According to its 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. In November 2017, VA initiated a pilot test of the new VBA higher-level  review and supplemental claim options. VA Has Addressed Some Aspects of GAO’s Recommendations on Appeals Reform Planning

In our March 2018 report, we found that VA could help ensure successful  implementation of appeals reform by addressing gaps in its planning. We  recommended four actions that VA should take: (1) address all legally  required elements required by the Act; (2) articulate how it will monitor  and assess the performance of the new appeals process compared to the  legacy process, (3) augment its master schedule to manage the project,  and (4) address risk more fully. VA Has Yet to Provide Complete Information on GAO’s Recommendation to Address the Act’s Required Elements

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 most, but not all,  elements required by the Veterans Appeals Improvement and  Modernization Act of 2017. VA’s updated plan, however, continues to only partially address 3  elements related to monitoring implementation and workforce planning,  and now addresses the 1 element related to projecting productivity and  partially addresses the 1 element related to delineating the total  resources. Specifically, the plan had not (1) established  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) articulated additional aspects of  performance important for managing appeals, such as accuracy of  decisions, veteran satisfaction with the process, or cost; (3) provided  important details about what aspects of the new appeals’ performance  would be compared to what aspects of the legacy process’ performance;  or (4) explained how the agency would monitor whether resources are  being appropriately devoted to both the new and legacy appeals  processes and how it will track both sets of workloads. In its May 2018 updated plan, VA addressed some but not all aspects of  this recommendation. However, VA does not intend to establish timeliness goals or balanced  measures for all options until after fully implementing the new appeals  process. We recommended that the Secretary of Veterans Affairs augment the  master schedule for VA’s appeals plan to reflect all activities—such as  modifications to IT 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 its updated plans, VA took steps to develop interim goals and  milestones for monitoring implementation, among other positive actions,  but the master schedule still included gaps in sound practices for project  management. VA has  taken steps to address this aspect of the recommendation. VA’s updated plan states the agency will use  existing resources to implement the new appeals process. In recent discussions on the status of implementing our  recommendations, VA officials indicated they plan to address some of  these issues in the August 2018 update. Until all necessary activities are  accounted for, VA cannot be certain whether key activities are scheduled  in the correct order, resources are properly allocated, and key risks have  been identified, among other sound practices for guiding implementation  and accountability. VA Has Addressed Many, but Not All Aspects of GAO’s Recommendation to More Fully Assess Risk

In our 2018 report, we found that VA’s November 2017 appeals plan  could more fully assess key risks related to implementing the new  appeals process. We recommended the Secretary of Veterans Affairs 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 an assessment plan for RAMP, and testing or  conducting sensitivity analyses of all appeals options—prior to fully  implementing the new appeals process. Since our March 2018  report, VA has taken steps to pilot test the three new Board appeals  options. By taking these steps, VA may be better  positioned to estimate future disability appeals inventories, timeliness,  and resource needs as well as assess risks associated with implementing  a new appeals process. Defining success criteria and articulating how to assess RAMP and  BEAAM. Finally, although VA’s updated plan includes a timeline for testing and  assessing the new processes, VA’s updated schedule indicates that VA is  planning to assess RAMP results between February 15, 2019 and May  10, 2019. Thus, VA may not have comprehensively reflected key risks in its updated  plan. However, VA needs to fully address our  four recommendations to reasonably assure smooth implementation of  appeals reform.
Why GAO Did This Study

VA's disability compensation program pays cash benefits to veterans with disabilities connected to their military service. In recent years, the time needed to complete appeals of VA's decisions on claims has increased. For appeals resolved in fiscal year 2017, veterans 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 further reviewed by VA or appeal directly to the Board. The Act requires VA to submit a plan to Congress and GAO for implementing a new appeals process (which VA submitted in November 2017) and periodic updates (which VA submitted in February and May 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 and what aspects remain unaddressed.
For this statement, GAO reviewed VA's May 2018 updated plan, and interviewed VA officials and reviewed information they provided about steps taken to implement GAO's recommendations.

What GAO Found

In a March 2018 report, GAO assessed the Department of Veterans Affairs' (VA) November 2017 plan for changing how veterans appeal disability claim decisions and found that VA could do more to successfully implement these reforms. The March 2018 report made four recommendations to address planning gaps. Since then, VA has updated its plan and taken some steps to address aspects of these recommendations, but further steps are needed:
Address all legally required elements . GAO reported that VA's plan did not address one and partially addressed four of 22 elements required by the Veterans Appeals Improvement and Modernization Act of 2017 (Act), and recommended VA fully address them all. In a May 2018 update to its plan, VA took steps to address the five elements, such as developing productivity projections and a model to forecast resource needs for processing appeals. These steps address one element related to projecting productivity, and partially address the four remaining elements.
Articulate performance measurement . GAO also recommended VA clearly articulate how it will monitor and assess the new appeals process relative to the legacy process. This recommendation includes specifying timeliness goals for five new appeals options to be made available to veterans, and additional goals or measures of performance, such as accuracy in processing appeals. VA's updated plan states that the agency will develop goals and measures for all appeals options after fully implementing appeals reform. Contrary to sound planning practices, it does not articulate these performance goals and measures now, which would provide a vision for what successful implementation would look like. Lacking this vision, VA does not have an “end state” to guide its implementation and help establish accountability.
Augment project plan . GAO recommended VA augment its master schedule for implementing appeals reform to include all key activities and reflect other sound practices for guiding implementation and establishing accountability. Although VA's May 2018 updated master schedule added activities, it omitted a pilot test of the new Board of Veterans' Appeals (Board) options. More generally, the plan does not reflect interdependencies among activities. Until all key activities are accounted for and the master schedule reflects sound practices, VA cannot provide reasonable assurance that it has the essential information needed to manage its appeals reform implementation.
Address risk fully . GAO recommended that VA's appeals plan more fully address risks in implementing a new process by, for example, testing all appeals options prior to full implementation. In its updated plan, VA stated it will pilot all five new appeals options. By taking these steps, VA should be better positioned to assess implementation risks. However, the updated plan does not have well-defined, measurable criteria for assessing lessons learned from these pilots and does not articulate how well these lessons translate to a broader context. Taking these steps would improve VA's ability to assess and mitigate risks as it implements its reforms.