VA Caregiver Support – PCAFC and PGCSS are not Clinical or Clinical Intervention Programs

In this post, I’m going to prove the two (2) caregiver support programs are not clinical or clinical intervention programs through legal supporting documents.

The Caregiver Support governing documents:

  1. Public Law 111-163
  2. 38 USC 1720G
  3. 38 CFR 71 (Latest final rule with amendments is 80 FR 1357 January 09, 2015 as most online regulations haven’t included the amendments. Click here for an online version with the amendments.)
  4. VHA Directive 1152 June 14, 2017

Public Law 111-163 and 38 USC 1720G (§ 1720G, Assistance and support services for caregivers) enacted and codified the Caregiver Support (CS) to establish two (2) caregiver support programs. Excerpt from both documents:

(a) PROGRAM OF COMPREHENSIVE ASSISTANCE FOR FAMILY CAREGIVERS.—(1)(A) The Secretary shall establish a program of comprehensive assistance for family caregivers of eligible veterans. ‘‘(B) The Secretary shall only provide support under the program required by subparagraph (A) to a family caregiver of an eligible veteran if the Secretary determines it is in the best interest of the eligible veteran to do so.

‘‘(b) PROGRAM OF GENERAL CAREGIVER SUPPORT SERVICES.— (1) The Secretary shall establish a program of support services for caregivers of covered veterans who are enrolled in the health care system established under section 1705(a) of this title (including caregivers who do not reside with such veterans).

Based on the above information, these are not clinical or clinical intervention programs, both programs are SUPPORT programs for CAREGIVERS. You might have thought these caregiver support programs were for the Veteran but they are for the caregivers hence the names of the programs, and the stipend, benefits and support is for the caregivers. Reference the above excerpts from the law and statue if you still believe these caregiver support programs are for the Veteran. If these were clinical or clinical intervention programs, it would be for the caregivers. For the PCAFC, our family member (applicant) needs to have a Veteran with serious injuries which occurred or aggravated on or after 9/11 to participate in this caregiver support program to receive a stipend, benefits and support. 

Again, these caregiver support programs are not clinical or clinical intervention programs.

Both caregiver support programs have two (2) independent and separate roles and responsibilities:

1) Clinical (VA Medical Department) = Veteran’s primary care team, and VA clinicians who treat the  caregivers. Excerpt from the CS regulation, 38 CFR 71. 71.15 Definitions:  Primary care team means a group of medical professionals who care for a patient and who are selected by VA based on the clinical needs of the patient. The team must include a primary care provider who coordinates the care, and may include clinical specialists (e.g., a neurologist, psychiatrist, etc.), resident physicians, nurses, physicians’ assistants, nurse practitioners, occupational or rehabilitation therapists, social workers, etc., as indicated by the needs of the particular patient.

2) Support (VA Social Worker Department) = Caregiver Support Coordinator (CSC) to only provide support and assistance to caregivers of both caregiver support programs according to law, statue and regulation. The CSC is in an administrative position regardless of her/his professional title. Examples of support and assistance is help filling out forms, directing caregivers to the appropriate sections to file for benefits, provide educational material, assist with navigating the VA system, etc. It’s not mandatory for caregivers to use the CSC for support or assistance but she/he is there if the caregivers need them.

Note: Most Veterans and their caregivers are familiar with the military’s Family Support Group (FSG) program so I will use this program for comparison to the Caregiver Support (CS) programs. The VA = Military; Primary Care Team = Chain of Command; Veteran = Servicemember; Caregiver = Family Member and Caregiver Support Coordinator = Family  Support Group leader. The chain of command (CoC) takes care of the Servicemember and the FSG leader takes care of the family member. The FSG isn’t mandatory for family members but there if a family member needs it. The FSG leader can’t perform or approve any military responsibilities for a Servicemember, and the CoC can’t perform or approve any FSG responsibilities for a family member. Two (2) independent and separate roles and responsibilities just like the VA CS programs. Note: I’m not referring to obtaining information or assistance from either side such as a Servicemember contacting the FSG leader to find out when the next meeting is or asking for someone to check on his family when he goes TDY or a family member contacting the Servicemembers administrative office to obtain a copy of the Servicemembers pay stub.

The directive, VHA Directive 1152 June 14, 2017 is the only document stating the two (2) caregiver support programs are ‘clinical’ programs which is in violation of the law, statue and regulation. A directive cannot violate, alter or omit the guidance of the law, statue or regulation.

In the next post, I’ll discuss the issues with the VA Caregiver Support and then will do a separate post on the issues with the processes and procedures.

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