Revised June 7, 2021
X.i.6.H.1.aRequired DRAS Actions Upon Completion of VA Examinations
Proposed rating activity should begin upon completion of the Medical Evaluation Stage. The Disability Rating Activity Site (DRAS) will identify cases requiring action using the Pending Rating Preparation Report in Veterans Tracking Application (VTA).In each Integrated Disability Evaluation System (IDES) case with completed Department of Veterans Affairs (VA) examinations, the DRAS must complete the actions outlined in the table below. — Step — Action 1 — Determine the duty status of the participant. If the case involves a
- service member currently serving on active duty, go to Step 2, or
- Veteran (not currently serving on active duty), complete the actions outlined in M21-1, Part X, Subpart i, 6.K.2.d and take no further action in this table.
2 — Prepare a proposed rating decision under the pending end product (EP) 689 that addresses all claimed and referred conditions in accordance with M21-1, Part X, Subpart i, 6.H.1.c. Important:
- The rating must fully address all issues known to be referred by the service department. If incomplete development prevents a decision on any referred condition(s), the DRAS must resolve the deficiency before going to the next step.
- When all referred conditions can be decided, but the evidence is insufficient to decide all claimed conditions, claimed conditions should be deferred in accordance with M21-1, Part X, Subpart i, 6.H.1.d.
| 3 | Finalize the proposed rating in Veterans Benefits Management System-Rating (VBMS-R). |
|---|---|
| 4 | In VTA, update the following fields
|
| 5 | Prepare the benefits estimate letter (BEL) in accordance with M21-1, Part X, Subpart i, 6.H.1.f and M21-1, Part X, Subpart i, 6.H.5. |
| 6 | Update the BENEFIT ESTIMATE LETTER COMPLETED ON DATE field in VTA. |
| 7 | Clear EP 310 in accordance with M21-1, Part X, Subpart i, 6.H.1.h. |
| 8 | Initiate development on any deferred claimed conditions in accordance with M21-1, Part X, Subpart i, 6.H.1.d. |
X.i.6.H.1.bConsidering Evidence in Proposed Rating Decisions
Proposed IDES ratings must be prepared on the basis of the evidence of record at the time the examination is completed. This evidence will typically consist of
- the service treatment records provided as part of the IDES referral, and
- the results of the IDES examination(s).
Receipt of additional records after completion of a proposed rating does not necessitate readjudication of the proposed rating. Any additional records will be considered as part of the final rating process (or the rating reconsideration process, if applicable).
X.i.6.H.1.cAddressing Claimed and Referred Conditions in Proposed Rating Decisions
The DRAS is responsible for preparing proposed rating decisions for Physical Evaluation Boards (PEBs)s that address every disability that was
- referred by the service department, and
- formally claimed by the participant during the initial meeting with the Military Services Coordinator (MSC).
Exceptions:
- When the evidence is sufficient to decide all disabilities that were referred by the service department, but not yet sufficient to decide claimed issues, the DRAS may defer a decision on the claimed issue(s) and return a partial rating decision to the PEB.
- In cases involving members of the National Guard and Reserve who are not on active duty, a final VA rating decision will be prepared and returned to the PEB in lieu of a proposed rating (in accordance with M21-1, Part X, Subpart i, 6.K.2).
Important: The rating decision returned to the PEB must always fully address all conditions that are understood to be referred by the service department at the time of the proposed rating action. When referred issues cannot be decided due to incomplete development, the DRAS must resolve the deficiency prior to preparing the proposed rating, as referred issues cannot be deferred on proposed ratings. Deferrals of claimed conditions must be handled in accordance with
- M21-1, Part X, Subpart i, 6.H.1.d, in cases involving participants serving on active duty, and
- M21-1, Part X, Subpart i, 6.J.1.e, in cases involving participants who are not currently on active duty.
References: For more information on
- disabilities that IDES participants claim after their initial meeting with their MSC, see M21-1, Part X, Subpart i, 6.K.1.c and d
- issues associated with claims that were pending prior to the participant’s referral to IDES, see M21-1, Part X, Subpart i, 6.G.1.d and e
- disabilities that cannot be evaluated due to a participant’s pregnancy, see M21-1, Part X, Subpart i, 6.K.3.e
- participants who are too disabled to report for examinations, see M21-1, Part X, Subpart i, 6.F.2.n, and
- disabilities found on examination that were not specifically claimed or referred, see M21-1, Part X, Subpart i, 6.K.1.i.
X.i.6.H.1.dDeferring Claimed Conditions in Proposed Rating Decisions
When evidence is sufficient to decide all referred conditions in a proposed rating decision, but insufficient to decide one or more claimed issues, the claimed issues must be deferred on the proposed rating decision. Note: Current VBMS-R functionality does not allow deferrals on proposed ratings via typical VBMS deferral process. As such, these deferrals must be entered as a “Free Text” issue in VBMS-R to ensure the deferral is properly indicated on the Codesheet. Important: When claimed issues are deferred in proposed ratings, the DRAS must take timely corrective development so that the issue can be resolved on the final rating (the claim should not be returned to the rating activity prior to the participant’s discharge). If the at the time of the final rating, DRAS is still unable to fully resolve the deferred issue(s), the issues should be deferred on the final rating and handled in accordance with M21-1, Part X, Subpart i, 6.J.1.e.
X.i.6.H.1.eRequired Information on the Codesheet of a Proposed Rating Decision
DRAS decision makers must select the appropriate decision when entering a proposed rating decision into VBMS-R, either
- Proposed DES Service Connected , for proposed grants of service connection (SC), or
- Proposed DES Not Service Connected , for proposed denials of SC.
Important: Do not use
- PEB Referred Proposed Service Connected , or
- PEB Referred Proposed Not Service Connected.
X.i.6.H.1.fNotification Letter to Accompany Proposed Rating Decisions
The DRAS must prepare a notification letter in conjunction with proposed rating decisions according to the table below. — If the participant is ... — Then the DRAS must prepare a …on_ active duty — BEL shown in M21-1, Part X, Subpart i, 6.H.5. Rationale: The purpose of the BEL is to provide the participant with a proposed estimate of VA benefits to assist him/her with financial planning following discharge from active duty. is not on active duty — standard Veteran’s notification letter in accordance with M21-1, Part X, Subpart i, 6.K.2.d. Exception: If the participant declined to file a VA claim as part of the IDES process, the DRAS must prepare the notification letter as indicated in M21-1, Part X, Subpart i, Chapter 6.K.10.b.
X.i.6.H.1.gIncluding Dependents on the BEL
The DRAS must include dependents on the BEL when VA Form 21-686c , Application Request to Add and/or Remove Dependents, is of record and complete. If the VA Form 21-686c of record is incomplete or the participant did not submit VA Form 21-686c, the DRAS must add the following information to the dependency section of the BEL: If you have submitted a complete VA Form 21-686c, Declaration of Status of Dependents, this information will be considered on your final rating. If you have eligible dependents, but have not yet submitted the VA Form 21-686c, please contact your Military Services Coordinator (MSC).
X.i.6.H.1.hEP Credit for Proposed Rating Decisions
Upon completion of a proposed rating decision, the DRAS must complete a one-time clear of EP 310 (with the IDES Rating – Proposed claim label) and use the current date the date of claim.Exception: The one-time clear of EP 310 is not appropriate if the rating decision was prepared under a rating EP for an IDES participant who is a member of the Reserves or National Guard and is not on active duty, per M21-1, Part X, Subpart i, 6.K.2.d. Note: If an IDES participant declines to file a VA claim, and the DRAS prepares a rating under M21-1, Part X, Subpart i, 6.K.10.a, an EP 310 should be cleared regardless of the participant’s duty status.
2Special Considerations Relating to Proposed Ratings
This topic contains information about special rating considerations in IDES claim, including
- rating decisions for IDES participants who are not on active duty
- rating issues that are unique to IDES cases
- decisions involving coexisting claimed and referred disabilities
- addressing referred conditions for PEB purposes only, and
- denying SC for a referred condition in a proposed rating.
Revised June 7, 2021
X.i.6.H.2.aRating Decisions for IDES Participants Who Are Not on Active Duty
In IDES cases involving Veterans (i.e., members of the National Guard and Reserve not currently serving on active duty), DRAS will prepare a standard VA rating and notification letter to be provided to the PEB in lieu of a proposed rating and BEL.Reference : For more information on processing IDES claims from members of the Reserves or National Guard who are not on active duty, see M21-1, Part X, Subpart i, 6.K.2.
X.i.6.H.2.bRating Issues That Are Unique to IDES Cases
DRAS decision makers must consider the issues in the table below when preparing proposed ratings that will be used by the PEB. — Issue — Discussion
Goniometer Readings | Use the goniometer readings in examination reports when assigning evaluations for back disorders unless an examiner indicates in a report that the readings do not accurately reflect the IDES participant’s true functional limitations. Important: When goniometer readings do not accurately reflect the IDES participant’s true functional limitations, provide an explanation in the narrative of the proposed rating decision. |
Evaluations Subject to Change | When the evaluation assigned to a disability in a proposed rating decision is subject to change, explain in the narrative of the proposed rating decision that a different evaluation may be warranted when the final rating decision is made. |
Future Examinations | When a future examination of a disability is necessary, note this in the proposed rating decision. Rationale: When deciding whether to place a participant on the Temporary Disability Retired List or the Permanent Disability Retired List, PEBs consider a determination that a future examination of a disability is necessary. This information must be included in the proposed rating decision because PEBs do not receive copies of final rating decisions. |
Coexisting Claimed and Referred Disabilities | When preparing a proposed rating decision, take the additional actions described in M21-1, Part X, Subpart i, 6.H.2.c if
|
Examinations Found Insufficient for Rating Purposes | When IDES examinations are determined to be insufficient for rating purposes, the DRAS must take the actions outlined in M21-1, Part X, Subpart i, 6.F.3.h. |
X.i.6.H.2.cDecisions Involving Coexisting Claimed and Referred Disabilities
If an IDES participant has coexisting claimed and referred disabilities that must be assigned a single disability rating under the rating schedule, the DRAS decision maker must
- determine the appropriate disability rating for the referred disability alone (as if the coexisting claimed disability did not exist), and
- note the separate disability rating and the rationale for its assignment in the Reasons for Decision part of the rating decision that discusses the coexisting disabilities.
Rationale: PEBs may consider only the disability ratings VA assigns to referred disabilities when deciding a participant’s final disposition.Example: A participant claims SC for sleep apnea. Referred conditions include asthma. Both conditions are appropriately diagnosed, and sleep apnea is confirmed by a sleep study. Pulmonary function tests warrant a 10-percent disability rating. However, the participant also uses a continuous positive airway pressure machine which is medically necessary for sleep apnea.VA awards SC for asthma and sleep apnea as coexisting disabilities and assigns a disability rating of 50 percent. Result: The individual who prepares the proposed rating decision must indicate in the corresponding Reasons for Decision that the participant’s asthma, if rated alone, would warrant the assignment of a 10-percent disability rating based on the results of pulmonary function testing.
X.i.6.H.2.dAddressing Referred Conditions for PEB Purposes Only
The DRAS must prepare a proposed evaluation for PEB purposes only when there are
-
both coexisting claimed and referred disabilities as indicated in M21-1, Part X, Subpart i, 6.H.2.c, or
-
referred conditions
-
that are the subject of a pending appeal or higher-level review (HLR) as indicated in M21-1, Part X, Subpart i, 6.G.1.a and c
-
where the IDES participant subsequently declines to file a VA claim, as indicated in M21-1, Part X, Subpart i, 6.K.10.a, or
-
where a prescribed form was not used.
The proposed decision must include a clear indication that the evaluation assigned is for PEB purposes only. Note: Evaluations for PEB purposes only must not be
- prepared for any issue for which SC cannot be established (these conditions must be handled in accordance with M21-1, Part X, Subpart i, 6.H.2.e), or
- indicated on final VA ratings (cases involving participants who are not on active duty that require evaluations for PEB purposes only must be handled in accordance with M21-1, Part X, Subpart i, 6.K.2.e).
X.i.6.H.2.eDenying SC for a Referred Condition in a Proposed Rating
If the evidence does not support SC for a referred condition, the DRAS must
- prepare a proposed rating denying the condition with no disability evaluation, and
- provide a notice containing the following wording to the requesting PEB:
_The evidence of record does not establish that the referred condition, [name of condition] is related to the participant’s military service; as such, no disability rating will be provided. Please refer to the proposed rating decision narrative for additional information regarding the reason(s) for this proposed denial. _If DoD is in possession of any new/additional evidence that resolves the reason for denial, or otherwise might serve to establish service-connection, please submit a PEB-Directed Rating Return in VTA and forward the new information to DRAS for consideration. The notice must be added to
- the Special Notations box on the Codesheet of the proposed rating, and
- a note placed in VTA.
3Providing Proposed Ratings to the PEB
This topic contains information on providing IDES ratings to the PEB on request, including
- handling a PEB request for a proposed rating decision
- distribution of the proposed rating decision, and
- presentation of the proposed rating documents to the participant.
Revised June 7, 2021
X.i.6.H.3.aHandling a PEB Request for a Proposed Rating Decision
PEBs will indicate their need for a VA rating decision via VTA update; no physical request or records will be sent to DRAS. Cases in which the PEB has requested a VA rating will be indicated on the Pending Proposed Rating Report in VTA. For each case that appears on the VTA Pending Proposed Rating Report , the DRAS must complete the actions indicated in the table below. — Step — Action
| 1 | Enter a date in the PROPOSED RATING START DATE field in VTA. (The date entered in this field must match the date entered in the PROPOSED RATING REQUEST DATE field on the PEB Tab of VTA ). |
|---|---|
| 2 | Review VTA and/or VBMS to confirm that the following items have been completed
|
| 3 | Are both the rating decision and notification letter completed and in the electronic claims folder (eFolder)?
|
| 4 | Has the requesting PEB agreed to obtain proposed ratings directly from the eFolder?
Note: Some PEB personnel have access to the VBMS eFolder; as such, PEBs may elect to obtain the rating and notification letter directly from the eFolder. This method of transfer is encouraged, as it eliminates the need for DRAS to take additional action to transfer the documents. |
| 5 | Provide the rating decision, Codesheet , and notification letter to the requesting PEB via Department of Defense Secure Access File Exchange (DoD SAFE). Reference: For more information on sending files through DoD SAFE, see M21-1, Part X, Subpart i, 6.K.9.a. |
| 6 | Update the PROPOSED RATING END DATE field in VTA in accordance with the table below. If the documents were provided to the PEB via … Then the DRAS must update the PROPOSED RATING END DATE field to reflect ... |
DoD SAFE transfer the date the documents were sent via DoD SAFE.
the eFolder the current date.
Note: This entry serves to notify the PEB of the documents’ availability in the eFolder and must never be backdated.
| If the documents were provided to the PEB via … | Then the DRAS must update the PROPOSED RATING END DATE field to reflect ... |
|---|---|
DoD SAFE transfer | the date the documents were sent via DoD SAFE. |
the eFolder | the current date. Note: This entry serves to notify the PEB of the documents’ availability in the eFolder and must never be backdated. |
Note: If claimed issues were deferred in the proposed rating, DRAS must continue efforts to resolve.
X.i.6.H.3.bDistribution of the Proposed Rating Decision
The table below describes the order in (and restrictions on) which a proposed rating decision and notification are distributed. — The … — Provides proposed rating documents to the …
| DRAS | PEB. |
|---|---|
| PEB | Physical Evaluation Board Liaison Office (PEBLO). |
| PEBLO | participant. |
Additionally, the DRAS must ensure the rating Codesheet is made available to the PEB. However, the participant does not later receive the Codesheet from the PEBLO. As stated in M21-1, Part X, Subpart i, 6.H.3.c, the participant receives the rating decision and notification letter from the PEBLO.
Important: With the following exceptions, neither a DRAS nor an MSC may provide a proposed rating decision to a participant’s representative.
-
In IDES cases involving Veterans (not currently on active duty), DRAS must release the rating and notification letter to the Veteran (and power of attorney, if applicable) upon completion. The DRAS will provide a copy of the same documents to the PEB at the time of their requests.
-
If, at the time of exit interview (after the PEB process has concluded), the MSCs may the provide a copy of the proposed rating decision and/or BEL at the participant’s request.
X.i.6.H.3.cPresentation of the Proposed Rating Documents to the Participant
The PEBLO will present the participant with the proposed rating decision and notification letter, when briefing the participant on the PEB’s findings. MSCs may attend these briefings at the request of the participant or PEBLO if the MSC’s schedule allows it. PEBLOs may advise participants that they may schedule a meeting with their MSC to discuss the proposed rating decision. MSCs must make every effort to meet or speak with participants who have questions about their proposed rating decision within 48 hours of receiving a request.
4Requests for Reconsideration, Review, and Correction of Proposed Rating Decisions
This topic contains information about requests for reconsideration, review, and correction of proposed rating decisions, including
- requests for reconsideration of a proposed rating decision
- system updates
- upon receipt of a request for reconsideration, and
- after processing a request for reconsideration
- identification of errors in a proposed rating decision
- PEB-directed rating returns (PDRRs), and
- handling PDRRs: DRAS responsibilities.
Revised November 22, 2019
X.i.6.H.4.aRequests for Reconsideration of a Proposed Rating Decision
IDES participants may submit a one-time request for reconsideration of a proposed rating decision regarding any disability the participant’s service department referred to VA. A proposed rating decision regarding a claimed disability is not subject to reconsideration. Participants must submit a request for reconsideration to their PEB. If the PEB approves the request, it forwards the request to the DRAS that made the proposed rating decision. DRAS Decision Review Officers (DROs) are responsible for deciding all requests for reconsideration of a proposed rating decision. If a DRO decides revision of a proposed rating decision
- is warranted
- the DRO prepares either
- a new proposed rating decision for active duty cases, or
- a new final rating decision for non-active-duty cases, and
- the DRAS forwards the decision to the appropriate PEB, or
- the DRO prepares either
- is not warranted
- the DRO prepares a memorandum that states this fact, and
- the DRAS forwards the memorandum to the appropriate PEB.
Important:
- If a PEB submits a request for reconsideration that has not been initiated by the service member, then notify the PEB that no action will be taken and indicate the reason the request failed to meet the criteria for a formal reconsideration.
- The only acceptable bases for revision of a proposed rating decision are:
- receipt of new evidence, and/or
- error on the part of the individual who made the decision.
- See M21-1, Part X, Subpart i, 6.K.2.e for instructions that are unique to requests for reconsideration from participants that are
- members of the Reserves or National Guard, and
- not on active duty.
X.i.6.H.4.bSystem Updates Upon Receipt of a Request for Reconsideration
Upon receipt of a request for reconsideration of a proposed rating decision, the DRAS must update
- VTA by entering the date the DRAS received the request in the VA RECONSIDERATION RATING START DATE field on the RO/RATING ACTIVITY tab, and
- VBMS by changing
- the claim-level suspense so it expires seven days in the future
- the suspense reason to Special Project Team Claim, Awaiting: RD, and
- the claim status to Ready for Decision.
X.i.6.H.4.cSystem Updates After Processing a Request for Reconsideration
After processing a request for reconsideration, the DRAS must
- update VTA by entering the date the DRAS sent a new proposed rating decision or a memorandum to an IDES participant’s PEB in the VA RECONSIDERATION RATING END DATE field on the RO/RATING ACTIVITY tab
- complete a one-time clear of
- EP 310 (with the IDES Reconsideration Request – Active Duty claim label) for active duty cases, or
- EP 020 (with the IDES Reconsideration Request – Not on AD claim label) for non-active-duty cases, and
- update VBMS by changing
- the claim level suspense so it expires 30 days in the future, and
- the suspense reason to Awaiting Guidance from: PEB.
Important: If a DRAS prepares a new proposed rating decision, it must also update VTA by selecting one of the following entries from the drop-down box in the REVISED VA RATING RESULTS field on the RO/RATING ACTIVITY tab:
- No change
- Increased evaluation, less than 30% , or
- Increased evaluation, 30% or more.
Note : If an evaluation is increased as a result of a reconsideration request, the percentage in the REVISED VA RATING RESULTS field should indicate the combined percentage for all referred conditions after the change.
X.i.6.H.4.dIdentification of Errors in a Proposed Rating Decision
The table below describes the necessary actions to take when an error is identified in a proposed rating decision.
| If the ... | Then the DRAS must ... |
|---|---|
MSC identifies an error |
|
PEB requests a correction | handle the PEB’s request in accordance with M21-1, Part X, Subpart i, 6.H.4.e and f. |
Note: A DRAS’s failure to address or properly defer a decision on all claimed and referred disabilities is considered an error.
X.i.6.H.4.ePDRRs
When a PEB administrator has questions or concerns about an evaluation assigned on a proposed rating, the PEB may submit a request to the DRAS for clarification or potential correction. Such a request is called a PEB-Directed Rating Returns (PDRR). When submitting a PDRR, the PEB will enter the date in the PEB DIRECTED RATING RETURN START DATE field in VTA and transmit associated documents to the DRAS via the eFolder or DoD SAFE. Note: A PDRR is not considered the participant’s one-time request for reconsideration of a proposed rating decision (as discussed in M21-1, Part X, Subpart i, 6.H.4.a).
X.i.6.H.4.fHandling PDRRs: DRAS Responsibilities
For each PDRR submitted by the PEB (identified by the Pending PDRR report in VTA) the DRAS must:
- evaluate the request to determine if corrective action is needed
- prepare a memo for the PEB explaining the outcome of the PDRR, including any appropriate clarification or explanation required
- prepare a corrected rating and notification letter or BEL (if necessary)
- return the response to the PEB in the manner the request was submitted, and
- enter the date in the PEB DIRECTED RATING RETURN END DATE field in VTA.
Important: The PROPOSED RATING END DATE field in VTA should never be adjusted because of the outcome of a PDRR.
5Exhibit: Benefits Estimate Letter (BEL) for IDES Participants
This topic contains a sample of the various pages and paragraphs that make up a BEL.
Revised September 14, 2016
X.i.6.H.5.aSample BEL
The images displayed below represent a sample BEL.
End of Part X, Subpart i, Chapter 6, Section H