Comment Responses - 30-day FRN - 2900-0798 - Part 7

30 Day FRN 2900-0798_Additional Comments Rec'd 10-19-24_VA Responses.docx

Veteran/Beneficiary Claim for Reimbursement of Travel Expenses (VA Form 10-3542 and BTSSS)

Comment Responses - 30-day FRN - 2900-0798 - Part 7

OMB: 2900-0798

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30 Day FRN 2900-0798-Veteran Beneficiary Claim for Reimbursement of Travel Expenses 

Federal Register :: Agency Information Collection Activity Under OMB Review: Veteran/Beneficiary Claim for Reimbursement of Travel Expenses 

OMB received 37 public comments on 10/19/24. VTP received on 11/7/24 for response.

Attachments Received:



  1. PC-202402-2900-022-101924-094434-1

Add the costs of BTSSS to your ICR and provide details.

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-094734-1

See "Veteran Travel Reimbursement Headaches Prompt VA to Pursue New Options for Claims Filing, Processing" at https://www.military.com/daily-news/2024/02/27/veteran-travel-reimbursement-headaches-prompt-va-pursue-new-optionsclaims-filing-processing.html

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-095055-1

Reference proposed VA Form 10-3542, instruction 6 and See "Montana VA Makes Appointment Verification Letter More Available to Veterans" at https://www.va.gov/montana-health-care/stories/montana-va-makes-appointment-verification-lettermore-available-to-veterans/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-095225-1

See "New Online VA Travel Reimbursement Program Is Failing Veterans, Inspector General Finds" at https://www.military.com/daily-news/2023/06/13/new-online-va-travel-reimbursement-program-failing-veterans-inspector-

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-095403-1

See "VA’s online claims system comes under fire in House subcommittee" at https://thehill.com/homenews/house/4718530-va-travel-claims-system-under-fire-house/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-095546-1

See "Veteran pleads for help as VA leaders struggle to keep pace with reimbursement claims" at https://www.alaskasnewssource.com/2024/04/12/veteran-pleads-help-va-leaders-struggle-keep-pace-with-reimbursement-

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-100231-1

See BT-OIT Update 20240425 attached.

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-100411-1

See "BTSSS Status Update Final to OIG 20240410" attached.

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-100936-1

Reference proposed VA Form 10-3542 instruction 6 and see "Add an appointment 20241010" attached.

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-101717-1

Reference proposed VA From 10-3542 instruction 6 and see "Verification of Community Care Appointment" at https://www.va.gov/files/2023-11/Verification%20of%20Community%20Care%20Appointment.pdf and attached.

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-102232-1

Reference proposed VA Form 10-3542 instruction 6 and see "BTSSS brochure August 2022" at https://www.va.gov/files/2022-08/BTSSS%20brochure%20August%202022.pdf and attached.

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-102759-1

Reference proposed VA Form 10-3542 instruction 6 and see "Beneficiary Travel Mileage Reimbursement Tri-Fold" at https://www.tn.gov/content/dam/tn/veteranservices/learning/powerpoints/2024-quarterly-training/2024-spring-regionaltraining/veterans-transportation-program-presentation/Benficiary%20Travel%20Mileage%20Reimbursment%20Tri-Fold.pdf and attached.

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-103209-1

Reference proposed VA From 10-3542 instruction 6 and see "Community Care Travel Reimbursement" at https://vetsbenefits.net/community-care-travel-reimbursement-t201799.html#google_vignette

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-103412-1

See "Maine Delegation Calls on VA Secretary to Fix Travel Reimbursement System" at https://golden.house.gov/media/press-releases/maine-delegation-calls-on-va-secretary-to-fix-travel-reimbursement-system

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-104012-1

See "Lab test, one way or round trip travel reimbursement?" at https://community.hadit.com/topic/87307-lab-test-one-way-orround-trip-travel-reimbursement/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-104137-1

See "VA Tallahassee and Gainesville refuse to mail glasses or provide travel pay" at https://community.hadit.com/topic/67567-va-tallahassee-and-gainesville-refuse-to-mail-glasses-or-provide-travel-

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-104500-1

See "STATEMENT OF JON RETZER DAV ASSISTANT NATIONAL LEGISLATIVE DIRECTOR BEFORE THE SUBCOMMITTEE ON TECHNOLOGY MODERNIZATION COMMITTEE ON VETERANS’ AFFAIRS UNITED STATES HOUSE OF REPRESENTATIVES June 11, 2024" at https://www.dav.org/wp-content/uploads/Retzer20240611.pdf and attached.

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-105347-1

Reference proposed VA Form 10-3542 instruction 6 see and see "What do I need to do to get reimbursed if I had an offsite appointment with a civilian doctor that the VA paid for me to see?" at https://www.va.gov/san-diego-health-care/programs/vatravel-reimbursement-form-va-form-10-3542-with-instructions/ and below.

"Fill out this same form that's stapled to this sheet (VA Form 10-3542). Ask your provider's office for documentation on their office letterhead providing the following requirements:

Statement showing the Veteran's full name. the date the Veteran completed the appointment(s). The address of the provider's office. Wording showing the appointment was completed. Please do not attach an appointment schedule. The key is that the documentation must show the appointment was completed in order for VA to provide reimbursement. Telephonic inquiries cannot satisfy this requirement. Please do not have your provider send it in separately. It has to come with your completed travel reimbursement request form submitted by the Veteran."

VA Response: VA has received your response and appreciates your feedback. VA has provided guidance to VAMCs for collecting BT claim information during the OMB recertification process, as well appropriate steps and acceptable ways to verify and document completed appointment for non-VA care. We will follow up with all VAMCs to ensure they are following that guidance and their local resources are in line with Agency guidance and meeting OMB PRA requirements.

  1. PC-202402-2900-022-101924-111915-1

Reference proposed VA From 10-3542 instruction 6 and see "Add your expenses and receipts" at https://www.va.gov/resources/how-to-file-a-va-travel-reimbursement-claim-online/ and below. "If you have receipts or proof of attendance records for non-VA care appointments, select Add Attachments. You can add up to 5 attachments."

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-013126-1

See "Has anyone ever actually been able to file a travel claim for va healthcare" at https://www.reddit.com/r/Veterans/comments/11fit4u/has_anyone_ever_actually_been_able_to_file_a/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-013436-1

See "The VA is trash!" at https://www.reddit.com/r/Veterans/comments/14f9xmk/the_va_is_trash/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-013558-1

See " BTSSS Online Upload Down?" at https://www.reddit.com/r/Veterans/comments/1dfbmsk/btsss_online_upload_down/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-013921-1

See "Has anyone that uses VA medical care actually been compensated for travel?" at https://www.reddit.com/r/Veterans/comments/19faxpr/has_anyone_that_uses_va_medical_care_actually/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-014025-1

See "The VA has made it impossible to get travel pay" at https://www.reddit.com/r/Veterans/comments/pgpeya/the_va_has_made_it_impossible_to_get_travel_pay/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-014148-1

See "The travel claim change the last few years has probably cost veterans millions and unclaimed travel expenses, and someone needs to do something about it." At https://www.reddit.com/r/Veterans/comments/1bu5zq0/the_travel_claim_change_the_last_few_years_has/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-014318-1

See "VA Travel Pay Down?" at https://www.reddit.com/r/Veterans/comments/174kmex/va_travel_pay_down/

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-020631-1

See "Chairman Rosendale Exposes Failed VA Beneficiary Travel Self-Service System" at https://www.youtube.com/watch?v=dtMK8mMFNLg

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-021428-1

See "Questioning the VA on their decision to remove travel reimbursement kiosks" at https://www.youtube.com/watch?v=lg3XGnTwMR4

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-021902-1

See "Maine delegation wants VA to fix travel reimbursement system" at https://www.youtube.com/watch?v=bCDjoxNLd_Y

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-021945-1

See "Veterans who must travel long distances to receive VA healthcare are entitled to compensation" at https://www.youtube.com/watch?v=TZrQj1f7azY

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-110051-1

Reference proposed VA Form 10-3542 instruction 6 and see "BTSSS says" below.

"when a veteran is seen in the Community per VA referral, they must provide from that outside facility a note stating veterans name, completed appointment date, this information must be on facilities letterhead signed by staff at that facility."

From COLTRIN, Gloria A. (TUC BENEFICIARY TRAVEL)

Subject Appointment: BTSSS says

Message ID 5138905567

Attachments Proof of attendance letter.Pdf (281.50 KB).

22 Dec 2023 @ 1057 ET

VA Response: VA has received your response and appreciates your feedback. 

  1. PC-202402-2900-022-101924-110247-1

Reference proposed VA Form 10-3542 instruction 6 and see the SAVAHCS "proof of attendance letter" attached.

VA Response: VA has received your response and appreciates your feedback.

  1. PC-202402-2900-022-101924-111255-1

Reference proposed VA Form 10-3542 instruction 6 and see "IMPORTANT UPDATE COMMUNITY CARE CONFIRMATION" at https://content.govdelivery.com/attachments/USVHA/2021/08/05/file_attachments/1898626/Business%20Office%20newslett er%20August%202021.pdf, below and attached.

"To process claims for Community Care appointments, proof of attendance must be attached to the travel claim. Proof may be provided by memorandum of appointment confirmation OR on official letterhead from the community provider (work excuse). The original document must be attached to the claim and include the date and time of appointment and signature of a representative of the clinic. Memoranda are available at any John J. Pershing VA Medical Center campus. It is important that you attach the original document to each claim submitted and ensure your claim is received within 30 calendar days of your appointment. "

VA Response: VA has received your response and appreciates your feedback.

  1. PC-202402-2900-022-101924-112120-1

Supporting Statement A, item 2,:

VTP says "The claimant may provide self-attestation of their attendance at a VA authorized appointment with a non-VA provider."

Explain and justify the verification document on the proposed VA Form 10-3542 instruction 6.

Explain and justify the multitude of forms and letters already in use throughout the VA without OMB authorization.

Specify your reasoning in reference to the data elements to be collected in item 2, using IT to reduce the burden in item 3, and avoiding the obvious duplication you're creating in item 4..

https://www.va.gov/montana-health-care/stories/montana-va-makes-appointment-verification-letter-more-available-toveterans/

https://www.va.gov/files/2022-05/Appointment%20Verification%20Letter.pdf

https://content.govdelivery.com/attachments/USVHA/2021/08/05/file_attachments/1898626/Business%20Office%20newsletter%20August%202021.pdf

https://www.va.gov/files/2023-11/Verification%20of%20Community%20Care%20Appointment.pdf

https://www.va.gov/st-cloud-health-care/programs/btsss-brochure/

https://www.va.gov/files/2022-08/BTSSS%20brochure%20August%202022.pdf

https://www.va.gov/san-diego-health-care/programs/va-travel-reimbursement-form-va-form-10-3542-with-instructions/

https://www.tn.gov/content/dam/tn/veteranservices/learning/powerpoints/2024-quarterly-training/2024-spring-regionaltraining/veterans-transportation-program-presentation/How%20to%20File%20for%20Travel%20Reimbursement.pdf

https://www.tn.gov/content/dam/tn/veteranservices/learning/powerpoints/2024-quarterly-training/2024-spring-regionaltraining/veterans-transportation-program-presentation/Benficiary%20Travel%20Mileage%20Reimbursment%20Tri-Fold.pdf

VA Response: VA has received your response and appreciates your feedback.

  1. PC-202402-2900-022-101924-112144-1

Reference proposed VA From 10-3542 instruction 6 and see "BTSSS: How to submit a travel reimbursement claim for a non-VA facility appointment 5 of 6" at https://www.youtube.com/watch?v=ai_LYF3al-s

VA Response: VA has received your response and appreciates your feedback.

  1. PC-202402-2900-022-101924-114501-1

Proposed VA Form 10-3542 instruction 6:

Explain and justify how 38 CFR 70.20 (e) "additional information" for *application*, from item 2, morphed into "verification" of attendance for *determination* on the form.

Specify your reasoning for adding this burden in reference to the data elements to be collected in item 2, using IT to reduce the burden in item 3, and avoiding the obvious duplication you're creating in item 4.

How does verification of attendance reconcile with "The claimant may provide self-attestation of their attendance at a VA authorized appointment with a non-VA provider.

Explain and justify the multitude of forms, letters and instructions already in use throughout the VA without OMB authorization since 2008.

https://www.va.gov/montana-health-care/stories/montana-va-makes-appointment-verification-letter-more-available-toveterans/

https://www.va.gov/files/2022-05/Appointment%20Verification%20Letter.pdf

https://content.govdelivery.com/attachments/USVHA/2021/08/05/file_attachments/1898626/Business%20Office%20newsletter%20August%202021.pdf

https://www.va.gov/files/2023-11/Verification%20of%20Community%20Care%20Appointment.pdf

https://www.va.gov/st-cloud-health-care/programs/btsss-brochure/

https://www.va.gov/files/2022-08/BTSSS%20brochure%20August%202022.pdf

https://www.va.gov/san-diego-health-care/programs/va-travel-reimbursement-form-va-form-10-3542-with-instructions/

https://www.tn.gov/content/dam/tn/veteranservices/learning/powerpoints/2024-quarterly-training/2024-spring-regionaltraining/veterans-transportation-program-presentation/How%20to%20File%20for%20Travel%20Reimbursement.pdf

https://www.tn.gov/content/dam/tn/veteranservices/learning/powerpoints/2024-quarterly-training/2024-spring-regionaltraining/veterans-transportation-program-presentation/Benficiary%20Travel%20Mileage%20Reimbursment%20Tri-Fold.pdf

VA Response: VA has received your response and appreciates your feedback. VHA provides standardized guidance to VA Medical Centers for posting on their local pages and will address any deviations.

  1. PC-202402-2900-022-101924-115632-1

Supporting Statement A, 2.:

VTP says "If VA determines that additional information is needed to make a determination concerning an application for benefits, VA will notify the claimant in writing in accordance with 38 CFR 70.20(e). "

This should be stricken form the ICR.

VA may request "missing" information that was *approved* by this ICR, they may *not* request "additional" information, not identified and not approved by this ICR, regardless of what the CFR may say.

44 USC 3501 et seq. overrides any and all agency written regulations.

VA Response: VA has received your response and appreciates your feedback. If the claimant failed to include all of the information needed to adjudicate a claim for reimbursement such as receipts for meals and lodging, tolls, etc., VA provides the opportunity to the claimant to submit documentation to support the claim.





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