VA Caregiver Support Strategies--Congress approved?

Email sent to VA officials and Congressional offices:


We’ve obtained information from the “Caregiver Support Program Hub” that is quite alarming, but it’s great that the Hub is now open to all VA staff!  There are multiple areas of concern within the “Transition Plan” as noted in the attached document.  

  1. Identify cases that      will be d/c due to Veteran currently working.”  This is a red      flag for all as there is NOTHING within that law that prohibits veterans      from working.  Veterans and caregivers have long understood that      veterans COULD be employed as long as all the eligible veteran’s needs      were met.  There are multiple areas in which a veteran can be      eligible and require assistance that does not prohibit the veteran from      working.  

i. Code of Federal Regulations FINAL RULE dated January 9, 2015, page 1367, last paragraph far left row: In describing the eligibility criteria in the Senate bill, the joint statement states that ‘‘[s]everely injured veterans are defined as those who need personal care services because they are unable to perform one or more independent activities of daily living.’   This is VERY CLEAR, a veteran CAN qualify due to needing assistance performing ONE (or more) activities of daily living; requiring assistance with ONE ADL does NOT make a veteran unable to work.

  1. Example: veteran      requires assistance with medication management; veteran requires morning      and night medication; veteran is unable to safely and interpedently      self-medicate per the veteran’s record.  This veteran WOULD qualify      for the program at a tier 1 if the veteran ONLY needed assistance with      medication management.  This veteran would be able to work and still      have their needs met.  
  2. Example: veteran      requires assistance with medication management; veteran requires      assistance to REMEMBER to take medication morning and night.  Veteran      is able to physically TAKE the medication but does not REMEMBER to take      medication; this veteran WOULD qualify for the program at a tier 1.       HOWEVER, if a veteran needs reminding to take medication it is likely that      the veteran will need assistance with other areas such as REMINDERS to      bathe, dress, groom, etc.; this is called a REMINDER PROMPT and would be individually     scored at 1 under the Scoring Methodology as approved by Congress.       Please keep in mind that VACO is also attempting to change the Scoring      Methodology, has Congress approved this change?

ii. Please see the attached Tier 3 employment simulation document we have created to show that a veteran CAN work and still qualify for TIER 3 on this program.

  1. Example: veteran      recently got out of the service and is simply staying afloat, not really      able to work but is struggling day in and day out to provide for their      family.  This veteran needs assistance but also knows that he/she      needs to keep food on the table.  Just because the veteran is working      doesn’t mean that it is not a struggle, it doesn’t mean they’re not      working without accommodations or that it is “typical” work.  

     Is it discrimination if a veteran has an ADA diagnosis and/or reasonable accommodations to suddenly not be allowed in this program?  Are we no longer considering reasonable accommodations for employment?  What about those who are grandfathered into this program who are already in the program and employed?  It is unethical to abruptly revoke veterans due to employment simply because VA chooses not to allow these veterans into the program OR because VA wishes to adjust their budget, please take note that the law is not written to make these veterans ineligible.  

              Who made the decision to discharge/not allow any veterans who are employed?  Was it Dr. Kaplan?  VACO?  Congress?  Asking because the law is clear, the Congressional officials we work with have made it clear that the program is intended to provide support to veterans who need it but do NOT qualify for a nursing home and who CAN still work, even if that means with accommodations.  

  1. Cross train      staff on areas where they need help: CAT, home visits, 90 monitoring.”       Shouldn’t ALL staff be trained on the Caregiver Program?  Training      has been pushed for quite some time and advocates have been told that      training all CSP employees is “a tall ask” as recently as June 2019 by Mr.      Jason Beardsley.  Why would there be CAT training if the new system      is CARMA?  Is CAT still going to be the way everything is uploaded to      the grid?  Is CARMA going to be the OVERALL overview comprehensive      system where you capture everything in CAT plus more?  Are we doing      away with CAT?
  2. CARMA  launched as the new CSP      program.  How can VA deploy a program that has not been properly      tested?  Without proper testing, it opens the potential for issues      but with a larger group of veterans.  Proper testing would require a      12 month pilot, per MISSION.  CARMA was purchased “off the shelf”,      per Mr. Beardsley June 2019, the system required a lot tweaking and he      would be surprised if it was even up by summer  2020.  So, are      we deploying this CARMA system October 1, 2019 that we don’t even know if      it will properly handle the caseload with expansion?
  3. “Complete transition by 9/27/2019.”       What      transition is to be completed by 9/27/2019?  The revocation of all      employed veterans?  The cross training of staff?  The launch of      CARMA?  The moratorium being lifted?  Are veterans who are      employed to be discharged immediately or after the moratorium is lifted?
  4. What is the mission of      this program?  It seems the mission has changed and is no longer to      provide assistance to veterans who need it but rather to limit access.       It seems the HUMAN FACTOR has been completely removed from this program.       Every veteran has to be looked at individually, what works for one will      not work for all, what applies to one doesn’t apply to all.  

These processes have not been thought out and the after effects WILL be detrimental to many families.  This lack of understanding but making of decisions is all at the expense of veterans who are already struggling.  Per Brian Masts statements, “There are 435 representatives sitting in the Capitol. Everyone, of which is saying, on a weekly basis, they want to effect 22 suicides a day, they want to make the VA a better place for people to get their healthcare needs, they want to make it a better place.”  To be clear, the current actions taking place within this program, the current plans, will ensure there are more than 22 a day and it will not only be veterans but caregivers as well.  These actions effect FAMILIES who are being put in a situation where they see no other way out because without this program they cannot properly care for the veteran.

Very respectfully,

Holly Ferrell

National Appeals Director

Veteran Warriors, Inc.

P: 727.247.8141 Ext. 7

F: 727.255.5085


Email attachments

VA Internal Strategy Documents :

Plans for transition

Caregiver Support Hub (internal use)

CARMA Champions (internal contacts)

CFR (Law) stating veteran's qualify for the program if they meet ONE (or more) needs for ADLs.

VA Waives Veterans' Rights to Privacy, Which Rights Are Next?