The PACT Act was signed into law on August 10, 2022 and mandates that VA implement toxic exposure screening to identify Veterans with potential toxic exposures during military, naval, air, or space service. The PACT Act imposes a Congressionally mandated timeline to implementation of 90 days, therefore full implementation must be completed by November 8, 2022.
To ensure efficacy of the screening tool and ease of use by screeners, the project team recommends testing the toxic screening tool with a sampling from targeted clinical areas and sites for 10 days, beginning September 6, 2022. The goal is to collect feedback and best practices to use in refining the screening tool and training to increase best chance for success. Testing will be limited to staff in seven clinical settings and pilot sites. The toxic screening tool consists of 1-7 questions, depending upon how the Veteran answers, and will be administered initially in the electronic health record (VistA CPRS). The team estimates completion time for the screening to be approximately 5 minutes.
Due to the Congressionally mandated implementation timeline of 90 days from when the PACT Act was signed into law (August 10, 2022) there is not enough time for VA to follow regular PRA clearance procedures. Also, to ensure efficacy of the screening tool and ease of use by screeners, the project team recommends testing the toxic exposure screening tool with a sampling from targeted clinical areas and sites for 10 days, beginning September 6, 2022. This will allow the final screening tool to be adjusted, as necessary, and launched by the mandatory deadline of November 8, 2022.
Further, it is important to note stakeholder interest in, and support for, a swift and successful implementation of toxic exposure screening mandated under PACT Act from the President, the Hill, The Department of Veterans Affairs, Veterans and their families, and caregivers. The project team has built an effective screening tool and implementation plan in the three weeks since enactment of the PACT Act.
On behalf of VHA Leadership, the project team respectfully requests an emergency OMB PRA Clearance, with plan to follow-up with submission of an official 3-year request. This clearance, if granted, would allow the team to move forward with the important task of testing the screening tool starting Tuesday, September 6. Delaying the start of pilot testing would impact time allotments for collecting and incorporating feedback into the finalized toxic screening tool, ultimately risking implementation within the parameters set by Congress.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.