Veterans Appeals Improvment

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Submissions of appeals reform regulatory comments

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On October 9th, PVA submitted comments to VA in response to proposed regulations implementing the Veterans Appeals Improvement and Modernization Act.

The comments focused on the following concerns: communication and notices provided by VA, lack of clarity about how VA will define the record and timing around the rules, and lastly, interaction between VA and accredited representatives. The last concern is of particular importance since we want to ensure our service officers are timely informed so they can, in turn, timely advise our clients.

PVA’s concern with VA’s interaction with representatives is warranted. Currently, if a veteran gets a letter or an email from VA, the representative should also receive a notice. This practice is inconsistent, however, and often means the representative must search the Veterans Benefits Management System for whether a client has received notice of a decision. This is not a notice to representatives, but a scavenger hunt that impairs PVA’s ability to effectively advise our clients.

PVA has always agreed that the appeals system needs to be improved; however, we do not agree with all the changes that VA has proposed. Furthermore, PVA has concerns with VA’s implementation of the Appeals Modernization Act and whether or not it will have a positive effect on veterans’ claims.


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Veterans Appeals Improvment


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