Comment on AO21-Proposed Rule-Nguyen, Bao D.

March 29, 2013 RE: Proposed Changes to Priority Group 4 Standards To Whom It May Concern: As a law student at UC Hastings in San Francisco with an especially strong interest in Veteran’s Affairs, I would like to express a few concerns about the proposed rule changes regarding the standards for Priority Group 4 Catastrophically Disabled Veterans. I would also like to acknowledge that the proposed changes are a welcome sight in light of the bleak shadow that has been cast upon the treatment of veterans. We as citizens can never hope to repay the sacrifice of our men and women in uniform, but this proposed alteration to the rules is a step in the right direction in improving the quality of care for the most grievously wounded of our veterans. The proposed rule change eliminates the need to use the International Classification of Diseases (ICD) and Current Procedural Terminology (CPT) to classify the types of injuries suffered by a veteran. The attending physician has a much greater amount of flexibility in diagnosing the veteran’s injuries and determining his degree of disability. The old system relied on a rigid categorization where the injuries would fall under a classification. A veteran could be denied benefits because he “wasn’t injured enough,” the Department of Veterans Affairs has recognized the fundamental flaw in this system and abolished it completely for purposes of enrolling into Priority Group 4. Freeing up physicians to make a call about a veteran based on that physician’s expertise and opinion is more conducive to allowing proper levels of care than the old system. Veteran care should never turn on a technicality or “missing an injury.” It is preposterous to entertain the idea that because a veteran wasn’t injured quite enough that he deserves a lower level of care. These relaxed standards and deference to professional opinion are a step in the right direction for the bulk of the proposed rule change.