ࡱ> %` -Sbjbj 7̟̟J3FFFFFFFP / / /8D/|/DW0&0"H0H0H0H0H0H0 W W W W W W W$Yh[0WF3H0H0330WFFH0H0EW"5"5"53FH0FH0 W"53 W"5"5QFF.TH00 D /3RV[W0WR\3Z\4.T.T\FBTH00|"5r1d1H0H0H00W0W5H0H0H0W3333$(+(+Z^L FFFFFF  STATEMENT OF J. DAVID COX, RN NATIONAL SECRETARY-TREASURER AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO BEFORE THE SUBCOMMITTEE ON HEALTH HOUSE COMMITTEE ON VETERANS AFFAIRS ON HUMAN RESOURCES CHALLENGES WITHIN THE VETERANS HEALTH ADMINISTRATION MAY 22, 2008 The American Federation of Government Employees (AFGE) appreciates the opportunity to present its views on human resources challenges within the Veterans Health Administration (VHA). AFGE represents nearly 160,000 employees in the Department of Veterans Affairs (VA), more than two-thirds of whom are VHA professionals on the front lines treating the physical and mental health needs of our veteran population. The vast majority of VHAs workforce is covered by personnel rules known as pure Title 38 providers (e.g. registered nurses (RN), physicians and physician assistants (PA)) or hybrid Title 38 (e.g. licensed practical nurses (LPN), pharmacists, psychologists and social workers). The Title 38 boarding process for appointment and promotion of these two groups of VHA professionals was designed to be more flexible and expeditious than Title 5, but as will be discussed, the process faces extreme delays and backlogs. A small number of VHA direct patient care positions remain under Title 5, e.g., Nursing Assistants and Medical Technicians. AFGEs testimony focuses primarily on two significant human resource challenges facing VHA today: Loss of grievance rights for pure Title 38 employees; Extreme delays in the hybrid Title 38 boarding process; In my nearly 25 years as a registered nurse and union official at the Salisbury, North Carolina VA Medical Center, I have seen the impact of many Veterans Health Administration (VHA) personnel policies on recruitment and retention of health care professionals. In the 1980s, I saw first hand how regular collaboration between front line providers and management helped transform the VA into a world-class health care system, becoming a model in patient safety, health care information technology, and best practices. Sadly, what I have seen over the past seven years is a sea change in VAs personnel practices that now hurt, rather than help, recruitment and retention, and exclude front line providers from medical affairs. The current culture of exclusion is very demoralizing to these dedicated providers who are extremely committed to the mission of the VA work and so hard to care for our veterans. For example, according to a January 2008 VA national RN satisfaction survey, for the past two years, Participation in Hospital Affairs was one of two areas where RNs at VA medical facilities were the least satisfied. Loss of grievance rights for pure Title 38 employees The most harmful, far-reaching VHA personnel policy in place today is the severe erosion of collective bargaining rights (hereinafter grievance rights) of RNs, physicians, PAs and other pure Title 38 providers (providers.) These rights include the right to challenge management personnel actions through grievances, arbitrations, labor-management negotiations, unfair labor practices (ULPs) and litigation before the Federal Labor Relations Authority (FLRA) and courts. VHA denies these rights by asserting an arbitrary and unsupported interpretation of 38 USC 7422 (7422), the law that provides collective bargaining rights to these providers. VAs 7422 policy blocks virtually every provider grievance on the basis of three narrow exceptions in the law: professional conduct and competence (defined as direct patient care or clinical competence); peer review; and compensation. VHAs 7422 policy has undermined Congress attempts improve VHA recruitment and retention through rights to better pay and schedules. The effect, to quote the old adage, is rights without remedies which "are no rights at all. AFGE greatly appreciates the support of Chairman Michaud and Subcommittee members Berkley, Brown and Doyle for H.R. 4089, legislation introduced by Committee Chairman Filner to amend Section 7422 and restore these critical rights. This bill is an essential enforcement tool for all past and future legislation that addresses VHA recruitment and retention of pure Title 38 providers, as well as federal statutes that provide rights to information and prohibit employment discrimination. VHAs 7422 policy directly contradicts Congressional intent as to the scope of these three exceptions. Specifically: Congress viewed Title 38 and Title 5 employees as having the same collective bargaining rights when it enacted the Civil Service Reform Act (CSRA) in 1978. Congress enacted Section 7422 in direct response to a 1988 federal appeals court decision involving annual nurse comparability pay increases. The Court held that the VA could not be compelled by the CSRA to engage in collective bargaining over conditions of employment for Title 38 providers. Colorado Nurses Assn v. FLRA, 851 F.2d 1486 (D.C. Cir. 1988). The plain language of the 1991 law narrows the scope of the exceptions by specifying that the matter must relate to direct patient care or clinical competence. The 1990 House committee report on the underlying bill defined the direct patient care exception as medical procedures physicians follow in treating patients. This report also cited guidelines for RNs wishing to trade vacation days as falling outside the exception. (H. Rep.No.101-466 on H.R. 4557,101st Cong., 2d Sess., 29 (1990)). VHAs 7422 policy also contradicts its own 1996 agreement with labor to clarify the scope of the law and resolve remaining disputes in a less adversarial manner. Sadly, the VA unilaterally abandoned this useful, inclusive agreement in 2003. More specifically, in that agreement: The VA committed to a new process for resolving 7422 disputes that departed from the adversarial, litigious, dilatory nature of past labor-management relations. The VA acknowledged that providers provide valuable input into medical affairs: We recognize that the employees have a deep stake in the quality and efficiency of the work performed by the agency.; The purpose of labor-management partnership is to get the front line employees directly involved in identifying problems and crafting solutions to better serve the agencys customers and mission. The VA recognized the narrow scope of the direct patient care exception, i.e. it does not extend to many matters affecting the working conditions of Title 38 employees [that] affect patient care only indirectly (emphasis provided). The VA agreed that scheduling matters may be grievable: For example, scheduling shifts substantially in advance so that employees can plan family and civic activities may make it more expensive to meet patient care standards under certain circumstances. That does not relieve management of either the responsibility to assure proper patient care or to bargain over employee working conditions. The VA agreed that pay matters other than setting pay scales are grievable: Under Title 38, pay scales are set by the agency, outside of collective bargaining and arbitration. Left within the scope of bargaining and arbitrations over such matters as: procedures for collecting and analyzing data used in determining scales, alleged failures to pay in accordance with the applicable scale, rules for earning overtime and for earning and using compensatory time, and alternative work schedules. The 7422 appeals process: Section 7422 gives the Undersecretary of Health (USH) the sole authority to determine what matters are grievable. USH decisions are posted on the VA website ( HYPERLINK "http://www1.va.gov/lmr/page.cfm?pg=28" http://www1.va.gov/lmr/page.cfm?pg=28.) The VA does not keep AFGE apprised of unpublished decisions or pending cases. AFGE is very concerned by the lack of meaningful, balanced review by the USH and by failure of local facilities to comply with the USH review process. A review of posted decisions and member reports received by AFGE reveals how VAs 7422 policies directly undermine recruitment and retention legislation passed over the past decade and deprive providers of a fair appeals process. For example: No right to grieve over denial of request to review nurse locality pay survey data Background: Congress enacted legislation in 2000 to authorize directors to conduct third party surveys to set competitive nurse pay (P.L. 106-419). USH Ruling: Compensation exception blocks employees access to third party survey data. (Decision dated 1/06/05) No right to grieve over VA nurse mandatory overtime policy Background: Congress enacted legislation in 2004 requiring facilities to establish policies limiting mandatory overtime except in cases of emergency (P.L. 108-445). USH Ruling: National grievance over definition of emergency for requiring overtime is barred by the professional conduct or competence exception. ( Decision dated 10/22/07). No right to grieve over composition of panels setting physician pay Background: Congress enacted legislation in 2004 to use local panels of physicians to set market pay that would be competitive with local markets (P.L.108-445). AFGE contended that management unfairly excluded practicing clinicians and employee representatives from the panels. USH Ruling: Grievance barred by compensation exception. (Decision dated 3/2/07). Other grievances blocked by VAs 7422 policy (based on member reports of pending disputes or unpublished USH decisions) No right to challenge Intimidation of arbitration witnesses: After two VA nurses testified for the union at arbitration, management sent them letters questioning their conduct and suggesting that they could be subject to discipline. The union filed an unfair labor practice with the FLRA which initiated steps to file charges against management. Management invoked the professional conduct or competence exception to suspend FLRA action pending an USH ruling. No right to challenge performance rating based on use of approved leave: Management invoked 7422 when a nurse tried to grieve the lowering of her performance rating that was based on her authorized absences using earned sick leave and annual leave, and carried out without any written justification. No right to challenge error in pay computation: Management invoked 7422 when a nurse was incorrectly denied a within-grade pay increase because of lost time arising out of a work-related injury covered by workers compensation. No right to challenge low reimbursement for costs of required training: Management invoked 7422 when a nurse tried to grieve the amount of reimbursement she received for attending required training to maintain her Advanced Practice RN certification. Exclusion from hospital affairs: Management invoked 7422 to block a local unions efforts to have input into the drafting of medical staff bylaws that impact personnel policies. No right to challenge unfair bonus policies: VA physicians are unable to challenge policies that are not in compliance with the 2004 physician pay law because managers set arbitrarily low bonuses and impose unfair performance measures based on factors beyond the physicians control. Recent court decisions confirm the need for Congressional action on 7422: AFGE Local 446 v. Nicholson, 475 F.3d 341 (D.C. Cir. 2007). The federal court held that the VA operating room nurses could not file a grievance over denial of premium pay weekend and evening shifts. AFGE Local 2152 v. Principi, 464 F.3d 1049 (9th Cir. 2006), A VA physician was removed from his surgical duties at age 76 and his specialty pay was discontinued. The court held that the physicians grievance alleging unlawful age and gender discrimination was barred by the professional conduct or competence exception in 7422. The court rejected the unions contention that managements 7422 assertion was a mere pretext for unlawful discrimination. Similarly, in a posted USH decision dated 6/1/07, a nurse alleging that managements denial of specialized skills pay was racially motivated was not allowed to pursue a grievance. Amending 7422 will not hurt patient care. Those defending VAs current 7422 policy are likely to suggest that labor will try to disrupt patient care if 7422 is amended. In fact, Title 5 makes the three exceptions in 7422 redundant and unnecessary. Federal sector unions areonly authorized to negotiate on "conditions of employment" as that term is defined in 5 USC 7103(a)(14). In contrast, 5 USC 7106(a)(1) makes it a management right(i.e., notto be modifiedat the bargaining table) for an agency to determine its "mission. Furthermore, a review of published cases that have come before the USH did not reveal even one attempt to interfere with medical procedures or other direct patient care matters. Finally, if grievance rights can interfere with VHA operations, than why do hybrid Title 38 providers hired under Title 5 and working side by side with pure Title 38 providers have rights to grieve over these prohibited matters? For example, psychologists have full grievance rights while psychiatrists do not; licensed practical nurses have full grievance rights while RNs do not. The current dispute resolution process for 7422 is broken and biased against employees. Those defending VAs current 7422 policy are also likely to argue that employees already have a fair process though the USH for resolving 7422 disputes. Numbers tell a very different story: Of the 25 published USH decisions over the past three years, the USH ruled in favor of management one hundred percent of the time. Opponents are unlikely to mention that many, many more cases never get to the USH even though the law clearly states that he has sole authority to make these rulings. Across the country, human resource departments with no authority regularly make 7422 determinations and refuse to go through the proper USH channels. The current 7422 process wastes taxpayer dollars. Finally, the VAs 7422 policies result in a great waste of taxpayer dollars that would be much better spent on patient care. The Asheville case previously discussed was pending for seven years. HR departments in facilities around the country regularly block or delay the Section 7422 review process, draining resources and staff time away from the VAs mission of caring for veterans. Extreme delays in the hybrid Title 38 boarding process Congress primary objective in establishing hybrid Title 38 positions (i.e. employees are hired under Title 5 but appointed and promoted at the facility level under Title 38) was to expedite the appointment and promotion of more VHA employees involved in direct patient care. Unfortunately, the hybrid boarding process has been anything but expeditious. Employees involved in medical care and mental health treatment, including the large numbers of psychologists and social workers the VA is trying to bring on board, are facing extreme delays in appointment and promotion A second concern is the impact of this process on veterans preference in employment. OIF/OEF veterans experience great difficulty in securing and retaining employment, including reservists and members of the National Guard who return to federal service following active duty. VA employees lose veterans preference protections when they are converted from Title 5 to Title 38 status. All veterans, whether they are covered by Title 38 or Title 5. should have equal employment opportunities in the VA, which strives to be a model employer of veterans. We urge the Subcommittee to reject proposals to convert additional Title 5 employees to hybrid status. A substantial increase in the number of covered employees would be disastrous. Rather, we recommend the suspension of all hybrid boarding pending completion of a pilot project using a streamlined Title 5 hiring process and comparative study of the two systems. AFGE would like to work with the Subcommittee to develop this pilot project. A pilot project using an alternative Title 5 process can also provide valuable lessons for other federal agencies. Other human resources challenges Physician Pay Law: AFGE urges this Subcommittee to conduct oversight into the many problems surrounding the implementation of the physician and dentist pay provisions in P.L. 108-445, Department of Veterans Affairs Health Care Personnel Enhancement Act of 2004. Congress primary objective in enacting these provisions was to reduce the use of expensive fee basis physicians and dentists and fill vacancies at medical facilities has clearly not been achieved. The law required the VA to provide an initial report on progress toward this goal to Congress followed by five annual reports. AFGE is not aware of a single report having been published to date. Meanwhile, many facilities face severe recruitment problems and the VA continues to spend substantial sums on costly contract care, including Project HERO, a pilot project impacting 23 states. Problems are evident both in the laws market pay and performance pay systems for physicians and dentists, specifically: Improper composition of local compensation panels setting market pay for individual providers ; Managements refusal to share market pay survey data; The VAs unilateral reduction of the maximum performance pay award set by Congress; In many facilities, there have severe delays in developing performance pay criteria; Most criteria were developed without any input from front line provider or employee representatives; Many of the criteria are improper, for example penalizing missed patient appointments which is clearly beyond the providers control. AFGE urges the Subcommittee to conduct its own study of the laws effectiveness, including the following criteria including in the laws reporting requirement: rates of pay by facility and specialty; rates of attrition; number of unfilled positions in each specialty and length of time positions have been unfilled; and, a yearly comparison of staffing levels, contract expenditures, and average salaries. Nurse Alternative Work Schedules: In 2004, Congress authorized facility directors to offer nurse alternative work schedules (AWS) in the form of full-time pay for three 12-hour work days. This schedule option is widely available in the private sector. AFGE is not aware of a single VA facility that has offered AWS to date. We urge the Subcommittee to stop relying on the discretion of facility directors who are resistant to implementing AWS, and mandate by law that facilities offer this option consistent with their prevalence in the local labor market. Equality for Part-Time Nurses: Part-time nurses represent a valuable resource to VHA. We recommend that Title 38 be amended to enable part-time nurses to earn the same rights and job security as their full-time colleagues. Also, many full-time nurses convert to part-time status for family and other personal reasons after they acquire permanent status. Changing to a part-time schedule should not result in a loss of permanent status. Thank you.     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