The Veteran's Spectator

Victories, Frustrations, and VA Idiocracy

Individual Longitudinal Exposure Record (ILER)

PACT Act & Toxic Exposure · 13 pages · Obtained

For any claim related to toxic exposure, the VA should now develop an ILER Memorandum.

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Department of Memorandum Veterans Affairs Date: December 5, 2022 FROM: Office of Field Operations (OFO), Office of Administrative Review, Compensation Service, and Pension & Fiduciary Service TO: All Veterans Benefits Administration (VBA) Veterans Service Centers (VSCs), Decision Review Operations Centers (DROC) and Pension Management Centers (PMCs) Subject: Guidance for using Individual Longitudinal Exposure Record (ILER) when processing certain claims for service connection. Purpose This memorandum provides guidance to all claims processors on the mandatory use of ILER when reviewing and processing certain service-connected claims that may be subject to a toxic exposure risk activity (TERA). It will also provide guidance on the suggested use of ILER in other specific non-TERA-related claims. Note: The absence of exposure or deployment-related verification in ILER does not mean exposure-related evidence does not exist. If a Veteran that may be subject to a TERA is not found in ILER or ILER does not provide exposure or deployment-related verification for a Veteran, claims processors should continue developing for a potential TERA through normal verification methods. Background The Individual Longitudinal Exposure Record (ILER) is a joint Department of Defense (DoD) and VA web-based application that provides the ability to link a Veteran to military exposures and/or deployments to improve the efficiency, effectiveness, and quality of care. The exposure data in ILER currently integrates information from multiple sources, including, but not limited to, the Defense Occupational and Environmental Health Readiness System-Industrial Hygiene (DOEHRS-IH), Armed Forces Health Surveillance Branch (AFHSB), Defense Manpower Data Center (DMDC), and Military Health System (MHS) Data Repository. For a complete list of data sources and registries in ILER, see Appendix A. ILER currently provides access to over two million unique Veteran records and acts as a single access point to deployment history; including time, location, military occupational specialty (MOS), occupational hazard data, environmental hazards known or later found, monitoring performance in the area(s), diagnosis, treatment, and laboratory data.

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ILER has the capability of enabling a search by individual, location, and exposure type. Note: The only information in the ILER tool that contains self-reported information is located under the Health Assessments drop-down. Access to ILER For more information about access to ILER, please reference the ILER Interim Guidance that was provided to the field on October 7, 2022. The ILER Training Course (TMS 4626459) includes additional information on how to access and navigate in ILER. Additionally, to access ILER, users must first request access. ILER access requires completion of the following TMS courses: • TMS #10203 - Privacy and HIPAA Training • TMS #10176 - VA Privacy Awareness and Information Security Awareness and Rules of Behavior • TMS #4626459 — ILER (Individual Longitudinal Exposure Record) The first two courses are mandatory courses that most users complete annually, so there should not be an additional training burden. Certificates must be downloaded from TMS for this training in preparation for requesting access. ILER does not require an upload of the certificate for TMS Course #4626459. Once users have completed the required training and downloaded their certificates, they will need to request access to ILER. Users can request ILER access by first logging in using their Personal Identity Verification Card (PIV) on the ILER site and then clicking the link to request access. The ILER training provides more detail regarding the access request process. Required Use of ILER in TERA-related claims. Effective January 1, 2023, the use of ILER is required when processing certain claims for benefits. Claims processors shall perform an ILER inquiry to determine if the Veteran participated in a TERA unless the condition(s) claimed by the Veteran: • Is a claim for an increase or • Meets one of the §1168 exceptions noted below in the “Exceptions to TERA Examinations” section of the PACT Act SOP, (e.g., ACL tear of right knee), or • Can otherwise be granted service connection based on the evidence of record (e.g., flashed records or based on a presumption of service connection). Notes: • ILER can be used to help verify service location(s) for PACT Act presumptive claims. • Even if a TERA can otherwise be verified through other means, (e.g., DD Form 214 shows naval service and MOS that allows concession of exposure to asbestos), claims processors must check ILER, as examiners must review the ILER record

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when considering “the synergistic, combined effect of all toxic exposure risk activities of the Veteran,” as required by the PACT Act. • Mandatory use of ILER applies to claims for service-connected death that involve TERA-related service-connected conditions or causes of death where: o the evidence of record does not provide exposure-related verification and o the benefit cannot otherwise be granted based on the evidence of record. What Actions are Required if There is an ILER Entry? As required by law, if an ILER inquiry reflects an entry for the Veteran, then the Veteran will be considered to have participated in a TERA. In all such cases, as noted in the “Procedures for Establishing TERA” section in the PACT Act Implementation SOP, claims processors shall generate and upload the Individual Exposure Summary to the Veteran’s eFolder. Requesting Examinations Deployment Information: For TERA-related examinations, examiners must consider “the total potential exposure through all applicable military deployments of the Veteran.” Deployment information must be provided to examiners and must be tabbed in the file. Deployment information may be found in a variety of locations; if the deployment information is used to concede the TERA, it must be tabbed for the examiner. Exposure Levels Within Permissible Levels: It is not necessary to tab evidence in the Individual Exposure Summary when an exposure level(s) for an environmental assessment is within permissible levels. In such cases, it is still important to make the summary available to Compensation and Pension (C&P) Examiners. The summary may not necessarily denote a specific “toxic exposure,” but it may contain valuable information on potential environmental hazards that were present at a location in which the Veteran served and may be useful to C&P Examiners when considering the combined effect of all TERAs. When there is potential for a harmful level of toxic exposure, DoD conducts site assessments that are available in ILER. It is important to note that these assessments are only a snapshot in time, which does not characterize the potential exposure over an extended period of time. Exposure Levels that Exceeded Permissible Levels: It is necessary to tab certain evidence in the Individual Exposure Summary, specifically when a Registry or Industrial Hygiene tile header is displayed in red as this means that an ILER entry exceeded the recommended exposure level. Since the Veteran in this case has been exposed beyond permissible limits, it is necessary to make the C&P Examiners aware of the specific details of such exposure. Note: For more information on the suggested use of ILER, see Appendix B. Exposure-related Information in ILER

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The exposure information related to the individual is grouped and displayed in one of the following tiles (for more detailed information on the tiles, please refer to the ILER User Guide: Chapter 3 found in the ILER tool): Individual Deployment History The Individual Deployment History data is provided by Defense Manpower Data Center (DMDC) and encompasses a complete history of a Veteran’s military career: geographic location/country, start/end date of deployment, unit name/organization/unit number, and description of duty/work assignment. Exposure Pathways Exposure Pathways are based on a collection of site-specific data to identify potential or actual exposure for an individual. Exposure Pathways contain the potential health hazard/exposure route, threat source, environment media, priority, exposure pathway start/end date, personnel assigned to exposure pathway, location, and the number of samples. Table 1: Interpreting “Personnel Assigned to Exposure Pathway” If Then “Yes” is marked The Veteran was located in the general vicinity of the exposure. Note: Clicking on the “Yes” link will display the timeframe the Veteran was assigned to the exposure pathway. “No” is marked The Veteran was at the location and may have been exposed and could possibly experience symptoms of exposure. Periodic Occupational and Environmental Monitoring Summary (POEMS) POEMS is a DoD provider-focused, technical document that describes Occupational and Environmental Health (OEH) exposures and associated health implications for a deployment location during a specific timeframe. POEMS describes the types of OEH hazards identified during that time and provides a characterization of the base camp population’s exposures and potentially associated health effects. The documents provide a description of the risk estimates for short and long-term medical implications and any recommendations for medical action, follow-up, or surveillance. POEMS is based on all available site-specific OEH data, surveys, and reports, and is reviewed by Combatant and Command (COCOM) Force Health Protection (FHP) personnel. Industrial Hygiene

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Industrial Hygiene displays exposure information from the industrial hygiene assessments that were performed on each of the Similar Exposure Groups (SEG) to which the Veteran was assigned. Text in the Industrial Hygiene header will be displayed in red if any of the entries exceed the recommended exposure level. Registry The registry contains general information about the event, a listing of locations, any associated incident reports, and a listing of hazards tracked by the registry. Text in the Registry tile header will be displayed in red if any of the entries exceed the recommended exposure level. You will see a Registry tile for all individuals who have been associated with a Registry via an Individual Exposure Profile, Population Exposure Profile, or Potentially Exposed Population (PEP) through an Incident Report. Incidents Incidents are a comprehensive form to document all aspects of an incident and whether potentially exposed personnel exhibited signs or symptoms of exposure. Documenting the use of ILER in VBMS for TERA-related claims Documenting the use of ILER in the e-folder is required for TERA-related claims. Claims processors should download the complete ILER results to substantiate the claim and then upload these results to VBMS. See Appendix C for Job Aid on Uploading ILER Individual Exposure Summary for TERA-related claims. If a Veteran is not found in ILER, or the Individual Exposure Summary Information screen indicates the Veteran does not have an exposure record, capture a screenshot to document that there is no toxic-exposure-related evidence in ILER. The screenshot should be converted into an acceptable format that can be uploaded to VBMS. Use the following attributes when uploading the screenshot indicating the Veteran does not have an exposure record: In the document field.. Enter.. SUBJECT ILER – No exposure record CATEGORY_TYPE Correspondence-Miscellaneous Identification Materials SOURCE DoD Integration DATE OF RECEIPT The date the screenshot was created/submitted in VBMS If there are issues logging in to the ILER tool, the Individual Exposure Summary can be accessed via Joint Legacy Viewer (JLV). See Appendix D for how to open the widget in JLV that contains ILER results. Documenting review of ILER in Claim Decisions The ILER record should be treated as a service record for the purpose of evidence entry. When generating the evidence list claims processors should follow the table in M21-1 V.iv.1.A.4.c.

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If an exposure event is found in ILER for a TERA-related claim, but service connection is unable to be granted, then decision-makers should list the exposure using the premade Favorable Findings in VBMS-R. Additional References Individual Longitudinal Exposure Record (ILER) Login Individual Longitudinal Exposure Record (ILER) VBA Training (TMS 4626459) Questions Questions concerning this guidance should be directed via email through station leadership to Districts/OFO.

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Appendix A – Data Sources and Registries included in ILER The following data sources and registries are currently included in ILER: Registries: VA Registries: • Airborne Hazards and Open Burn Pit • Gulf War Registry DoD Registries • Operation Tomodachi • Gulf War Oil Well Fire Smoke Registry (GOWFSR) • Chemical Warfare Agents (CWA) during OIF/OND • Khamisiyah Investigation • Depleted Uranium (DU) • Chemical Biological Warfare Exposure Data Sources: • Armed Forces Health Surveillance o Pre-Deployment Health Assessment (Pre-DHA) o Post-Deployment Health Assessment (PDHA) o Post-Deployment Health RE-Assessment (PDHRA) o Annual Periodic Health Assessment • Defense Manpower Data Center (DMDC) Contingency Tracking System • Defense Occupational and Environmental Health Readiness System – Industrial Hygiene (DOEHRS-IH) • Defense Enrollment Eligibility Reporting System (DEERS) • Military Exposure Surveillance Library (MESL) • MHS Data Repository (MDR) o Comprehensive Ambulatory/Professional Encounter Record (CAPER) o Standard Inpatient Data Record (SIDR) o Theater Medical Data Store (TMDS)

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Appendix B – Suggested use of ILER on other than TERA-related claims The use of ILER is suggested for the following types of claims (this is not an all-inclusive list and claims processors should determine if information available in ILER may satisfy the elements of an event, injury, or disease in service): • Posttraumatic stress disorder, to include military sexual trauma (MST) o If the Veteran claims a stressor took place in a certain location or due to fear of hostile military or terrorist activity, the Individual Deployment History can be reviewed to identify the locations in which the Veteran served. • Undiagnosed illness and medically unexplained chronic multi-symptom undiagnosed illnesses and MUCMIs under 38 CFR 3.317 o Individual Deployment History in ILER can be used to determine if the Veteran has qualifying service in the Southwest Asia theater of operations as defined in 38 CFR 3.317(e)(2), or in Afghanistan, Israel, Egypt, Turkey, Syria, and Jordan. • Tropical diseases under 38 CFR 3.309(b) o Individual Deployment History in ILER should be used to determine if the Veteran had qualifying tropical service. • Diseases associated with service in Afghanistan under 38 CFR 3.317(c)(2) o Individual Deployment History in ILER can be used to determine if the Veteran has qualifying service in Afghanistan (for the purpose of a claim under 38 CFR 3.317(c) only). • Specific environmental hazards identified by DoD as defined in M21-1 VIII.iii.9.A.1.b o Information contained in ILER can be used on a case-by-case basis to determine if the Veteran meets the element of having an exposure event in service and/or was in a specified location when filing a claim under M21-1 VIII.iii.9.A.1.b and M21-1 VIII.iii.9.A.1.d. • Specific military occupational hazard as defined in M21-1VIII.iii.9.B.2.g o A Veteran’s exposure to a specific military occupational hazard can be conceded if the claimed exposure is consistent with the occupational duties and responsibilities performed during the Veteran’s military career. Exposure Pathways, POEMS, Incidents, and/or Industrial Hygiene should be checked for the claimed exposure. • Hearing loss o The Individual Exposure Summary Information screen lists the most recent Service MOS Description. • Common claimed exposures related to service-connected (SC) Survivor benefits such as Dependency and Indemnity Compensation (DIC) and SC Burial claims o Diseases specific to former prisoners of war under 38 CFR 3.309(c). o Diseases specific to radiation-exposed Veterans under 38 CFR 3.309(d). o Chronic diseases and rare cancers associated with fine particulate matter under 38 CFR 3.320.

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Appendix C – Uploading ILER Individual Exposure Summary (IES) to VBMS Step One — Locate the Veteran’s Electronic Data Interchange Personal Identifier (EDIPI) number in VBMS Core. This information is found in the “Veteran Information” tab in the “Veteran Summary” column on the right side of the VBMS Core when you access a Veteran’s record: Step Two — Login to ILER, select “Individual Search” at the top, and then input the Veteran’s EDIPI number in the search box labeled “EDIPI/DoD ID.” Once you enter the EDIPI, select “Search” at the bottom of the “Search Criteria” box.

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Step Three — Once the Veteran’s ILER Results are shown, select the red PDF icon in the top right corner of the Veteran’s search results. When you hover over the icon, it should read, “Export Exposure Summary Information.” Once selected, a pop-up will appear that states the Veteran’s Individual Report has successfully queued. Navigate to “User Generated Reports”, located on the left side of the screen and select this tool. Step Four — From User Generated Reports, find the queued report. Once the status notes “Complete”, select the “Download” icon to download this report as a PDF. The “Download” icon is located to the right and is a blue square with an arrow pointing down. If you hover over this icon, it will display, “Download.”

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Step Five — Navigate back to VBMS and upload the PDF you downloaded from ILER. Use the following attributes when uploading the ILER results: • Subject: ILER Records • Category – Type: Correspondence – Miscellaneous: Identification Materials • Content Source: DOD Integration • Date of Receipt: Date the ILER record was created (found on the first page of the ILER PDF)

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Appendix D – Opening the ILER Widget in JLV Step One — Login to JLV and perform a search. Once the search results are available, navigate to the bottom right of the screen and select “Open Widget Tray.” Step Two — The Widget Tray will open up at the bottom of the screen. Find the widget that you would like to add. To View ILER results, the “Questionnaires, Deployment, Exposure Records” widget is needed. Step Three — Grab the widget by hovering over the widget and pressing down on the left mouse button. Keep the left mouse button depressed and “drag” the widget into the open area above the Widget Tray, then release the left mouse button. This should open the widget you selected.

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The “Questionnaires, Deployment, Exposure Records” widget displays a Veteran’s ILER results as “Individual Exposure Summary.”

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