This is a brief excerpt from a letter we were copied on which was sent from Daniel L. Cooper, Under Secretary of Veterans Affairs for Benefits, to our U.S. Congressman. This was in regards to the fact that the VA rating software rated my husband at 90%, but the Combined Rating Table rated him at 95% = 100%, a situation that was corrected by the Appeals Management Center last August, apparently unbeknownst to Secretary Cooper, since his letter dated October 25th insisted that his staff had researched the situation and came to the same absolutely correct conclusion as that which the AMC had already deemed was in error and has since corrected. I'm going to insert my comments in red...
"Historically, combined evaluations were determined by manual use of the Combined Ratings Table (this is the only codified method of rating disabilities contained in 38 CFR). With the Federal Government's increased use of information technology, VA developed a software application, Rating Board Automation 2000 (RBA 2000), which performs that function (which apparently was never codified). RBA 2000 implements the Combined Ratings Table but does not replace it (this is semantics, what is the difference, when the VA chooses to take the result yielded by its uncodified software program over the results of the Combined Ratings Table? This is a smokescreen to avoid submitting the software to the codification process). There is no prohibition against the use of software applications to implement government functions (come to think of it, there isn't a specific prohibition against determining ratings by throwing darts at a dartboard, either, which follows this same rationale). RBA 2000 is engineered to be in compliance with the Code of Federal Regulations (Who says? Who's checked that it's in compliance? We have only the VA's word for it, and don't we feel comfortable doing that!) and is the only software program used by VA to combine disability evaluations."
At the risk of repeating myself, please everyone, check your ratings against the actual Combined Ratings Table in 38 CFR. Please don't trust these quickie Excel spreadsheet programs, they do not always give you the correct rating, especially in borderline cases depending on tenths of a point. It took me almost a year and Congressional intervention to hear the VA admit it used a software program for this purpose, and a letter from the Under Secretary to actually tell us what the name of it was. This is not information made easily available to the veteran, which begs the question - - why?
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vaf
This is a brief excerpt from a letter we were copied on which was sent from Daniel L. Cooper, Under Secretary of Veterans Affairs for Benefits, to our U.S. Congressman. This was in regards to the fact that the VA rating software rated my husband at 90%, but the Combined Rating Table rated him at 95% = 100%, a situation that was corrected by the Appeals Management Center last August, apparently unbeknownst to Secretary Cooper, since his letter dated October 25th insisted that his staff had researched the situation and came to the same absolutely correct conclusion as that which the AMC had already deemed was in error and has since corrected. I'm going to insert my comments in red...
"Historically, combined evaluations were determined by manual use of the Combined Ratings Table (this is the only codified method of rating disabilities contained in 38 CFR). With the Federal Government's increased use of information technology, VA developed a software application, Rating Board Automation 2000 (RBA 2000), which performs that function (which apparently was never codified). RBA 2000 implements the Combined Ratings Table but does not replace it (this is semantics, what is the difference, when the VA chooses to take the result yielded by its uncodified software program over the results of the Combined Ratings Table? This is a smokescreen to avoid submitting the software to the codification process). There is no prohibition against the use of software applications to implement government functions (come to think of it, there isn't a specific prohibition against determining ratings by throwing darts at a dartboard, either, which follows this same rationale). RBA 2000 is engineered to be in compliance with the Code of Federal Regulations (Who says? Who's checked that it's in compliance? We have only the VA's word for it, and don't we feel comfortable doing that!) and is the only software program used by VA to combine disability evaluations."
At the risk of repeating myself, please everyone, check your ratings against the actual Combined Ratings Table in 38 CFR. Please don't trust these quickie Excel spreadsheet programs, they do not always give you the correct rating, especially in borderline cases depending on tenths of a point. It took me almost a year and Congressional intervention to hear the VA admit it used a software program for this purpose, and a letter from the Under Secretary to actually tell us what the name of it was. This is not information made easily available to the veteran, which begs the question - - why?
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