M28C Veteran Readiness and Employment Manual

Veteran Readiness And Employment Quietly Launches New M28C Policy Manual Online

The Chapter 31 Veteran Readiness And Employment program, formerly Vocational Rehabilitation and Employment, quietly launched its new online M28C bible on Friday.

The release comes after years of preparation and rewriting the internal policies governing decisionmaking and conduct of Chapter 31 vocational rehabilitation counselors and related employees. The M28C Veteran Readiness and Employment Manual is now online in searchable digital formal for the first time.

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Previous versions of the policy manual, formerly M28, then M28R, now M28C, were not searchable using HTML. Instead, readers were required to download each subpart of the manual to review parts of the document.

RELATED: Chapter 31 Voc Rehab Survival Guide

Why Does M28C Matter?

These manuals are required reading for employees who work in Chapter 31. Vocational rehabilitation counselors are mandated to follow the M28C.

Policy manuals like this, similar to the M21-1MR for disability compensation, are supposed to interpret ambiguities in regulations to help VA employees make proper decisions. While these manuals do not carry the weight of law, they are generally treated like bibles by agency staff.

It is important veterans and their representatives are familiar with the documents because they usually broadcast how agency employees will decide various matters. The documents are also useful because it helps identify errors in legal reasoning that can impact decisionmaking.

As a VA accredited attorney with a practice focus on denied Chapter 31 benefits, I’ve been waiting for the new iteration of the manual for some time. I previously created a paginated, searchable PDF version of the M28R for my readers to make it easier to address bad agency decisions. This was a process that took a lot of time and focus.

How That Happened

Some years ago, when I had to fight for my own Chapter 31 benefits, I received a denial of self-employment services. That denial did not contain what I would call natural flowing language.

What I mean by this is that it was clear the counselor cut and paste certain text from somewhere else, without citation, and then used that text as the basis for the denial. I had just become an attorney at the time waiting for my VA accreditation after completing law school at the University of Minnesota and passing the state bar.

I cannot remember what led me to the M28R page on VA WARMS, but I realized quickly that downloading over 100 different PDF attachments and searching all 1,000+ pages in individual downloads would be a waste of time.

RELATED: The Five Chapter 31 Training Tracks

So, I found software that allowed me to paginate each PDF into one singular PDF to then search. I hit Control + F on my Mac and located the relevant phrase the counselor included. This helped me locate the context the counselor cited.

Finding the context of the citation helped me know the counselor misapplied the text from the section of the manual.

This was somewhere around 2014.

I eventually prevailed and won self-employment benefits that helped me with my law practice helping veterans and their family members fight against wrongful agency denials and other issues.

A side perk of that experience to the veteran population happened when I published a copy of and regularly updated the M28R for other veterans to read and research.

RELATED: 4 Fibs Voc Rehab Counselors Tell Veterans

Now, we have a new Chapter 31 bible to check out called the M28C.

Is it better? Yes… and no.

Not Better Than M28R

Google Indexing.  At least at the time of this writing, the website is not indexed by Google meaning general searches from the public will not pull up the policy manual.

ADA Compliance. The knowva.ebenefits.gov website does not appear to be ADA compliant when it comes to the navigation menu.

Rehab Act Compliance. When you click on the “508 Help” button on the website, nothing happens. When I click on it, I get, well, nothing. This feature is in reference to Section 508 of the Rehabilitation Act of 1973. It requires federal government websites to be compliant with various accessibility standards for disabled people.

I would argue, given this snafu alone, that the site is likely not 508 compliant or ADA compliant.

Okay, side bar.

Is it ironic that VA’s own 508 feature is inoperable at the time VA finally releases its HTLM searchable M28C policy manual for the agency’s own vocational rehabilitation program? Doesn’t the agency have a $4 billion annual IT budget to help disabled veterans?

It seems odd. Oh, what I could do with even 1 percent of $4 billion.

I digress. The tricky menu feature to search through the manual via menu makes it difficult to manually sift through the different parts of the manual including the main index.

PDF Preference. I prefer the ability to search an entire PDF using Acrobat to locate each instance where a certain phrase or word is used. The new iteration of the policy manual requires pulling up each subsection and then searching that for the specific term.

Better Than M28R

Searchable. Veterans and counselors can now search and access any part of the M28C without needing to download over 100 separate PDF and Word documents. This is GREAT!

More Data. The new manual includes other documents previously not available online including its template decision letters and other forms of guidance.

To Be Determined

Now that a new policy manual iteration has been issued, we will need to review it for changes against its previous updates. Unlike the old M28R, this new M28C format does not lend itself to quickly discerning updated sections.

Previously, the WARMS website for VA did provide for this kind of quick review. The new HTML version does not appear to be as quickly accessible.

I ended up conducting a search within the M28C section using “2020” to see what might come up. It appears around 50 different parts of the previous policy manual were updated this year prior to publication of this manual last Friday.

The agency has gotten a lot better at annotating when certain parts of the manual were updated, which his always a plus.

Why No Drum Roll?

Some of you may be surprised that the agency did not announce the release of this new version of the policy manual in an agency press release.

The most recent press releases instead included:

I checked elsewhere on the agency’s website and on Google using various searches to see if I could locate some kind of press release or other notice. Nothing.

So, why do you think VA would not issue a press release about the new policy manual? The agency had been working on the update for years, after all.

VR&E did push out emails about the new COLA information about increased monthly subsistence payment amounts as of October 1, but I did not see much about the M28C.

Eye Roll

For some background. These VR&E manuals are not exactly something the Chapter 31 program’s employees were thrilled I stumbled upon in 2014 and then published for my readers.

It’s kind of like getting the playbook of your opposing football team a week ahead of the big game, and knowing that playbook makes it easier to ensure VA employees are doing what they are required to do.

At the time, veterans within my Facebook group regularly reported back that counselors would roll their eyes at veterans citing regulations and policies when self-advocating during meetings. This still happens.

Some counselors get annoyed by veterans who know the rules agency employees are required to follow.


Manuals like this are aimed at increasing consistency across regional offices nationwide. It removes a lot of gray area.

While the program has improved significantly since 2014 as far as training quality and other factors (a lot), many counselors then and some counselors now like to shoot from the hip rather than base their decisions on sound analysis of the statutes and regulations governing program entitlement.

This trend was noted in a recent GAO audit of the program that concluded decisionmaking between counselors and offices lacked consistency. One veteran could get denied certain training in one office but get approved when she moved across state lines into the jurisdiction of a different Regional Office.

All the more reason to know what the policy manual says.

I could go on and on about this topic, but I’ll summarize by saying this newest publication is a good thing. It increases accessibility and hopefully updates the programs policies to bring them into compliance with current law.

Until next time…

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  1. Not the most tech proficient. Wondering if there is still and ILP component and if so has it been strippped to nothing or ??

    1. One more point and I will get out of your hair Benjamin.
      In one of my comments referring to the service officers and the providers here locally, i.e., with excluding the same ones that I had mentioned before who were trying to work in my best interest as well as other veterans, mostly were at a total disconnect as to what was going on in my situation while even in this VISN under their noses. In other words, they slammed without knowing the facts and no way I could present the facts. Because they assume and believe what they want to believe. Basically, they flocked together and that was that. And, ultimately they could have careless because it was not impacting them. Best.

    2. Benjamin, I am a Gulf War Era veteran. I do not fit any of their claims. They have all the legislation to fit other veterans in other periods of time. Basically, I have been truly on my own since 2004 with the exception of the 3 VA providers of whom I was referring to earlier. My process forward mostly occurred out of the VA with involvement with private sector folks not medical care. I am not talking about medical care. I am talking about doing. The system did not fit my forward. Now, if I had had a life threatening illness, then the VA would have then fit the path. Benjamin, the situations are not black and white but they believe they are. Well, they are not. As for trying to work while under their care, the dysfunction of the VA made it impossible. I witnessed many veterans who did not have Tricare or any other alternative to turn too besides the VA; and, this contributed to many veterans losing their jobs. And, the numbers they put out about the veterans’ homelessness having decreased under the Obama administration, I find those numbers hard to believe. The only time that I actually witnessed in this VISN and I am referring to the VA that I was mostly assigned to here of when the VA actually delivered great medical care was when the VA medical care folks were paid at market value of the going profession. My car insurance company pay the VA medical providers at full healthcare provider rate as being exactly the same rate as the private sector. This was when I was involved in a major car accident that caused a broken arm, a gash in my forehead, and unconsciousness.
      Thank God, though, I had car insurance and was able to get an attorney. Thank God, I was fortunate enough that UF Shands was able to do the surgery. Please, if I did not have the car insurance and if I had to have depended on the VA during that time, I might not be alive today. This happened in 2012 right smack in the middle of the Obama administration. So trust me I witnessed the decline with everything under the Obama administration. I have a plate in my right arm due to that car accident. I have zero pain anywhere today. I know you did not ask for all of this I was just painting the story that is all. But getting back to the work situation, people on the outside would have no way of knowing the barriers because they were not under them. They would just piggy back with whatever the VA was doing or not doing. Do you know the year that I had the car accident I was not able to involve myself in any schooling. Plus, I even had a Chapter 31 Vocational Rehabilitation appointment scheduled right about the same time as the car accident October 2012. The accident did not happen on the same day but it happened right before. And, yes, I had to cancel the appointment. So I was SOL. So what could I complete during that time? Almost nothing except I was able to get the GRE exam completed the following August 2013. The scores were good enough to get into most UF programs with exception of a couple. Those scores became outdated in August 2018. I could not use them. I had been denied Chapter 31 in summer 2015 and proceeded that fall to have to assist my sister in Atlanta who had almost died in February 2016. Then, I come back and in summer or 2016, I could not get anything done basically. So that is when I proceeded to move my care out of the VA. This went on into 2017 with straightening out and improving what had not been being seen about. And on into 2018 with still improving my status and then had to move out of an apartment that became almost dilapidated. I had lived there since 2005 basically. So much was happening that I could not get moved out of the apartment until summer 2018. So this is when my scores became outdated. Plus, not only did I have to move my own care out; but, I had to move and then too I was having to assist to help my mom with her brother who was a veteran. And, I was fighting with the VA here too in regards to his care with what they were or were not doing. Then he died in November 2018. The VA was so difficult to deal with that I had to assist my mom with this issue. My family is scattered across the country. Then, oh my gosh, his home with all the federal government medical supply waste in his home. Ben if the VA Secretary ever wonders why the shortage in medical supplies? It is because his agency was sending out too much. Some could still be used and the rest I had to take to a police station to be incinerated. So Ben, tell me where has been the opportunity for me to try to work? Show me. So in 2019, I enroll in a computer A+ certification class. Only able to get the first half of it completed. Come summer 2019, I had to pick up the pieces with my mom’s surgery in which the ball was dropped. Yes I had to see about it and help with the care until the home care was arranged. While assisting, I had taken my laptop with me because it had not been feasible for me to be positioned in a classroom or positioned to do much of anything under what one would say a employer environment. I completed a Calculus class online while there helping. Then I proceeded to come back after the home kicked in which was Fall 2019. However backing up to 2015, I had had an informational interview with the College of Health Professions with a PhD UF professional. At that time, participating in any program as being degree seeking was not feasible even with the good GRE scores. My tolerance level for stress was low. Plus, I did not have fluent and spontaneous speech at that time. Plus, I had an interview with the SS folks for employment. They did not hire me. Even in 2016, I had checked with them again but no go. However if you look at the whole picture in regards to furthering my own path, holding employment was not feasible. I have had barriers everywhere that did not pertain to me. The real change in regards to my functioning at a much higher level started when assisting my sister.
      So I may not even vote at all. So now I’m older and judged. I have zero kind words for the VA except yes 24 years ago in a different VISN, they were genuinely investing in the veterans and doing their best to deliver care and assistance. I know you did not ask for all of this; but, I spoke anyway. Most of this I have communicated before.

  2. @Crazy Elf,
    for the first news article regarding mental health care, yes, I did note the change with the mental health care sessions with a couple veterans. They had shared with me the time length of the sessions and how many they were allowed. This was around a year ago. Now, also what has been shared with me is the VA has started shifting veterans out in the community for mental health care for example some of the PTSD therapies. This is what I was told by a couple of veterans. The veteran asked me if I knew anything about or heard about a certain type mental health therapy. I said, Yes, I was aware of it; but, I personally never did receive that type of care. I had become aware of it through an Independent Study that I did under a PhD professor /LCSW at a college and an Internship under a Senior Counselor at a Forensic Treatment Facility. So from what I am aware of, it seems the mental health folks at least near me are having to adapt around what the GAO is trying to implement in order to meet the veterans needs.
    Also, as for the TownHall, the Under Secretary did call and leave a voicemail with saying to call in. I did listen to the voicemail on the fly but it was not feasible for me to call in. I was not sure if I could get directly in because an extension number was not left on the 1-800 number.At the same time, I was dealing with a company. So I was not able to get back when the Town-Hall was in progress.
    When dealing with the VA, the person cannot be positioned in correcting and trying to solve other situations with companies and be on the phone with the VA in a TownHall at the same time.
    The VA VBA Under Secretary had called about the same time. And the task had to be done before 8pm and the VA under Secretary called around 6pm or so and the company was having issues. And plus, the situation could not wait until the next day. The task had to be done by 12pm.
    Ben, the E-Commerce Fraud and Fraud attempts are unbelievable. Plus, yes we know the federal government and the companies love their technology; but, however, half the time they can barely get their jobs done. I am referring to the technology such as IPADs and etc that seem to constantly malfunction. So therefore, the business transactions are delayed or cannot happen. Best.

    1. Ben, I clicked into the link that you provided in the article; and, kind of glanced at it and plan to read through it. Thank you for staying on top of and keeping an eye out. The VA under Secretary mentioned in his article that he wrote about reaching out to veterans who are isolated. Does he mean isolated from the VA? Or isolated from just everything? In my situation, it would be being isolated from the VA because I had left. My only contact with the happenings of the VA is what some of the vets tell me or what I see and read in articles and media. Though, I am not isolated out here trust me. There is never a dull moment. How can there be? Just look around.

      1. Ben,
        it is good that they made the time to improve the M28 Policy Manual. The Manual was probably most definitely needing to be updated like most policies in the VA. Mr. Wilkie and some leadership types are trying so it seems to deliver the VA to a more veteran friendly status. Plus, the veterans truly needed more substantive information that they could access in order to be more able to advocate for themselves. When one has the correct information in hand, the situation in many cases can move along smoother to reach a resolve or to reach the delivery instead of having to accept the only option being the VA counselors spoken or written words. It enhances accountability which is a plus. As for myself, I would not count on them approving anything in my case. Although, they may have a predetermined position that would more than likely contribute to them not approving Chapter 31.
        Here is my point; I am 58 years old. However, my physical age is much younger than my chronological age. When companies and institutions always want to do online whatever and they see the person’s age only, they probably just delete the resume or application or just skip over it. However, they might also look at other entities such as high school graduation year. In the end though all of this is off track.
        Had 3 people this week tell me out of the blue that I look in my late 30s or early to mid 40s. We were discussing the happenings in the country and sometimes when people are aware of certain aspects it would conjure up people’s age because they would know the history on some things. This is how the age came up into the conversation. See this happened face to face in person. Plus, I participated in a professional/ graduate school expo yesterday with a university. I have some online training going on myself that is free or low cost. Applying for employment and internships. FDIC has a 4 year corporate training program coming up. The person only has to have 6 hours of Accounting to be eligible to apply.
        Plus some other happenings are in the making. With this being said though, “I do not look for the VA to do anything at this point in my situation.”
        I am referring to assisting with education and training for substantive employment. They may think I cannot cut it like they have always thought.
        I will just have to continue doing it myself. They already blew the opportunity with the continual denials and now the eligibility criteria has passed.

    2. Benjamin, I will say veterans’ homelessness, veterans not getting retrained into substantive employment, and veterans lives being truly messed over has all to do with the federal government.
      Ben, look at this. The VA will go ahead and cut on a veteran before even doing a CTSCAN or a MRI or some type of imagery to view the condition. Yes they do this. They do indeed. This leads me to see the vets life truly doesn’t matter. This methodology is truly unethical. But you see when it comes down to it and if the veteran dies, the attorneys will not have a way to get the information on this. Because they will more than likely doctor the records. I know they are doing because they are doing it. I am referring to doing the procedure before doing a scope or whatever.

      In regards to employment and or school, Ben, they believe what they want to believe. See the VISN in the Northeast that I was initially in, this VA years ago was really trying to help many veterans with their lives. A genuine effort was really in play here during the late nineties. Now switch to the VISN that I was in since 2000 until 2015, most of the time they were trying to take me out with the exception of about 3 VA providers.

      Over the years in this VISN, there were comments made that I never understood what they were talking about. In other words, Ben, most of them never spoke with information that was in line with what had happened to me and never spoke with information that pertained to my situation. Ben, even the DAV in this VISN has been clueless. They have made comments that are really off the wall and are truly not correct. So this continues to lead me to ask the question what changed. What have they put into my records that I do not know about? I know with what I do know about I have had to correct it or wind up just leaving the VA.
      Sending me employment opportunities from whomever is sending them from the VA overall via Indeed. Ben, the jobs they send of course I am not qualified for.
      And how could I be? They were running their nobody knows anything scams and kicking my care down the road and denying me and making claims that were never accurate. And since I left I had been involved in correcting behind them and cleaning up their negligence.
      And they do not care about a progression at all and they do not care about the facts. They assume and make false judgements. I say this due to their actions and statements that they have made. I truly believe they only want to know about what they want to push regardless if it is correct or not. And Ben, like I say this VISN that I was in here have always been in left field in regards to me. And I know for a fact that I was even sicker in the past of when they initially established my rating. I have this information and they seemed to have not wanted to acknowledge it at all. And VISN 8 here would have never fathomed the way that I was when the Navy initially retired me with how that I am today. This is why I believe they are attacking me so. But in reality I honestly do not know. Ben, my degree of functioning is at a much higher level than when the Navy retired me.
      I believe they reject this due to how they have thwarted my school to return to workforce process.
      And I truly do not understand. They believe that I can only do today what the rating they had established many years ago stated that defined my condition. Ben, this was years ago. These are their laws not mine. They are the ones who have blocked me at every turn. But yet they send me employment opportunities that I should be qualified for?? How Ben? They have been attacking me for at least in the last 10 years non stop. Now I could get qualified but they do not think so. How can they say one way or the other when they have been trying to take me out? And they say they want veterans working. Well Ben I have not witnessed that. Constant situations to straighten out.,. Enroll in school and put it on a credit card. Yes I am ready to go yes low level employment.
      And I have not seen a doctor since last December for anything except to basically get a mammogram done.
      And why? Because the federal government has been in the way with the way they do things. Democrats in particular. I do not want assistance from them and never have. I landed where I landed. I have never truly understood where this VA VISN and even these particular Service Officers were coming from. Only 3 or 4 VA types here have ever worked in my best interest. And truly if the VA had left these providers along, I might would already be qualified to do those jobs that they have been sending me. Truly pathetic.

      1. Benjamin and everyone, those Hillary Clinton emails are soon to be released to the public. Ben, I will say that whomever I had voted for in past was never an issue because it just was never discussed. It just wasn’t. But when this President started running for office and when some VA employees asked and found out who I was voting for, I was slammed and shutdown even more. Do you see this? Benjamin we all have a right to vote for whomever. It is none of the VA’s business. We veterans are not their pawns and we should be allowed to make our own decisions. I almost believe what has been happening to me particularly in the last ten years has had all to do with politics. And Ben, I never cared anything about politics until this current president. Ultimately, I have not deserved their slamming and their sabotaging actions directed at me. No veteran does.,,,

      2. As for the M28C, I was able to access it before you sent out the email claiming the broken link. I had accessed it from within your article. So Benjamin, I am not sure what you are saying here in regards to the link being broken. Thanks, everyone have a nice weekend.

  3. OT

    GWS & anthrax vaccines Copied from the comments: “-“500,000 sharks will be killed because the shark oil based SQUALENE will be used in the Covid vaccines. Squalene has been a highly controversial vaccine ingredient.

    A 2000 study published in the American Journal of Pathology demonstrated a single injection of the adjuvant squalene into rats triggered “chronic, immune-mediated joint-specific inflammation,” also known as rheumatoid arthritis. The researchers concluded the study raised questions about the role of adjuvants in chronic inflammatory diseases.

    In humans, the immune system recognizes squalene as an oil molecule native to your body. It is found throughout your nervous system and brain. In fact, you can consume squalene in olive oil and not only will your immune system recognize it, you will also reap the benefits of its antioxidant properties.

    The difference between “good” and “bad” squalene is the route by which it enters your body. Injection is an abnormal route of entry which incites your immune system to attack all the squalene in your body, not just the vaccine adjuvant.

    Your immune system will attempt to destroy the molecule wherever it finds it, including in places where it occurs naturally, and where it is vital to the health of your nervous system.

    Gulf War veterans with Gulf War Syndrome (GWS) received anthrax vaccines which contained squalene. MF59 (the Novartis squalene adjuvant) was an unapproved ingredient in experimental anthrax vaccines and has since been linked to the devastating autoimmune diseases suffered by countless Gulf War vets.

    The US Department of Defense made every attempt to deny that squalene was indeed an added contaminant in the anthrax vaccine administered to Persian Gulf war military personnel – deployed and non-deployed – as well as participants in the more recent Anthrax Vaccine Immunization Program (AVIP).

    However, the FDA discovered the presence of squalene in certain lots of AVIP products. A test was developed to detect anti-squalene antibodies in GWS patients, and a clear link was established between the contaminated product and all the GWS sufferers who had been injected with the vaccine containing squalene.

    A study conducted at Tulane Medical School and published in the February 2000 issue of Experimental Molecular Pathology included these stunning statistics:
    “ … the substantial majority (95%) of overtly ill deployed GWS patients had antibodies to squalene.

    All (100%) GWS patients immunized for service in Desert Shield/Desert Storm who did not deploy, but had the same signs and symptoms as those who did deploy, had antibodies to squalene.
    In contrast, none (0%) of the deployed Persian Gulf veterans not showing signs and symptoms of GWS have antibodies to squalene.

    Neither patients with idiopathic autoimmune disease nor healthy controls had detectable serum antibodies to squalene. The majority of symptomatic GWS patients had serum antibodies to squalene.”

    According to Dr. Viera Scheibner, Ph.D., a former principal research scientist for the government of Australia:
    “… this adjuvant [squalene] contributed to the cascade of reactions called “Gulf War Syndrome,” documented in the soldiers involved in the Gulf War. The symptoms they developed included arthritis, fibromyalgia, lymphadenopathy, rashes, photosensitive rashes, malar rashes, chronic fatigue, chronic headaches, abnormal body hair loss, non-healing skin lesions, aphthous ulcers, dizziness, weakness, memory loss, seizures, mood changes, neuropsychiatric problems, anti-thyroid effects, anemia, elevated ESR (erythrocyte sedimentation rate), systemic lupus erythematosus, multiple sclerosis, ALS (amyotrophic lateral sclerosis), Raynaud’s phenomenon, Sjorgren’s syndrome, chronic diarrheic, night sweats and low-grade fevers.”
    – Neil Johnston, Pharmacist, Patient Safety Advocate” ”

    ‘Riding the Dragon’ Director Reveals Hunter Biden’s China Deals@13:ish”https://www.youtube.com/watch?v=YZpUj5TWUFI”

    Trevor Loudon.researches radical and terrorist groups, and so discusses programmed rioting followers@11:ish”https://www.youtube.com/watch?v=yBVhkb-pUNo”

  4. Here’s something of interest for “caregivers”:

  5. 1.) *”https://www.military.com/daily-news/2020/10/05/new-productivity-targets-counselors-could-hurt-mental-health-care-veterans-gao.html”*

    2.) “The VA is working harder than ever to connect with isolated veterans!”
    (Google this title to read the article!)

    1. Here’s the link to #2)

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