This week, the Elizabeth Dole Foundation (EDF) submitted comments to the U.S. Department of Veterans Affairs over its proposed rules to improve and standardize the VA Program for Comprehensive Assistance for Family Caregivers (PCAFC), more commonly known as the VA Caregiver Program. EDF’s recommendations were developed by our policy experts, in collaboration with our Dole Caregiver Fellows who represent the 5.5 million Americans providing care to a loved one wounded, made ill, or injured during their military service. While VA’s proposed rules address many challenges for which EDF has long advocated, we remain concerned regarding how the department plans to implement such a robust and ambitious program for millions of veteran caregivers nationwide, given the two years of delays implementing the VA Mission Act of 2018.
Sen. Elizabeth Dole and our EDF team worked tirelessly with our partners on the Hill to pass the VA Mission Act, which pledged an unprecedented level of support to family caregivers of all veterans, regardless of when they served. Since passage of the act in June 2018, we have been anxiously awaiting the new regulations for the VA caregiver program, which were set to outline exactly how the department planned to finally expand caregiver benefits to the approximately 4.4 million Americans caring for veterans who served before Sept. 11, 2001.
Unfortunately, the last two years have been fraught with delays and administrative challenges; aging IT infrastructure has become a significant obstacle to expanding the caregiver program, effectively blocking millions of potential applicants from receiving critical support. The proposed rules released last month still do not hold VA accountable for a date for full expansion. Given the pressing needs of caregivers for pre-9/11 veterans, VA should move urgently to designate a specific date for expansion and, until that date is determined, publish monthly updates on progress towards publishing a final rule and full expansion.
Additionally, VA must address the biggest concern of caregivers — the process for evaluating program applicants. Since the caregiver program launched in 2011, VA has not used a consistent protocol for evaluating applicants, which has led to frustrations and anxiety across the caregiver community. While VA has identified clinical tools for assessment and established centralized eligibility teams to oversee this process, none of these important changes are included in the proposed rules. These processes and tools should be included for public comment. Furthermore, VA should increase transparency and consistency for how these tools will be used by making them publicly accessible. Most of the challenges faced by caregivers occur when an individual VA medical center or integrated service network releases information that is inconsistent with national guidance.
Despite these challenges, a number of the proposed changes represent a welcomed shift to the program and align with long-advocated reforms. We specifically commend VA for adopting many of the recommendations supported by the Veterans’ Family, Caregiver, and Survivor Advisory Committee chaired by Senator Elizabeth Dole. The work of this advisory committee can be seen throughout the proposed regulations, including the addition of a 60-day notification period when a caregiver and veteran are discharged from PCAFC and a reduction in annual reassessments for caregivers of the catastrophically injured who are expected to need the same amount and degree of care over time. While technical in nature, these changes will have a profound effect on the lives of veteran caregivers nationwide.
We also strongly support VA’s proposal to expand program eligibility beyond caregivers of veterans with injuries to include service-connected veterans whose disabilities are caused by illnesses. This represents a policy change that EDF and our caregiver network have long advocated. Often times, caregivers supporting veterans with cancer, ALS, and other diseases have not had access to this program, and we thank Secretary Wilkie and VHA’s Executive in Charge, Dr. Stone, for spearheading these changes to support veteran families nationwide.
As always, EDF is committed to working with VA to ensure all qualified caregivers can access the support and benefits available to them. We look forward to continued collaboration with our caregivers and partners to ensure VA is equipped to provide the highest quality of care and support to our nation’s hidden heroes.
Steve Schwab, CEO, Elizabeth Dole Foundation.
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