| Once a veteran has achieved service connection | | | | Mental Disorders (DSM). See 38 C.F.R. 4.125(a). |
| for his or her disability, the next question to be | | | | The DSM recognizes the differences among the |
| addressed is somehow evaluating (or rating) the | | | | various psychiatric disorders (e.g., psychoses, like |
| severity of the symptoms to determine the | | | | schizophrenia, and neuroses, like PTSD). Some |
| appropriate level of compensation. The VA uses | | | | psychiatric disorders are organic in natures, some |
| what has evolved from a 1945 Schedule for | | | | are acquired and some are congenital. Some are |
| Rating Disabilities, which is codified at 38 C.F.R. Part | | | | chronic, some are intermittent and acute. Yet the |
| 4 (known as the "rating schedule"). The rating | | | | rating schedule completely ignores such |
| schedule is designed to compensate veterans | | | | differences. Instead, it lumps all psychiatric |
| based on the average impairment of their | | | | disorders together and evaluates them under the |
| industrial (or earning) capacity. Explained simply, | | | | exact same list of symptoms. See 38 C.F.R. |
| the rating schedule is a collection of disabilities, | | | | § 4.130. This is both inherently inconsistent |
| grouped by body systems that delineate a group | | | | and illogical. The DSM diagnostic criteria are |
| of different symptoms in an increasing order of | | | | expressly adopted, but fundamental differences |
| severity. Percentages of disability are assigned to | | | | among various psychiatric disorders are virtually |
| each level of symptoms from zero | | | | ignored. |
| (non-compensable disabling) to one hundred | | | | Consequently, the VA should initially undertake a |
| percent (totally disabling) in ten percent | | | | comprehensive review of the rating schedule in |
| increments. Each disorder is assigned an identifying | | | | concert with medical, psychiatric and vocational |
| diagnostic code. If a particular disorder is not | | | | experts. New rating criteria should be developed |
| listed, it is rated by analogy to a listed disorder | | | | that take into account not only impairment in |
| that most closely approximates it. See 38 C.F.R. | | | | industrial capacity, but also the psychiatric effects |
| § 4.20. Multiple disability ratings are combined | | | | of physical disability and the effect of physical and |
| according to a complex tabulation matrix, rather | | | | psychiatric disability on the veteran's quality of life. |
| than added together, to produce a combined | | | | VVA often advocates for a "Veterans' Health |
| rating of all service-connected disabilities. See id, | | | | Care System", rather than a health care system |
| § 4.25. Essentially, the adjudicator reviews | | | | for veterans, based on the unique nature of |
| the medical evidence of record, finds the | | | | veterans' disabilities. Such disabilities are incurred in |
| compatible diagnostic code and compares the | | | | unique ways and have unique consequences. It is |
| clinical evidence of the severity of the veteran's | | | | the very "veteran-ness" of a veteran's disability |
| current symptoms with the list of symptoms | | | | that demands a system of evaluating disabilities |
| under that diagnostic code. The commensurate | | | | that keeps pace with technology, current medical |
| rating percentage is assigned. Each year, Congress | | | | standards and practices, socioeconomic factors |
| sets the monetary level of compensation for | | | | and individual self-esteem. |
| each percentage level. | | | | Once the rating schedule has been adequately |
| Anyone would be hard pressed to say that the | | | | revised, it may be utilized just as it is today. It |
| VA's rating schedule even approaches perfection. | | | | works logically, the documented symptomology is |
| It is antiquated, imprecise, and vulnerable to great | | | | compared with the diagnostic criteria and a |
| subjectivity and does not take into account the | | | | commensurate rating results. As long as Congress |
| diminution of a disabled veteran's quality of life. | | | | sets adequate payment levels for the various |
| However, given the uniqueness of the veterans' | | | | ratings (which, in equity, should be higher than |
| benefits system, the rating schedule, in principle, | | | | they currently are), veterans should receive |
| does serve its essential purpose. With certain | | | | adequate compensation. |
| refinements, the rating schedule may be able to | | | | Meaningful Accountability and Training of VA |
| live up to its original expectations. | | | | Adjudication Personnel |
| Part of the current problem with the rating | | | | It is axiomatic that a system is only as good as |
| schedule is that it was formulated at a time when | | | | the people who run it. The VA disability |
| disabled veterans were returning home from | | | | compensation system can be flawlessly designed; |
| World War II. Veterans were universally admired | | | | however, if the personnel who operate it not are |
| and their disabilities were, for the most part, | | | | not adequately trained, supervised and held |
| clear-cut. Orthopedic injuries, amputations, | | | | accountable for repeated errors, the system will |
| psychiatric disorders; these are known quantities. | | | | grind toward disaster. |
| Since World War II, however, veterans have | | | | In a recent rather disturbing press conference, |
| returned with more insidious illnesses. Diseases | | | | VA Secretary R. James Nicholson, Inspector |
| such as hepatitis C and HIV (which were unknown | | | | General Richard Griffin and Under Secretary for |
| until decades later), diseases as the result of | | | | Benefits Daniel Cooper, announced a May 19, |
| exposure to chemical, biological and/or radiological | | | | 2005, VA Inspector General's (IG) Report, entitled |
| agents, mysterious syndromes such as Gulf War | | | | "State Variances in VA disability Payments". The |
| Illness and chronic fatigue syndrome, were not | | | | report was generated following newspaper |
| contemplated by the framers of the original rating | | | | reports of low disability compensation payments |
| schedule. | | | | for Illinois veterans as compared to veterans in |
| In the 1940s, the United States was more of an | | | | other states. In response, several Illinois |
| industrial society. Quite naturally, the emphasis | | | | Representatives requested the VA investigate |
| within the VA disability compensation scheme was | | | | the disparity. Following the investigation, the IG |
| on the impairment of a veteran's earning capacity. | | | | conceded that variances in average disability |
| However, times have changed. Advances in | | | | compensation payments by states have existed |
| medicine have allowed for qualitatively greater | | | | for decades, and stated that "[p]ayments by |
| treatment, cures and rehabilitation. Medical | | | | state are affected by legislated pay increases, an |
| knowledge has increased exponentially in the last | | | | antiquated rating schedule, veteran demographics |
| five decades, diagnostic tools have been refined | | | | and inconsistent rating decisions [including] claims |
| and today's medical professionals are practicing | | | | processing practices, disability examinations, |
| medicine in ways that could not have been | | | | timeliness pressures, staffing levels, rate |
| envisioned by doctors even two generations ago. | | | | experience and training, and fraud." Executive |
| Yet the rating schedule remains static. While new | | | | Summary and Management Comments of State |
| disorders have been added from time to time and | | | | Variances in VA Disability Compensation |
| the symptoms listed in the diagnostic codes have | | | | Payment¸ IG Report No. 05-00765 (May 19, |
| been updated here and there, it is long past time | | | | 2005) at x. The IG further concluded that "some |
| for a wholesale revision of the rating schedule to | | | | disabilities are inherently prone to subjective rating |
| bring it in synchronization with the state of | | | | decisions, especially for conditions such as PTSD |
| modern medicine and American society. | | | | where much of the information needed to make |
| One example of the inadequacy of the current | | | | a rating decision is not physically apparent and is |
| rating schedule is rather glaring. VA regulations | | | | more susceptible to interpretation and judgment |
| have historically adopted the nomenclature and | | | | [which] leads to inconsistency in rating decisions." |
| diagnostic criteria of the American Psychiatric | | | | Id. |
| Association's Diagnostic and Statistical Manual of | | | | |