M21-4 · Section 3.6

Formally Addressing Disagreements

M21-4 section 3.6. Official source text with a separately reviewed Claim Raven explanation when available.

Claim Raven wrote the explanation that follows. The original VA text appears below it, unchanged.

What this means

m21-4:3.6 explains formally addressing disagreements. In plain terms, the official guidance says it is anticipated that occasionally ROs may disagree with the results of a review or believe the explanation is unclear or inadequate. Any basic disagreement over the correctness of an error citation must be formally addressed. It also addresses QA will not accept reconsideration requests on any errors that are reopened as part of QA’s error correction validation procedures described in M21-4, Chapter 3.5.m, as those errors have already been accepted as being a valid error citation or comment by a RO.

How this may help with a claim

Use m21-4:3.6 as an internal VA audit trail for formally addressing disagreements, not as a promise of a particular result. Compare the actions recorded in your claim file or decision notice with this source-specific detail: It is anticipated that occasionally ROs may disagree with the results of a review or believe the explanation is unclear or inadequate. QA will not accept reconsideration requests on any errors that are reopened as part of QA’s error correction validation procedures described in M21-4, Chapter 3.5.m, as those errors have already been accepted as being a valid error citation or comment by a RO. 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: It is anticipated that occasionally ROs may disagree with the results of a review or believe the explanation is unclear or inadequate.
  • Confirm that the record or notice addresses this source point: If a RO believes an erroneous error call has been made, the clearing RO may request a formal reconsideration by QA under the direction of the Compensation Service Quality Assurance Assistant Director.
  • Document how this stated step or exception applies: All errors cited at the national level require a two-step process in QMS in order successfully route the error to the appropriate business line responsible for issuing the reconsideration decision.

Important limits

m21-4:3.6 is primarily internal workflow guidance about formally addressing disagreements. 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: It is anticipated that occasionally ROs may disagree with the results of a review or believe the explanation is unclear or inadequate. Compensation Service will not remove BE errors on reconsideration merely because the error was misclassified on the STAR Checklist (e.g.

Search terms when useful

Phrases that may help when searching your claim file or this library.

  • Formally Addressing Disagreements
  • m21-4:3.6
  • Requests Reconsideration
  • This section describes requests
  • requesting reconsideration
  • time limit reconsideration requests
  • misclassified errors
  • formal reconsideration requests

Original VA guidance

The official VA text of this section

6. Requests for Reconsideration

Introduction

This section describes procedures for requests for reconsideration, including

  • formally addressing disagreements
  • requesting reconsideration
  • time limit for reconsideration requests
  • misclassified errors
  • formal reconsideration requests, and
  • secondary reconsideration requests.

Change Date

June 5, 2025

3.6. a. Formally Addressing Disagreements

It is anticipated that occasionally ROs may disagree with the results of a review or believe the explanation is unclear or inadequate. Any basic disagreement over the correctness of an error citation must be formally addressed.

3.6. b. Requesting Reconsideration

If a RO believes an erroneous error call has been made, the clearing RO may request a formal reconsideration by QA under the direction of the Compensation Service Quality Assurance Assistant Director. To request a formal reconsideration of an error, the clearing station must submit the request through QMS.

All errors cited at the national level require a two-step process in QMS in order successfully route the error to the appropriate business line responsible for issuing the reconsideration decision. Failure to properly complete the two-step process results in the reconsideration not being successfully referred for review. It is the completion of the second step of the two-step process that establishes the date the reconsideration was received by QA.

Note: Reconsideration of errors includes STAR reviews and SFRs.

3.6. c. Time Limit for Reconsideration Requests

Requests for all national level reconsiderations should be submitted within 10 business days so that timely corrections may take place. The 10 business day submission period begins the day after the “ Created Date ” shown in the error correction record.

QA will not accept reconsideration requests on any errors that are reopened as part of QA’s error correction validation procedures described in M21-4, Chapter 3.5.m, as those errors have already been accepted as being a valid error citation or comment by a RO.

Any inquiries regarding reconsiderations on QA cited errors or comments should be sent to VAVBAWAS/CO/QRT.

Important: QA reserves the right to enforce a 10 business day timeliness period at the end of the STAR performance year so that year-end performance data may be provided. While any late submissions will be considered on the merits, any untimely reconsiderations that result in an overturned error may not be reflected in the RO’s performance year data.

Note: Reconsiderations for SFRs will also be considered on the merits. However, for SFR reporting purposes, once the final report is finalized and published on QA’s intranet page, no further reconsiderations will be accepted.

3.6. d. Misclassified Errors

Compensation Service will not remove BE errors on reconsideration merely because the error was misclassified on the STAR Checklist (e.g. B2 vs. C1) when a legitimate BE error exists. Removing known errors on cases included in the nationally mandated sample is contrary to sound quality control principles and provides stakeholders with inaccurate data.

Notes:

  • In these cases, the error will be upheld, but the appropriate classification will be discussed in the reconsideration decision narrative in QMS.
  • This process will not affect the ROs right to ask for an additional reconsideration using the secondary process detailed below.

3.6. e. Formal Reconsideration Requests

The formal reconsideration request must include pertinent

  • supporting statutes
  • regulations
  • CAVC Opinions
  • GC Opinions
  • manual, or
  • other appropriate citations.

The clearing RO must submit the reconsideration request via QMS using the two-step process required for all QA completed reviews. The reconsideration decision will be made by QA and returned to the clearing RO through current QMS notification procedures. Results of reconsideration requests will be maintained in QMS and monitored to ensure the effectiveness and integrity of the review process.

3.6. f. S econdary Reconsideration Requests

ROs will have the right to seek additional reconsideration from Compensation Service on upheld BE errors. QMS has the capacity to record a secondary reconsideration decision. Submitting and referring a secondary reconsideration for QA review requires the same two-step process as submitting a first-level reconsideration request.

  • Secondary reconsideration requests must be submitted through QMS
  • QRT Coaches may authorize the submission of any secondary reconsideration request.
  • Once a reconsideration decision has been made, any errors or comments that were upheld or mitigated will be returned in QMS to the individual that initiated the reconsideration request.
  • Secondary reconsideration requests should be made within five (5) business days of when the RO receives notification of the first level reconsideration decision.

Important: Compensation Service reserves the right to alter this timeline at the end of the fiscal year reporting period to ensure timely final quality reports. If the Deputy Director of Operations for Compensation Service disagrees with the action taken by the QA Staff, the error will be withdrawn. The case will be returned to the QA Staff to amend the decision as directed, and feedback will be given to ensure that such errors are not cited in the future.