Better Oversight Needed of Accessibility, Safety, and Cleanliness at Contract Facilities Offering VA Disability Exams
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Summary
When a veteran files a claim for disability benefits, a medical exam may be necessary. If the nearest VA medical center cannot conduct the exam, a contract exam vendor is utilized. Medical Disability Exam contracts require contract exam facilities to comply with the American with Disabilities Act (ADA) and Occupational Safety and Health Administration (OSHA) standards.
In response to accessibility, safety, and cleanliness concerns documented in customer satisfaction surveys, the VA Office of Inspector General (OIG) directly inspected facilities and reviewed Medical Disability Examination Office (MDEO) oversight of vendors. The OIG identified one or more ADA and OSHA deficiencies at 114 of the 135 exam facilities visited. MDEO relied on vendors to self-certify compliance with ADA and OSHA standards; however, MDEO did not provide necessary oversight.
The OIG noted four specific oversight deficits. First, MDEO lacked independent access to facilities, depending on vendors for locations to assess compliance issues. Second, MDEO relied on vendors to distribute their own exam satisfaction survey cards. Third, at the time of the review, MDEO lacked formal standardized procedures and training for inspections. Fourth, MDEO required exam vendors to inspect and self-certify facilities, yet vendors stated they relied on self-reporting or photos from subcontractors. Further, MDEO did not verify ADA and OSHA compliance despite receiving complaints from veterans.
While the OIG acknowledges the improvement plans MDEO leaders shared during the review, the OIG made nine recommendations to the under secretary for benefits, including that MDEO more closely monitor inspections, visit sites, use a revised inspection checklist, maintain a facilities inventory, and have independent access. MDEO and vendors should also ensure accessibility prior to scheduling. Finally, inspection processes and training should be standardized and vendor contracts enforced. Until oversight improves, veterans are at risk of harm and benefits compensation may be delayed.



Formalize the executive director’s intent by requiring the submission to the OIG of a related plan and documentation of progress on implementing VA’s maintenance of an independent and updated list of contract facilities.
Comply with the requirements of the customer satisfaction survey contract to route exam comment cards directly between the survey vendor and veteran.
Develop and implement formal standard operating procedures for the contract exam facility site visits detailing roles, responsibilities, objectives, and monitoring.
Update the Medical Disability Examination Office site visit checklist to include a focus on specific ADA and OSHA criteria required by contracts with exam vendors.
Complete a standardized training plan for staff who conduct site visits at contract exam facilities to include ADA and OSHA compliance.
Ensure the Medical Disability Examination Office is conducting complaint-based contract facility inspections.
Enforce contractual requirements for vendors to conduct inspections and recertify all facilities to ensure ADA and OSHA compliance.
Review and analyze all veteran complaints related to exam facilities received through all entities and perform complaint-based site visits or create action plans, as necessary.
Make certain that the Medical Disability Examination Office develops a plan with the vendors to determine if each veteran seeking an exam requires accessibility arrangements prior to scheduling.