Veterans Affairs Computer Systems: Action Underway Yet Much Work Remains
To Resolve Year 2000 Crisis (Testimony, 09/25/97, GAO/T-AIMD-97-174).
Pursuant to a congressional request, GAO discussed federal progress in
addressing the Year 2000 problem, focusing on: (1) action taken by the
Department of Veterans Affairs (VA) as a whole; (2) steps taken by the
Veterans Benefits Administration (VBA) in response to recommendations
contained in a GAO report; and (3) results of its review of the Veterans
Health Administration's (VHA) Year 2000 activities.
GAO noted that: (1) according to VA's August 14, 1997, quarterly report
to the Office of Management and Budget, the Department has made progress
in addressing the Year 2000 problem; (2) as noted in the report, one of
its 11 mission-critical systems--the one serving the National Cemetery
System--is already fully compliant; (3) of the ten remaining mission
critical systems and their applications, 85 percent have been assessed
and 51 percent have been renovated; (4) in addition, VA has updated its
total Year 2000 cost estimate from $144 million (May 1997) to $162
million; (5) VA's stated reason for the increase is the need for
upgrades to its commercial off-the-shelf software and hardware, and more
contractual support; (6) VA's current estimate shows that it expects
systems assessment to be completed by the end of next January,
renovation of systems by November 1998, validation by January 1999, and
implementation by October 1999--2 months earlier than VA reported in
May; (7) VBA has responded to the Year 2000 challenge by initiating a
number of actions, including developing an agencywide plan and a Year
2000 strategy and creating a program management organization; (8)
however, several substantial risks remain; (9) if VBA is to avert
serious disruption of its ability to disseminate benefits, it will need
to strengthen its management and oversight of Year 2000-related
activities; (10) VHA is in the initial stages of assessing the
compliance of its two mission-critical systems; (11) it is essential
that each of VHA's 22 regional health care networks thoroughly assesses
and plans for ensuring Year 2000 compliance so that service delivery is
not interrupted; (12) in order to effectively assess and renovate, it is
necessary to understand how local customizations, software add-ons,
external interfaces, and physical facilities may affect Year 2000
compliance; (13) VHA is assessing Year 2000 impact on medical devices;
and (14) while GAO's detailed review of the VHA area is just now under
way, it is clear that for VA as a whole to have all of its
mission-critical systems compliant by January 1, 2000, will entail a
huge, well-coordinated effort.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: T-AIMD-97-174
TITLE: Veterans Affairs Computer Systems: Action Underway Yet Much
Work Remains To Resolve Year 2000 Crisis
DATE: 09/25/97
SUBJECT: Systems development life cycle
Information resources management
Strategic information systems planning
Systems conversions
Data integrity
Veterans benefits
Computer software
Computer equipment management
Systems compatibility
Systems design
IDENTIFIER: OMB Year 2000 Program
VA National Cemetery System
VA Veterans Health Information Systems and Technology
Architecture
VA Veterans Integrated Service Network
VA Year 2000 Strategy
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Cover
================================================================ COVER
Before the Subcommittee on Oversight and Investigations, Committee on
Veterans' Affairs, House of Representatives
For Release on Delivery
Expected at
9:30 a.m.
Thursday,
September 25, 1997
VETERANS AFFAIRS COMPUTER SYSTEMS
- ACTION UNDERWAY YET MUCH WORK
REMAINS TO RESOLVE YEAR 2000
CRISIS
Statement of Joel C. Willemssen
Director, Information Resources Management
Accounting and Information Management Division
GAO/T-AIMD-97-174
GAO/AIMD-97-174T
(511236)
Abbreviations
=============================================================== ABBREV
CIO - chief information officer
DHCP - Decentralized Hospital Computer Program
FDA - Food and Drug Administration
MR - Imagnetic resonance imaging
OMB - Office of Management and Budget
VA - Department of Veterans Affairs
VBA - Veterans Benefits Administration
VHA - Veterans Health Administration
VISN - Veterans Integrated Service Network
VISTA - Veterans Health Information System Technology Architecture
============================================================ Chapter 0
Mr. Chairman and Members of the Subcommittee:
We are pleased to be here today to discuss the progress being made by
the federal government and, in particular, the Department of Veterans
Affairs (VA), in making sure that its automated information systems
are ready for the upcoming century change. As you know, we testified
before the Subcommittee earlier this summer, at which time our report
was released detailing the activities of one VA component,\1 the
Veterans Benefits Administration (VBA), to make its systems Year 2000
compliant.\2
As requested, my testimony today will first summarize federal
progress in addressing the Year 2000 problem and will then examine VA
and its major components. My statement will discuss action taken by
VA as a whole, and steps taken by VBA in response to recommendations
contained in our recent report. We have just begun a detailed review
of the Veterans Health Administration's (VHA) Year 2000 activities;
consequently, my testimony in this area will be limited to results to
date.
--------------------
\1 Along with VBA, the other two major VA components are the Veterans
Health Administration and the National Cemetery System.
\2 Veterans Benefits Computer Systems: Uninterrupted Delivery of
Benefits Depends on Timely Correction of Year-2000 Problems
(GAO/T-AIMD-97-114, June 26, 1997) and Veterans Benefits Computer
Systems: Risks of VBA's Year-2000 Efforts (GAO/AIMD-97-79, May 30,
1997).
FEDERAL AGENCY PROGRESS:
EFFORTS MUST BE EXPEDITED
---------------------------------------------------------- Chapter 0:1
As we testified in July,\3 time is running out for agencies and the
pace needs to be accelerated if widespread systems problems are to be
avoided as the Year 2000 approaches. We stressed in our testimony
that the Office of Management and Budget (OMB) and key federal
agencies need to move with more urgency. Among the other related
issues we noted was that increased attention was required on
validation and testing of Year 2000 solutions, data interfaces and
exchanges, and contingency planning.
OMB's most current Year 2000 progress report on the federal
government's efforts, released last week, again demonstrates that
although federal agencies are generally making progress toward
achieving Year 2000 compliance, the overall pace of that progress is
too slow.\4 Based on individual agency reports, 75 percent of the
agencies' approximately 8,500 mission-critical systems remain to be
repaired or replaced, and the total cost estimate has risen to $3.8
billion, up $1 billion from the previous quarterly report.\5
According to OMB, reports of several of the agencies were
disappointing; consequently, it placed agencies in one of three
categories, depending upon evidence of progress. In the first
category are four agencies that OMB found had "insufficient evidence
of progress."\6
For these agencies, OMB established a "rebuttable presumption going
into the Fiscal Year 1999 budget formulation process this Fall that
we [OMB] will not fund requests for information technology
investments unless they are directly related to fixing the year 2000
problem."
OMB's second category contains 12 other agencies for which it cited
"evidence of progress but also concerns." These agencies were put on
notice that continued funding for information technology investments
would be contingent on continued progress.\7
Finally, for the eight remaining agencies that according to OMB,
appear to be making progress--and this includes VA--funding requests
will be handled in the usual manner, although progress at all
agencies will be reevaluated on the basis of their next quarterly
reports, due November 15.\8
We are encouraged by OMB's statements and believe they reflect an
increased urgency to address the Year 2000 issue. Further, we note
that in its report, OMB states that it plans to address other issues
that we raised in our July testimony.\9
-- OMB emphasized that proper validation of changes was critical to
success. It stated that it planned to meet with agencies over
the coming months to discuss the adequacy of scheduled
timetables for completing validation.
-- OMB said it would discuss with agencies the preparedness of
communications interfaces with systems external to the federal
government, including those of state and local governments and
the private sector.
-- OMB asked agencies for a summary of the contingency plan for any
mission-critical system that was reported behind schedule in two
consecutive quarterly reports so that it could summarize such
plans in future reports to the Congress.
We look forward to implementation of these key activities as we
continue monitoring OMB's leadership of the federal government's Year
2000 effort.
--------------------
\3 Year 2000 Computing Crisis: Time Is Running Out for Federal
Agencies to Prepare for the New Millennium (GAO/T-AIMD-97-129, July
10, 1997), before the Subcommittee on Government Management,
Information and Technology, House Committee on Government Reform and
Oversight, and the Subcommittee on Technology, House Committee on
Science.
\4 Progress on Year 2000 Conversion, U.S. Office of Management and
Budget, August 15, 1997.
\5 Getting Federal Computers Ready for 2000: Progress Report, U.S.
Office of Management and Budget, May 15, 1997.
\6 These are the Departments of Agriculture, Education, and
Transportation and the Agency for International Development.
\7 These are the Departments of Commerce, Defense, Energy, Health and
Human Services, the Interior, Justice, and the Treasury and the
Environmental Protection Agency, Federal Emergency Management Agency,
National Aeronautics and Space Administration, Office of Personnel
Management, and Small Business Administration.
\8 Along with VA, this category encompasses the Departments of
Housing and Urban Development, Labor, and State and the General
Services Administration, National Science Foundation, Nuclear
Regulatory Commission, and Social Security Administration.
\9 GAO/T-AIMD-97-129.
VA: THE STAKES ARE HIGH
---------------------------------------------------------- Chapter 0:2
VA is very vulnerable to the impact of the new millennium because of
the large number of veterans and their dependents that it serves;
this is why it is so important that VA's systems be made compliant in
time to avoid disruption to the benefits and services on which
millions of Americans depend. Our past and current work at VA
indicates that the Department recognizes the urgency of its task, and
it has made progress. But much remains to be done if it is to avoid
the widespread computer failures that unmodified systems could bring.
If left uncorrected, the types of possible problems that could occur
include but are not limited to late or inaccurate benefits payments,
lack of patient scheduling for hospital treatments, and
misinterpretation of patient data. The number of areas vulnerable to
problems is vast.
The Department's June 1997 Year 2000 plan (VA Year 2000 Solutions)
outlines VA's strategy, activities, and major milestones. According
to this plan and in line with OMB guidance, VA's primary approach is
to make its 11 existing mission-critical systems compliant; one, in
fact, already is. Table 1 lists these systems, along with the
numbers of applications they serve and the responsible VA component
or office.
Table 1
VA's Mission-Critical Computer Systems
(11) and Their Applications (464)
Number of
Component/office applicatio
(Number of systems) Systems ns
---------------------------- ---------------------------- ----------
Veterans Benefits Compensation & Pension 157
Administration (6) Education
Insurance
Loan Guaranty
Vocational Rehabilitation
Administrative
Veterans Health Veterans Health Information 143
Administration (2) Systems and Technology
Architecture
Veterans Health 160
Administration Corporate
Systems
National Cemetery System Burial Operations Support 2
(1)\a System/Automated Monument
Application System
Reengineer
Office of Financial Personnel and Accounting 1
Management (2) Integrated Data
Financial Management System 1
----------------------------------------------------------------------
\a The only system that VA considers to be fully Year 2000 compliant.
Source: VA.
Responsible for overseeing the Year 2000 problem at VA is its chief
information officer (CIO); he is assisted by the CIOs of both VBA and
VHA, by senior information technology managers in the National
Cemetery System, and by staff offices at VA headquarters. VA has
also designated a Year 2000 project manager, responsible for general
oversight and monitoring.
According to VA's August 14, 1997, quarterly report to OMB, the
Department has made progress in addressing the Year 2000 problem. As
noted in the report, 1 of its 11 mission-critical systems--the one
serving the National Cemetery System--is already fully compliant. Of
the 10 remaining mission-critical systems and their applications, 85
percent have been assessed and 51 percent have been renovated. In
addition, VA has updated its total Year 2000 cost estimate from $144
million (May 1997) to $162 million; VA's stated reason for the
increase is the need for upgrades to its commercial off-the-shelf
software and hardware and more contractual support.
Further, VA's current estimate shows that it expects systems
assessment to be completed by the end of next January, renovation of
systems by November 1998, validation by January 1999, and
implementation by October 1999--2 months earlier than VA reported in
May.
VBA HAS BEGUN TO IMPLEMENT GAO
RECOMMENDATIONS
---------------------------------------------------------- Chapter 0:3
As we testified before the Subcommittee in June,\10 correcting the
Year 2000 problem is critical to VBA's mission of providing benefits
and services to veterans and their dependents. VBA has responded to
this challenge by initiating a number of actions, including
developing an agencywide plan and a Year 2000 strategy, and creating
a program management organization. However, several substantial
risks remain. If VBA is to avert serious disruption to its ability
to disseminate benefits, it will need to strengthen its management
and oversight of Year 2000-related activities.
Our May 30, 1997, report contained 10 specific recommendations to the
Secretary of Veterans Affairs on actions that VBA needed to take to
address the Year 2000 problem.\11
VA concurs with all 10, and is in the process of implementing them.
For example, according to VBA:
-- To strengthen its Year 2000 program management office, it has
assigned oversight and coordination responsibilities for all
Year 2000 activities to this office alone.
-- It has completed inventories of data interfaces and third-party
products (hardware, software, mainframes, minicomputers,
operating systems, and utilities). VBA has also determined that
most of its third-party products are Year 2000 compliant--98
percent of its personal computers, local area networks,
minicomputers, and commercial software; and all of its imaging
equipment and associated software.
-- It has renovated half of the 157 applications that make up its
six mission-critical systems. It plans to renovate the
remaining applications by November 1998.
While we are encouraged by these positive actions, we understand from
discussions with VBA officials that key work schedules have been
compressed, creating added pressure. For example, renovation of
VBA's largest and most critical applications--those necessary to the
functioning of its Compensation and Pension Service--may not be
completed by VBA's target date of December 1998. Changes to these
applications have had to be delayed in order to effect this year's
legislatively mandated changes and cost- of-living increases. Time
is similarly short for work on the loan guaranty system, for which
key phases remain to be completed.\12 For example, the new
construction and valuation application is scheduled to start in early
fiscal year 1998, but it has a fail date\13 of December 1998. This
leaves VBA only slightly 1 year to design, develop, test, and
implement this application.
A further challenge for VBA is that it has not modified its schedule
to take into account recent problems and delays in its attempts to
replace an education payment system for selected reservists known as
chapter 1606. Such schedules are important to ensuring that all
mission-critical applications are fixed; they therefore need to be
modified or updated to reflect realistic estimations of the
difficulty of the work involved.
In addition, although VBA has completed an inventory of 590 internal
and external interfaces, as of July 31, 1997, only 26 percent of the
interfaces had been assessed for compliance. VBA's Year 2000 project
manager indicated that VBA is encountering problems determining
whether its external interfaces\14 are Year 2000 compliant because
external sources have not provided the necessary information.
VBA also has not updated its January 1997 risk assessment to reflect
the recent change in its Year 2000 strategy. Specifically, in
response to concerns raised regarding its initial approach, VBA
redirected its Year 2000 strategy by focusing on converting its
existing benefits payment systems rather than replacing the
noncompliant systems. Since risk assessment is an important
prerequisite for effectively prioritizing projects and mitigating
potential problems, updating the previous risk assessment to take
this change into account is essential.
An internal VA oversight committee, established to monitor and
evaluate the progress of VBA's Year 2000 activities, identified
concerns similar to ours. Specifically, according to a member of
this committee, little time remains for VBA to make the necessary
modifications to its compensation and pension and loan guaranty
systems, and much work remains in assessing the external interfaces
for compliance.
--------------------
\10 GAO/T-AIMD-97-114.
\11 GAO/AIMD-97-79.
\12 The key Year 2000 program phases remaining are renovation,
validation, and implementation.
\13 The date on which this application will experience the effects of
dates on calculations.
\14 An example of an external interface is the exchange of disability
compensation information between the Department of Defense and VBA.
Defense currently provides VBA with electronic information on the
amount of disability benefits paid to a veteran by Defense for offset
against the amount paid by VBA to this same veteran. This offset is
necessary because, by law, the veteran cannot be paid twice for the
same disability.
VHA HAS BEGUN TO ASSESS ITS
SYSTEMS AND RELATED PRODUCTS
FOR COMPLIANCE
---------------------------------------------------------- Chapter 0:4
The Year 2000 challenge for VHA is enormous. As the largest
centrally directed civilian health care system in the United States,
VHA manages health care delivery to veterans within 22 regional areas
geographically dispersed throughout the country; these areas are
known as Veterans Integrated Service Networks (VISNs), and they
encompass 173 VA medical centers, 376 outpatient clinics, 133 nursing
homes, and 39 domiciliaries--a total of 721 facilities. These sites
utilize a wide range of electronic information systems, biomedical
equipment, facilities systems, and other computer-based system
products. Accordingly, it is essential that each of these 22
regional health care networks thoroughly assesses and plans for
ensuring Year 2000 compliance so that service delivery is not
interrupted.
Within VHA, the CIO has overall responsibility for planning and
managing Year 2000 compliance. The CIO created a VHA Year 2000
project office, empowered to develop compliance guidance. In April
1997, this office developed a VHA plan for addressing the year 2000;
the plan was approved by VA's Under Secretary for Health on May 14 of
this year. The CIOs of each of the 22 regional networks, medical
facility directors, and managers have ultimate responsibility for
preparing and executing their individual Year 2000 plans, including
all required assessment, renovation, validation/testing, and
implementation activities.
According to VA's August 14, 1997, quarterly report to OMB, VHA is in
the initial stages of assessing the compliance of its two
mission-critical systems--the Veterans Health Information Systems and
Technology Architecture (VISTA)\15 --formerly known as the
Decentralized Hospital Computer Program (DHCP)--and the VHA corporate
systems. VA also reported that of the two systems' applications, 17
percent have been assessed and 16 percent renovated. VHA plans to
complete this assessment and renovation by the end of January 1998
and July 1998, respectively.
According to VA's Year 2000 readiness review, VHA's strategy for the
national VISTA applications is to assess all 143 applications and
recode as necessary. According to VHA, 34 of its 143 applications\16
have been assessed; 33 of these 34 were eliminated as a result of the
assessment.
In order to effectively assess and renovate, it is necessary to
understand how local facilities are using the national VISTA
applications. One potential risk is that some local facilities have
customized national applications, according to VA's Year 2000
readiness review.\17 If this is true, it is important that VHA know
where applications have been changed--even in small ways--so as to
ensure that they are Year 2000 compliant. Beyond customization,
local facilities may purchase software add-ons to work with the
national applications; here, too, these must be inventoried and Year
2000 compliance assessed.
An inventory of internal and external VISTA interfaces has not yet
been completed; systems developers plan to identify such interfaces
when they assess each application. Should internal information be
corrupted by exposure to uncorrected external interfaces through
network exchanges, system crashes and/or loss of data could result.
VA's Year 2000 project manager has expressed concern that this
information may not be obtainable from external sources, who have yet
to inform VHA whether their interfaces are Year 2000 compliant.
As with interfaces, VHA must be assured that the commercial software
products it uses are Year 2000 compliant. It has completed an
inventory of its commercial products, such as personal computer
operating systems, office automation software, and medical
applications; according to the project manager, over 3,000 software
products and 1,000 software vendors have been identified. VHA plans
to rely on the General Services Administration to provide it with a
general list of commercial products that are Year 2000 compliant.
For specialized products unique to the health care industry, VHA
plans to contact manufacturers for compliance information.
Physical facilities are another area of concern. According to VHA's
Year 2000 program manager, VHA has not completed an inventory of
facilities-related systems and equipment such as elevators; heating,
ventilating, and air conditioning equipment; lighting systems;
security systems; and disaster recovery systems. Such elements are
vitally important to VHA's ability to provide high-quality health
care services. VHA is working with the General Services
Administration and manufacturers on this issue. Since it is often
critical that medical services not be interrupted, VHA is required to
have contingency plans in place in case hospital systems fail. These
plans are reviewed and assessed regularly by the Joint Commission on
Accreditation of Healthcare Organizations. However, such contingency
plans are meant to ensure continued operation in the event of
disaster; such approval does not necessarily ensure that all backup
systems are Year 2000 compliant.
--------------------
\15 VISTA represents the national health care information
applications along with related commercial products, personal
computers/workstations, and other items used in VHA health care
facilities.
\16 Examples of applications include dietetics, pharmacy/inpatient,
health summary, prosthetics, and laboratory.
\17 Such customization includes special-purpose programs written by
local information resources management staff or other system users
on-site or imported from other VA medical centers. They generally
meet a specific local need or extend the functionality of nationally
released software.
VHA IS ASSESSING YEAR 2000
IMPACT ON MEDICAL DEVICES
---------------------------------------------------------- Chapter 0:5
Health care facilities depend on the reliable operation of a variety
of biomedical devices--equipment that can record, process, analyze,
display, or transmit medical data. Examples include computerized
nuclear magnetic resonance imaging (MRI) systems, cardiac monitoring
systems, cardiac defibrillators, and various tools for laboratory
analysis. Such devices may depend on a computer for calibration or
day-to-day operation. This computer could be either a personal
computer that connects to the device from a distance or a
microprocessor chip embedded within the device. In either case, the
software that controls the operation of the computer may be
susceptible to the Year 2000 problem. The impact could range from
incorrect formatting of a printout to incorrect operation of the
device, having the potential to affect patient care or safety.
The risks for a specific medical device depend on the role of the
device in the patient's care and the design of the device. Although
medical treatment facilities have the expertise to understand how
medical devices are used, they rely on device manufacturers to
analyze designs and disclose Year 2000 compliance status.
As a health care provider and user of medical devices, VHA is a key
stakeholder in determining compliance of such tools. Another key
player is the Food and Drug Administration (FDA), in its role of
protecting the public from unsafe and/or ineffective medical devices.
In attempting to ascertain the potential impact of the century change
on its biomedical devices, VHA on two separate occasions sent letters
to manufacturers. Its first letter was sent over a period of a few
days beginning June 23 of this year to equipment manufacturers
identified by selected experts within VHA. In the letter, VHA
inquired as to steps the manufacturer planned to take to resolve the
Year 2000 issue. Out of 118 letters, VHA received 32 responses.
These responses were reviewed by VHA's medical device integrated
product team, comprising internal experts from a variety of fields.
On the basis of the team's analysis, VHA sent more detailed letters
asking specific questions, including whether the manufacturer
provided any devices to VA that incorporate a real-time clock; if
such devices were provided, whether they are Year 2000 compliant;
and, for those that are not compliant, asking for model numbers,
device names, and the specific impact the century change would likely
have on the device. These letters were sent to about 1,600
manufacturers on September 9, 1997, with a request for responses by
October 3. According to VHA, 50 responses had been received as of
September 15.
Product team members plan to review responses to ensure that they are
categorized correctly as compliant, noncompliant, or pending; VHA
will maintain a database of the manufacturers and their responses.
This database will be made available to VA medical centers through
the VHA intranet, although key personnel such as biomedical engineers
may not have easy access to the intranet at some medical centers.
The information will also be communicated to VA medical centers
through monthly conference calls among engineers and communications
with medical center directors. We feel that it is imperative that
such results be widely disseminated; if the VHA intranet is
insufficient for this task, other means should be found.
FDA also recently began communicating with manufacturers. According
to officials, FDA sent a letter in early July of this year to about
13,000 such manufacturers, reminding them of their responsibility to
ensure that their products will not be affected by the century
change. In the letter, FDA reminded manufacturers that, according to
section 518 of the Federal Food, Drug, and Cosmetic Act, they are
required to notify users or purchasers when FDA determines a device
presents an unreasonable risk of substantial harm to public health.
Although one response was received, the acting director of FDA's
Division of Electronics and Computer Science explained that it was
not the agency's intention to solicit a specific response because FDA
expects manufacturers to report any problems found through normal
reporting channels. FDA plans to disseminate information on any Year
2000 problems reported by manufacturers to the public through its
reporting systems, such as the Medical Products Reporting Program
("MedWatch").
According to the director of FDA's Cardiovascular Division, the
agency's strategy for helping to determine whether medical devices
are Year 2000 compliant is to rely on the knowledge and experience of
its resident experts. These experts, with backgrounds in electrical
engineering, software engineering, and/or biomedical engineering,
have reviewed the design of selected medical devices to determine
whether the devices would be affected by the century change. In the
case of pacemakers, for example, FDA experts have concluded that no
adverse effect will result. This conclusion was based on the fact
that the internal operations of pacemakers do not involve dates. The
experts further said that although pacemaker settings are often
changed with the assistance of a computer, which often uses dates and
may be noncompliant, a trained physician is always involved in
controlling the settings.
A federal entity--the Year 2000 Subgroup on Biomedical Equipment--is
working to coordinate the effort to obtain Year 2000 compliance
status information from medical device manufacturers. This group
plans to follow up on nonrespondents to questionnaires sent out by
VHA, FDA, and other federal health care providers to manufacturers
requesting this information.
-------------------------------------------------------- Chapter 0:5.1
In closing, Mr. Chairman, I want to stress that while our detailed
review of the VHA area is just now underway, it is clear that for VA
as a whole to have all of its mission-critical systems compliant by
January 1, 2000, will entail a huge, well-coordinated effort.
This concludes my statement. I would be happy to respond to any
questions that you or other Members of the Subcommittee may have at
this time.
*** End of document. ***