VA Disability Benefits: Planning Gaps Could Impede Readiness for Successful Appeals Implementation

VA's disability compensation program pays cash benefits to veterans with disabilities connected to their military service. In recent years, veterans who appealed VA decisions on their claims have waited an average of 3 years. The subset of appeals resolved by the Board of Veterans Appeals—a separate VA agency that provides a higher level of appeals review—took on average 7 years to resolve.

The Veterans Appeals Improvement and Modernization Act of 2017 makes changes to VA's current (legacy) process, giving veterans options to have their claims reviewed by VA or to appeal directly to the Board. The Act requires VA to submit to Congress and GAO a plan for implementing a new appeals process (which VA submitted in November 2017) and periodic progress reports (which VA submitted in February, May, August, and November 2018). The Act also includes a provision for GAO to assess VA's original plan.

In March 2018, GAO found that VA could help ensure successful implementation of appeals reform by addressing gaps in planning and made four recommendations, with which VA agreed. This testimony focuses on the steps VA has taken to address GAO's recommendations, what aspects remain unaddressed, and risks these gaps pose for implementation.

For this statement, GAO reviewed VA's updated plans, assessed VA's schedules against best practices, interviewed VA officials and reviewed information they provided about steps taken to implement GAO's recommendations.

In a March 2018 report, GAO made four recommendations to address planning gaps in the Department of Veterans Affairs' (VA) November 2017 plan for changing its appeals process for disability compensation claims. Since then, VA has updated its appeals reform plan and taken steps to address aspects of these recommendations, but further steps could enhance its readiness for implementation:

Address all legally required elements . VA's November 2017 plan did not address one and only partially addressed four of 22 elements required by the Veterans Appeals Improvement and Modernization Act of 2017 (Act); GAO recommended VA fully address all 22. As of November 2018, VA addressed one element related to projecting productivity and took steps to partially address the other four. VA is still missing information the agency needs to certify that it has the resources needed to successfully implement appeals reform.

Articulate plans for performance monitoring and assessment . GAO recommended VA clearly articulate how it will monitor and assess the new appeals process relative to the legacy process, including, for example, specifying timeliness goals for the five new appeals options, and measures for decision accuracy in processing appeals. As of November 2018, VA officials stated their intention to use productivity, timeliness, accuracy, and veteran satisfaction metrics to assess the new versus the legacy appeals processes. However, VA has yet to specify a complete set of goals or measures for monitoring and assessing the relative efficacy of the new process or articulate detailed steps and timeframes for establishing them.

Augment master schedule . GAO recommended VA augment its master schedule for appeals reform to reflect sound practices for guiding implementation of reform. Although VA's updated schedule reflected progress since VA's original 2017 plan, it still did not fully meet sound practices for project management. For example, the schedule does not appropriately define the work, activities, and resources necessary to accomplish appeals reform implementation. Without following sound practices, it is unclear whether the schedule poses risks to successful implementation of appeals reform.

Address risk fully . GAO recommended that VA's plan more fully address risks in implementing a new appeals process by, for example, testing all appeals options prior to full implementation. As of November 2018, VA took many steps to address risks, although opportunities exist to better assess them. For example, although VA has used lessons learned from tests to update the implementation process, it has not fully tested all aspects nor has it developed mitigation strategies for all identified risks, such as veterans appealing to the Board at higher rates than expected. Until VA takes these remaining steps, it may not have sufficiently accounted for key risks in implementing the new process.

I appreciate the opportunity today to provide an update on the  Department of Veterans Affairs’ (VA) plans for implementing a new  disability appeals process while still attending to appeals under the  current, or legacy, process.

VA provides cash benefits to veterans for disabling conditions incurred in  or aggravated by military service, paying about $72 billion to about 4.5  million veterans in fiscal year 2017. If veterans are dissatisfied with VA’s  initial decision they can appeal—first to the Veterans Benefits  Administration (VBA) and then, if not satisfied there, to the Board of  Veterans’ Appeals (Board), a separate agency within VA. For appeals  resolved in fiscal year 2017, veterans waited an average of approximately  3 years from the date they initiated their appeal to resolution by either  VBA or the Board—and an average of 7 years for appeals resolved by the  Board. Due in part to the challenges VA faces managing large workloads  and deciding disability claims and appeals in a timely manner, in 2003 we  designated VA disability compensation, along with other federal disability  programs, as one of the government’s highest risk areas.

The Veterans Appeals Improvement and Modernization Act of 2017 (Act)  makes changes to VA’s disability appeals process by replacing it with one  that gives veterans various options either for further review by VBA or to  bypass VBA and appeal directly to the Board. These changes may  generally take effect no earlier than February 2019, which is about 18  months from the date of enactment. The Act also built in flexibility for VA  regarding this time frame by stating that most of these changes will not  take effect until 30 days after the Secretary of Veterans Affairs certifies  that the agency is prepared to carry out timely processing of appeals  under the new and legacy appeals process, in addition to giving VA the  option of phasing in implementation of the new process at that time.

The Act further required VA to submit a comprehensive plan for  implementing the new appeals process to the appropriate committees of  Congress and GAO. (VA submitted its plan to GAO on November 22,  2017.) The Act delineates 22 legally required elements—some with  subparts—for this plan. In addition, the Act requires VA to provide  progress reports to the appropriate committees of Congress and GAO at  least every 90 days until the Act’s changes to the appeals process  generally go into effect and then at least every 180 days after this date for  7 years. VA submitted progress reports in February, May, August, and  November 2018.

The Act also includes a provision for GAO to assess whether VA’s  appeals plan comports with sound planning practices and identify any  gaps in the plan. In response, we have issued a series of reports and  testimonies assessing VA’s plans. In our March 2018 report, we  concluded that while VA’s November 2017 plan reflected aspects of  sound planning, improvements in planning were still needed to ensure  successful appeals reform. We recommended VA’s plan (1) address all  legally required elements in the Act; (2) articulate how VA will monitor and  assess the performance of appeals processes; (3) augment its project  plan for implementation; and (4) address risk more fully. VA agreed with  our recommendations. In a July 2018 testimony we concluded that VA  had updated its plan and taken some steps to address aspects of these  four recommendations, but further steps were needed.

My statement today addresses VA’s recent progress in implementing the  four recommendations in our March 2018 report, what aspects of those  recommendations VA has yet to address, and the risks these gaps pose  for successful implementation of appeals reform.

For this statement, we reviewed VA’s most recent progress reports on its  appeals reform plan, dated August and November 2018, and information  we received from VA officials about steps taken to implement our March  2018 recommendations. We assessed VA’s schedules and supporting  documentation against applicable best practices in GAO’s Schedule  Assessment Guide. We also interviewed VA officials and reviewed  information related to VA’s progress in addressing related  recommendations from work that we conducted prior to enactment of the  Act.

The work upon which this statement is based 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 that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

VA’s Current Disability Compensation Appeals Process

VA’s process for deciding veterans’ eligibility for disability compensation  begins when a veteran submits a claim to VA. Staff in one of VBA’s 57  regional offices assist the veteran by gathering additional evidence, such  as military and medical records, that is needed to evaluate the claim.  Based on this evidence, VBA decides whether the veteran is entitled to  compensation and, if so, how much. A veteran dissatisfied with the initial  claim decision can generally appeal within 1 year from the date of the  notification letter sent by VBA.

Under the current appeals process (now referred to by VA as the legacy  process), an appeal begins with the veteran filing a Notice of  Disagreement. VBA then re-examines the case and generally issues a  Statement of the Case that represents its decision. A veteran dissatisfied  with VBA’s decision can file an appeal with the Board. In filing that  appeal, the veteran can indicate whether a Board hearing is desired.  Before the Board reviews the appeal, VBA prepares the file and certifies it  as ready for Board review. If the veteran requests a hearing to present  new evidence or arguments, the Board will hold a hearing by  videoconference or at a local VBA regional office. The Board reviews the  evidence and either issues a decision to grant or deny the veteran’s  appeal or refers the appeal back to VBA for further work.

According to VA’s appeals plan, VA intends to implement the Act by  February 2019, by replacing the current appeals process with a process  offering veterans who are dissatisfied with VBA’s decision on their claim  five options. Two of those options afford the veteran an opportunity for an  additional review of VBA’s decision within VBA, and the other three  options afford them the opportunity to bypass additional VBA review and  appeal directly to the Board.

Under the new appeals process, the two VBA options will be:  1.  Request higher-level review: The veteran asks VBA to review its  initial decision based on the same evidence but with a higher-level  official reviewing and issuing a new decision.  2.  File supplemental claim: The veteran provides additional evidence  and files a supplemental claim with VBA for a new decision on the  claim. The veteran can also request a VBA hearing.

The three Board options will be:  3.  Request Board review of existing record: The veteran appeals to  the Board and asks it to review only the existing record without a  hearing.  4.  Request Board review of additional evidence, without a hearing.  5.  Request Board review of additional evidence, with a hearing.

In November 2017, VA initiated a test of the new VBA higher-level review  and supplemental claim options. According to VA’s appeals plan, a  purpose of this test—the Rapid Appeals Modernization Program  (RAMP)—is to reduce legacy appeals by providing veterans with a  chance for early resolution of their claims within VBA’s new process.

Participation in RAMP is voluntary, but veterans must withdraw their  pending legacy appeal to participate, according to VA’s appeals plan.

VA Has Not Provided Complete Information on Four Elements in the Act

In our March 2018 report, we found that VA’s November 2017 plan for  implementing a new disability appeals process while attending to appeals  under way in the current (legacy) process, addressed 17 of 22 elements  required by the Act. For the 5 remaining elements, we found that it  partially addressed 4 elements related to implementation monitoring,  productivity projecting, and workforce planning, and did not address 1  element related to identifying total resources. This element called for  delineating the resources needed by VBA and the Board to implement the  new appeals process and address legacy appeals.

We recommended in March 2018 that VA address all 22 required  elements in the Act in VA’s appeals plan to Congress—including  delineating resources required for all VBA and Board appeals options— using sensitivity analyses and results from its test, RAMP, where  appropriate and needed.

Since our March 2018 report, VA has taken some action on each of the  five elements that we found were not fully addressed at that time. For  example, VA added details related to projecting staff productivity,  identifying total resources, as well as determining personnel requirements  and productivity projections for processing appeals. For identifying total  resources, VA added FTE information for other offices that help  implement the appeals process and prepared a model to project resource  needs.

Although VA now addresses the 1 element related to projecting  productivity, it only partially addresses 4 elements related to monitoring  implementation, workforce planning, and delineating the total resources.  For example, as of November 2018, VA’s plan does not contain metrics  for monitoring implementation. Moreover, for total resources, the updated  plan does not delineate the total resources required by VBA and the  Board, such as the resources necessary for information technology and  training. We acknowledge that in some cases delineating total resources  could prove challenging, such as delineating information technology  resources for the legacy and new appeals processes. We also  acknowledge that implementing corrective actions to fully address these 4  elements may be challenging within the next several weeks, but we  continue to believe VA has an opportunity to further address these 4  elements as part of certifying the agency’s readiness prior to the full  implementation of the new process.

VA Has Addressed Some Gaps in Its Plans to Monitor and Assess Performance, though Further Steps Remain

In our March 2018 report, we found gaps in VA’s planning for how it will  monitor and assess performance of the new appeals process when it is  implemented. Specifically, we reported that the plan did not (1) establish  timeliness goals for two of the three Board options (i.e., Board review of  additional evidence without a hearing and Board review of additional  evidence with a hearing); (2) articulate aspects of performance important  for managing appeals, such as accuracy of decisions, veteran satisfaction  with the process, or cost; (3) explain how the performance of the new  appeals process would be compared to that of the legacy process; or (4)  explain how the agency would monitor relative workloads of, and  resources devoted to, the new and legacy appeals processes.

To address these gaps, we recommended that VA clearly articulate in its  appeals plan how VA will monitor and assess the new appeals process  compared to the legacy process, including specifying a balanced set of  goals and measures—such as timeliness goals for all VBA appeals  options and Board dockets, and measures of accuracy, veteran  satisfaction, and cost—and related baseline data. Articulating a balanced  set of goals that cover key aspects of managing appeals is important to  avoid promoting skewed behaviors (e.g., favoring timeliness over  accuracy) and to fully understanding performance.

In its progress reports, VA addressed some but not all aspects of this  recommendation (see table 1).

VA has made progress in monitoring performance and addressing  workload changes in its new and legacy appeals processes, but still lacks  a complete set of balanced goals and measures. As we noted in our July  2018 testimony, VA has developed sensitivity models and other analyses  to monitor and forecast future VBA and Board workloads, production, and  staffing requirements to help VA manage the legacy and new appeals  processes. However, VBA and the Board have yet to specify a complete  set of balanced goals for monitoring the performance of the new appeals  processes. According to the November 2018 progress report, the Board  plans to develop timeliness goals after VA fully implements the new  appeals process. Until VA fully develops a set of balanced goals and  measures, the agency risks not fully understanding how well the reforms  are performing.

Regarding comparing the performance of the new and legacy appeals  processes, VA has previously reported that the agency plans to  implement the reporting requirements in section 5 of the Act. This  section requires VA to report performance measures related to, among  other things, timeliness, productivity, and outcomes, without specifying  whether or how VA should compare performance of the new versus  legacy processes.

In November 2018, VBA and Board officials told us they intend to use  timeliness and productivity metrics from section 5 to compare the two  processes. However, in its updated plans to date, VA has been reporting  average timeliness of decisions made to date under RAMP—VA’s test of  the two VBA options—without reporting the average time cases are  pending. Moreover, VA has not been reporting timeliness data on both  decisions and pending cases according to the month that they entered  into RAMP, which present a more balanced indication of performance and  trends. In November 2018 VBA and Board officials told us they would  consider reporting timeliness using a monthly cohort that reflects when  appeals were filed.

VBA and Board officials also said they have taken steps to collect,  through surveys, comparable information on veterans’ satisfaction with  the new and legacy appeals processes. According to VBA and Board  officials, they have pre-tested the surveys—which is considered a best  practice by survey methodologists—and are coordinating the survey  efforts with one another. VBA and Board officials also told us that the  agency will report on accuracy and outcomes (grants and denials of  claims) in the new process. However, they also stated that these  measures would not provide a fair comparison with the legacy process  because the Act eliminated several of the requirements formerly required  in the legacy appeals administrative processes.

Although VA officials said they would develop a plan for comparing the  performance of the two appeals processes after the new process is fully  implemented, they did not indicate how soon they would do so.  Developing such a plan would better position the agency to fully  understand whether the new process is an improvement.

VA Has Augmented Its Master Schedule to a Limited Extent

Our March 2018 report identified elements of a high-quality and reliable  implementation schedule that were missing from VA’s master schedule  for appeals reform. Specifically, we reported that VA’s high-level master  schedule—which the agency included with its November 2017 plan—did  not (1) include all key activities; (2) show which activities must finish prior  to the start of other activities, or the amount of time an activity could be  delayed before the delay affects VA’s estimated implementation date; (3)  reflect interim goals and milestones for monitoring implementation; or (4)  assign resources for activities.

We recommended that VA augment the master schedule for its appeals  plan to reflect all activities—such as modifications to information  technology systems—as well as assigned responsibilities,  interdependencies, start and end dates for key activities for each workgroup, and resources. These steps establish accountability and  reduce overall risk of implementation failures.

In response to our recommendation, the Board, VBA and other VA  administrations made progress over time with developing and integrating  underlying plans into the integrated master schedule (IMS) in spring and  summer 2018. According to VA officials, VA set a baseline schedule for  implementing appeals reform in response to the potential February 2019  implementation date established in the Act. Since November 2017, VA’s  plan and progress reports have stated that VA uses an agency-wide  governance structure to coordinate implementation, and regularly uses  the schedule as a management tool for monitoring progress on appeals  reform. For example, the Board’s project manager meets regularly with  those responsible for major activities to check progress, including weekly  meetings with leadership, and identifies and corrects issues related to  schedule execution.

In October 2018, VA provided us with lower-level schedules and  information that allowed us to conduct a more detailed assessment of  VA’s IMS against applicable best practices criteria. The six criteria we  assessed lower-level schedules against were:

Capturing all activities: schedule should reflect all activities  necessary to perform work to accomplish a project’s objective.

Sequencing activities: activities should be logically sequenced in the  order they are to be carried out so that critical program dates can be  met.

Assigning resources: schedule should reflect all resources  necessary to complete work, verify whether resources will be  available, and identify any constraints.

Verifying horizontal and vertical traceability: schedule should be  rational and logically sequenced, account for interdependencies  among activities, and provide a way to evaluate the current status  (horizontal traceability). Also, the various levels of a schedule— summary, intermediate, and detailed—should be consistent with one  another and enable different teams to work to the same schedule  expectations (vertical traceability).

Updating the schedule using actual progress and logic: maintain  and continually update the schedule to reflect a realistic forecast of  start and end dates of activities.

Maintaining a baseline schedule: use original configuration of the  program plan as a point of comparison for the current plan to manage  scope, timeframes, and required resources.

We found that, while VA has made progress with providing more detail, its  master and underlying schedules only minimally met sound practices for  project management. Specifically, as with our March 2018 assessment,  we found that the schedule does not contain enough detail to manage the  work or provide a realistic representation of the resources and time  needed for this project. For example, the schedule did not contain a work  breakdown structure that defines the work, activities, and resources  necessary to accomplish implementation. Moreover, half of all the  remaining activities are missing logic that shows which activities must  finish prior to the start of other activities. In addition, the schedule  contains an invalid critical path, meaning that the schedule does not  present the amount of time that key activities could be delayed before  such delays affect VA’s estimated implementation date. Without a valid  critical path, management cannot focus on activities that will detrimentally  affect the key program milestones and deliveries if they slip.

To address our March 2018 recommendation, VA would need to ensure  that all activities are accounted for, that scheduled activities appear in the  correct order, that resources are properly allocated, that all activities  appear on the critical path, and that a schedule risk analysis accounts for  all risks. We provide a more detailed explanation of our assessment  results in appendix I.

In addition, establishing an overly optimistic schedule can reduce capacity  for carrying out a project and potentially create pressure to sacrifice the  quality of work activities to meet deadlines. Moreover, many of VA’s  activities are slated to be concurrently completed just before  implementation, posing a significant risk to implementing reform in  February. For example, according to VA’s schedule, the agency needs to  complete 117 activities after January 1, 2019. Further, other VA efforts to  redesign or update key aspects of VA’s disability compensation  process—including the Veterans Benefits Management System  (VBMS)—were not driven by robust, comprehensive planning and did not  achieve their schedule goals.

While VA intends to start full implementation in February, we do not know  the extent to which the lack of a robust schedule poses risks to successful  and smooth implementation. Even if taking corrective actions to address  our findings may not be feasible before February, incorporating such  lessons learned into future project planning could help VA improve its  project scheduling capabilities.

VA Has Addressed Many, but Not All Key Risks to Implementation

In our March 2018 report, we found that VA’s appeals plan could more  fully assess key risks related to implementing the new appeals process.  In particular, we found that VA’s plan did not include testing of new Board  options or clearly define how it would assess the RAMP test of the VBA- only options before implementing them more broadly. Further, we  reported that VA’s plan had not comprehensively reflected key risks  because the agency had not established a complete and balanced set of  goals and measures, which are a necessary pre-condition to effectively  assessing risk.

We recommended that VA ensure that the appeals plan more fully  addresses risk associated with appeals reform by, for example, assessing  risks against a balanced set of goals and measures, articulating success  criteria and an assessment plan for RAMP, and testing or conducting  sensitivity analyses of all five appeals options before fully implementing  the new appeals process.

In its progress reports, VA took many steps to address our  recommendation, although key steps are remaining for VA to better  assess risks associated with implementing appeals reform and managing  appeals workloads in the legacy process (see table 2).

Sound redesign and change management practices both suggest that  tests be rigorously monitored and evaluated and that further roll-out occur  only after an agency takes any needed corrective action and determines  that the new process is achieving previously identified success criteria.  Until VA takes these remaining steps, it may not have comprehensively  addressed key risks to better position the agency for successful  implementation of appeals reform.

In conclusion, VA is undertaking an ambitious effort to reform its disability  appeals process—while onboarding hundreds of new staff and  implementing new technology—that will affect the lives of hundreds of  thousands of veterans with disabilities for years to come. Consistent with  our prior recommendations, VA has made concrete progress to improve  its planning for disability appeals reform while it attends to legacy  appeals. Efforts such as resuming sensitivity analysis to monitor  workloads and testing VBA and Board appeals options will provide useful  information to guide VA through the uncertainty often associated with  process change.

However, VA has reported it plans to fully implement the new disability  appeals process in February 2019 even though it has yet to fully address  our recommendations. While fully implementing our recommendations  prior to February 2019 may not be feasible, doing so would better position  VA to ensure successful implementation. Nevertheless, VA should still  work to increase clarity around its plans prior to fully implementing reform.

Moreover, many of the principles of sound planning practices that  informed our recommendations remain relevant during process change.  By continuing to improve its approach to performance measurement,  scheduling, and risk management, even after implementation, VA could  better ensure that the new process meets veterans’ needs.

Chairman Roe, Ranking Member Walz, and Members of the Committee,  this concludes my prepared statement. I would be pleased to respond to  any questions you may have at this time.

For further information about this testimony, please contact Elizabeth H.  Curda at (202) 512-7215 or curdae@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this testimony. Other key contributors to this testimony  include James Whitcomb (Assistant Director), Juaná Collymore, Michele  Grgich, Sara Pelton, and Rachel Pittenger. In addition, key support was  provided by Susan Aschoff, Mark Bird, Alex Galuten, Jason Lee, Sheila  R. McCoy, Almeta Spencer, and Walter Vance.

Appendix I: Assessment of the Extent to Which VA Followed Aspects of Scheduling Leading Practices

For this testimony, we assessed the steps that the Department of  Veterans Affairs (VA) has taken to address our March 2018  recommendations and what aspects remain unaddressed, including the  extent to which VA is using sound practices for scheduling key projects.  In summary, we identified several areas where VA’s most recent  schedule falls short of sound practices. Further incorporating sound  practices into future project planning could help VA improve its project  scheduling capabilities.

We reviewed VA’s integrated master schedule (IMS) for the appeals  reform effort and underlying sub-schedules to assess them against 6 of  the 10 best practices, which we determined most relevant to our March  2018 recommendation that VA augment its master schedule for VA’s  appeals plan to reflect all activities—such as modifications to information  technology  systems—as well as assigned responsibilities,  interdependencies, start and end dates for key activities for each  workgroup, and resources, to establish accountability and reduce the  overall risk of implementation failures. Specifically, we analyzed the  following related scheduling best practices: (1) Capturing all activities, (2)  Sequencing all activities, (3) Assigning resources to all activities, (4)  Verifying that the schedule can be traced vertically and horizontally, (5)  Updating the schedule using actual progress and logic and (6)  Maintaining a baseline schedule.

We assessed VA’s lower-level schedules against these 6 best practices  by:

Checking for specific problems that could hinder the schedule’s ability  to respond to changes. For example, we:  o  Examined if there are any open-ended activities (i.e., activities  with no predecessor and/or successors),  o  Searched for activities with poor logic:

For example, Start to Start successor only or Finish to Finish  predecessor only which represent dangling logic, or

Logic on summary tasks rather than attached to detailed tasks  (summary tasks are for organizing the schedule and should  not drive the logic).  o  Looked for activities with constraints which keep the schedule rigid  (e.g., start no earlier than, finish no later than, etc.),  o  Determined if activities were resource loaded—which helps to cost  out the schedule—and examine whether resources are over- allocated or not available when needed,  o  Examined the schedule’s critical path to determine whether or not  it was reliable and logical,  o  Examined schedule float and determined if it was reasonable, and  o  Examined whether the schedule was baselined, its status cycle,  and what deviations there were from the original plan. We also  determined if there were any actual start or finish dates recorded  in the future and whether there was any broken logic between  planned tasks.

We also interviewed VA officials responsible for managing the schedule.  We scored each scheduling leading practice on a five-point scale: “not  met”, “minimally met”, “partially met”, “substantially met” and “fully met.”  We determined the characteristic assessment rating by assigning each  best practice rating a number and taking the average. Our resulting  conclusions based on this assessment are as follows:

VA’s project schedule minimally meets the best practice of  capturing all activities. The schedule does not have well-defined  start and finish milestones and there is not a project work breakdown  structure (WBS) or corresponding WBS dictionary to define the work  for each WBS element. We were not able to independently verify  contractor work or major handoffs and deliverables in the schedule. In  addition, there were activities with duplicate names, which could make  communication difficult between VA teams, particularly between team  members who are responsible for updating and integrating multiple  schedules.

VA’s project schedule minimally meets the best practice of  sequencing activities. There are issues with missing dependencies,  dangling activities, summary links, constraints and lags that affect the  schedule meeting this best practice. Specifically, of the remaining  activities, 55 percent have missing logic, over 12 percent are  dangling, 42 percent have date constraints and 4 percent have leads  assigned. When activities are not correctly linked, the program cannot  use the integrated master schedule (IMS) to identify disconnects or  hidden opportunities and cannot otherwise promote efficiency and  accuracy or control the program by comparing actual to planned  progress. When this happens, the schedule will not allow a sufficient  understanding of the program as a whole, and users of the schedule  may lack confidence in the dates and the critical path.

VA’s project schedule minimally meets the best practice of  assigning resources. While the schedule contains ‘Task Owner’  assignments, the Task Owner information has no effect on the  durations or forecasted start and finish dates of detailed activities.  Information on resource needs and availability in each work period  assists the program office in forecasting the likelihood that activities  will be completed as scheduled. If the current schedule does not allow  insight into the current or projected allocation of resources, then the  risk of the program’s slipping is significantly increased.

VA’s project schedule minimally meets the best practice of  verifying the schedule is traceable horizontally and vertically.  There was no evidence in the schedule of hand-offs within the  schedule—that is givers and receivers are easily identifiable in the  schedule. We were unable to determine the relationship between  lower-lever activities in the project schedule and higher-level activities  and milestones in the management briefs provided to us. Specifically,  we could not map the activities in the briefs to activities in the  schedule. This inconsistency also prevented the verification of dates  between the project schedule and higher-level management  documents, even with documents that were provided from the same  month as the October schedule.

Products and outcomes were not easily traced through the  sequencing of effort in the project schedule. In both cases the  schedule did not respond appropriately to “shocks”; that is, greatly  increasing the durations of some activities to increase the overall time  required to complete the project did not affect the dates of key  milestones. The duration increase of each activity did not affect the  overall time line because the activity in question had a constraint that  would not allow the project to appropriately extend.

VA’s project schedule minimally meets the best practice of  updating the schedule using progress and logic. Date anomalies,  such as planned dates in the past or actual dates in the future, were  found. The schedule was not current as of the date delivered to GAO.  While officials report that they update the schedule regularly, a  schedule narrative document does not accompany the schedule  update that would detail changes to the current schedule and describe  information such as the status of key milestone dates, changes in  network logic, and a description of the current critical path(s).

VA’s project schedule minimally meets the best practice of  maintaining a baseline schedule. Officials said that the baseline  schedule is the basis for performance measurement. But while  baseline start and baseline finish dates were provided in the initial  schedule, its activities were too high level, obfuscating the calculation  of detail variances in subsequent schedules. There is also no  evidence of a schedule basis document, which would include a  general overview of the purpose of the schedule, other key basis  information such as an overview of assumptions, rationale for  durations specific to the CMR schedule, and required software  settings. There is also no evidence of performance measuring.

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The Department of Veterans Affairs is seeking to reduce the time veterans wait for decisions on disability claim appeals, which average 3 years for initial appeals.

Five new appeals options are scheduled to become available in February. In our prior work, we made recommendations on how VA could better plan these reforms.

This testimony is an update on VA's progress. The agency is acting on our recommendations, but it has more to do. For example, VA needs to determine how to assess how well the new options work.

VA disability compensation, along with other federal disability programs, has been a topic on our High Risk List since 2003.