Quality Review Checklists

3. Quality Review Structure

Introduction

This topic describes the quality review structure, including

• quality review checklists
• general guidelines for benefit entitlement (BE) quality reviews
• grace period for national quality errors
• procedural deficiencies
• deselections
• error citations when corrective action has already been taken
• reviewing all evidence associated with a claim
• clearly identifying and explaining errors
• appropriate citations, and
• cascade effect.

Change Date

January 14, 2026

3.3.a. Quality Review Checklists

The STAR process requires a comprehensive review and analysis of all elements of processing associated with a specific claim or issue. Quality review checklists are designed to facilitate consistent structured reviews.

3.3.b. General Guidelines for BE Quality Reviews

The general guideline is to record a benefit entitlement (BE) error when an action taken violates current regulations or other directives and affects outcome, or has the potential to affect outcome.

Examples of outcome-related deficiencies include, but are not limited to

• failing to adequately address all issues requiring a formal decision, or
• errors that result in an overpayment or underpayment to a claimant, or
• premature decisions that violate the claimant’s due process rights, fail in VA’s duty to assist, and/or otherwise lack necessary development actions that may impact the outcome of the claim.

3.3.c. Grace Period for National Quality Errors

QA may provide a 30 calendar day grace period on any substantive manual changes before officially citing a national quality error. The 30 calendar day grace period is counted as 30 calendar days from the date the corresponding Department of Veterans Affairs (VA) Key Changes document is published. Changes issued for language or other minor grammatical corrections are not considered substantive changes. Examples of substantive changes include, but are not limited to, new procedures being introduced or new rating criteria being effectuated.

STAR grace periods may not be of the same duration when an extended grace period is established for the local Individual Quality Review (IQR) program.

Example: VA Key Changes document showing new manual guidance is published on October 4, 2023, so the grace period includes the next 30 calendar days. BE errors based on the new guidance would be cited with cleared EPs on and after November 2, 2023.

Note: Guidance issued through other means, such as interim guidance or guidance issued by the Office of Field of Operations (OFO) that contains specific claim processing instructions, does not warrant a grace period unless one is specifically provided by OFO or Compensation Service.

3.3.d. Procedural Deficiencies

Procedural deficiencies generally do not rise to the level of BE errors. These deficiencies are usually recorded as

• decision documentation errors
• notification errors
• administrative (internal controls) errors
• examination and medical opinion request-related errors
• expedited favorable decision comments, and
• non-BE comments when corrective action is needed.

Notes:

• If an error requiring correction is identified with an issue not related to the EP under review, that error is also recorded as a comment.

3.3.e. Deselections

With the goal of ensuring a statistically valid and representative sample, every effort will be made to perform a quality review on the cases selected for STAR, however, in instances where it would be inappropriate to perform a quality review on the EP selected, QA will deselect the review.

Generally speaking, for rating claims, QA will complete a review on all cases where it is clear that the RO has completed the claim and there is no remaining development outstanding. For example, if an EP is cleared prematurely when the final rating included directed development for one or more contentions, this would warrant deselection. As the RO personnel indicated that the claim required further development, it was not the intent of the RVSR to have the EP cleared and thus included in the RO's rating sample pool.

However, if the EP has been cleared and the final rating decision contains no directed development instructions, then the review would not warrant a deselection. In the absence of documented development needs, it is presumed that RO staff has found all actions that were taken or should have been taken to be complete. Clearing the EP will then include the claim as part of the RO's rating sample pool.

3.3.f. Error Citations When Corrective Action Has Already Been Taken

QA will not cite any errors in cases of EPs selected for STAR assessment where ROs have discovered the error(s), made proper correction(s), and cleared the correcting EP before the case was selected, regardless of whether not the claimant received incorrect notification.

However, if a correcting EP is established and still pending, or if the correcting EP was previously established but cleared with final corrective action on or after the QMS “Run Date”(the date PA&I pulls the case in QMS for national quality review), QA will cite the error(s) made on the EP under STAR assessment. Please note that the corrective action(s) taken will also be subject to STAR assessment.

Note: The QMS Run Date is the same date that the review record was created.

Example: A claim with a transaction date of January 15, 2024 is selected for STAR review. The run date shown in QMS is February 1, 2024. The RO identified an error on the claim on February 8, 2024, before QA finalized its STAR review on the claim. QA will still cite any error(s) on the EP as the the Run Date on the review record is before February 8, 2024.

If the RO had identified the error and completed corrective action on or before January 31, 2024, no errors would be cited against the RO.

Important: On Special Focused Reviews (SFRs), errors may still be cited even if corrected by the RO. SFRs may be used to collect point-in-time data for claims processing and have a longer look back period from which the sample is being selected from. As a result, an error may still be relevant for data collection purposes even if corrected by the RO prior to being selected for an SFR.

3.3.g. Reviewing All Evidence Associated With a Claim

STAR Quality Reviewers must thoroughly review each issue in every case. It is not sufficient to simply review a decision and the letter of notification. All of the evidence associated with a claim must be reviewed to ensure that all issues (inferred as well as claimed) have been properly adjudicated.

3.3.h. Clearly Identifying and Explaining Errors

Sufficient narrative must be provided to clearly identify and explain the error cited. In most cases the explanation for the error(s) found should be sufficient to allow a reader to understand the problem area(s) without reviewing the claims folder. If the correct action was something other than the obvious converse of the erroneous action, then a statement indicating what the correct action would have been is required.

3.3.i. Appropriate Citations

Appropriate citation supporting an error call must be provided. In most cases, the reference should cite the appropriate statute or regulation, but it may also cite a

• manual provision
• General Counsel (GC) precedent decision, or
• Court of Appeals for Veterans Claims (CAVC) precedent decision.

Note: VBA letters may also be referenced.

3.3.j. Cascade Effect

Based on the logical progression of the review sheets, when an error is identified, generally all subsequent processing related to that issue will also be in error. This pattern of derived error is referred to as a cascade effect.

Examples:

• If an issue was not addressed, it is most likely that the issue was not developed, not rated, or notification for the issue was not sent.
• If a claim was properly developed but not properly rated, then inherently, the notification would be incorrect.

Issue-based reviews focus on the accuracy of specific diagnostic codes (DCs) so the prohibition of cascading errors that exists for traditional claim-based reviews is modified for issue-based reviews.

If the same error is committed across multiple DCs, each instance of the error will be cited when completing the issue-based review. This is not considered cascading as each DC is reviewed independently of the others.

For issue-based reviews, we need more data regarding the complete decision for each DC. An issue-based review requires that we determine if a disability was adequately evaluated, even if it was erroneously granted. This modification to the normal procedures will generally only apply to incorrect grants, as there will be no evaluation or effective date for an incorrect denial or missed issue, though incorrect evaluations could also have incorrect effective dates.

With a claim-based review, an incorrect grant would result in a C1 error, with no further consideration or errors concerning the evaluation or effective date of that erroneous grant.