PCAFC Extension Work Group Letter to Secretary of Veterans Affairs
The Honorable Doug Collins
Secretary of Veterans Affairs
810 Vermont Avenue, NW
Washington, DC 20571
September 3, 2025
Dear Secretary Collins,
In March 2022, the Department of Veterans Affairs (VA) suspended revocations and discharges from the Program of Comprehensive Assistance for Family Caregivers (PCAFC) due to an overly restrictive regulation that failed to reflect the intent of Congress. Despite thissuspension, many veterans and caregivers who should qualify for PCAFC remain unable to participate because a revised final rule has not yet been published.
In March 2025, the undersigned organizations met with senior VA leadership to raise several urgent concerns regarding PCAFC, including: (1) the need for an extension of the Legacy cohort's participation beyond September 30, 2025; (2) the reopening of casework communication with the Caregiver Support Program (CSP) leadership; and (3) the need for greater transparency with stakeholders, veterans, and caregivers concerning the development and publication of a new final rule governing PCAFC.
We are grateful that casework communication with CSP leadership has since been reestablished, enabling meaningful dialogue and case-specific resolutions. This renewed engagement has significantly improved our ability to support the veterans and caregivers we serve.
We were also encouraged by VA’s recent indication that it intends to publish a rule granting an extension for Legacy participants. However, with the current September 30, 2025, discharge date rapidly approaching, we remain concerned that the rule has not yet been published or implemented. Although we understand that the proposed rule is undergoing regulatory review, we are increasingly worried that it will not be finalized in time to prevent the discharges. Compounding this concern is the absence of clear communication to veterans, caregivers, and stakeholders regarding the regulatory timeline. This uncertainty is generating significant anxiety among Legacy participants, and it is limiting our ability as stakeholder organizations to provide them with reassurance or guidance. We respectfully urge the Department of Veterans Affairs to issue a formal assurance to the Legacy caregiver and veteran population affirming that the extension will be published by the September 30, 2025, deadline, and that no participant will be discharged because of delays in the regulatory review process.
Furthermore, no timeline has been communicated for the publication of a new final PCAFC regulation to replace the currently in-force version, which has been in place since October 1, 2020. We understand VA has recognized the inadequacy of the current regulation—evidenced by the suspension of discharges in 2022—but without a replacement rule, veterans and caregivers continue to be denied access to PCAFC, or are receiving insufficient support due to the rule’s overly restrictive criteria such, as the requirement for assistance “each and every time an Activity of Daily Living is performed.”
The announcement of a proposed extension of Legacy participants through September 2028 strongly suggests that relief from the current regulation is not imminent. Meanwhile, application approval and appeal rates for PCAFC continue to decline as evidenced by VA’s own monthly Caregiver Support Program data. The ongoing delay in publishing a new regulation, combined with the lack of communication from VA, is causing demonstrable harm to veterans, caregivers, and their families. The uncertainty surrounding program participation, the inability to access necessary support, and the stress of navigating an unclear regulatory environment are taking a heavy toll.
As stakeholder organizations, we are increasingly unable to offer meaningful guidance, support, or optimism to the veterans and caregivers we serve because we are not receiving timely or substantive updates from VA regarding the progress or timeline of the revised regulation. In the absence of such communication, we are left with the growing concern that the Department does not intend to meaningfully revise the 2020 Final Rule. We respectfully renew our request for clear communication regarding the publication timeline for the new final rule and any associated re-evaluation process.
We strongly believe in collaboration with VA and in working together to improve the lives of veterans and their caregivers. We remain committed to supporting VA in these efforts. However, the continued lack of transparency is hindering that partnership. While we understand that the Department is restricted from commenting on the substance of regulations currently undergoing review, these restrictions do not preclude the Department from promptly sharing a projected timeline for the publication and implementation of a new final rule. Providing such a timeline would help reduce the uncertainty and anxiety experienced by both Legacy and current participants and would enable stakeholder organizations to more effectively support the veteran and caregiver community. This coordination could be further enhanced if the Department were to adopt a Negotiated Rulemaking Committee process—similar to the approach currently being used by the Department of Education in its rulemaking for higher education policy.
Please reach out to Andrea Sawyer, Advocacy Director, Quality of Life Foundation, at ASawyer@QoLFoundation.org or 703-328-9677, with questions you may have.
Respectfully,
Quality of Life Foundation
Elizabeth Dole Foundation
National Defense Committee
National Veterans Legal Services Program
The Independence Fund
WiseHealth/Veteran Caregiver
Veteran Warriors