NCD Letter to Allison A. Hickey, Veterans Affairs Under Secretary for Benefits

February 11, 2014

General Allison A. Hickey
Under Secretary for Benefits
U.S. Department of Veterans Affairs
810 Vermont Avenue, NW
Washington, DC 20420

Dear General Hickey:

On behalf of the National Council on Disability (NCD), I thank the Department of Veterans Affairs (VA) Veterans Benefits Administration (VBA) for demonstrating commitment to oversee and administer earned benefits to the men and women who have given proudly through their military service to this nation. NCD applauds the concerted efforts undertaken to reduce the backlog of disability claims benefits applications and appeals. Your personal ongoing commitment to ensure the reduction of the backlog and resolution of applications for all Veterans seeking benefits within 125 days by January of 2015 is a significant and meaningful promise. NCD has recently issued its report, “Clearing the Backlog and Facilitating Benefits for Veterans with Disabilities” (, examining the critical issue of claims backlog issues, and is privileged to have submitted its recommendations to your office for consideration.

NCD strongly supports all means for ensuring every Veteran an equal opportunity to file a disability benefits claim or appeal. As a federal partner sharing the VA’s commitment to America’s service members and their families, NCD respectfully calls attention to the proposed changes in the disability claims applications process for all Veterans with service-connected disabilities. (See Federal Registration notification at

The critical nature of an inclusive filing opportunity is underscored by the omnibus bill before Congress, which notes that: "As of Jan. 11, 2013, the number of pending disability benefits claims stood at 686,861, over 58 percent of which have been pending for over 125 days." While the goal to streamline system processes is commendable, NCD requests that the VA and VBA seek ways to build upon and ensure inclusive principles as new policies and practices are developed. The claims processes available to all Veterans with disabilities should clearly reflect the needs of various service member groups, the impact of their service connected injuries or disabilities upon access to filing processes, their methods of transition to Veteran status, and their locations. The proposed changes must embrace and support principles of equal opportunity for participation in the claims process by the men and women of National Guard and Reserve units and other Veterans with disabilities who may be without or have limited access to the Internet or computers because they reside in rural areas, are aging or hospitalized, or are endangered by homelessness or other desperate conditions. NCD emphasizes its concern that the most vulnerable of the Veterans’ disability community be fully supported and enabled to file and manage their claims in order to return to healthy and fulfilled lives.

NCD also appreciates the positive impact of the VA’s online complaint system for student Veterans created in response to President Obama’s executive order (April 2012) to combat and report fraud, waste and abuse. Your “Principles of Excellence” program serves as a great avenue for Veterans to file complaints if their schools or employers are failing to follow the agreed guidelines. In particular, Veterans with disabilities can use the system to identify programs that failed to provide necessary services and supports following their recruitment.

NCD is grateful for the commitment of the VA and VBA to inclusive principles critical to equal access for Veterans with disabilities. NCD offers its Council Members and staff to serve as a resource to VA during your deliberations about changes to the general disability claims filing processes in the interests of Veterans and their families.


Jonathan Kuniholm

National Council on Disability


National Council on Disability • 1331 F Street, NW, Suite 850 • Washington, DC 20004