Inside VA's Contract Exam Program
45 months of reported exam requests, vendor timeliness, examiner training requirements, and public oversight gaps
The four contractors in VA's release perform most of the department's disability medical examinations. Using records obtained through the Freedom of Information Act, this report analyzes 13,591,213 reported exam requests and 11,850,699 reported completions across 45 monthly snapshots, from October 2022 through June 2026. VA's file states that its monthly figures are frozen at month end and cannot be used to compute fiscal-year totals, so the totals shown here are sums of reported monthly values. The report also reviews the 1,118-page release VA produced in response to a separate request for examiner credentialing and training records, and identifies vendor-level operational and quality measures that the released records did not provide.
- By Alec Morgan
- The Veteran Benefit Desk
- Published September 5, 2026
- ISSN 3144-0835
- https://doi.org/10.68077/vbd.contract-exams
Independent research; not peer reviewed. Corrections and version notes are published under our Corrections Policy.
Version 1.0 · Last source check September 5, 2026 · Source values re-checked row by row against VA's released workbook.
Key findings
Reported contract exam requests increased 47.6 percent between two 12-month windows
Monthly exam requests averaged 242,908 from October 2022 through September 2023 and 358,484 from July 2025 through June 2026, an increase of 47.6 percent. Requests peaked at 383,651 in August 2025. VA's file states that monthly figures are frozen at month end and cannot be used to compute fiscal-year totals, so period sums here are sums of reported monthly values. The record documents substantial growth during the PACT Act era; GAO separately reports, citing VBA officials, that contractors performed about 3.2 million exams in fiscal year 2024 against 1.8 million in fiscal year 2022 (GAO-25-107483). These data do not isolate the causes of that growth.
June 2026 completion-time averages differed by vendor
For Regions 1 through 4, VA's fiscal-year-to-month cumulative completion-time averages in June 2026 ranged from 20.6 days for QTC Medical Services (Leidos) to 29.7 days for Loyal Source Government Services, a 9.1-day spread. The measure includes new examinations and reworks. These are aggregate vendor measures. They do not control for region, examination type, case mix, or other scheduling conditions and should not be used to predict an individual veteran's wait.
Appointment disruption and exam sufficiency measures were not provided by vendor
VBA stated that no-show rates, rescheduling rates, and insufficient-examination counts are not captured by vendor and are available only in aggregate. These are distinct operational and quality measures. Publishing them by vendor, or explaining why they cannot be reliably attributed, would help identify where appointments are disrupted and where examinations require correction or repetition.
The requested oversight results by vendor were not provided
VA released 1,118 responsive pages documenting contract requirements for examiner credentialing, training, and oversight. For the request seeking aggregate quality assurance or audit results by vendor, MDEO stated that no responsive documents exist. That response does not establish that VA maintains no quality data or conducts no quality review: GAO separately documents quarterly error reporting, contractor action plans, quality checklists, financial incentives, and focused reviews. The Veteran Benefit Desk is pursuing clarification through an administrative appeal and a targeted follow-up request.
Loyal Source's share of reported requests rose from 2.2 to 18.9 percent
Loyal Source Government Services accounted for 2.2 percent of reported requests in the first 12 months of the released record (October 2022 to September 2023) and 18.9 percent in the latest 12 months (July 2025 to June 2026); in the current fiscal year to date (October 2025 to June 2026) its share is 22 percent. Over the same windows QTC's share moved from 36.6 to 28.2 percent, VES from 32.2 to 25.8 percent, and Optum Serve from 29.1 to 27.1 percent. The dataset does not state why work was distributed this way.
Requested vs completed, month by month
All four vendors combined. Requested and completed examinations reported in the same month are not necessarily the same examinations, so the space between the lines is not a backlog count.
- Completed
- Requested
View the data table (45 rows)
| Month | Requested | Completed |
|---|---|---|
| October 2022 | 193,809 | 174,976 |
| November 2022 | 203,790 | 164,185 |
| December 2022 | 199,415 | 174,804 |
| January 2023 | 226,331 | 171,704 |
| February 2023 | 239,135 | 170,734 |
| March 2023 | 283,695 | 213,788 |
| April 2023 | 187,663 | 217,287 |
| May 2023 | 259,783 | 217,287 |
| June 2023 | 246,907 | 215,166 |
| July 2023 | 239,257 | 206,431 |
| August 2023 | 327,882 | 239,504 |
| September 2023 | 307,223 | 237,508 |
| October 2023 | 308,181 | 245,218 |
| November 2023 | 294,964 | 243,145 |
| December 2023 | 292,796 | 247,982 |
| January 2024 | 321,461 | 258,614 |
| February 2024 | 284,458 | 264,415 |
| March 2024 | 292,053 | 295,836 |
| April 2024 | 299,520 | 285,948 |
| May 2024 | 297,555 | 287,827 |
| June 2024 | 256,313 | 255,606 |
| July 2024 | 313,030 | 268,653 |
| August 2024 | 322,398 | 273,012 |
| September 2024 | 295,352 | 270,220 |
| October 2024 | 339,322 | 280,869 |
| November 2024 | 278,091 | 243,243 |
| December 2024 | 275,512 | 249,836 |
| January 2025 | 293,083 | 253,457 |
| February 2025 | 289,002 | 258,568 |
| March 2025 | 308,001 | 281,219 |
| April 2025 | 334,421 | 290,243 |
| May 2025 | 353,311 | 296,228 |
| June 2025 | 325,687 | 297,406 |
| July 2025 | 361,536 | 312,952 |
| August 2025 | 383,651 | 309,136 |
| September 2025 | 373,498 | 313,999 |
| October 2025 | 373,392 | 332,015 |
| November 2025 | 299,924 | 295,732 |
| December 2025 | 357,821 | 325,763 |
| January 2026 | 352,681 | 292,296 |
| February 2026 | 339,235 | 305,660 |
| March 2026 | 367,595 | 345,812 |
| April 2026 | 370,850 | 321,767 |
| May 2026 | 356,448 | 317,176 |
| June 2026 | 365,181 | 327,472 |
Average days to complete, by vendor
VA reports this measure as a fiscal-year-to-month cumulative average for Regions 1 through 4 (the contiguous U.S.), so each line resets at the start of October. Lower is faster. Compare vendors within the same month; compare months only across equivalent reporting windows.
- LSGS
- OSHS
- QTC
- VES
View the data table (45 rows)
| Month | OSHS | LSGS | QTC | VES |
|---|---|---|---|---|
| October 2022 | 27.2 | no value | 18 | 34.7 |
| November 2022 | 27.8 | no value | 18.1 | 34.4 |
| December 2022 | 29.1 | 8.8 | 18.8 | 35.3 |
| January 2023 | 30.5 | 19.4 | 19.2 | 36.3 |
| February 2023 | 26.4 | 27.3 | 16.9 | 29.3 |
| March 2023 | 27.9 | 34.6 | 17.9 | 30 |
| April 2023 | 34 | 42.5 | 20.8 | 35.2 |
| May 2023 | 34 | 42.5 | 20.8 | 35.2 |
| June 2023 | 34.8 | 50.7 | 21.2 | 35.5 |
| July 2023 | 35.7 | 57.4 | 21.4 | 35.8 |
| August 2023 | 36.8 | 64.2 | 21.5 | 36 |
| September 2023 | 36.9 | 67.9 | 21.6 | 36.3 |
| October 2023 | 37.1 | 79.7 | 25.7 | 39.8 |
| November 2023 | 38.3 | 74.2 | 27 | 40.3 |
| December 2023 | 39.5 | 67.8 | 27.9 | 41.3 |
| January 2024 | 41.2 | 62.4 | 28.5 | 42.8 |
| February 2024 | 42 | 57.2 | 28.7 | 43.3 |
| March 2024 | 42 | 51.8 | 28.8 | 44.1 |
| April 2024 | 41.8 | 47.7 | 28.6 | 44.3 |
| May 2024 | 41 | 44.1 | 28.2 | 44.8 |
| June 2024 | 40.2 | 41.7 | 27.7 | 44.4 |
| July 2024 | 38.9 | 39.6 | 27 | 43.9 |
| August 2024 | 36.7 | 43.3 | 27.4 | 42.4 |
| September 2024 | 36.2 | 28.5 | 24.2 | 42.1 |
| October 2024 | 22.7 | 24.6 | 16.8 | 37.6 |
| November 2024 | 22.2 | 26 | 16.8 | 37.3 |
| December 2024 | 22.1 | 25.9 | 17 | 38.9 |
| January 2025 | 21.5 | 25.2 | 17.9 | 40.7 |
| February 2025 | 21 | 24.2 | 17.9 | 41.7 |
| March 2025 | 20.6 | 23.2 | 17.6 | 42.1 |
| April 2025 | 20.3 | 22.4 | 17.5 | 42 |
| May 2025 | 20 | 21.8 | 17.4 | 41.3 |
| June 2025 | 20.1 | 21.4 | 17.5 | 40.7 |
| July 2025 | 20.3 | 21 | 17.7 | 40.3 |
| August 2025 | 20.4 | 20.6 | 17.8 | 39.6 |
| September 2025 | 20.8 | 21.2 | 18.1 | 38.8 |
| October 2025 | 26.4 | 28.3 | 24.2 | 28.1 |
| November 2025 | 26.2 | 28 | 27.2 | 27.2 |
| December 2025 | 25.9 | 28.6 | 24.8 | 26.7 |
| January 2026 | 25.2 | 29.1 | 25.1 | 26.2 |
| February 2026 | 24 | 29.6 | 24.1 | 25.4 |
| March 2026 | 22.9 | 30.1 | 22.9 | 24.6 |
| April 2026 | 22.2 | 30.3 | 21.9 | 24.1 |
| May 2026 | 22.5 | 30.1 | 21.1 | 23.7 |
| June 2026 | 22.6 | 29.7 | 20.6 | 23.6 |
| Reporting month | OSHS | LSGS | QTC | VES |
|---|---|---|---|---|
| June 2023 | 34.8 | 50.7 | 21.2 | 35.5 |
| June 2024 | 40.2 | 41.7 | 27.7 | 44.4 |
| June 2025 | 20.1 | 21.4 | 17.5 | 40.7 |
| June 2026 | 22.6 | 29.7 | 20.6 | 23.6 |
Each June value accumulates the same nine months of its fiscal year (October through June), which is the only sound way to compare years under VA's cumulative measure. The measure includes new examinations and reworks. Which vendor reported the lowest average has changed from year to year.
The four vendors
| Vendor | First month in dataset | Requests | Share | Completions reported | June 2026 FY-to-month average days |
|---|---|---|---|---|---|
| Optum Serve Health Services | October 2022 | 4,003,584 | 29.5% | 3,569,333 | 22.6 days |
| Loyal Source Government Services | December 2022 | 1,115,451 | 8.2% | 891,040 | 29.7 days |
| QTC Medical Services (Leidos) | October 2022 | 4,360,399 | 32.1% | 3,847,452 | 20.6 days |
| Veteran Evaluation Services (Maximus) | October 2022 | 4,111,779 | 30.3% | 3,542,874 | 23.6 days |
Shares total 100.1 percent because each vendor's share is rounded independently to one decimal place. Requests and completions are sums of the monthly snapshots in the release. The dataset begins in October 2022 and does not establish when any vendor entered VA's program; Loyal Source Government Services first appears in the released dataset in December 2022, with 2 completions and a 8.8-day average that month, consistent with a start-up period. Days to complete are VA's fiscal-year-to-month cumulative averages for Regions 1 through 4 in June 2026.
| Window | OSHS | LSGS | QTC | VES |
|---|---|---|---|---|
| First 12 months (October 2022 to September 2023) | 29.1 | 2.2 | 36.6 | 32.2 |
| Latest 12 months (July 2025 to June 2026) | 27.1 | 18.9 | 28.2 | 25.8 |
| Fiscal year 2026 to date (October 2025 to June 2026) | 25.6 | 22.0 | 26.8 | 25.6 |
Share = vendor requests in the window / all four vendors' requests in the window. Rows may not total 100 because each share is rounded independently.
The records by vendor that were not provided
Two of our FOIA requests asked, in different ways, how this program is measured. When we asked for insufficient examination counts and no-show and rescheduling rates by vendor, VBA answered that these "are not captured data points" and are "not available by vendor, only aggregate." MDEO answered the three parts of our companion request separately: credentialing and licensure records were provided, training and certification records were provided, and for aggregate quality assurance or audit results by vendor the response stated that no responsive documents exist.
That response does not establish that VA maintains no quality data or conducts no quality review. GAO's August 2025 report documents the oversight MDEO operates: quarterly exam-error reports to each contractor and contractor quality action plans due within 45 days; a quarterly random sample of completed questionnaires scored against a 10-question quality checklist; quarterly financial incentives (rewards and penalties of up to plus or minus 3 percent of quarterly invoices per measure) on five measures, including quality accuracy, production, and average days to complete; and Special Focused Reviews of individual examiners, quality topics, and complex claims. (GAO-25-107483; see also GAO-24-107730).
GAO also found that MDEO overpaid almost $2.3 million in incentives in the first quarter of fiscal year 2024 because of manual data-entry errors, and that its biennial Special Focused Reviews of complex claims (traumatic brain injury, military sexual trauma, Gulf War Illness) were behind schedule or unscheduled as of May 2025. VA concurred with three of GAO's four recommendations and concurred in principle with the fourth. The contract itself requires review packages, reports, and recurring verification activities. Publishing the resulting aggregate findings by vendor, where maintained, would improve public visibility into how those controls operate. The Veteran Benefit Desk is pursuing clarification through an administrative FOIA appeal and a targeted follow-up request, and this report will be updated with whatever they produce.
The 1,118-page release, page by page
Case 26-23670-F produced 1,118 responsive pages containing contract provisions, several versions of Attachment Y, course materials, job aids, resource lists, and accessibility records. The release does not mark original file boundaries, so it is organized below into sixteen subject groupings by title page and page header. Page numbers are release page numbers.
| Release pages | Grouping | Pages |
|---|---|---|
| 1 to 34 | Conducting Spina Bifida Examinations course package MDEO course dated April 23, 2025, with its resource list and accessibility documentation. | 34 |
| 35 to 50 | Attachment Y, Examiner Training Requirements (multiple versions) Five versions of the contract's training attachment. Release pages 48 through 50 are marked "Update June 2025" and "Pre-Decisional." | 16 |
| 51 to 156 | Military Culture course package Course dated June 4, 2025: service branch structure, transition, and the circumstances of military life. | 106 |
| 157 to 166 | Attachment J, Medical Disability Examination Types and oversight provisions Body-system exam types, the exams that require specialists, examiner qualification standards, and the administrative site review and credentialing provisions. | 10 |
| 167 to 199 | Camp Lejeune Contaminated Water course package Course dated April 8, 2025 for examiners providing CLCW medical opinions, including when a subject matter expert opinion is still required. | 33 |
| 200 to 270 | General Certification Overview The core certification course for all contract examiners (TRAIN 1102029). | 71 |
| 271 to 299 | Lethal Means Safety Awareness Training Required of all examiners in the later Attachment Y versions (TRAIN 1108433). | 29 |
| 300 to 333 | Suicide Awareness and Prevention Required of all examiners in every released Attachment Y version (TRAIN 1102111). | 34 |
| 334 to 395 | Military Culture supplemental materials DOD mission, branch structure, and related context material. | 62 |
| 396 to 537 | Medical Opinions course How examiners write medical opinions, including how they apply VA's "at least as likely as not" formulation when responding to medical nexus questions (TRAIN 1102027). | 142 |
| 538 to 635 | Mental Health Examinations course Specialty certification content required before mental health or PTSD examinations (TRAIN 1102092). | 98 |
| 636 to 827 | Military Sexual Trauma and the VA Exam Course dated May 13, 2025. The largest grouping in the release and one of the General Certification courses (TRAIN 1102030). | 192 |
| 828 to 898 | Musculoskeletal Examinations course Specialty certification content for joints, feet, or spine examinations (TRAIN 1101966). | 71 |
| 899 to 955 | ILER Examiner Job Aid and supporting accessibility records Individual Longitudinal Exposure Record guidance for exposure-related examinations, followed by the accessibility check reports produced for the file. | 57 |
| 956 to 1071 | Separation Health Assessment and examination-documentation materials Courses dated May 9 and 14, 2025, including DBQ documentation standards (TRAIN 1109557). | 116 |
| 1072 to 1118 | Traumatic Brain Injury Residuals Examination Specialty certification content required before TBI residuals examinations (TRAIN 1102093). | 47 |
| Total release pages | 1,118 | |
The archive as released
- File
- foia_release.zip, ZIP, 347 MB (346,625,046 bytes)
- Contents
- One folder (26-23670-F) holding 1,118 single-page PDF scans numbered 1.pdf through 1118.pdf in release order. The scans are image-only; no text layer was released.
- SHA-256
- 0734533021b62291c5ab993c60802b3443667678b87d78b2548b21538864079d
How examiner training requirements changed across the released versions
Release pages 35 to 50 hold five versions of Attachment Y, the contract section that sets examiner training requirements. The versions differ in their course lists and identifiers, and the final three pages are marked "Update June 2025" and "Pre-Decisional." For that reason, the release does not support presenting one blended list as the current and complete certification ladder. The sections below distinguish requirements appearing across the released versions from additions and proposed revisions found in later versions.
Requirements appearing across the released versions
- Examiners must complete all applicable certification training before conducting the examinations to which the training applies.Release pp. 35 to 47
- The released versions require five General Certification courses before an examiner conducts examinations; the June 2025 pre-decisional update proposes six.Release pp. 35 to 47
- Specialty examination types require additional specialty training before the corresponding exam.Release pp. 35 to 47
- Every released version includes a five-year recertification cycle.Release pp. 35 to 47
- An examiner who has not performed an examination for more than one year must be recertified before returning.Release pp. 35 to 47
- Beginning January 31, 2022, the released versions generally require training to be completed and recorded in VBA MDE TRAIN, subject to stated exceptions for courses delivered through another designated learning system (the Camp Lejeune course in versions 1 through 4).Release pp. 35 to 47
Requirements that changed across versions
Later versions add courses, move courses between general, supplemental, and specialty classifications, and update course identifiers. The release presents the versions back to back without dates, except for the final one.
- 1. Version 1pp. 35 to 37
Baseline text: five General Certification courses, two courses required of all examiners, three specialty courses plus Camp Lejeune and spina bifida, and the WRIISC MOD exposures course due by December 31, 2022. Effective January 31, 2022, required training must be completed within VBA MDE TRAIN.
- 2. Version 2pp. 38 to 40
Adds Lethal Means Safety (TRAIN 1108433) to the courses required of all examiners and adds PACT Act: Key Terms and Medical Opinions for Examiners (TRAIN 1107558) for examiners providing medical opinions on non-presumptive PACT Act claims.
- 3. Version 3pp. 41 to 43
Aggravation Opinions becomes "see note": effective December 19, 2022 the course was temporarily combined with Medical Opinions, with a separate course to be added in a future update. Adds the Separation Health Assessment (SHA) DD3146 DBQ examiner course (TRAIN 1109557).
- 4. Version 4pp. 44 to 47
"Contractor" becomes "Vendor." Adds The Veteran Experience (TRAIN 1104973), due within 60 calendar days of the release of VGM 23-42. Recertification is defined as all General Certification, Supplemental, and applicable specialty courses; an examiner may not examine if any required course completion is more than five years old in VBA MDE TRAIN. Training completed after March 31, 2022 outside the designated VBA LMS is not accepted. Course lengths appear for the first time. Dates the Aggravation Opinions consolidation December 15, 2022, where version 3 says December 19, 2022.
- 5. Update June 2025pp. 48 to 50Pre-Decisional
Marked "Update June 2025 (Pre-Decisional)" on each page. Not presented here as an operative requirement.
Course by course, version by version
How each course is classified in each released version, with the TRAIN identifier the version lists. The June 2025 column is pre-decisional.
| Course | Version 1pp. 35 to 37 | Version 2pp. 38 to 40 | Version 3pp. 41 to 43 | Version 4pp. 44 to 47 | Update June 2025pp. 48 to 50 · pre-decisional |
|---|---|---|---|---|---|
| General Certification Overview | G General1102029 | G General1102029 | G General1102029 | G General1102029 | G General1102029 |
| Military Sexual Trauma and the Disability Examination Process | G General1102030 | G General1102030 | G General1102030 | G General1102030 | G General1102030 |
| Aggravation OpinionsVersions 3 and 4: temporarily combined with the Medical Opinions course (dated December 19, 2022 in version 3 and December 15, 2022 in version 4). | G General1102026 | G General1102026 | G Generalsee note | G Generalsee note | G GeneralTBD |
| Medical Opinions | G General1102027 | G General1102027 | G General1102027 | G General1102027 | G General1102027 |
| Gulf War General Medical ExamThe June 2025 pre-decisional update lists a revised Gulf War Certification Course (TRAIN 1112502) in its place. | G General1104888 | G General1104888 | G General1104888 | G General1104888 | not listed |
| Gulf War Certification Course (revised) | not listed | not listed | not listed | not listed | G General1112502 |
| PACT Act: Key Terms and Medical Opinions for ExaminersVersions 2 through 4: for examiners providing medical opinions on non-presumptive PACT Act claims. The June 2025 pre-decisional update moves it into General Certification. | not listed | S Specialty1107558 | S Specialty1107558 | S Specialty1107558 | G General1107558 |
| Understanding Military Culture and Veterans | A All examiners1101617 | A All examiners1101617 | A All examiners1101617 | A All examiners1101617 | A All examiners1101617 |
| Suicide Awareness and Prevention | A All examiners1102111 | A All examiners1102111 | A All examiners1102111 | A All examiners1102111 | A All examiners1102111 |
| Lethal Means Safety | not listed | A All examiners1108433 | A All examiners1108433 | A All examiners1108433 | A All examiners1108433 |
| The Veteran ExperienceVersion 4: all vendor examiners must complete it within 60 calendar days of the release of VGM 23-42. | not listed | not listed | not listed | A All examiners1104973 | A All examiners1104973 |
| Assessing Deployment Related Environmental Exposures (WRIISC MOD)Versions 1 through 3: required of all MDE providers by December 31, 2022; providers onboarded later have 60 days from completing their initial certification courses. Version 4 keeps the 60-day rule. The June 2025 pre-decisional update lists it as supplemental with recertification not required. | T Additional1101919 | T Additional1101919 | T Additional1101919 | T Additional1101919 | A All examiners1101919 |
| Mental Health Certification CourseBefore any mental health or PTSD examination. | S Specialty1102092 | S Specialty1102092 | S Specialty1102092 | S Specialty1102092 | S Specialty1102092 |
| Traumatic Brain Injury (TBI) ExaminationBefore TBI examinations. | S Specialty1102093 | S Specialty1102093 | S Specialty1102093 | S Specialty1102093 | S Specialty1102093 |
| Musculoskeletal ExaminationBefore joints, feet, or spine examinations. | S Specialty1101966 | S Specialty1101966 | S Specialty1101966 | S Specialty1101966 | S Specialty1101966 |
| Separation Health Assessment (SHA) DD3146 DBQ Examiner Training | not listed | not listed | S Specialty1109557 | S Specialty1109557 | S Specialty1109557 |
| Camp Lejeune Contaminated Water (CLCW)Versions 1 through 4: delivered through the vendor's own learning system with the completion date reported to VBA. The June 2025 pre-decisional update moves it into VBA MDE TRAIN. | S Specialtyvendor LMS | S Specialtyvendor LMS | S Specialtyvendor LMS | S Specialtyvendor LMS | S Specialty1127976 |
| Conducting Spina Bifida ExaminationsThe June 2025 pre-decisional update assigns a new identifier. | S Specialty1102749 | S Specialty1102749 | S Specialty1102749 | S Specialty1102749 | S Specialty1122190 |
| MDE Examiner Recertification Part 1, General Certification Training | not listed | not listed | not listed | not listed | R Recertification1121290 |
| MDE Examiner Recertification Part 2, Supplemental Training | not listed | not listed | not listed | not listed | R Recertification1121294 |
The June 2025 update, listed separately
Release pp. 48 to 50Each of these three pages carries the footer "Update June 2025 (Pre-Decisional)." Nothing in the release confirms adoption, so the changes below are proposals as of June 2025, not operative requirements. What the pages do show is how VA's training architecture was being revised.
- General Certification grows from five to six courses: PACT Act: Key Terms and Medical Opinions for Examiners (TRAIN 1107558) moves from specialty to general certification, and a revised Gulf War Certification Course (TRAIN 1112502) replaces the Gulf War General Medical Exam (TRAIN 1104888).
- Aggravation Opinions is listed with the identifier "TBD."
- The WRIISC MOD exposures course (TRAIN 1101919) moves into the supplemental list for all examiners, marked "recertification not required."
- Camp Lejeune Contaminated Water moves into VBA MDE TRAIN (TRAIN 1127976, 0.5 hours) instead of the vendor's learning system.
- Conducting Spina Bifida Examinations receives a new identifier (TRAIN 1122190, 0.75 hours).
- Two recertification modules appear: Part 1, General Certification Training (TRAIN 1121290, 3 hours) and Part 2, Supplemental Training (TRAIN 1121294, 1 hour).
- The January 31, 2022 effective date is removed; all required training must be completed within the VBA-designated learning management system unless otherwise noted.
Examiner qualifications by examination type
Attachment J specifies provider qualifications for certain examination types. These provisions help readers understand the standards the contract requires. Whether a particular examination is adequate depends on the examiner's qualifications, the examination itself, the complete claim record, and the applicable VA rules.
Must be conducted by specialists in those fields. Eye examinations require an ophthalmologist or licensed optometrist. No audiology assistant, trainee, or extern may complete any portion of a hearing examination.
Where no prior TBI diagnosis exists, only a physiatrist, psychiatrist, neurologist, or neurosurgeon who has completed the VA TBI course may diagnose or rule out TBI. A generalist clinician does not include a psychologist or neuropsychologist, so those examiners cannot complete the TBI DBQ.
May be conducted by a C&P-certified generalist physician, physician assistant, or nurse practitioner who has completed the VA TBI course. Neuropsychological testing, when warranted, must be performed by a neuropsychologist.
For examinations in Regions 1 through 4 and the pre-discharge program, psychologists must hold an APA-accredited doctorate, either a PhD or PsyD, and a full, current, unrestricted doctoral-level license, with the professional specialty appropriate to the assignment. Attachment J contains separate provisions for international examinations.
Require a sound-controlled environment, ANSI-standard equipment, and the Maryland CNC word list. If cerumen impaction is found, it must be removed unless the veteran refuses or removal is medically contraindicated. If the impaction cannot be cleared, the examination must not be completed.
Examiners must be trained in physiatry, neurology, neurosurgery, or occupational medicine.
Interstate license portability. Attachment J cites the federal license-portability authority for contract examiners (section 504(c) of Public Law 104-275, as amended by Public Law 116-315, section 2002), under which a physician, physician assistant, nurse practitioner, audiologist, or psychologist holding a current unrestricted license may examine in any state within the scope of the contract. The 2021 expansion to the four non-physician professions was temporary. Its sunset was moved from five years to six years after January 5, 2021 by Public Law 119-37, section 7203 (November 12, 2025), so the expanded authority now runs through January 5, 2027; physician portability predates the 2021 expansion and is not affected by the sunset. Verified against the U.S. Code notes to 38 U.S.C. 5101 on September 5, 2026. (Release pages 161 and 163.)
The oversight the contract requires
The release documents a recurring oversight cadence. Each mechanism below is a contractual requirement from the released attachments; what the release does not contain is the results these mechanisms produce.
Administrative Site Reviews are performed monthly by the vendor. MDEO provides the list of sites, and the vendor must deliver a completed Administrative Site Review Package (Attachment AN) for each location within 30 days of the request.
A quarterly report of all active providers in the vendor's network (Attachment AO), where an active provider is a vendor employee or subcontractor available to perform examinations.
The vendor must report examiner status monthly to confirm each license is current with no revocation or pending professional-conduct proceedings, send the contracting officer's representative a report certifying the review, and provide an updated subcontractor list quarterly.
A provider who is not properly licensed and credentialed is an "Inadequate Provider" and must be excluded immediately under Attachment AT. Within 48 hours the vendor must give the contracting officer's representative a list of every examination that provider conducted while out of compliance; at VBA's request it must re-examine claimants at no cost and return the amounts paid.
The vendor posts an Examiner Training Roster (Attachment Z) weekly to its VA SharePoint site, and new examiners are verified through the MDEO Train mailbox and the contracting officer's representative as having completed all required training before an exam is scheduled.
Where this record points for improvement
- Publish aggregate oversight findings, where maintained: the contract requires monthly site review packages, monthly license certifications, and quarterly rosters, and GAO describes quarterly error reports, quality action plans, checklist accuracy rates, and financial incentive results by contract. Publishing those aggregate results by vendor would improve public visibility into how the controls operate. A pending administrative appeal and a follow-up request ask for exactly that.
- Capture appointment disruption and exam sufficiency measures by vendor: VBA stated that no-show rates, rescheduling rates, and insufficient examination counts are not captured by vendor and are available only in aggregate. Publishing them by vendor, or explaining why they cannot be reliably attributed, would show where appointments are disrupted and where examinations require correction or repetition.
- Publish a training version log: the release itself shows five versions of Attachment Y, the most recent marked pre-decisional. A public change log of curriculum revisions, with effective dates, would let anyone match an examination to the training requirements in force when it was performed.
Records that would let this series be read with confidence
The Veteran Benefit Desk is seeking clarification from VBA on the workbook's aggregation warning and its repeated April and May 2023 values, together with the aggregate operational measures VBA says are available, and is requesting the oversight outputs GAO and the contract describe. The pending administrative appeal in case 26-23670-F and follow-up request 26-25371-F cover the quality assurance results by vendor.
- VBA's clarification of the workbook: what the frozen monthly snapshots include, why the April and May 2023 values repeat for 16 fields, and what the 6,123 Optum Serve requests in April 2023 represent.
- The aggregate no-show, rescheduling, and insufficient-examination figures VBA says exist at the program level, with the periods they cover.
- Quarterly quality reports and quality action plans by vendor (the error-trend reports and 45-day contractor responses GAO describes).
- Quality checklist accuracy rates by vendor and quarter, and the financial incentive calculations and results by contract since fiscal year 2022.
- Special Focused Review schedules and summary findings for traumatic brain injury, military sexual trauma, and Gulf War Illness examinations.
- Monthly administrative site review results and the annual inspection plans and reports required under the December 2024 contracts.
- Training compliance summaries by vendor: completion rates for required courses and the version of Attachment Y in force in each period.
Methodology and caveats
- All source values come from the workbook released by VA in case 26-23677-F (VBA Medical Disability Examination Office, August 11, 2026). This report calculates totals, vendor shares, period averages, and percentage changes from those source values. These are arithmetic calculations rather than statistical estimates. Every released cell was re-checked against the workbook on September 5, 2026.
- VA's file carries this note: "All numbers are captured and frozen at end of individual month and cannot be use[d] to calculate total fiscal year numbers." The bracketed letter is ours; the rest is VA's wording. Every total, period sum, and share in this report is therefore a sum of the monthly snapshots as released, not an official VA fiscal-year figure, and the downloadable CSV repeats the note.
- The first twelve-month comparison period is October 2022 through September 2023. The latest twelve-month period is July 2025 through June 2026.
- Formulas: first-period average = 2,914,890 requests / 12 months = 242,908 per month; latest-period average = 4,301,812 / 12 = 358,484 per month; growth = (358,484 minus 242,908) / 242,908 = 47.58 percent, shown as 47.6 percent. Vendor share = vendor requests / 13,591,213 total requests; window shares in the vendor mix table use the same formula within each window.
- VA reports completion time as a fiscal-year-to-month cumulative average for contiguous U.S. Regions 1 through 4, and its note states the measure includes new examinations and reworks. Comparisons across vendors use the same reporting month. Longitudinal comparisons use the same calendar month in each fiscal year (the like-for-like table above) because each October begins a new cumulative series.
- VA's file notes that the pre-discharge and international completion-time averages were combined from October 2022 through January 2023 ("Oct-Jan 2023 Pre-Discharge & International ADC were combined").
- Requested and completed examinations reported in the same month are not necessarily the same examinations. This report does not estimate a backlog, failure rate, or individual claimant wait from the difference between those values.
- The source file's unit should be read as an "exam request" unless VA provides a more specific definition. The counts should not be interpreted as unique claims or unique veterans without supporting documentation.
- VBA stated that insufficient examination counts, examination no-show rates, and rescheduling rates are not captured data points and are not available by vendor. The report therefore makes no vendor-level statement about no-shows, rescheduling, or insufficient examinations.
- VA's file reports 6,123 Optum Serve exam requests for April 2023, against 86,020 in March 2023 and 78,243 in May 2023. The figure is reproduced exactly as VA released it.
- VA's file repeats 16 nonblank April 2023 values verbatim in the May 2023 column (OSHS 3, LSGS 3, QTC 5, VES 5 fields, including requests, completions, and completion-time averages). No other pair of consecutive months repeats more than one field. The values are reproduced exactly as released and are not altered or deduplicated here; the Desk is seeking VBA's clarification of whether theMay 2023 column reproduces the April 2023 snapshot.
- Loyal Source Government Services first appears in the released dataset in December 2022.
- Pre-discharge and international completion times are included in the downloadable dataset but not charted above.
Data dictionary for the CSV downloads
- month
- Calendar month of the VA report row, YYYY-MM.
- vendor
- VA's vendor code: OSHS (Optum Serve Health Services), LSGS (Loyal Source Government Services), QTC (QTC Medical Services), VES (Veteran Evaluation Services).
- requested
- Exam requests VA recorded for the vendor in that month, exactly as released. The unit is an exam request, not a unique claim or veteran.
- completed
- Exams VA recorded as completed by the vendor in that month, exactly as released. Not necessarily the same exams as that month's requests.
- adc_regions_1_4
- Average days to complete for Regions 1 through 4 (the contiguous U.S.), reported by VA as a fiscal-year-to-month cumulative average. Resets each October.
- adc_pre_discharge
- Average days to complete for pre-discharge examinations, same cumulative basis.
- adc_international
- Average days to complete for international examinations, same cumulative basis. Blank where VA reported no value.
- version
- v1 through v5, in release order. v1 through v4 are released versions of Attachment Y; v5 is the June 2025 pre-decisional update.
- version_label / release_pages
- The label used in this report and the release page range the version occupies (pages 35 to 50 of the 1,118-page release).
- version_status
- released, or pre_decisional for pages 48 to 50, which carry the footer "Update June 2025 (Pre-Decisional)".
- course
- Course title as printed in Attachment Y.
- classification
- general_certification (required before any exam), all_examiners (supplemental course required of all examiners), specialty (required before the named exam type), additional_training (required of all providers with its own deadline), recertification (recertification module), or not_listed when the version omits the course.
- train_id
- The VBA MDE TRAIN course identifier as printed, or a note such as "see note", "TBD", or "vendor LMS" (delivered through the vendor's learning system).
- course_note
- Deadlines, consolidations, and identifier changes recorded in the versions for that course.
Source records
- FOIA case 26-23677-F decision letter (PDF): the response releasing the exam volume and timeliness data, including VBA's statement that no-show, rescheduling, and insufficient examination measures are not captured by vendor.
- VA's released data file (XLSX): the native spreadsheet exactly as produced by the Medical Disability Examination Office.
- FOIA case 26-23670-F decision letter (PDF): the response releasing the 1,118-page credentialing and training record and stating that no responsive documents exist for aggregate quality assurance or audit results by vendor.
- The 1,118-page release (ZIP, 347 MB (346,625,046 bytes)): all pages as released; SHA-256 checksum and contents listed above.
- Attachment Y training requirements, course by version (CSV): the version matrix above as data, so any exam date can be matched to the training rules in force.
- The Desk's public FOIA log: every request this publication has filed, with outcomes.
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