Comment on FR Doc # N/A
Michael MacDonaldSupportIndividual
Summary: A veteran is commenting in support of the proposed records disposition schedule for Veterans Health Administration Mental Health and Behavioral Science records. The commenter agrees with the 75-year retention period for clinical records but suggests that some psychological testing materials might also benefit from longer retention periods to assist with future claims.
Comment for Docket DAA-0015-2025-0003
I appreciate the opportunity to comment on the proposed records disposition schedule for Veterans Health Administration Mental Health and Behavioral Science records (DAA-0015-2025-0003). As a veteran who has relied on VHA mental health services, I understand how critical these records are for continuity of care, supporting benefits claims, and maintaining accountability within the system.
The detailed documentation contained in the Mental Health/Hygiene Folder File (Item 0002) — including therapy notes, psychological evaluations, treatment progress notes, and related clinical information — directly supports veterans’ ongoing care and their ability to substantiate service-connected conditions for disability compensation and other benefits. These records often serve as the primary evidence when veterans file claims or appeals years after treatment ends. The proposed 75-year retention period after the last episode of care is appropriate and necessary to protect veterans’ rights and ensure continuity across decades of potential need.
I also note the shorter retention periods proposed for Clinical Psychology Research Folders (Item 0001) and raw Psychology Test Data and Worksheet Files (Item 0003). While I understand the need for efficient records management, I encourage NARA and VHA to consider whether certain subsets of psychological testing materials may retain clinical or evidentiary value beyond seven years, particularly when they could assist in future evaluations or claims.
Overall, I support the careful balance reflected in this schedule and thank NARA for its review. Adequate retention of VHA mental health records is essential not only for individual veterans but also for the integrity and accountability of the benefits system that serves them.