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The following are examples of concerns expressed by the veterans to the committee:
The perception of an extraordinarily low rate of successful claims under the nonpresumptive regulation.
The validity of dose reconstruction as a basis for compensation.
The burden to veterans and their spouses posed by the claims and appeal process.
The lack of timeliness of claims resolution and responses from DTRA and VA.
Changes in doses assigned by the NTPR program to individual veterans as they continue to make inquiries or seek help from a legislative official.
Use of a low-level internal dose screen to eliminate the need for calculation of inhalation dose.
Failure to account properly for inhalation dose in some scenarios.
Neglect of possible ingestion doses in dose reconstructions.
Improper assumptions about scenarios of exposure and failure to consider veterans’ own accounts or accounts of companions.
That is not a comprehensive or ranked list, but several of those concerns seem to be overriding and consistent in importance. A few are discussed below, and others are discussed in more detail throughout this report.
The issue that has appeared to be of most concern to the veterans throughout our interaction during the project is the overall effectiveness of the compensation program under 38 CFR 3.311, the nonpresumptive regulation. Although that concern seemed to be somewhat peripheral to our scope, it is indirectly related because knowledge about the “accuracy” of the doses, as stated in the committee’s charge, could affect decisions about compensation. The veterans have been led to believe that over the course of the compensation program, relatively few claims have been awarded under the nonpresumptive regulation even though more than 4,000 dose reconstructions have been performed. As a consequence, there is an intense distrust and skepticism by the veterans about how dose reconstructions are being performed, and about whether accurate dose reconstruction is even possible, given the lack of historical data and the period of time since exposures occurred. The committee hopes that some of the information provided in this report will be helpful in addressing that issue.
Veterans are also concerned about some of the elements of the dose reconstruction process, including assumptions about scenarios of exposure, improper accounting of internal doses, and the use of a “low-level internal dose screen” that they believe improperly eliminates the need to estimate inhalation doses to some veterans. The concept and use of an internal dose screen is a good example of an issue to which the committee devoted considerable attention in an effort to provide clarification to the veterans. Although DTRA has consistently stated that it does not use an internal dose screen to eliminate the need to estimate inhalation