---
title: "Part X, Subpart i, Chapter 5, Section A Establishing Veteran Status Based on Merchant Marine Service"
document: "M-21-1"
section: "Part X, Subpart i, Chapter 5, Section A"
canonical: "https://veteranai.co/va-regulations/m21-1/x.i.5.a-establishing-veteran-status-based-on-merchant-marine-service"
source: "https://www.knowva.ebenefits.va.gov/system/templates/selfservice/va_ssnew/help/customer/locale/en-US/portal/554400000001018/content/554400000177948/M21-1-Part-X-Subpart-i-Chapter-5-Section-A-Establishing-Veteran-Status-Based-on-Merchant-Marine-Service"
updated: "2026-09-07T14:37:49.120212Z"
---

September 21, 2018  

### X.i.5.A.1.a. Eligibility for a U.S. Merchant Marine Discharge Certificate

Members of the U.S. Merchant Marine who served under the Coast Guard, Naval Transportation Service, or Army Transport Service in active, oceangoing service during the period from

  * December 7, 1941, to August 15, 1945, are eligible to receive discharge certificates under _Public Law (PL) 95-202_ , or
  * August 16, 1945, to December 31, 1946, are eligible to receive discharge certificates under _PL 105-368_.

Each of these services will issue a _DD Form 214_ , _Certificate of Uniformed Service_ , or a _DD Form 1300_ , _Report of Casualty_ , as applicable.**Important:** Claims processors must pay close attention to the law under which the _DD Form 214_ or _DD Form 1300_ is issued to avoid entitlement errors.**References:** For more information on the eligibility of merchant mariners under

  *  _PL 95-202_ , see M21-1, Part X, Subpart i, 5.A.1.b, and
  *  _PL 105-368_ , see M21-1, Part X, Subpart i, 5.A.1.c.

### X.i.5.A.1.b. Merchant Mariners Who Are Eligible for All VA Benefits Under PL 95-202

On January 19, 1988, in response to Section 401 of _PL 95-202_ , the Secretary of the Air Force approved service aboard certain merchant or public vessels in oceangoing or foreign waters as active duty in World War II (WWII).If the discharge document shows eligibility under _PL 95-202_ , the merchant mariner and his/her survivors are eligible for benefits in the same manner as any other Veteran or survivor.**Reference:** For more information on the eligibility of merchant mariners under _PL 95-202_ , see [38 CFR 3.7(x)(15)](<http://www.ecfr.gov/cgi-bin/text-idx?SID=9e5509539edbba3668ccfe58def65f5e&mc=true&node=se38.1.3_17&rgn=div8>).  

### X.i.5.A.1.c. Merchant Mariners Who Are Eligible for Burial Benefits Only Under PL 105-368

_PL 105-368_ , Section 402, provides that the qualified service of certain merchant mariners between August 16, 1945, and December 31, 1946, is deemed active duty service for purposes of all Department of Veterans Affairs (VA) burial benefits, including:

  * burial flags
  * burial, plot, and transportation allowances
  * headstones and markers
  * interment in national cemeteries, and
  * markers in memorial areas of national cemeteries.

**Important:** Merchant Marine service after August 15, 1945, does _not_ establish eligibility for compensation and/or pension.**Reference:** For more information on merchant mariner benefits under Section 402 of _PL 105-368_ , see [46 U.S.C. 11201](<https://www.law.cornell.edu/uscode/text/46/11201>)-[11204](<https://www.law.cornell.edu/uscode/text/46/11204>).  

### X.i.5.A.1.d. Applying for a DD Form 214 or DD Form 1300 for Merchant Marine Service

To apply for a _DD Form 214_ or _DD Form 1300_ , a claimant must

  * complete and sign _DD Form 2168_ , _Application for Discharge of Member or Survivor of Member of Group Certified to Have Performed Active Duty with the Armed Forces of the United States_ , and
  * submit the _DD Form 2168_ to the appropriate service department.

**Notes:** 

  * The applicant should also submit copies of any documentation of sea service that he or she may have.
  * An applicant must resubmit the _DD Form 2168_ and supporting documentation to establish periods of duty other than those that are shown in Item 18, _REMARKS_ , on the _DD Form 214_.
  * If the merchant mariner is deceased, the applicant must submit evidence of death with the _DD Form 2168_.  A photocopy of a death certificate, a funeral obituary, or other evidence showing the date of death is acceptable for this purpose.
  * For certification under _PL 105-368_ , the applicant must enclose a $30.00 check or money order, payable to the U.S. Treasury.

### X.i.5.A.1.e. Determining Where to Send DD Form 2168

Use the information below to determine where the claimant should send the _DD Form 2168_.| **If …**| **Then the claimant sends the _DD Form 2168_ to …**  
the alleged service was employment as a civil servant for the U.S. Army Transport Service (or the U.S. Army Transportation Corps, Water Division)| Commander  
U.S. Army Human Resources Command  
Department 420  
Ft. Knox, KY 40122-5402  
ATTN: AHRC-PDR  
the alleged service was employment as a civil servant for the Naval Transportation Service| Commander  
U.S. Navy Personnel Command (PERS-312)  
5720 Integrity Drive  
Millington, TN 38054-5045  
  * the alleged service was employment with the War Shipping Administration or Office of Defense Transportation or their agents, and
  * the U.S. Coast Guard or Department of Commerce acknowledged the employment in a document such as a Merchant Mariner Document/Certificate of Service 

| Commanding Officer  
U.S. Coast Guard – National Maritime Center  
ATTN: Records Management Branch (NMC-41)  
100 Forbes Drive  
Martinsburg, WV 25404  
Phone:  (888) 427-5662 _**Reference**_ :  For more information about verification of maritime service through the Coast Guard, see the [National Maritime Center](<https://www.dco.uscg.mil/national_maritime_center/>) website.  

## 2. Merchant Marine Service Verification Required for a VA Claim

This topic contains instructions regarding information required for a claim, including

  * information required to establish a claim based on Merchant Marine service
  * entering service information during claim establishment
  * correct voyage entries and release dates on _DD Form 214_
  * information required on the _DD Form 1300_
  * service information received from the Department of War (DOW), and
  * prior Coast Guard certification of certain Merchant Marine service.

February 2, 2026  

### X.i.5.A.2.a. Information Required to Establish a Claim Based on Merchant Marine Service

VA requires evidence of Merchant Marine service before a claim can be established.  This includes electronic transmission of service information from the Department of War (DOW) to VA, documented in the Veterans Benefits Management System (VBMS) by _Yes_ in __ the SYSTEM VERIFIED SERVICE field on the MILITARY SERVICE screen.If there is no evidence of Merchant Marine service, establish an end product 400 and inform the claimant that VA cannot initiate development until the claimant provides a _DD Form 214_ or _DD Form 1300_ or other evidence of Merchant Marine service.**Important:** 

  * Develop the claim while awaiting receipt of the certified discharge document when evidence of Merchant Marine service
    * exists, or
    * a copy of a discharge document has been submitted by the claimant or approved VA representative.
  * Although it is ultimately the claimant’s responsibility to provide a discharge document, VA is not precluded from accepting the discharge document from any legitimate source such as the service department or power of attorney when warranted.

### X.i.5.A.2.b. Entering Service Information During Claim Establishment

During claims establishment, add the claimant’s three earliest voyages as individual periods of Merchant Marine service on the MILITARY SERVICE screen in VBMS.  Use the beginning and ending dates of each voyage for entry on duty (EOD) and release from active duty (RAD) information, unless the claim is established based on the _System Verified Service_ entry and voyage information is not yet available.If the three earliest voyages do not satisfy the minimum 90-day active duty requirement for pension eligibility, enter the three longest voyages instead.  

### X.i.5.A.2.c. Correct Voyage Entries and Release Dates on DD Form 214

The _DD Form 214_ issued should show the

  * EOD as December 7, 1941, or the date of the earliest voyage, and
  * RAD date as the date of completion of the last voyage or
    * August 15, 1945 (for _PL 95-202_), or
    * December 31, 1946 (for _PL 105-368_).

**Notes:** 

  * The actual voyages and inclusive dates of each voyage will be shown in Item 18, _REMARKS_ , on the _DD Form 214_.  If all of the voyages cannot be entered in Item 18, an attachment sheet will be provided. 
  * For computation of service, only the actual dates of each voyage are considered as qualifying active duty for VA purposes.
  * Do _not_ use the information provided in Item 12, _RECORD OF SERVICE_ , to determine an applicant's entitlement to VA benefits.

### X.i.5.A.2.d. Information Required on the DD Form 1300

If the death of a merchant mariner occurred during service, _DD Form 1300_ is issued in lieu of _DD Form 214_.The _DD Form 1300_ should show the equivalent military pay grade.  If the pay grade information is necessary but not provided, request pay grade verification by following the instructions in [M21-1, Part III, Subpart ii, 2.H.10](</system/templates/selfservice/va_ssnew/help/customer/locale/en-US/portal/554400000001018/content/554400000037154/M21-1-Part-III-Subpart-ii-Chapter-2-Section-H-Service-Department-Organizational-Structures-and-Service-Number-Assignments>).**Note:** A _DD Form 1300_ is valid even without pay grade information or a Social Security number.  

### X.i.5.A.2.e. Service Information Received From DOW

When processing paper copies of _DD Forms 214_ for certain categories of service members, the VADS unit entered _DEV_ as the separation reason into the corporate record.  This _DEV_ entry ensured that merchant mariners who served during the WWII era did not receive the benefits information package that is intended to be sent only to recently discharged. If the corporate record was updated by DOW data sharing with VA 

  * prior to 2015, it is not necessary to clarify a separation reason code listed as _DEV_ , or
  * on or after January 1, 2015, a separation reason code listed as _DEV_ requires additional development to obtain the actual separation reason. 

_**Important**_ :  In either circumstance, if the _SEPARATION CODE_ on a certified copy of _DD Form 214_ (or electronic equivalent) is SAT, update the corporate record to reflect the correct entry.**Reference:** For more information on the VADS data format field in the corporate record, see the _Share User Guide._  

### X.i.5.A.2.f. Prior Coast Guard Certification of Certain Merchant Marine Service

Previously, the Coast Guard would certify 90 days of service in certain cases, without providing specific periods of service, if there was proof that a mariner sailed on oceangoing vessels, but the records of vessels or dates of voyages were incomplete.Even if Item 18, _REMARKS_ , on _DD Form 214_ shows no voyage information, consider a previously issued _DD Form 214_ to be valid if it contains the following statements:

  * _The above individual falls into a special class of World War II Merchant Mariners.   The complete sea service records for these individuals, which indicate specific sailing dates and vessel names, cannot be located due to their no longer being in the Federal records system; were lost with the ship; or the individual served aboard the ship in a capacity for which official records were not kept._
  * _Based on the information available, the Coast Guard certifies that the above individual has at least 90 days of service aboard oceangoing vessels during the period between 7 December 1941 and 15 August 1945._

**Reference:** For more information about what a currently issued _DD Form 214_ must contain, see M21-1, Part X, Subpart i, 5.A.2.c.
