Archival study, updated with each new edition
The Slipping Schedule: How VA's Projected Rule Dates Move, Edition by Edition
Twice a year, VA publishes its rulemaking plan in the federal Unified Agenda, and each entry carries a projected date for the rule's next step. Those projections matter to anyone waiting on a rule, but each new edition overwrites the last, so a date that quietly moves leaves no public trace. We archived every edition from Fall 2018 through Fall 2025 and compared VA's own projections, rule by rule and step by step. This report is what the preserved record shows.
- By Alec Morgan
- The Veteran Benefit Desk
- Published August 16, 2026
- ISSN 3144-0835
- https://doi.org/10.68077/vbd.agenda-slippage
Independent research; not peer reviewed. Corrections and version notes are published under our Corrections Policy.
What a projection is, and is not
A Unified Agenda date is an estimate, not a commitment, and agencies say so. Estimates move for ordinary reasons: priorities shift, comment volume surprises, legal review takes longer, staff change. None of that is misconduct. The problem is narrower: because each edition replaces the last, the public cannot normally see how far an estimate has traveled, or how long a rule has been one step from done. Preserving the editions turns a rolling promise into a measurable record. That record is useful to veterans waiting on a specific rule, to researchers studying regulatory throughput, and to VA itself.
The deepest slip: 86 months and counting
The furthest traveled projection in the archive belongs to Reimbursement for Emergency Treatment (RIN 2900-AQ08), which has appeared in 15 consecutive editions. When it entered the archive, VA projected its final action for 05/2019 (Fall 2018). The latest edition projects 07/2026 (Fall 2025): a move of 86 months, or just over 7 years, across the editions in between.
What the rule would do, per VA's own agenda abstract: The Department of Veterans Affairs (VA) amends its emergency treatment regulations to authorize payment or reimbursement for coinsurance, temporarily waive the timely filing requirements for veterans affected by an earlier interim final rule, and authorize payment or reimbursement for emergency transportation associated with emergency treatment when VA has paid for the emergency treatment using a separate authority.
How widespread the slipping is
Of the 221 VA rulemakings that appear in at least two archived editions, 134 (60.6 percent) have at least one projected step that moved later. The median slip among them is 15 months. For balance: 8 rulemakings moved a projection earlier, not later.
The ten furthest traveled projections
| RIN | Rule | Step | First projected | Latest projection | Slip |
|---|---|---|---|---|---|
| 2900-AQ08 | Reimbursement for Emergency Treatment | Final Action | 05/2019 (Fall 2018) | 07/2026 (Fall 2025) | 86 mo |
| 2900-AQ32 | Automobile Adaptive Equipment Quality and Safety Standards | NPRM | 08/2019 (Fall 2018) | 06/2025 (Fall 2024) | 70 mo |
| 2900-AP70 | Equipment for Blind Veterans | NPRM | 12/2018 (Fall 2018) | 06/2024 (Spring 2023) | 66 mo |
| 2900-AQ73 | Schedule for Rating Disabilities: Neurological Conditions and Convulsive Disorders | NPRM | 01/2020 (Fall 2019) | 12/2024 (Fall 2024) | 59 mo |
| 2900-AQ11 | VA Vocational Rehabilitation and Employment Nomenclature Change for Position Title--Revision | Final Action | 12/2018 (Fall 2018) | 09/2023 (Spring 2023) | 57 mo |
| 2900-AQ57 | Access to State-Based Prescription Drug Monitoring Programs | NPRM | 11/2019 (Spring 2019) | 06/2024 (Spring 2023) | 55 mo |
| 2900-AQ94 | Authority of VA Professionals to Practice Health Care | Final Action | 01/2022 (Spring 2021) | 07/2026 (Fall 2025) | 54 mo |
| 2900-AP85 | Month-of-Death Payments and Income Exclusion for Property Loss Reimbursement | NPRM | 02/2019 (Fall 2018) | 06/2023 (Spring 2022) | 52 mo |
| 2900-AQ72 | Schedule for Rating Disabilities: Ear, Nose, Throat, and Audiology Disabilities; Special Provisions Regarding Evaluation of Respiratory Conditions; Schedule for Rating Disabilities: Respiratory System | Final Action | 01/2023 (Spring 2022) | 04/2027 (Fall 2025) | 51 mo |
| 2900-AQ80 | Aggravation Definition | Final Action | 08/2021 (Fall 2020) | 10/2025 (Fall 2024) | 50 mo |
The live, sortable version of this record, covering every VA rulemaking in every edition, is on our Unified Agenda Archive tracker.
The agenda itself, edition over edition
The size of VA's public rulemaking plan is its own signal. The latest edition (Fall 2025) lists 118 entries, of which 67 are new since the prior edition while 22 dropped off (finished, withdrawn, or shelved).
Methodology and sources
- Source: the semiannual Unified Agenda XML editions published at reginfo.gov . We archive each edition in full and keep only Department of Veterans Affairs entries (RINs beginning 2900).
- A projection is a timetable date printed at month precision (the agenda's convention for future steps). Completed steps carry exact dates and are excluded from slip measurement.
- A slip compares the same named step for the same RIN: its first projected date in the archive against its most recent projection. A rule's reported slip is its largest slipped step. Steps renamed between editions are treated as different steps, which makes this measure conservative.
- Slips are measured in calendar months between projections. A slip is a fact about the estimate, not a finding about cause; the agenda does not publish reasons.
- Coverage begins with the Fall 2018 edition. Rules appearing in only one edition cannot slip by construction and are excluded from the share calculation.
- We publish the complete underlying record, not a selection. Download it below.
Writing about VA benefits? You are welcome to reference this page. Copy the citation below and link back so your readers can verify the source.