Claim Raven explanation
What this means
In the legacy appeal system, a claimant generally must use the Notice of Disagreement form VA supplied with the decision and identify the disputed issues as the form requires.
An indication in the claims file or online account that VA sent the form triggers the form requirement. Returning a form designed for another benefit or review system does not toll the legacy Notice of Disagreement deadline.
How this helps your claim
Part 19 primarily governs legacy appeals. When VA provides an appeal form, another form or informal statement does not substitute for it and does not extend the filing period. If VA provided no designated form, a written statement expressing disagreement and a desire for appellate review can qualify. Simultaneously contested claims use the written-communication rule.
What to check in your records
Confirm the decision belongs to the legacy system, identify the form VA supplied, and compare the filed document, issues, and receipt date with that notice.
- Keep the decision notice, enclosed appeal form, envelope or electronic delivery record, and appeal-rights page.
- Save the completed Notice of Disagreement and proof of VA receipt.
- List every issue decided and mark which issues the form expressly appealed.
Confirm the appeal system before choosing a form
Use the decision date and its review instructions to distinguish a legacy appeal from a modernized review. The systems send disagreements to different places and use different forms.
When a decision contains several issues, name each one you intend to appeal. A general statement such as “I disagree with everything” is useful only when the required form clearly permits and records that selection.
Can a letter replace the legacy Notice of Disagreement form?
Only when VA did not provide a designated appeal form. When it did, this section requires the completed, timely form and says another communication does not extend the deadline.
Official regulatory text
38 CFR § 19.21
eCFR snapshot: 2026-09-17. Layout and spacing are adapted for reading. The full section and its tables are included below.
§ 19.21 Notice of Disagreement.
(a) Cases in which a form is provided by the agency of original jurisdiction for the purpose of initiating an appeal.
(1) Format. For every case in which the agency of original jurisdiction (AOJ) provides, in connection with its decision, a form for the purpose of initiating an appeal, a Notice of Disagreement consists of a completed and timely submitted copy of that form. VA will not accept as a notice of disagreement an expression of dissatisfaction or disagreement with an adjudicative determination by the agency of original jurisdiction and a desire to contest the result that is submitted in any other format, including on a different VA form.
(2) Provision of form to the claimant. If a claimant has established an online benefits account with VA, or has designated an email address for the purpose of receiving communications from VA, VA may provide an appeal form pursuant to paragraph (a)(1) of this section electronically, whether by email, hyperlink, or other direction to the appropriate form within the claimant's online benefits account. VA may also provide a form pursuant to paragraph (a)(1) of this section in paper format.
(3) Presumption form was provided. This paragraph (a) applies if there is any indication whatsoever in the claimant's file or electronic account that a form was sent pursuant to paragraph (a)(1) of this section.
(4) Specificity required by form. If the agency of original jurisdiction gave notice that adjudicative determinations were made on several issues at the same time, the specific determinations with which the claimant disagrees must be identified to the extent a form provided pursuant to paragraph (a)(1) of this section so requires. If the claimant wishes to appeal all of the issues decided by the agency of original jurisdiction, the form must clearly indicate that intent. Issues not identified on the form will not be considered appealed.
(5) Alternate form or other communication. The filing of an alternate form or other communication will not extend, toll, or otherwise delay the time limit for filing a Notice of Disagreement, as provided in § 19.52(a). In particular, returning the incorrect VA form, including a form designed to appeal a different benefit does not extend, toll, or otherwise delay the time limit for filing the correct form.
(b) Cases in which no form is provided by the agency of original jurisdiction for purpose of initiating an appeal. A written communication from a claimant or his or her representative expressing dissatisfaction or disagreement with an adjudicative determination by the agency of original jurisdiction and a desire to contest the result will constitute a Notice of Disagreement relating to a claim for benefits in any case in which the agency of original jurisdiction does not provide a form identified as being for the purpose of initiating an appeal. The Notice of Disagreement must be in terms which can be reasonably construed as disagreement with that determination and a desire for appellate review. If the agency of original jurisdiction gave notice that adjudicative determinations were made on several issues at the same time, the specific determinations with which the claimant disagrees must be identified.
(c) Simultaneously contested claims. The provisions of paragraph (b) of this section shall apply to appeals in simultaneously contested claims under Rules 500 and 501 (§§ 20.500 and 20.501 of this chapter), regardless of whether a standardized form was provided with the decision of the agency of original jurisdiction.
(Authority: 38 U.S.C. 7105 (2016))
[79 FR 57698, Sept. 25, 2014. Redesignated and amended at 84 FR 177, 178, Jan. 18, 2019]
Related references
- 38 CFR § 19.30: What VA sends with a legacy Statement of the Case
- 38 CFR § 19.34: Appealing a finding that a legacy appeal was late
- 38 CFR § 19.54: New evidence usually does not extend a legacy appeal deadline
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