Comment from George Hou on VA-2026-VACO-0001-0207
George HouSupportOther
Summary: The commenter supports the proposed reduction of VA Form 21-526EZ but argues that the VA should go further by moving toward a data-driven, auto-adjudication model. They advocate for using existing Department of Defense data and enterprise software to automatically approve benefits for certain conditions, thereby eliminating the need for manual applications entirely.
The proposed information collection framework outlined in this notice continues to place an avoidable administrative and cognitive burden on transitioning service members, veterans, and administrative staff. Under the Paperwork Reduction Act (PRA), agencies are mandated to evaluate whether the collection of information is necessary for the proper performance of functions, including whether the information will have practical utility.
The VA’s current proposal to significantly shorten VA Form 21-526EZ from 15 pages down to 5 pages—thereby reducing estimated completion time from 25 minutes to 15 minutes—is an admirable and necessary optimization of a legacy process. However, a reduction in form length still inherently tethers the VA to an obsolete, manual, form-centric philosophy and process.
To fully achieve the PRA’s goal of minimizing public burden, the Department of Veterans Affairs (VA) must move beyond merely shortening paperwork and instead shift toward a data-driven, auto-adjudication model triggered directly by existing Department of War (DoW) [formerly Department of Defense (DoD)] data. For a distinct subset of claims, the burden should not be reduced by 40 percent—it should be eliminated entirely.
Computable data from DoW systems converted to "digital paper" and resubmitted to VA by a veteran is completely unnecessary in this day and age with currently and readily available technology already implemented and fully deployed across VA.