STAR Checklist

3. Quality Review Structure

Introduction

This topic contains information on quality review structure, including

• STAR checklist
• general guidelines for benefit entitlement (BE) quality reviews
• grace period for national quality errors
• procedural deficiencies
• determining whether a case is correct or in error
• deselections
• error citations when corrective action has already been taken
• reviewing all evidence associated with a claim
• clearly identifying and explaining errors
• appropriate citations
• cascade effect
• recording additional errors, and
• documentation of additional errors.

Change Date

March 24, 2025

7.3.a. STAR Checklist

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.

7.3.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

• errors that result in an overpayment or underpayment to a claimant
• procedural deficiencies that violate the claimant’s due process rights
• deficiencies which would result in a remand from the Board of Veterans' Appeals (BVA) if not corrected, and
• incorrect calculations of income/expenses or incorrect entry of income/expenses in Department of Veterans Affairs (VA) award-processing system.

Note: For STAR purposes, if the incorrect income/expense is of record but does not affect payment of benefits, it will not rise to the level of a BE error. However, corrective action is necessary.

Reference: For more information on the requirement to calculate income accurately and enter it into the appropriate VA system correctly, see M21-1, Part IX, Subpart iii, 1.A.1.a and b.

7.3.c. Grace Period for National Quality Errors

Pension and Fiduciary (P&F) Service will provide a 30 calendar day grace period on any new manual changes or substantive changes to existing procedures before officially citing a national quality error. For PMCs, the 30 calendar day grace period is counted as 30 calendar days after the relevant information is published in Compensation and Pension Knowledge Management (CPKM) portal.

Notes:

• This grace period does not apply to clarifications of existing guidance.
• P&F Service may choose to apply a different grace period and will notify the PMCs in writing of any deviation to the 30 day grace period standard.

Example: The change date in CPKM showing new manual guidance was updated on October 4, 2016. Therefore, the grace period includes the next 30 calendar days. Errors based on the new guidance would be cited on or after November 3, 2016.

7.3.d. Procedural Deficiencies

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

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

Notes:

• If an error is identified with an issue not related to the EP under review, that error is also recorded as a comment.
• Accuracy rates for decision documentation/notification comments are assessed monthly by STAR for quality improvement purposes. This information is useful in tracking station adherence to establish procedural guidance.

7.3.e. Determining Whether a Case Is Correct or in Error

For each case reviewed, the case is considered either correct or in error (i.e., it is either entirely correct or it is wrong).

Important: An answer of no to any of the questions on the checklist relating to the processing of the issue (EP) under review will result in the case being classified as in error.

Note: The last section of the rating and authorization checklists contains an area for administrative questions that are not related to the accuracy of claims processing. An answer of no for one of these questions will not indicate an error in the case.

7.3.f. Deselections

In an effort to ensure a statistically valid sample, every effort will be made to perform a quality review on all cases identified on the national review call-up list. In rare instances, when a review may not be appropriate, P&F Service will deselect the case if there is no other alternative.

7.3.g. Error Citations When Corrective Action Has Already Been Taken

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

However, if a correcting EP is established and still pending, or if the correcting EP was previously established and cleared with final corrective action on or after the Quality Management System (QMS) run date, QA will cite the error(s) made on the EP under STAR assessment. Actions taken on the correcting EP are also subject to STAR assessment.

Note: The QMS run date is the date PA&I pulls the case for national quality review and the date the review record is created.

Example: A claim with a transaction date of January 15, 2024, is selected for STAR assessment. The run date shown in QMS is February 1, 2024. On February 8, 2024, the PMC identified an error on the claim prior to QA finalizing the STAR assessment. QA will cite any error(s) on the EP because the run date is earlier than the date the PMC identified the error.

If the PMC had identified the error(s) and completed corrective action on or before January 31, 2024, no error would be cited on the PMC.

7.3.h. Reviewing All Evidence Associated With a Claim

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

7.3.i. Clearly Identifying and Explaining Errors

A 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.

7.3.j. Appropriate Citations

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

• manual provisions
• Office of General Counsel (OGC) precedent decisions or opinions, or
• Court of Appeals for Veterans Claims (CAVC) precedent decisions.

Note: VBA letters may also be referenced.

7.3.k. 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.

7.3.l. Recording Additional Errors

Recording additional errors inherent in the initial deficiency would distort identification of the basic or critical errors of the case, while adding little or no insight into root causes or the error itself.

STAR reviews are outcome-oriented and not process-oriented. Once an error concerning a specific issue associated with a claim (e.g., no answer for one of the processing questions) is detected and recorded, no additional error related to that issue should be recorded. The review of the case must continue for any other areas subject to review and the first error found in processing each additional issue contained within the claim should be recorded.

7.3.m. Documentation of Additional Errors

The additional errors found and documented will not change the outcome for the particular case, since any one critical error (a no answer) makes the entire action incorrect.

Documentation of additional critical errors, however, will provide valuable information about the nature of primary errors and a better definition of the extent of accuracy concerns for station or District Office review (e.g., of the cases in error, how many total critical errors were identified and in what categories?).