Comment on AQ72 (SNPRM); Julie Tomaska, PhD Posted by the...

Comment on AQ72 (SNPRM); Julie Tomaska, PhD
Posted by the Department of Veterans Affairs on Sep 26, 2024
Docket Document (VA-2022-VBA-0009-2683)

"As a veteran who has endured extensive testing under the VA system, I know firsthand how flawed the current evaluation process is for constrictive bronchiolitis (CB). Despite suffering from deployment-related respiratory issues, all the standard tests the VA relies on—PFTs, CPETs, and imaging—came back as "normal." It wasn’t until I underwent an invasive open lung biopsy that my diagnosis was finally confirmed. Unfortunately, many veterans face the same struggle, with severe lung damage going undetected by these inadequate tests.

The VA’s continued reliance on outdated and unreliable methods like PFTs, while dismissing expert recommendations from its own Delphi study, is a critical failure. The study emphasized that non-invasive tests are often insufficient, and biopsy results should be prioritized for CB diagnosis. By ignoring biopsy-confirmed cases, the VA forces veterans through unnecessary testing, delaying access to proper disability ratings, benefits, and specialized care.

This approach not only fails veterans like me but contradicts the purpose of the PACT Act, which was designed to expand healthcare for those exposed to toxic substances. To make meaningful change, the VA must update its disability rating criteria to include biopsy-proven CB cases and invest in establishing specialized care centers for deployment-related respiratory diseases.

Moreover, with advances in medical technology, we must work together to implement less invasive diagnostic techniques, so veterans aren’t forced to endure risky procedures for a proper diagnosis. This starts with creating clear diagnostic pathways and establishing the appropriate diagnostic code for CB, ensuring veterans have timely access to the benefits they’ve earned. Anything less is a disservice to those who served and sacrificed. It's time the VA provides comprehensive, evidence-based care for all veterans impacted by toxic exposures."