M21-4 · Section 6.4

Overview

M21-4 section 6.4. 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

This section describes local individual quality review. The reviewer looks beyond the single transaction to associated work, expects compliance with current official guidance, and must support an error with a regulation, manual provision, or other accepted authority. It also emphasizes objectivity, documentation, root-cause analysis, and specific error narratives rather than personal preference.

How this may help with a claim

Use the section to understand why documentation gaps can matter. When auditing your own file, look for claim-level notes, completed development, exam-review documentation, all evidence available at the decision date, and a clear explanation of any correction. If those are missing, translate the concern into the underlying claims rule and raise it through the review option available to you.

What to review in your file

  • Compare the complete file as it existed at the relevant transaction date with the action VA took.
  • Look for documented examination review, record-relevancy findings, and completion of required development.
  • Distinguish the root procedural or rating error from later consequences caused by that same error.
  • Require a specific factual explanation and substantive citation for any asserted quality deficiency.

Important limits

An IQR is an employee-quality process, not a claimant-controlled remedy, and its five-day correction practices do not create a veteran-facing decision deadline. A quality finding must be translated into an authorized claim or review argument to affect benefits.

Search terms when useful

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

  • individual quality review
  • IQR
  • quality error narrative
  • root cause error
  • exam review note
  • local quality review
  • VA corrective action

Original VA guidance

The official VA text of this section

4. Fundamentals of Quality Reviews

Introduction

This topic contains information on the fundamentals of quality reviews, including

  • overview
  • misclassified errors
  • deselections
  • grace period for IQRs
  • error narratives: required elements
  • error narratives: multiple error citations
  • error narratives: use of error question and descriptors
  • definition of cascading
  • avoiding the cascade effect, and
  • interim guidance.

Change Date

August 20, 2026

6.4.a. Overview

The fundamentals of quality review are listed below.

  • Perform a comprehensive review and analysis of all elements of processing the specific claim, issue, transaction, task, or end product (EP).
  • All associated actions taken, or that should have been taken, with the transaction pulled in QMS.
  • All work items and concurrent EPs pulled into the rating or assigned to the employee at the time of the selected transaction are under review and are subject to error citations.
  • The selected transaction or EP shown in QMS does not limit the scope of the quality review.
  • The standard for a critical error is when the employee commits a clear and unmistakable error (CUE) or clearly violates current regulations or directives.
  • All work products are expected to be fully compliant with officially published VBA references. Noncompliance is to be cited with a critical error. When properly classified under a critical question of appropriate checklist, the deficiency rises to the level of a critical error.
  • In limited circumstances, Quality Assurance may instruct that certain fact patterns do not rise to a critical error and should be cited as a correctable comment instead. In a large part, these fact patterns are caprtured on the appropriate checklist by using a non-critical task to document the deficiency.
  • The QRT is required to follow all guidance on citing errors provided by the Compensation Service Quality Assurance Staff. This includes guidance delivered via the QRT corporate mailbox or other official Quality Assurance communications.
  • Salesforce Chatter is not considered an official Quality Assurance communication source for the purposes of establishing if an error exists.
  • The QRS must provide a regulation citation, manual reference, or other appropriate reference to support every cited error, regardless of the type of quality review.
  • When reviewing a claim, maintain objectivity, never allow personal feelings to enter into the review process and show fairness and courtesy at all times to the employee being reviewed.
  • QRS should approach each review as if the work completed is correct.
  • A QRS may not inject personal opinions of how a claim should have been worked if the actions taken by employee under review are not clearly incorrect or erroneous based on nationally provided guidance.
  • If there exists a way the employee could more effectively or efficiently worked the claim under review, this does not rise to the level of a critical error. Events such as this should be handled through a mentoring opportunity and not cited on the QMS Checklist.
  • For VSRs, due to the specialization of issues or claim types, as well as other factors, it may not be possible for all actionable EPs to be consolidated and assigned to a single VSC or BEST site. As such, it does not rise to the level of a critical error if a claims processor only takes action on the EP(s) assigned to that specific user as reflected in the VBMS assignment history notes.
  • QRS cannot adjudicate the claim on behalf of the employee under review and the quality review must be limited to the documentation contained in the file at the time of the quality review. Decisions as to the relevancy of records or whether an examination was needed are examples of adjudicative decisions that are the responsibility of the employee being reviewed to determine and document in the official VBMS record following proper procedures outlined in the adjudicative manual.

For example, if there are additional VAMC medical records available after the initial upload to VBMS, those records must be obtained and associated with the claim unless a documented relevancy determination has been made in accordance with M21-1, III.i.2.E.1.f.

In the development stage, examination reviews are to be documented in accordance with M21-1, IV.i.1.A.1.e. In the absence of a documented examination review, the QRS cannot assume that one has been completed. Closure of the associated examination review tracked items without the corresponding VBMS note(s) would rise to the level of an error.

6.4.b. Misclassified Errors

Errors will not be removed on reconsideration merely because the error was misclassified, such as being considered under the incorrect task or desciptor, on the appropriate checklist or due to insufficient supporting reference. Removing known errors on cases on the mandated random sample is contrary to sound quality control principles and provides stakeholders with inaccurate data.

A misclassified error may be mitigated only if the error should have been recorded under a non-critical question of the checklist. Corrective actions are still required of the employee.

Note: This process will not affect the employee’s right to ask for an additional reconsideration using the applicable reconsideration procedures.

6.4.c. Deselections

In an effort to ensure a statistically valid sample, every effort will be made to perform a quality review on all cases identified in QMS.

The Office of Performance Analysis and Integrity (PA&I) provides reviews to QMS based upon specific system transactions by individual. Therefore, generally, there should be an actionable transaction appropriate for quality review.

In rare instances, when a review may not be appropriate, the QRS will propose to deselect the case if there is no other alternative. Examples of proper deselections include:

  • no critical task on the checklist is applicable to the review, or
  • the employee under review annotated in VBMS that they conducted specialized development.

QRS will use a deselection reason that will result in a replacement review being provided by PA&I. QRS should select the most appropriate reason from the list of deselction reasons below:

  • Claim returned for correction,
  • EP not warranted; no documented basis,
  • EP not warranted; should have been cancelled,
  • EP not warranted; wrong EP cleared, or
  • Transaction Not Reviewable.

Note: The reasons listed above are not determinative as to whether a case should be deselected or if an error is present or not. The reasons above are provided for technical understanding of QMS functionality to ensure employees receive the correct number of reviews each performance year.

Examples of incorrect deselections include deselecting because the case is sensitive or the employee being reviewed and the QRS conducting the review are at the same station.

Examples of proper deselections include deselecting because the documents associated with the transaction under review are no longer viewable to the QRS (for example, the rating decision, award, correspondence).

QRT Coaches are responsible for finalizing all proposed deselections. Replacement reviews will not be selected by PA&I until after a coach approves the proposed deselection. Coaches should monitor the reason for deselection to ensure that a replacement review will result.

In rare circumstances the QRT Coach may need to change the reason for deselection based on personal knowledge of the employee selected for review so that a replacement transaction is not selected. The deselection reasons include:

  • Employee in Training,
  • Employee Not in Position, or
  • Employee Not with VBA.

The reason "Employee Not in Position" should be limited to instances where the correct checklist will not populate in QMS. For example, a VSR that has recently promoted to RVSR will have the promotion effective in WIT as quickly as possible. However, the employee may continue completing VSR duties while awaiting training. In this circumstance, any selected IQRs will have an RVSR checklist associated with the transaction based on the employee's WIT data. As any replacement IQRs will continue to have this same problem until the employee is eligible for RVSR reviews, the QRT Coach should select 'Employee Not in Position.'

The deselection reason "QMS Admin Bulk Deselect" is reserved for use by QMS Admins and should never be used by RO employees to deselect a review.

Important: The dates in VBMS should match the date of the transaction showing in QMS. There is an exception to this requirement for Manila employees. QMS will normalize the time of the transaction to the Eastern time zone, however, this does mean that for Manila RO employees, there are instances where some transactions will show in VBMS as the day after what is shown in QMS. These reviews should not be deselected for the dates on the transaction not matching.

Example 1: The transaction selected for a VSR IQR is “Award” with a transaction date of July 20, 2026. A review of the file indicates an authorizer returned the award on July 21, 2026. The same VSR generated another award on July 22, 2026, and it was authorized the same day.

Analysis: Deselection is appropriate because the draft award and correspondence letter(s) associated with the July 20, 2026, transaction are no longer available for review.

Example 2: QMS shows the identified transaction as “Rating Decision Complete” on August 5, 2026, but the only rating decision of record completed by the RVSR under review is dated August 8, 2026.

Analysis: Deselection is appropriate as the original rating completed on August 5, 2026, is no longer available to the QRS for review.

The deselected case will be forwarded via QMS to the QRT Coach (or appropriate designee) for verification and final deselection approval.

Example 3: The transaction selected for a RVSR IQR is “Deferred Rating” with a transaction date of July 8, 2026. The corresponding rating that contained a deferred issue is returned for correction and there is an electronic deferral in VBMS. There is a rating decision dated July 13, 2026.

Analysis: Deselection is not appropriate. The original VBMS deferral is still available to the QRS to review on the deferral only.

Example 4: The transaction selected for Manila RO employee, station 358, shows the date of the transaction as May 15, 2026. Review of VBMS shows the rating decision was completed on May 14, 2026.

Analysis: Deselection is not required not appropriate. Due to the time zone of the Manila RO and QMS using the Eastern time zone, this means that some transactions for Manila RO employees will show in VBMS the day after what QMS shows. The QRS should complete the review.

Reference: For more information on deselections, see QMS User Guide.

6.4.d. Grace Period for IQRs

Employees will have a 30-calendar day grace period for any new guidance provided in the M21-1 before QRS begin citing deficiencies as critical errors. The grace period is counted as 30 calendar days from the relevant Veterans Affairs (VA) Key Changes document is published. The QRS must ensure that the specific block being cited was subject to a substantive change before applying a grace period. Changes issued for language changes or other minor grammatical corrections are not considered substantive changes. Examples of substantive changes include, but are not limited to, new procedures being introduced, new special issues being created, or new rating criteria being effectuated.

An error noted prior to the expiration of the 30-calendar day grace period should be recorded on the checklist to ensure the employee is made aware of the change, and a correction to the case will be required. However, the employee's quality totals will not reflect that a critical error was cited. Instructions for indicating these errors on the appropriate checklist are found in M21-4, Chapter 6.5.c.

Example: VA Key Changes document showing new manual guidance is published on January 20, 2024, so the grace period includes the next 30 calendar days. Errors will be cited on or after February 19, 2024, for any errors relevant to the specific citation.

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

6.4.e. Error Narratives: Required Elements

Every error narrative must include

  • a statement of the error
  • a statement of the facts, and
  • supporting references.

The table below describes each of the required error narrative elements.

Scroll sideways to see the full table.

ElementDescription
Statement of the ErrorThe QRS should provide a specific statement that clearly identifies the error cited. Example 1: The Heart Disability Benefits Questionnaire (DBQ), dated July 18, 2022, is insufficient for rating purposes because required metabolic equivalent (METS) testing or estimate was not provided. Example 2: 5103 notice was not sent as required.
Statement of the FactsThe QRS should provide a concise statement of the facts that outlines the evidence supporting the finding of an error. Example 1: The VA examiner did not provide a well-supported rationale for the medical opinion. Examiner noted there were no records from service to support onset of symptoms during active duty. However, the service treatment records (STRs) contain multiple records showing treatment for the claimed right knee arthritis. Example 2: The application was signed by the Veteran's POA with no indication that 5103 notice was provided to the Veteran nor acknowledged by the Veteran with the last year. Notes: The QRS will refrain from including specific corrective action in the narrative. Questions regarding corrective actions should be addressed by the employee's local QRS to facilitate mentoring and learning opportunities. Employees following incorrect corrective actions provided by QRS are potentially subject to IQR and any applicable errors should be cited if selected for review. A judgment or a difference of opinion reflecting a possible better practice or solution will not be recorded as a comment.
Supporting ReferencesThe QRS should provide specific and appropriate references to support the error citation and correction(s) required. The references should be organized in a logical order and clearly separated. Appropriate references include Public Law Regulation manual instruction/citation interim guidance contained at VBA Interim Guidance websites, or supporting aids such as the National Work Queue (NWQ) Playbook and VBMS User Guides, and other procedural Job Aids found at Job Aids Home Page, such as the Reconstructing Fire-Related Records Job Aid. Appropriate references do not include court cases without a supporting manual citation or regulation local policy directive Fast Letters or Training Letters (unless relevant based upon a retroactive award), or information on QMS Chatter. Note: Information from QMS Chatter is valuable as clarification of existing policy or procedure. However, QMS Chatter is only assessible to QRS and not all claim processors. Therefore, the underlying regulation or manual citation should be cited in the error narrative, not a QMS Chatter post. Formal policy or procedure is not issued by Compensation Service in QMS Chatter.

Examples of VSR IQR error narratives:

Notes:

  • The QRS must spell out acronyms not commonly used in the M21-1, or if the acronym may represent multiple things. Uncommon jargon should not be used.
  • The QRS must ensure the error narrative clearly explains the citation and provides complete information for the employee to understand the error.
  • An exam was not ordered as required for the Veteran’s right knee condition. The elements required for ordering an exam are met as the medical evidence indicates a current right knee disability, there are multiple complaints of right knee pain and injuries in the service treatment records, and the evidence indicates that the right knee condition may be associated with the established injury in service. (38 CFR 3.159, M21-1, IV.i.1.A.1.a-b)
  • The 6/8/2026 date of claim (DOC) is incorrect. The DOC for claims establishment purposes is the earliest date any VA facility received the claim, and the Minneapolis VAMC first received the Veteran’s application for benefits on 6/3/2026. (M21-1, II.iii.1.A.4.c., M21-4, Appendix B.1.c.)

Examples of RVSR IQR error narratives:

  • A minimum evaluation was assigned based on an implanted pacemaker. However, the Veteran’s implanted device is an Automatic Implantable Cardioverter Defibrillator (AICD), which is not the same as a pacemaker. Therefore, a higher evaluation is warranted. (38 CFR 4.104 DC 7018, 38 CFR 4.104 DC 7011)
  • The medical evidence shows that the Veteran was diagnosed with coronary artery disease prior to the date that this disability became a presumptive disability based on herbicide exposure. Therefore, an earlier effective date is warranted. (38 CFR 3.114, 38 CFR 3.309, M21-1, V.ii.4.A.6a-e; M21-1, VIII.i.1.B.1.i)

6.4.f. Error Narratives: Multiple Error Citations

If multiple errors are cited, each error should be discussed independent from the others. Each error should include the three elements of a narrative as noted in the previous block.

QRS may also cite errors under multiple descriptors within the same question in QMS. If doing this, the QRS must ensure that each error narrative is specific to the descriptor being used. QRS should not copy unnecessary information from other error narratives/descriptors when using more than one descriptor to ensure each error stands on its own merit.

6.4.g. Error Narratives: Use of Error Question and Descriptors

Reviews completed in QMS should not include a reference to the question or descriptor. The QRS should not restate the task question or error descriptor in the error narrative. The checklist questions and/or descriptors may be adjusted; therefore, the order of the descriptors in QMS may change.

Descriptors for each question are designed to assist Quality Assurance with data gathering and to help establish error trends for training purposes.

Important: The lack of a descriptor for a given error is not indicative that it is not a critical error. QRSs are expected to select the closest descriptor possible when multiple descriptors may apply. If no descriptor describes the situation, the QRS should select the closest approximation.

QMS and other reporting tools have built-in functionality to sort the user selections for error trend analysis purposes.

6.4.h. Definition of Cascading

Cascading is the result of citing multiple errors based upon the same basis, or root cause.

Note: The theory of cascading used in the IQR program is applied at the task level. This theory is not interchangeable with the definition of cascade effect for the Systematic Technical Accuracy Review (STAR) contained at M21-4 Chapter 3, Topic 3, Block j

6.4.i. Avoiding the Cascade Effect

Once the QRS has determined the root cause of an error, no other errors should be cited as a natural result of the initial root cause error.

Once the root cause error has been identified, the QRS should review the claim “as if” the decision in error were correct when reviewing the remainder of the claim.

All errors associated with a decision should be captured on the appropriate checklist. Accuracy rates will be provided by VBA-approved reporting systems.

Note: The principles of avoiding the cascading effect apply to all quality reviews completed in QMS by any QRS. The concept of cascading as defined for an IQR is not interchangeable with the definition of cascade effect for Systematic Technical Accuracy Review (STAR) contained at M21-4, Chapter 3, Topic 3, Block j.

Example 1: Service connection (SC) is improperly granted because there was no event in service, but the assigned evaluation and effective date are otherwise correct.

Analysis: Once the QRS has determined that the root cause of the error is the improper grant of SC due to lack of an event in service, the QRS should continue to review the decision as if the grant were correct. In this case, only a single error should be cited for the improper grant of service connection. The QRS would be incorrect to cite additional errors based upon the assigned evaluation and effective date. Per the scenario, the assigned evaluation and effective date were correct based upon the evidence of record. The assigned evaluation and effective date are not in error based solely upon the fact that the grant of SC itself was improper.

Example 2: SC is improperly granted because there was no event in service. Additionally, the assigned evaluation and effective date are incorrect based upon the evidence of record.

Analysis: Once the QRS has determined that the grant of SC was improper, the QRS should continue to review the decision as if the grant were correct. In this example, the assigned evaluation was incorrect based upon the evidence of record, so a separate error should be cited for the incorrect evaluation. Similarly, the effective date was incorrect based upon the evidence of record, so the error should be cited as well.

Example 3: A VSR grants a dependent using an incorrect effective date, resulting in the award and the notification letter both being incorrect.

Analysis: The VSR would be cited for one error for the incorrect effective date under Task 8. The subsequent error (incorrect notification letter under Task 10) would not be cited because the notification error was the direct result of the effective date error.

Example 4: Veteran submits a VA Form 21-4138 attached to a VA Form 21-526EZ claiming an increase in PTSD. The contention is not added on the EP020 and no exam was requested.

Analysis: An error is appropriate under Task 11 of the VSR checklist for failing to include the contention on the claim. However, a Task 5 error for not requesting the examination for increase would not be cited as the failure to realize that an increase in PTSD was a valid contention is the direct cause for failing to request the increase examination.

6.4.j. Interim Guidance

For quality review purposes, when VBA Central Office issues interim guidance it supersedes the instructions found in the M21-1 or other VA procedural references. While the interim guidance is in effect, quality errors should be cited in instances where claims processors clearly do not follow the interim procedures correctly.

This includes citing systems compliance errors for incorrectly utilizing (or failing to properly add) corporate flashes or special issue indicators not listed as critical errors in M21-4, Chapter 6.A.d & e, but that are required by the interim procedures.

It is appropriate to utilize the interim procedures as a valid reference for the error citation.

This instruction applies to interim procedures located on the Compensation Service website or other VA-maintained websites.

Note: Interim guidance must be implemented immediately. Grace periods will not apply to interim guidance unless one is specifically provided by OFO or Compensation Service.