GAO Report on IDES: Improved Monitoring Needed to Better Track and Manage Performance

Jason Perry

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Attached is the recent GAO report: MILITARY DISABILITY SYSTEM Improved Monitoring Needed to Better Track and Manage Performance.

Some observations and points that should be understood:

1) Things are much faster now than they were under the traditional or "legacy" DES. But, over the last few years, the IDES system has slowed considerably. Still better than under the legacy system.


"DOD and VA established timeliness goals for the IDES process to provide VA benefits to active duty servicemembers within 295 days of being referred into the process, and to reserve component members within 305 days (see fig. 1). DOD and VA also established interim timeliness goals for each phase and stage of the IDES process. The overall timeframes are intended to represent an improvement over the legacy disability evaluation system, which was estimated to take 540 days to complete."
"IDES timeliness has worsened since the inception of the program. Since fiscal year 2008, the average number of days for servicemember cases to be processed and receive benefits increased from 283 to 394 for active duty cases (compared to the goal of 295 days) and from 297 to 420, for reserve component cases (compared to the goal of 305 days)."

"Along with increasing average processing times, the percent of IDES cases awarded benefits within timeliness goals has steadily declined. DOD’s and VA’s current goal is to complete 60 percent of IDES cases on time. In fiscal year 2008, an average of 63 percent of cases for active duty servicemembers and 65 percent for reservists completed the process and received benefits within the timeliness goals; by fiscal year 2011 this was down to 19 and 18 percent respectively."
2) The timelines are blown mainly at the MEB and transition levels.

"When examining timeliness across the four phases that make up IDES, data show that average processing time regularly fell short of goals for three—MEB, Transition, and VA Benefits. For example, for cases that completed the MEB phase in fiscal year 2011, active duty and reserve component members’ cases took an average of 181 and 188 days respectively to be processed, compared to goals of 100 and 140 days. For the PEB phase, processing times increased over time, but were still within the established goal of 120 days. Along with increasing average processing times, the percentage of cases meeting goals for most phases has generally declined (see fig. 6). In particular, the MEB and Transition phases have lower percentages of cases meeting goals than the other phases in most years, especially for active duty cases."

Within the MEB phase, significant delays have occurred in completing medical examinations (medical exam stage) and delivering an MEB decision (the MEB stage). For cases completing the MEB phase in fiscal year 2011, 31 percent of active duty and 29 percent of reservist cases met the 45-day goal for the medical exam stage and 20 percent of active duty and 17 percent of reservist cases met the 35-day goal for the MEB stage. Officials at some sites we visited told us that MEB phase goals were difficult to meet and not realistic given current resources. For example:
• Some military officials noted that they did not have sufficient numbers of doctors to write the narrative summaries of exam results neededcomplete the MEB stage in a timely manner.
One facility noted that while they have 7 doctors, they would need 11 additional doctors and 10 technician assistants to process cases through the initial medical exam and other additional disability specific examinations in a timely manner. Further, officials at another Army base we visited noted that there was a shortage of doctors and DOD board liaisons and that they had difficulty recruiting such staff due to the remote location of the base.
• At all the facilities we visited, officials told us DOD board liaisons and VA case managers had large case loads. While DOD has established a goal of 1 board liaison for every 20 servicemembers,12
the ratios varied widely by military treatment facility with a range from 1:1 as the lowest to the highest of 1:75 according to recent data. Because of high case loads and a reported increase in the complexity of cases, staff at one facility reported a liaison to servicemember ratio of 1:80 and noted that liaisons must often prioritize cases to deal with the most pressing issues first. As a result, cases that might otherwise be quick to process take longer simply because they are waiting to be processed. Liaisons are often working overtime and weekends to keep up with cases."
3) PEB cases have met timelines....but not at the IPEB level.


"Since fiscal year 2008, the majority of cases have completed the PEB phase under the goal of 120 days, however, PEB timeliness has still worsened over time. In 2011, 78 percent of active duty and 62 percent of reservist cases that completed the entire IDES process met the PEB goal.
The average processing time was 93 days for active duty servicemembers and 116 for reservists (see table 2).
Despite meeting the overall PEB goal in fiscal year 2011, established goals were not met for any of the interim PEB stages, including the informal PEB and VA rating stages which are the two stages all servicemembers must complete. For all cases that completed the PEB phase in fiscal year 2011, only 38 percent of active duty and 38 percent of reservists’ cases received an informal PEB decision within the 15 days allotted. Further, only 32 percent of active duty and 27 percent of reservist cases received a preliminary VA rating within the 15-day goal." (emphasis added).
4) Appeals do not seem to have an overall impact on timelines (but probably do impact those cases with appeals).

"Also during this phase, IDES planners allocated the majority of overall PEB processing time (75 out of the 120 days) for appeals—including a formal PEB hearing and a reconsideration of the VA ratings. According to officials, while the three appeal stages do not happen for every case, appeals can significantly increase processing times for any one case. However, only 20 percent of cases completed in fiscal year 2011 actually had any appeals; calling into question DOD and VA’s assumption on the prevalence and average effect of appeals, and potentially masking processing delays in other mandatory parts of the PEB phase."
5) The Transition phase has taken almost double the time set out in the guidelines.

"The transition phase has consistently taken longer than its 45-day goal—almost twice as long on average. While processing times improved slightly for cases that completed this phase in fiscal year 2011 (from 79 days in fiscal year 2010 to 76 days in fiscal year 2011 for active duty cases), timeliness has remained consistently problematic since fiscal year 2008 (see table 4)."
"Servicemembers may also take earned leave time—to which they are entitled—before separating from the service. For example, an Army official said that Army policy allows servicemembers to take up to 90 days of earned leave prior to separating, and that average leave time was about 80 days. Because many of these activities can occur simultaneously or in small intermittent segments of time, DOD officials said it is difficult to track which activities servicemembers participate in or determine how much time each activity takes. DOD is exploring options for better tracking how time is spent in this phase. Because a potentially substantial amount of the time in this phase may be for the personal benefit of servicemembers, DOD recently began reporting time in IDES with and without the transition phase included."
6) The satisfaction element seems to be "broken"- wide variance between measure used by GAO and DoD.


"In addition to timeliness, DOD and VA evaluate IDES performance using the results of servicemember satisfaction surveys. In principle, all members have an opportunity to complete satisfaction surveys at the end of the MEB, PEB, and transition phases; however, under current survey procedures servicemembers become ineligible to complete a survey for either the PEB or transition phases if they did not complete a survey in an earlier phase. Additionally, servicemembers who start but do not complete a phase are not surveyed. As such, DOD may be missing opportunities to obtain input from servicemembers who did not complete a prior survey or exited IDES in the middle of a phase.16 Further, response rates may be affected because DOD does not survey servicemembers once they separate from the service and become veterans. While it is not necessary for DOD to survey all servicemembers at the end of every phase,17
the percentage and characteristics of servicemembers covered by the survey (i.e., who completed a phase and were ultimately interviewed) may be insufficient to establish that the survey results are representative of servicemember satisfaction, especially for later phases. (See table 6 for response and coverage rates.) DOD officials recently told us that they will consider alternative survey eligibility requirements, including working with the Office of Management and Budget for permission to interview veterans. (For additional information regarding the timing of the survey, see app. II)."

"Our calculation is a more conservative measure of satisfaction, because it rules out the possibility that a servicemember is deemed “satisfied” even when he or she is dissatisfied on one or more questions in the scale. While not incorrect, DOD’s scale can mask pockets of servicemember dissatisfaction. For example, an individual may indicate that he or she is very dissatisfied with one phase of the program, but satisfied with other phases, and the overall satisfaction score can be the same as one for a servicemember who is generally satisfied across all phases of the process. Measuring satisfaction, or even dissatisfaction, in different ways may provide a more complete picture of satisfaction and how it varies in different circumstances, and thus may reveal areas where DOD could focus on improving management and performance."
While comprehensive and well written on the points addressed, I think the GAO Report did not address in enough detail certain issues or perhaps missed important issues. Here are my thoughts, questions, or observations.

1) The MEB portion of the process was not sufficiently addressed. I agree with the conclusion that the MEB process is at fault for missing IDES timelines. However, I think that more analysis of this step is required. Here are my comments:

A major, systemic, and problematic point is incomplete MEBs. That is, anecdotally, as an attorney who sees many MEBs in the course of representation, a continuing problem is that MEBs (and Narrative Summaries) do not adequately cover all of member's conditions. When this happens it is much more likely that a member will have to appeal/rebut and demand a formal hearing based on inadequate evaluations.

Legal advice, and more importantly, adequate legal advice, is not provided to most members early in the process. This causes many members to agree with their MEBs when they are inadequate. Later in the process (at the IPEB level or after referral to the FPEB), many members have to fight to have their conditions addressed. The requirement to fully address members conditions is contained in statute and regulations. (See, e.g., 10 USC 1216a, and DoDI 1332.38 - as amended, but yet not updated formally several years later, by the DoD Policy Memorandum Implementing the Disability Related Provisions of the 2008 NDAA, dated 14 OCT 2008).

Imagine the efficiencies if correct documentation were submitted early in the process? This would save time at both the IPEB, the VA rating activity, and the FPEB level (and, in many cases would negate the need for the FPEB).

2) There was no comment on the post-separation/retirement process.

Getting ratings and dispositions correct is a major goal of the entire process. The GAO report, and indeed, the entire IDES process, does not address what happens when a member gets a poor or inaccurate initial outcome. This should be addressed, with cases tracked and metrics applied, to ascertain the success of the entire system. Only focusing on cases that are processed without recourse to appeals is a poor measure of the entire system.

A major fault, also, is a lack of assessment of appeals (whether they be at the BCMR or in Federal Court).

3) Timelines should not be more important than an accurate outcome.

The overall thrust of this GAO Report was on timeliness. A big missing piece of the "puzzle" (and it should not be a puzzle- the goal should be timely and, more importantly, accurate adjudications), is how the military and the VA are doing with accuracy of outcomes and ratings.

I have seen an increase with concern for meeting timelines in my cases before the PEBs. This is correct if the only goal is to move cases quickly. However, accuracy should not be sacrificed for speed. A case adjudicated quickly, but incorrectly initially, will ultimately result in one of two outcomes: A case that is finally decided incorrectly, thereby denying the member benefits he or she is due, or a case that is incorrectly adjudicated and then appealed, greatly increasing costs to both the member and the government and denying those Veterans who are successful in their appeal their due benefits until a later date. Timeliness is important- however, not at the sacrifice of accuracy.
 

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usafaviator

PEB Forum Veteran
I have seen an increase with concern for meeting timelines in my cases before the PEBs. This is correct if the only goal is to move cases quickly. However, accuracy should not be sacrificed for speed. A case adjudicated quickly, but incorrectly initially, will ultimately result in one of two outcomes: A case that is finally decided incorrectly, thereby denying the member benefits he or she is due, or a case that is incorrectly adjudicated and then appealed, greatly increasing costs to both the member and the government and denying those Veterans who are successful in their appeal their due benefits until a later date. Timeliness is important- however, not at the sacrifice of accuracy.
Catch 22....they want to speed the process up to meet suspenses, but they don't want to speed the process up and risk decreased accuracy.
 

mike762414

PEB Forum Veteran
Registered Member
So basically, they are trying to cover the sheer amount of SMs who are dissatisfied with the process, byt skewing the numbers with other meanings, to make it seem better than it really is. Hmm, sound like a political cover up procedure to anyone else?
 
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