What this means
m21-1:IX.i.3.C explains pension income development. In plain terms, the official guidance says when information about recurring income is needed, some or all of the following information is required depending on the situation: It also addresses per 38 CFR 3.23(d)(6), hardship exists when expenses necessary for reasonable family maintenance exceed the sum of countable annual income plus VA pension entitlement.
How this may help with a claim
Use m21-1:IX.i.3.C as an internal VA audit trail for pension income development, not as a promise of a particular result. Compare the actions recorded in your claim file or decision notice with this source-specific detail: When information about recurring income is needed, some or all of the following information is required depending on the situation: Per 38 CFR 3.23(d)(6), hardship exists when expenses necessary for reasonable family maintenance exceed the sum of countable annual income plus VA pension entitlement. If the record does not show the expected action, identify the missing step precisely when asking VA or an accredited representative to review the file.
What to review in your file
- Check the file against this official condition: When information about recurring income is needed, some or all of the following information is required depending on the situation:
- Confirm that the record or notice addresses this source point: action to take when income for VA purposes is uncertain, see M21-1, Part IX, Subpart iii, 1.A.2.
- Document how this stated step or exception applies: If information is not available by accessing FOLQ, ask the veteran or claimant to furnish a copy of their latest Social Security award or disallowance letter or a statement from SSA, if an award or disallowance letter is not available.
Important limits
m21-1:IX.i.3.C is primarily internal workflow guidance about pension income development. It can help identify what VA was expected to document, but it does not by itself create a claimant deadline, a freestanding entitlement, or a guaranteed remedy. The source also states: When information about recurring income is needed, some or all of the following information is required depending on the situation: When the veteran or claimant has already provided the required VA Form 21P-0969, Income and Asset Statement in Support of Claim for Pension or Parents’ Dependency and Indemnity Compensation (DIC) because assets are over the asset threshold, additional development is only necessary if the interest portion was left blank or there is contradictory evidence.
Search terms when useful
Phrases that may help when searching your claim file or this library.
- Pension Income Development
- m21-1:IX.i.3.C
- Developing Recurring Income Developing
- Developing Child Hardship Exclusion
- Developing Interest Income Worth
- Developing Railroad Retirement Board
- Developing Recurring Income
- developing recurring monthly income
Original VA guidance
The official VA text of this section
Overview
In This Section
This section contains the following topics:
Scroll sideways to see the full table.
| 1 | Developing for Recurring Income |
|---|---|
| 2 | Developing for Child Hardship Exclusion |
| 3 | Developing for Interest Income From Net Worth |
| 4 | Developing for Railroad Retirement Board (RRB) Benefits |
| Topic | Topic Name |
1. Developing for Recurring Income
Introduction
This topic contains information on developing for recurring monthly income, including
- general information on developing for recurring monthly income, and
- information about
- Social Security benefits
- retirement or annuity income, and
- severance pay, accrued wages, or vacation pay.
Change Date
June 16, 2026
IX.i.3.C.1.a. General Information on Developing for Recurring Monthly Income
When information about recurring income is needed, some or all of the following information is required depending on the situation:
- gross amount of the recurring income
- date the first check was received
- date and amount of any retroactive payment received, and
- dates of any changes in the monthly rate of income.
References: For more information on
- generating letters with automated tools, see M21-1, Part III, Subpart i, 2.D.1.a
- developing for
- Railroad Retirement income, see M21-1, Part IX, Subpart i, 3.C.4, and
- income tax returns, see M21-1, Part III, Subpart ii, 1.C.3.b
- forms for developing specific types of income, see M21-1, Part IX, Subpart i, 3.B.3, and
- action to take when income for Department of Veterans Affairs (VA) purposes is uncertain, see M21-1, Part IX, Subpart iii, 1.A.2.
IX.i.3.C.1.b. Information About Social Security Benefits
Information about Social Security benefits may be obtained directly from the Social Security Administration (SSA) by using the Federal On-Line Query (FOLQ) through the SSA INQUIRY function in the Veterans Benefits Management System (VBMS).
If information is not available by accessing FOLQ, ask the claimant to furnish a copy of their latest Social Security award or disallowance letter or a statement from SSA, if an award or disallowance letter is not available.
Note: Social Security income for pension and Parents’ Dependency and Indemnity Compensation beneficiaries is verified via the annual match with SSA, once either type of benefit has been awarded.
References: For more information on
- the computer match with SSA, see M21-1, Part XIV, 2.A
- how to access FOLQ, see M21-1, Part III, Subpart ii, 1.B.3.c, and
- the SSA INQUIRY function in VBMS, see the VBMS User Guide.
IX.i.3.C.1.c. Information About Retirement or Annuity Income
For information about retirement or annuity income, ask the claimant to furnish a copy of their latest retirement or annuity award letter.
If an award letter is not available, ask the claimant to have the source of the retirement or annuity income send a statement showing the benefit rate and effective date.
IX.i.3.C.1.d. Information About Severance Pay, Accrued Wages, or Vacation Pay
Send VA Form 21-4192, Request for Employment Information in Connection with Claim for Disability Benefits, to a Veteran’s former employer to request information as to the amount and date of any payment of
- severance pay
- accrued wages, or
- vacation pay.
Note: If the former employer does not respond
- send VA Form 21-4192 to the Veteran, and
- ask that the Veteran have the employer complete the form.
2. Developing for Child Hardship Exclusion
Introduction
This topic contains information on developing for a child hardship exclusion, including
- hardship and the child hardship exclusion, and
- developing for the child hardship exclusion.
Change Date
April 29, 2021
IX.i.3.C.2. a. Hardship and the Child Hardship Exclusion
Per 38 CFR 3.23(d)(6), hardship exists when expenses necessary for reasonable family maintenance exceed the sum of countable annual income plus VA pension entitlement.
Per 38 CFR 3.272(m), the child hardship exclusion applies only in pension cases in which a Veteran or surviving spouse has a dependent child with countable income that is available to the Veteran or surviving spouse.
If the authorization activity determines that counting the child’s income would cause hardship, it is possible to exclude some or all of the child’s income.
Note: This exclusion does not apply if the child is the beneficiary.
Reference: For more information on the child hardship exclusion, see 38 CFR 3.23(d)(6).
IX.i.3.C.2.b. Developing for the Child Hardship Exclusion
If a Veteran or surviving spouse requests an exclusion of a child’s income, provide VA Form 21P-0571, Application for Exclusion of Children’s Income.
Do not develop for hardship if the child’s income is
- not available to the Veteran or surviving spouse, or
- otherwise excludable under 38 CFR 3.272(j).
Note: VA Form 21P-0571 can be used to develop for both availability of child income and hardship exclusion.
3. Developing for Interest Income From Net Worth
Change Date
April 27, 2023
IX.i.3.C.3.a. Developing for Interest Income From Net Worth
Initiate development for interest income from net worth if a claimant reports or Federal tax information (FTI) match information shows
- assets which may be earning interest, but it is not clear whether or not they are
- when FTI is not available and interest bearing assets are over the threshold provided on the application form with no interest income reported
- interest or dividend income of over $250, but does not report the source of the dividends or interest as net worth, or
- the same amount of interest and net worth, as the claimant most likely confused the two fields.
Important: Advise the claimant that failure to respond to the request for information will result in a denial of benefits.
Note: When the claimant has already provided the required VA Form 21P-0969, Income and Asset Statement in Support of Claim for Pension or Parents’ Dependency and Indemnity Compensation (DIC) because assets are over the asset threshold, additional development is only necessary if the interest portion was left blank or there is contradictory evidence.
Reference: For more information on when interest income development is required in connection with upfront verification using FTI, see M21-1, Part IX, Subpart iii, 1.A.2.f.
4. Developing for RRB Benefits
Introduction
This topic contains information on requests for information to and from the RRB concerning monthly benefits payable, tax contributions, unemployment, and sickness insurance, including
- considering railroad retirement benefits when determining entitlement to pension
- verifying railroad retirement benefits
- considering unemployment and sickness insurance from the RRB when determining entitlement to pension
- requesting information from the RRB, and
- RRB replies to information requests.
Change Date
June 16, 2026
IX.i.3.C.4.a. Considering Railroad Retirement Benefits When Determining Entitlement to Pension
Railroad retirement benefits are considered countable income.
Exception: Railroad retirement benefits to Veterans are excluded from countable income for Old-Law Pension purposes under 38 CFR 3.262(g)(2).
IX.i.3.C.4.b. Verifying Railroad Retirement Benefits
Access FOLQ through the SSA INQUIRY function in VBMS to verify monthly benefits payable by the Railroad Retirement Board (RRB).
Ask the claimant to furnish the original or a certified copy or photocopy of their award letter from the RRB in every case in which
- the monthly benefits payable by the RRB are in question, or
- there is a probability that recoupment of railroad retirement tax contributions will be an issue.
References: For more information on
- FOLQ, see
- M21-1, Part III, Subpart ii, 1.B.3, and
- the FOLQ User Guide, and
- the SSA INQUIRY function in VBMS, see the VBMS User Guide.
IX.i.3.C.4.c. Considering Unemployment and Sickness Insurance From the RRB When Determining Entitlement to Pension
Unemployment and sickness insurance are based on earnings, but no contribution is made by the employee. The entire amount is considered income for the purpose of determining entitlement to pension.
IX.i.3.C.4.d. Requesting Information From the RRB
If the claimant is unable to furnish the information, or if verification is required and cannot be obtained through FOLQ, send a letter, in duplicate, to the RRB. Use the table below to determine the appropriate address and required information for this letter.
Scroll sideways to see the full table.
| If the request for information is regarding... | Then requesting information from the RRB must include the... | And send the letter to... |
| amount of the railroad retirement benefit, and tax contributions, if relevant | claimant's or recipient’s name address Social Security number (SSN), and railroad retirement number type of VA benefit claimed or being received dates and amounts of VA payments if applicable, and year(s) for which the information is desired | Railroad Retirement Board 844 North Rush Street Chicago, IL 60611 |
| unemployment and sickness insurance information, requesting the amount of the benefit, and commencement and probable termination date, if relevant | claimant's or recipient’s name address SSN, and railroad retirement number, and year for which the information is desired | Bureau of Unemployment and Sickness Insurance Railroad Retirement Board 844 North Rush Street Chicago, IL 60611 |
Important:
- In the absence of contradictory information concerning unemployment and sickness insurance, accept the claimant’s statement showing the amount received or expected.
- Allow 30 days for a response to the initial request and 15 days for a response to a follow-up request, if necessary, being sure to annotate the follow-up request with Second Request.
Reference: For information on handling claims when Federal records are not available, see M21-1, Part III, Subpart i, 2.C.1.
IX.i.3.C.4.e. RRB Replies to Information Requests
The RRB will supply the requested information on the original letter or courtesy copy, or both, if two of their regional offices are involved.