M21-5 · Section 3.B.7

National Compensation/ Pension Rating Quality Review Checklist

M21-5 section 3.B.7. 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

m21-5:3.B.7 explains national compensation/ pension rating quality review checklist. In plain terms, the official guidance says the following is a sample of the National Compensation/Pension Rating Quality Review Checklist. It also addresses for the purpose of measuring technical accuracy under OAR QA assessment, OAR QA considers a case either “accurate” or “in error,” for the claim-based review.

How this may help with a claim

Use m21-5:3.B.7 to audit how VA handled national compensation/ pension rating quality review checklist. Start with the decision date, the issue being reviewed, and the evidence VA was allowed to consider, then compare the record with this rule: The following is a sample of the National Compensation/Pension Rating Quality Review Checklist. For the purpose of measuring technical accuracy under OAR QA assessment, OAR QA considers a case either “accurate” or “in error,” for the claim-based review. Cite the exact document and page when raising a factual or procedural error, and use the review rights in the actual notice for any deadline.

What to review in your file

  • Check the file against this official condition: 1. Were all claimed issues addressed and decided? — ☐ Yes ☐ No ☐ N/A; Error Description —; A1a-Ancillary benefit — ☐; A1b-Competency — ☐; A1c-IU — ☐; A1d-Pension — ☐; A1g-SMC-other — ☐; A1h-Service connection — ☐;
  • Confirm that the record or notice addresses this source point: A2l-Unclaimed issues within the scope of the claim — ☐
  • Document how this stated step or exception applies: B1a-N&M evidence verbiage — ☐

Important limits

m21-5:3.B.7 explains VA guidance for national compensation/ pension rating quality review checklist; it does not guarantee an award or replace the statutes, regulations, binding decisions, and review instructions that control an individual claim. Conditions and exceptions still matter, including this source point: The following is a sample of the National Compensation/Pension Rating Quality Review Checklist. OAR QA does not record procedural deficiencies as BE errors. OAR QA records these deficiencies as decision documentation/notification or administrative comments and either the DROC must take corrective action on these deficiencies or submit a timely reconsideration request.

Search terms when useful

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

  • National Compensation/ Pension Rating Quality Review Checklist
  • m21-5:3.B.7
  • National Compensation Pension
  • Rating Quality Review
  • National Compensation Pension Rating
  • This topic includes
  • instructions guidelines rating review
  • rating review elements.

Original VA guidance

The official VA text of this section

7. National Compensation/Pension Rating Quality Review Checklist

Introduction

This topic includes the

  • National Compensation/Pension Rating Quality Review Checklist
  • instructions and guidelines for rating review, and
  • rating review elements.

Change Date

December 21, 2023

3.B.7. a. National Compensation/ Pension Rating Quality Review Checklist

The following is a sample of the National Compensation/Pension Rating Quality Review Checklist.

Scroll sideways to see the full table.

1. Were all claimed issues addressed and decided?☐ Yes ☐ No ☐ N/A
Error Description
A1a-Ancillary benefit
A1b-Competency
A1c-IU
A1d-Pension
A1g-SMC-other
A1h-Service connection
A1i-Secondary Service connection
A1j-Increased evaluation
A1k-Earlier effective date
A1l-Other
A1f-SMC-HB
A1e-SMC-A/A
2. Were all inferred and/or ancillary issues addressed?☐ Yes ☐ No ☐ N/A
Error Description
A2a- 38 CFR 3.324 (multiple non-compensable SC disabilities)
A2b-Compentency
A2c-DEA
A2d-Hypertension
A2e-IU
A2f-Medical care under 38 U.S.C. 1702
A2g-Pension
A2h-SMC-A/A
A2i-SMC-HB
A2j-SMC-other
A2k-Other
A2l-Unclaimed issues within the scope of the claim
3. Was VCAA pre-decision "notice" provided and adequate?☐ Yes ☐ No ☐ N/A
Error Description
B1a-N&M evidence verbiage
B1b-Pension or SMP development incomplete
B1d-Special issue development incomplete-1151
B1e-Special issue development incomplete-Agent Orange
B1f-Special issue development incomplete-ALS
B1g-Special issue development incomplete-Asbestos
B1h-Special issue development incomplete-Camp Lejeune
B1i-Special issue development incomplete-Gulf War
B1j-Special issue development incomplete-Hepatitis
B1k-Special issue development incomplete-HIV
B1l-Special issue development incomplete-Mustard Gas
B1m-Special issue development incomplete-Non-PTSD personal trauma
B1n-Special issue development incomplete-POW
B1o-Special issue development incomplete-PTSD-combat or non-combat
B1p-Special issue development incomplete-PTSD-personal trauma
B1q-Special issue development incomplete-Radiation
B1r-5103 not sent
B1s-"What the Evidence Must Show" attachment missing or incorrect
B1t-Other
4. Does the record show VCAA compliant development to obtain all indicated evidence (including a VA exam, if required) prior to deciding the claim?☐ Yes ☐ No ☐ N/A
Error Description
B2dd-VA treatment records not obtained
B2ee-5103 reply period not expired before denial
B2ff-Other
B2y-Special issue development incomplete-PTSD combat or non-combat
B2z-Special issue development incomplete-PTSD personal trauma
B2aa-Special issue development incomplete-Radiation
B2gg-Stegall v. West (Remand compliance)
B2bb-VA exam was needed
B2cc-VA medical opinion was needed
B2a-Admin denial insufficient_rating decision needed
B2b-Advisory opinion needed from C&P Service
B2c-Appeals Issue
B2d-Complete income information not obtained
B2e-Dependency verification deficiency
B2f-Insufficient VA examination/medical opinion
B2g-IU development deficiency (i.e., 8940 needed before grant; employment history needed, etc.)
B2h-Non-VA treatment records development deficiency
B2i-SBP verification deficiency
B2j-Service personnel records needed
B2k-Service treatment records needed
B2l-Social Security records development deficiency
B2n-Special issue development incomplete-1151
B2o-Special issue development incomplete-Agent Orange
B2p-Special issue development incomplete-ALS
B2q-Special issue development incomplete-Asbestos
B2r-Special issue development incomplete-Camp Lejeune
B2s-Special issue development incomplete-Gulf War
B2t-Special issue development incomplete-Hepatitis
B2u-Special issue development incomplete-HIV
B2v-Special issue development incomplete-Mustard gas
B2w-Special issue development incomplete-Non-PTSD personal trauma
B2x-Special issue development incomplete-POW
B2hh-No standard application – ITF Issue
5. Was the grant or denial of all issues correct?☐ Yes ☐ No ☐ N/A
Error Description
C1a-Accrued benefits (warranted or not warranted)
C1b-Hearing loss not shown under 38 CFR 3.385
C1c-Service connection not warranted for symptom or lab finding (i.e., pain, proteinuria, etc.)
C1d-Service connection not warranted (general)
C1e-Service connection warranted (general)
C1f-Other
C1g-Veteran does not meet minimum number of required days of active service. (Pension)
C1h-Veteran does not meet the required days of wartime service. (Pension)
C1i-Veteran does not meet other than dishonorable service requirements. (Pension)
6. Was the percentage evaluation assigned correct (including combined evaluation)?☐ Yes ☐ No ☐ N/A
Error Description
C2a-Convalescence (warranted or not warranted)
C2b-Misapplication of 38 CFR 4.86, Exceptional Patterns of Hearing Impairment
C2c-Misapplication of the bilateral factor
C2d-Pyramiding (same symptomatology used for multiple disabilities)
C2e-Reduction (warranted, not warranted, or done prematurely or too late)
C2f-Separate evaluations warranted for one SC disability (e.g., knee LOM and instability)
C2g-Over-evaluation (general)
C2h-Under-evaluation (general)
C2i-Other
7. Are all effective dates affecting payment correct?☐ Yes ☐ No ☐ N/A
Error Description
D1a-Day after discharge
D1b-Dependency adjustment
D1c-Diabetes complication-incorrect effective date
D1d-Increased disability-incorrect effective date based on increase factually shown or not shown from that date
D1e-IU-criteria met or not met from an earlier date
D1f-Informal date of claim-missed or misapplied
D1g-Liberalizing legislation misapplied
D1h-Pension (granted administratively or by rating decision)
D1i-SMC or SMP change
D1j-Incorrect effective date for all other situations (general)
D1k-Other
D1l-Incorrect effective date reopen previous denial of SC
D1m-DOC - improperly identified.
D1n-DOC - electronically initiated/finalized.
D1o-DOC - continuously prosecuted (non-appeal)
D1p-DOC - continuously prosecuted (appeal)
D1q-DOC - multiple claims received on different dates
D1r-FDC-deselect
D1s-FDC - improper deselect
D1t-FDC - 1 yr. retro misapplied
D1u-FDC - 1 yr. retro predates factual entitlement date
D1x-ITF-Effective date based on invalid or non-existent ITF
D1y-Valid ITF missed or not applied correctly to effective date
8. Were all payment rates correct?☐ Yes ☐ No ☐ N/A
Error Description
D2a-CRDP or other MRP adjustment
D2b-CRSC adjustment
D2c-Dependency adjustment
D2d-Month of Death Payment
D2f-Severance, Readjustment, or Separation pay adjustment
D2g-SMC coding incorrect
D2h-Other
D2e-Pension calculation incorrect
9. Was Decision Documentation correct?☐ Yes ☐ No ☐ N/A
Error Description
E4a-A summary of the evidence considered was not provided (AMA)
E4d-For denied claim(s), identification of the missing element(s) required to grant the claim(s) was not provided (AMA)
E4b-An explanation of the laws and regulations applicable to the claim was not provided (AMA)
E4c-A summary of favorable findings made by the decision maker was not provided (AMA)
E4e-The decision did not identify the criteria required to grant the next higher level of compensation (AMA)
E4f-An explanation of how to obtain or access the evidence used in the decision was not provided (AMA)
E4g-A summary of the applicable review options available for the claimant when seeking a review of the decision was not provided
E1-All pertinent evidence not discussed
E2-The basis of each decision not identified and/or each denial not explained
E3-The rating narrative was not acceptable length, contained irrelevant or superfluous text, or portions were copied and pasted directly from CAPRI
E4h-Decision maker considered and/or listed evidence received after the record closed for a higher-level review
E4i-Decision maker failed to readjudicate issue on the merits when new and relevant evidence was of record
E4j-Higher-Level Review decision failed to provide notice that there was evidence received after the record closed that was not considered
E4k-Higher-Level Review informal conference not held when requested or attempts to schedule not documented properly
10. Was notification correct? (Notification)☐ Yes ☐ No ☐ N/A
Error Description
F1-Notification not sent
F2-Notification was incorrect
F3-Appeal rights were not included
F4-The Power of Attorney indicated, was incorrect, and notification was improperly documented
11. Were Appropriate Signatures (Internal Controls) correct?☐ Yes ☐ No ☐ N/A
Error Description
G1-Second signature not documented
G2-Third signatures not appropriately documented when required
G4-Unnecessary development delayed a decision on any claim associated with the EP under review
12. Was the end product selected for review timely developed? (over-developed)☐ Yes ☐ No ☐ N/A
Error Description
G3h-Unnecessary or incorrect development to verify stressor(s)
G3i-Development for SSA records when IU could be granted
G3j-Requesting VAE/MO when evidence of record was sufficient for rating
G3k-Requesting unnecessary clarification of VAE/MO from VA examiner
G3l-Requesting unnecessary clarification of VAE/MO from QTC provider
G3m-Requesting medical records (VA or private) that were already of record
G3n-Requesting private records more than twice
G3o-Development for service records when not necessary
G3p-Development for other government records when not necessary
G3q-Development for private records when not necessary
G3r-Development for medical evidence in NSC pension claims where Veteran has no qualifying service
G3s-Dependency development (686c, marriage cert, birth cert, divorce decree, etc.) when not required
G3t-Requesting VAE/MO when a public-use DBQ was of record and sufficient for rating
G3u-Other
G3a-Sending/resending VCAA when issue could be granted or increased to schedular max
G3b-Sending additional VCAA when duty to assist had already been fulfilled
G3c-Development to verify RVN when evidence of record already verifies RVN
G3d-Development to verify RVN when no entitlement to benefits exists
G3e-Development for DD214 when verified service is already of record
G3f-Development for radiation exposure instead of sending file to RO323
G3g-Development to verify special issue (Agent Orange, Gulf War, etc.) when not necessary
G3v-Requesting VAE/MO when private evidence of record, other than public-use DBQ, was sufficient for rating
G3w-Requesting VAE/MO when federal evidence of record as sufficient for rating
G5a-Requesting VAE/MO when a public-use DBQ or private evidence was of record and insufficient for rating 1 or more claimed issues; but not all issues
G5b-Requesting VAE/MO when a public-use DBQ or private evidence was of record and insufficient for rating any claimed issues
G5c-Higher-Level Review decision failed to grant maximum benefit when DTA error is present, if warranted
13. Were Examination & Medical Opinion Requests correct?☐ Yes ☐ No ☐ N/A
Error Description
H1-If a VA examination was requested, was that examination necessary and if an opinion was requested was the opinion an appropriate medical (not legal) question?
H2-Examination Requests - Incorrect DBQ requested
H3-Examination Requests - Issues (disabilities claimed) were not clearly identified
H4-Examination Requests - The claims folder was not provided by the regional office for necessary examination(s)
H5-Medical Opinion Requests - When a medical opinion was requested, pertinent issues were not clearly identified and appropriate question(s) were not clearly asked
H6-Medical Opinion Requests - The claim folder was not made available to the medical center by the regional office
H7–Routine Future Examination Establishment - An unnecessary and/or inappropriate routine future examination (RFE) was established/continued by the EP under review
H8-RFE Interval - Inappropriate interval established for a necessary RFE
14. Was there an Expedited Favorable Decision?☐ Yes ☐ No ☐ N/A
Error Description
I1-When evidence was sufficient to grant partial benefits, those benefits were not granted promptly, while developing other issues
15. Were Rating Comments correct (EP not under review)?☐ Yes ☐ No ☐ N/A
Error Description
J1A-Issue Errors not associated with end product under review
Development Errors not associated with end product under review
Decision Errors not associated with end product under review
Payment Errors not associated with end product under review
Comments for all other actions not associated with end product under review
16. Were Rating Comments correct (EP under review)?☐ Yes ☐ No ☐ N/A
Error Description
J2-Disability determination - end product under review
Notification - end product under review

FOR EACH “NO” ANSWER RECORDED, PROVIDE A BRIEF NARRATIVE SUMMARY OF THE ERROR AND STATUTORY, REGULATORY, OR MANUAL REFERENCES.

3.B.7. b. Instructions and Guidelines for Rating Review

OAR QA developed these instructions and guidelines to promote consistency and uniformity in the review of cases selected for OAR QA assessment. The checklist will be used for both Compensation and Pension National Quality Reviews. Use these instructions/guidelines in conjunction with the National Compensation/ Pension Rating Quality Review Checklist.

For the purpose of measuring technical accuracy under OAR QA assessment, OAR QA considers a case either “accurate” or “in error,” for the claim-based review. The claim-based review is separate and distinct from the issue-based review, in which OAR QA only considers the specific reviewed issue as either “accurate” or “in error.” For claim-based accuracy, OAR QA will consider a case “accurate” when OAR QA answers questions 1 through 8 of the National Compensation/Pension Rating Quality Review Checklist as either “YES” or “NO” but no payment adjustment is required.

For each case reviewed, OAR QA must complete and answer all questions on the National Compensation/Pension Rating Quality Review Checklist. A “YES” response indicates that the DROC accurately completed the activity associated with the question. A “NO” response indicates that the DROC completed the activity associated with the question “in error.” OAR QA must indicate “N/A” if the question is not applicable to the case under review, or if OAR QA previously recorded a “NO” response for the only issue subject to review. OAR QA is required to provide a narrative summary with statutory, regulatory, judicial, or manual references for any “error” or “NO” answer recorded.

The general guideline is that OAR QA will record an error when an action is taken that violates current regulations or established policies. Examples of outcome-related deficiencies include, but are not limited to, errors that result in an overpayment or underpayment to a claimant and deficiencies that would result in a remand from the Board if not corrected.

OAR QA does not record procedural deficiencies as BE errors. OAR QA records these deficiencies as decision documentation/notification or administrative comments and either the DROC must take corrective action on these deficiencies or submit a timely reconsideration request. OAR QA will not record a judgment or a difference of opinion reflecting a possible better practice or solution as a comment under question 16. If OAR QA identifies an error with an issue not related to the EP under review, then OAR QA also records that error as a comment under question 15.

3.B.7. c. Rating Review Elements

The National Quality Rating Review is, generally, focused on EPs associated with original claims, supplemental claims, claims for increased evaluation, HLRs, appellate issues and pension claims. OAR QA will review other issues such as dependency, income, net worth, withholdings/recoupments, incompetency, etc., when applicable to a case selected under National Quality Review, as part of that EP.

The following is a list of explanations of the questions of the National Rating Quality Review Checklist.

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QuestionExplanation
1. Were all claimed issues addressed and decided?DROCs must formally address and decide, in some fashion, all issues submitted by a Veteran. Entitlement to an earlier effective date generally applies only to an appeal, unless a Veteran submits such a claim in conjunction with a clear and unmistakable error (CUE), etc.
2. Were all inferred and/or ancillary issues addressed?DROCs should address all inferred issues which arise from the claim. This includes any ancillary issues, such as entitlement to Dependents’ Educational Assistance (DEA) benefits when DROCs establish a permanent and total evaluation, and any issue that is “within scope” of a claimed condition (such as a tinnitus grant when the Veteran claims hearing loss that warrants service connection (SC)).
3. Was VCAA pre-decision "notice" provided and adequate?38 CFR 3.159(b)(1) states, in part, that upon receipt of a substantially complete application, VA must notify the claimant and the claimant's representative, if any, of any information, and any medical or lay evidence, not previously provided that is necessary to substantiate the claim. As part of that notice, VA must indicate which portion of that information and evidence, if any, the claimant must provide, and which portion, if any, VA will attempt to obtain on behalf of the claimant.
4. Does the record show VCAA compliant development to obtain all indicated evidence (including a VA exam, if required) prior to deciding the claim?38 CFR 3.159(c)(2) states, in part, that VA must make reasonable efforts to help a claimant in obtaining the evidence necessary to substantiate a claim. Therefore, VA must complete all indicated and necessary development before deciding a claim unless the evidence of record warrants a grant. If a VA examination report was the basis for a rating decision, was that report adequate and sufficient for rating purposes? Was there already sufficient medical evidence of record to rate the claim (see 38 CFR 3.326(b) & (c))? While requesting an examination is generally a judgment area with considerable latitude, VA must exercise that judgment within a reasonable range. The record must contain evidence that fully supports the disability determination and not lack any evidence that would prompt a remand from the Board. A request for a medical opinion on legal issues such as “is a condition service-connected” constitutes an error.
5. Was the grant or denial of all issues correct?Does the evidence of record support the decision according to applicable law, regulation and policy? Any error called in this element must be the equivalent of a CUE. An error includes failure to allow benefits based upon application of the doctrine of reasonable doubt when a case is in equipoise (38 CFR 3.102). OAR QA will not consider an error or note in a comment a judgment variance such as “difference of opinion” or “better rating practice,” as OAR QA does not make best practice suggestions at this time. OAR QA should not call deficiencies invisible to the claimant such as award reason codes or entitlement codes. OAR QA should still note such deficiencies in the checklist.
6. Was the percentage evaluation assigned correct (including combined evaluation)?Generally, OAR QA may only call an error in this category when supported by evaluation tools, such as the Evaluation Builder. If the decision maker did not use the Evaluation Builder, then OAR QA may still call an error if the evaluation tool does not support the evaluation, or the evaluation is not in compliance with the Rating Schedule. The only possible judgment variance is when two evaluation criteria fit the evidence of symptomatology and the disability picture is not clear enough to conclusively apply 38 CFR 4.7.
7. Are all effective dates affecting payment correct?This category encompasses intent to file (ITF), date of claim (DOC), increases during the appeal period, various individual unemployability (IU) scenarios, and incorrect effective dates for ancillary benefits.
8. Were all payment rates correct?If applicable to the case being reviewed, VA must consider issues such as dependency, income, withholdings and recoupments, hospitalization, etc., when deciding whether the payment rates are correct.
9. Was Decision Documentation correct?Simply summarizing evidence and stating a conclusion does not constitute “reasons and bases.” In Gabrielson v. Brown, 7 Vet. App 36 (1994), the court stated: “fulfillment of the reasons and bases mandate requires the decision maker to set forth the precise basis for its decision, to analyze the credibility and probative value of all material evidence submitted by and on behalf of a claimant in support of the claim, and to provide a statement of its reasons and bases for rejecting any such evidence.” Failure to do this on an issue is an error.
10. Was notification correct? (Notification)This element includes Predetermination and Contemporaneous Notification, when applicable (38 CFR 3.103). It is essential that VA views correspondence to claimants, to the extent possible, from the claimant’s perspective. Notification must: be factually correct, address all issues, be as direct and concise as possible, be logically laid out so thought sequences are not broken, and be free from apparent contradictory statements. VA must provide notice of procedural and appellate rights following every decision by furnishing VA Form 20-0998, Your Right to Seek Review of Our Decision. VA should update the master record to include designation of the claimant’s representative so that VA furnishes computer-generated notices to both.
11. Were Appropriate Signatures (Internal Controls) correct?VA has added the appropriate signature for internal control purposes only. It is a means of checks and balances to eliminate potential fraud situations.
12. Was the end product selected for review timely developed? (over-developed)To be an overdevelopment error, the development must clearly be erroneous (e.g., ordering an examination for a condition for which VA cannot establish SC due to a statutory bar) and materially affect the claim (e.g., delay claim processing in and of itself). Mere differences of opinion regarding whether or not the evidence of record was sufficient to decide a claim without an examination are not valid quality errors. OAR QA does not classify notations in these questions as BE errors, and therefore does not reflect them in the national or individual station accuracy. OAR QA should only provide details in this category that focus only on scenarios where development was obviously improper or unnecessary to complete the claim. OAR QA uses this question only for data gathering purposes. A “YES” or “NO” response in G4 is only applicable when OAR QA selects “YES” in G3. Otherwise, OAR QA should mark G4 as “N/A.”
13. Were Examination & Medical Opinion Requests correct?VA may require a medical opinion to reconcile diagnoses, determine the relationship between conditions, determine etiology or nexus to service-incurred disease or injury, or determine whether and to what extent service-connected disability has aggravated a nonservice-connected condition. Before requesting an opinion, review the claim and supporting evidence to ensure that minimum evidentiary requirements have been met. Always provide the claims folder for the examiner to review. VA provides guidelines in M21-1, Part IV, Subpart i, 2.A. The employee must select the appropriate exam worksheet for each specific claimed condition identified in the General Remarks section, including appropriate use of General Medical exam. [NOTE: If the employee requested a general medical exam, the remarks or other information in the exam request must support the request (for example, recently discharged Veteran)]. It is not cascading to select “YES” for question 12 and “NO’ for 13 (H1). The employee must identify the specific condition (or conditions) in the General Remarks section for each exam requested. The employee must identify the evidence the examiner should review by tabbing it in the claims folder, indicating the source (provider or facility) of the evidence, the subject matter, and the approximate dates covered. However, the employee should also advise the examiner that the review is not limited to this evidence. The reviewer should also select “YES” if the claims folder was available in electronic format and the examiner stated that it was reviewed. The employee must clearly state the nature of the opinion requested, and explain why the opinion is needed, if it clarifies the request.
14. Was there an Expedited Favorable Decision?Make an intermediate rating decision if the record contains sufficient evidence to grant any benefit, including SC at a noncompensable level. Grant SC for a disability with a noncompensable evaluation, if supported by the evidence, even though the decisionmaker must defer the issue of SC, compensation for other disabilities, or the issue of a higher evaluation.
15. Were Rating Comments correct (EP not under review)?This question identifies discrepancies that OAR QA would have otherwise considered as errors had the EP in question been under review.
16. Were Rating Comments correct (EP under review)?This question identifies discrepancies that OAR QA does not consider errors in the EP under review.