M21-4 · Section 7.6

Formally Addressing Disagreements

M21-4 section 7.6. 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

m21-4:7.6 explains formally addressing disagreements. In plain terms, the official guidance says it is anticipated that occasionally PMCs may receive a review result with which the PMCs disagrees or believes the explanation offered is unclear or inadequate. Any basic disagreement over the correctness of an error citation must be formally addressed. It also addresses requests for reconsideration that are not received within the established time limit will be rejected and returned to the clearing PMC’s QMS Coach Team Queue for action.

How this may help with a claim

Use m21-4:7.6 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 PMCs may receive a review result with which the PMCs disagrees or believes the explanation offered is unclear or inadequate. Requests for reconsideration that are not received within the established time limit will be rejected and returned to the clearing PMC’s QMS Coach Team Queue for action. 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 PMCs may receive a review result with which the PMCs disagrees or believes the explanation offered is unclear or inadequate.
  • Confirm that the record or notice addresses this source point: To request a formal reconsideration of an error, the clearing station must submit the request through QMS.
  • Document how this stated step or exception applies: Requests for reconsiderations must be submitted within 10 business days. P&F Service will accept submission of reconsideration requests if the request is received within 10 business days from the created date of the error correction record in QMS.

Important limits

m21-4:7.6 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 PMCs may receive a review result with which the PMCs disagrees or believes the explanation offered is unclear or inadequate. A formal reconsideration request must include pertinent information such as

Search terms when useful

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

  • Formally Addressing Disagreements
  • m21-4:7.6
  • Requests Reconsideration
  • requesting reconsideration
  • time limit reconsideration requests
  • misclassified errors
  • formal reconsideration requests
  • secondary reconsideration requests.

Original VA guidance

The official VA text of this section

6. Requests for Reconsideration

Introduction

This topic contains information on 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

April 24, 2025

7.6.a. Formally Addressing Disagreements

It is anticipated that occasionally PMCs may receive a review result with which the PMCs disagrees or believes the explanation offered is unclear or inadequate. Any basic disagreement over the correctness of an error citation must be formally addressed.

7.6.b. Requesting Reconsideration

To request a formal reconsideration of an error, the clearing station must submit the request through QMS. The request for reconsideration must be submitted by a PMC Manager (PMCM) or designee no lower than an assistant coach.

7.6.c. Time Limit for Reconsideration Requests

Requests for reconsiderations must be submitted within 10 business days. P&F Service will accept submission of reconsideration requests if the request is received within 10 business days from the created date of the error correction record in QMS. The 10 business days begin the day after the created date.

Requests for reconsideration that are not received within the established time limit will be rejected and returned to the clearing PMC’s QMS Coach Team Queue for action.

Note: Exceptions to the 10-day period may be requested by contacting the P&F Service Quality staff at VAVBAWAS/CO/P&F QUAL OVRST.

7.6.d. Misclassified Errors

P&F Service will not remove BE errors on reconsideration merely because the error was misclassified on the National Pension Quality Review (NPQR) Checklist 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 reclassified in QMS to reflect correct classification.
  • This process will not affect the station’s right to ask for an additional reconsideration using the process detailed below.

7.6.e. Formal Reconsideration Requests

A formal reconsideration request must include pertinent information such as

  • supporting statutes
  • regulations
  • CAVC opinions/decisions
  • OGC opinions
  • manual citations, or
  • other appropriate citations.

The reconsideration request will be submitted via QMS. The reconsideration decision will be returned in QMS. When a reconsideration results in a withdrawal or change in the error status, P&F Service will update QMS to reflect the decision. Results of reconsideration requests will be maintained in QMS and monitored to ensure the effectiveness and integrity of the review process.

7.6.f. Secondary Reconsideration Requests

PMCs have the option to seek additional reconsideration from P&F Service on upheld BE errors.

  • Secondary reconsideration requests must be sent to P&F utilizing the RECON 2 button in QMS.
  • Requests must be submitted within five business days of the date the PMC receives notification that an electronic review has been completed and the request may be submitted via e-mail.

Important: P&F Service reserves the right to alter this timeline at the end of the FY reporting period to ensure timely final quality reports. If P&F 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.