. In May 2011,
VBA provided guidance to all VARO Directors to implement a policy
requiring a second signature on each TBI case an RVSR evaluates until the
RVSR demonstrates 90 percent accuracy in TBI claims processing. The
policy indicates second signature reviewers come from the same pool of staff
as those used to conduct local station quality reviews.
VSC staff correctly processed all four TBI claims completed from April
through June 2012 and complied with VBA’s second signature policies that
require these types of claims undergo an additional level of review. The
Quality Review Team (QRT) is responsible for conducting local quality
reviews at the Wilmington VARO. The QRT concept is an initiative
implemented by VBA to ensure standardized quality reviews among
VAROs. Staff assigned to QRT teams in VAROs receive specialized
training by Systematic Technical Accuracy Review (STAR) Program staff.
Our prior report, Inspection of the VA Regional Office, Wilmington,
Delaware (Report No. 09-01994-230, September 29, 2009), stated staff
followed VBA policy when processing TBI-related disability claims.
Results of our current inspection indicate staff continue to process TBI
claims accurately.
Recommendations
1. We recommend the Wilmington VA Regional Office Director develop
and implement a plan to ensure claims processing staff input suspense
diaries in the electronic record and timely schedule medical
reexaminations when the reminder notifications generate.
2. We recommend the Wilmington VA Regional Office Director develop
and implement a plan to ensure claims processing staff take timely
actions to finalize reductions in benefits when appropriate.
3. We recommend the Wilmington VA Regional Office Director conduct a
review of the 57 temporary 100 percent disability evaluations remaining
from our inspection universe and take appropriate action.
The VARO Director concurred with our recommendations. In December
2012 and again in February 2013, VARO staff received additional training
on processing reminder notifications and scheduling medical reexaminations.
The Director also plans to address these issues in future Systematic Analysis
of Operations. Additionally, the Director updated the VARO’s workload
management plan to include supervisory oversight procedures to ensure staff
take timely actions to reduce benefits when appropriate. VARO staff
reviewed the 57 temporary 100 percent disability evaluations remaining from
the OIG’s inspection universe and took appropriate actions.
VA Office of Inspector General 6
Inspection of VARO Wilmington, DE
OIG Response
Systematic
A
nal
y
sis of
Operations
Follow Up To
Prior VA OIG
Inspection
The Director’s comments and actions are responsive to the
recommendations.
II. Management Controls
We assessed whether VARO management had adequate controls in place to
ensure complete and timely submission of Systematic Analyses of
Operations (SAOs). We also considered whether VSC staff used adequate
data to support analyses and recommendations identified within each SAO.
An SAO is a formal analysis of an organizational element or operational
function. SAOs provide an organized means of reviewing VSC operations to
identify existing or potential problems and propose corrective actions.
VARO management must publish annual SAO schedules designating the
staff required to complete the SAOs by specific dates. The VSC Manager is
responsible for ongoing analysis of VSC operations, including completing
11 SAOs annually.
VARO staff completed all 11 mandated SAOs timely according to the SAO
schedule. All 11 SAOs included thorough analyses using appropriate data,
identified weaknesses or concerns, and provided recommendations for
improvement.
Our prior report, Inspection of the VA Regional Office, Wilmington,
Delaware (Report No. 09-01994-230, September 29, 2009), stated staff
timely completed all analyses related to mandatory SAOs as required.
Results of our current inspection indicate staff continue to complete thorough
and timely SAOs.
VA Office of Inspector General 7
Inspection of VARO Wilmington, DE
Medical
Treatment for
Mental
Disorders
Finding 2
III. Eligibility Determinations
Gulf War veterans are eligible for medical treatment for any mental disorder
they develop within 2 years of the date of separation from military service.
According to VBA, whenever an RVSR denies a Gulf War veteran service
connection for any mental disorder, the RVSR must consider whether the
veteran is entitled to receive mental health treatment.
In February 2011, VBA updated its Rating Board Automation 2000, a
computer application designed to assist RVSRs in preparing disability
ratings. The application provides a pop-up notification, known as a tip
master, to remind staff to consider a Gulf War veteran’s entitlement to
mental health treatment when denying service connection for a mental
disorder. This pop-up notification does not generate if a previous decision
did not address entitlement to mental health services and a mental condition
is not part of the current claim.
Gulf War Veterans Did Not Always Receive Entitlement Decisions
for Mental Health Treatment
VARO staff did not properly address whether 5 of 14 Gulf War veterans
were entitled to receive treatment for mental disorders. In all five cases,
VSC staff correctly addressed the entitlement decisions, but did not formally
annotate the decisions on the decision documents. These errors generally
occurred because RVSRs and QRT staff were unaware of the requirement to
annotate entitlement decisions on the decision documents.
We reviewed FY 2012 training records and confirmed VARO staff had not
received training emphasizing the need to document these entitlement
decisions on the rating documents. When VARO staff do not annotate
entitlement decisions on decision documents, VA treating facilities cannot
determine whether veterans are entitled to mental health care benefits.
In December 2012, VBA modified its policy to state that RVSRs no longer
have to address Gulf War veterans’ entitlement to mental health care in all
cases. RVSRs only have to consider this entitlement when the veteran’s
mental health benefit can be granted based on diagnosis of a mental disorder
within 2 years of separation from military service. Because this policy
modification became effective after we concluded our inspection of the
Wilmington VARO, we cannot determine whether the change might have
affected the number of errors we identified. Therefore, we make no
recommendation for improvement.
VA Office of Inspector General 8
Inspection of VARO Wilmington, DE
IV. Public Contact
Outreach to In November 2009, VA developed a 5-year plan to end homelessness among
Homeless veterans by assisting every eligible homeless veteran willing to accept
Veterans service. VBA generally defines “homeless” as lacking a fixed, regular, and
adequate nighttime residence.
Congress mandated that at least one full-time employee oversee and
coordinate homeless veterans programs at each of the 20 VAROs that VA
determined to have the largest veteran populations. VBA guidance, last
updated in September 2002, directs that coordinators at the remaining
VAROs be familiar with requirements for improving the effectiveness of
VARO outreach to homeless veterans. These requirements include
developing and updating a directory of local homeless shelters and service
providers. Additionally, the coordinators should attend regular meetings
with local homeless service providers, community governments, and
advocacy groups to provide information on VA benefits and services.
Finding 3 Oversight of the Homeless Veterans Outreach Program Needs
Improvement
The Wilmington VARO did not regularly contact or provide information and
training to homeless shelters and service providers in areas under its
jurisdiction. VARO management did not provide oversight or guidance to
ensure effective homeless veterans outreach. As a result, homeless shelters
and service providers may not be aware of benefits and services available to
homeless veterans.
Although VARO staff attended some local outreach events targeting
homelessness, they did not maintain a directory of homeless shelters and
service providers within their area of jurisdiction as required. Consequently,
staff did not regularly contact or provide these shelters and service providers
with information on benefits and services available to veterans. Management
told us they did not provide guidance or oversight of the homeless veterans
program prior to our inspection because they were unaware of the
requirement to do so. They instead focused on processing claims received
from homeless veterans.
In October 2012, VARO staff created a Homeless Veterans Standard
Operating Procedure that included the required directory of shelters and
service providers; however, we were unable to determine the impact of the
operating procedure on the homeless veterans outreach program because it
was implemented after we notified the VARO of our inspection. We also
noted that VBA needs a performance measurement to assess the
effectiveness of its homeless veterans outreach efforts.
VA Office of Inspector General 9
Inspection of VARO Wilmington, DE
Management
Comments
OIG Response
Recommendation
4. We recommend the Wilmington VA Regional Office Director develop
and implement a plan to ensure staff update the resource directory and
regularly contact and provide outreach to homeless shelters and service
providers under the VA Regional Office’s jurisdiction.
The VARO Director concurred with our recommendation. In February 2013,
staff updated the directory of homeless shelters and service providers within
the VARO’s jurisdiction. Staff then mailed information about homeless
veterans benefits and services to the shelters and service providers listed in
the directory. Management designated staff responsible for updating the
directory annually. Additionally, the outreach coordinator will now conduct
outreach to homeless shelters under the VARO’s jurisdiction on a quarterly
basis.
The Director’s comments and actions are responsive to the recommendation.
VA Office of Inspector General 10
Inspection of VARO Wilmington, DE
Appendix A VARO Profile and Scope of Inspection
Organization The Wilmington VARO administers a variety of services and benefits,
including compensation and pension benefits; vocational rehabilitation and
employment assistance; benefits counseling; and outreach to homeless,
elderly, minority, and women veterans.
Resources As of October 2012, the Wilmington VARO had a staffing level of
28 full-time employees. Of this total, the VSC had 25 employees assigned.
Workload The Wilmington VARO reported 1,076 pending compensation claims in
October 2012. The average time to complete claims was 210.5 days;
39.5 days less than the national target of 250.
Scope We reviewed selected management, claims processing, and administrative
activities to evaluate compliance with VBA policies regarding benefits
delivery and nonmedical services provided to veterans and other
beneficiaries. We interviewed managers and employees and reviewed
veterans’ claims folders.
Our review included 30 (34 percent) of 87 temporary 100 percent disability
evaluations selected from VBA’s Corporate Database. These claims
represented all instances in which VARO staff had granted temporary
100 percent disability evaluations for at least 18 months as of
September 5, 2012. We provided VARO management with 57 claims
remaining from our universe of 87 for its review. As follow-up to the
National audit, we sampled 40 temporary 100 percent disability evaluations
from the SharePoint list VBA provided to the VARO as part of its national
review. We also reviewed all four TBI-related disability claims that the
VARO completed from April through June 2012.
Where we identify potential procedural inaccuracies, this information is
provided to help the VARO understand the procedural improvements it can
make for enhanced stewardship of financial benefits. This information is not
provided to require the VAROs to adjust specific veterans’ benefits.
Processing any adjustments per this review is clearly a VBA program
management decision.
We assessed the 11 mandatory SAOs completed in FY 2012. We examined
14 completed claims processed for Gulf War veterans from April through
June 2012 to determine whether VARO staff addressed entitlement to mental
health treatment in the rating decision documents as required. Further, we
assessed the effectiveness of the VARO’s homeless veterans outreach
program.
VA Office of Inspector General 11
Inspection of VARO Wilmington, DE
Data Reliability
Inspection
Standards
We used computer-processed data from the Veterans Service Network’s
Operations Reports and Awards. To test for reliability, we reviewed the data
to determine whether any data were missing from key fields, contained data
outside of the time frame requested, included any calculation errors,
contained obvious duplication of records, contained alphabetic or numeric
characters in incorrect fields, or contained illogical relationships among data
elements. Further, we compared veterans’ names, file numbers, Social
Security numbers, VARO numbers, dates of claim, and decision dates as
provided in the data received with information contained in the claims
folders we reviewed.
Our testing of the data disclosed that they were sufficiently reliable to meet
our inspection objectives. Our comparison of the data with information
contained in the veterans’ claims folders at the Wilmington VARO did not
disclose any problems with data reliability.
While this report references VBA’s Systematic Technical Accuracy Review
(STAR) data, the overall accuracy of the VARO’s compensation
rating-related decisions was 75.2 percent—11.8 percentage points below
VBA’s FY 2012 target of 87 percent. This data was not reviewed as part of
this inspection.
We conducted this inspection in accordance with the Council of the
Inspectors General on Integrity and Efficiency’s Quality Standards for
Inspection and Evaluation. We planned and performed the inspection to
obtain sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our inspection objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our inspection objectives.
VA Office of Inspector General 12
Inspection of VARO Wilmington, DE
Appendix B Inspection Summary
Table 2 reflects the operational activities inspected, applicable criteria, and whether or not we
had reasonable assurance of VARO compliance.
Table 2. Wilmington VARO Inspection Summary
Five Operational
Activities
Inspected
Criteria Reasonable
Assurance of
Compliance
Yes No
Claims Processing
1. Temporary
100 Percent
Disability
Evaluations
Determine whether VARO staff properly processed temporary
100 percent disability evaluations. (38 Code of Federal
Regulations (CFR) 3.103(b)) (38 CFR 3.105(e)) (38 CFR 3.327)
(M21-1 MR Part IV, Subpart ii, Chapter 2, Section J) (M21-1MR
Part III, Subpart iv, Chapter 3, Section C.17.e)
X
2. Traumatic
Brain Injury
Claims
Determine whether VARO staff properly processed claims for
service connection for all disabilities related to an in-service TBI.
(FL 08-34 and 08-36) (Training Letter 09-01) X
Management Controls
3. Systematic
Analysis of
Operations
Determine whether VARO staff properly performed formal
analyses of their operations through completion of SAOs. (M21-
4, Chapter 5) X
Eligibility Determinations
4. Gulf War
Veterans’
Entitlement to
Mental Health
Treatment
Determine whether VARO staff properly processed Gulf War
veterans’ claims, considering entitlement to medical treatment
for mental illness. (38 USC 1702) ( M21-1MR Part IX, Subpart ii,
Chapter 2)(M21-1MR Part III, Subpart v, Chapter 7) (FL 08-15) (38
CFR 3.384) (38 CFR 3.2)
X
Public Contact
5. Homeless
Veterans
Outreach
Program
Determine whether VARO staff provided effective outreach
services. (Public Law 107-05) (VBA Letter 20-02-34) (VBA
Circular 27-91-4) (FL 10-11) (M21-1, Part VII, Chapter 6) X
Source: VA OIG
CFR=Code of Federal Regulations, FL= Fast Letter, M=Manual, MR=Manual Rewrite
VA Office of Inspector General 13
Inspection of VARO Wilmington, DE
Appendix C VARO Director’s Comments
Department of Memorandum
Veterans Affairs
Date: May 1, 2013
From: Director, VA Regional Office Philadelphia, Pennsylvania
Subj: Inspection of the VA Regional Office, Wilmington, Delaware
To: Assistant Inspector General for Audits and Evaluations (52)
1. The Philadelphia Regional Office remotely manages the Wilmington Regional
Office. The Wilmington VA Regional Office (RO) comments are attached on the
OIG Draft Report, Inspection of the VA Regional Office, Wilmington, DE.
2. Please refer questions to me at (215) 381-3001.
(original signed by:)
Robert McKenrick
Attachment
VA Office of Inspector General 14
Inspection of VARO Wilmington, DE
Recommendation 1: We recommend the Wilmington Regional Office Director develop and
implement a plan to ensure claims processing staff input suspense diaries in the electronic record
and timely schedule medical reexaminations when the reminder notifications generate.
Concur: The Wilmington RO will include this in our future SAOs. Since this finding, the RO
had RVSR training on December 18, 2012 and again on February 5, 2013, to address this issue.
Recommendation 2: We recommend the Wilmington Regional Office Director develop and
implement a plan to ensure claims processing staff take timely actions to finalize reductions in
benefits when appropriate.
Concur: The Workload Management Plan of December 12, 2012, includes oversight for
monitoring and processing claims involving proposed disability evaluation reduction ensuring
that prompt action is taken to minimize potential overpayments.
Recommendation 3: We recommend the Wilmington VA Regional Office Director conduct a
review of the 57 temporary 100 percent disability evaluations remaining from our inspection
universe and take appropriate action.
Concur: The Wilmington staff reviewed and took appropriate action on all 57 remaining
temporary 100 percent disability evaluations.
Recommendation 4: We recommend the Wilmington VA Regional Office Director develop
and implement a plan to ensure staff update the resource directory and regularly contact and
provide outreach to homeless shelters and service providers under the VA Regional Office’s
jurisdiction.
Concur. In February 2013, the Wilmington RO staff updated the directory of homeless shelters
and service providers within the RO’s jurisdiction. At that time, RO staff contacted these
shelters and service providers by mail to communicate information of homeless Veterans’
benefits and service. The outreach coordinator will make quarterly outreach to the Homeless
Shelters in the Wilmington Jurisdiction. Management also designated staff responsible for
ensuring that update of homeless resource directory and outreach to shelters and service
providers occur annually.
VA Office of Inspector General 15
Inspection of VARO Wilmington, DE
Appendix D Office of Inspector General Contact and Staff
Acknowledgments
OIG Contact For more information about this report, please
contact the Office of Inspector General at
(202) 461-4720.
Acknowledgments Nora Stokes, Director
Daphne Brantley
Robert Campbell
Madeline Cantu
Ramon Figueroa
Kyle Flannery
Lee Giesbrecht
Lisa Van Haeren
Nelvy Viguera Butler
VA Office of Inspector General 16
Inspection of VARO Wilmington, DE
Appendix E Report Distribution
VA Distribution
Office of the Secretary
Veterans Benefits Administration
Assistant Secretaries
Office of General Counsel
Veterans Benefits Administration Eastern Area Director
VA Regional Office Wilmington Director
Non-VA Distribution
House Committee on Veterans’ Affairs
House Appropriations Subcommittee on Military Construction, Veterans
Affairs, and Related Agencies
House Committee on Oversight and Government Reform
Senate Committee on Veterans’ Affairs
Senate Appropriations Subcommittee on Military Construction, Veterans
Affairs, and Related Agencies
Senate Committee on Homeland Security and Governmental Affairs
National Veterans Service Organizations
Government Accountability Office
Office of Management and Budget
U.S. Senate: Tom Carper, Chris Coons
U.S. House of Representatives: John C. Carney, Jr.
This report is available on our Web site at www.va.gov/oig.
VA Office of Inspector General 17

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