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Updated Nov 12, 2024

In This Section
 
This section contains the following:
 

  1.  Handling POA Appointments

Introduction
 
This topic contains information on handling representative appointment forms, including

Change Date
 
September 7, 2022

I.i.2.C.1.a.  When to Process POA Appointment Forms
 
Process representative appointment forms as soon as they are received from the claimant.

I.i.2.C.1.b.  Endorsing a POA Appointment Form as Limited Representation
 
Limited representation by a power of attorney (POA) must be clearly noted in order to prevent a POA’s access to claims folder material that does not relate to the authorized scope of representation.  This includes material that does not pertain to a non-Veteran claimant (such as an apportionee).
  
Use the table below to clearly endorse limited representation appointments.
  
If processing the POA appointment in a(n) …
Then …
paper format
endorse the form as limited.
electronic format
  • add a permanent note in Veterans Benefits Management System (VBMS) indicating the limited appointment of representation, and
  • edit the document’s subject line to read Limited, after the document has been uploaded to the electronic claims folder (eFolder).
Reference:  For more information on changing the subject line of a document in an eFolder, see the VBMS Core User Guide.
  
References:  For more information on

I.i.2.C.1.c.  Acceptable Versions of VA Form 21-22
 
 
The Department of Veterans Affairs (VA) can accept older versions of VA Form 21-22, Appointment of Veterans Service Organization as Claimant’s Representative, until depletion of existing stock in accordance with M21-1, Part II, Subpart i, 2.B.4.  Follow the guidance in M21-1, Part I, Subpart i, 2.C.1.g, for establishment of representation when an outdated version of the VA Form 21-22 is received.
 
Important:
  • Do not establish or change a claimant’s representation, unless the form is complete as described in M21-1, Part I, Subpart i, 2.C.1.e.
  • Always accept older versions of forms submitted via the Stakeholder Enterprise Portal (SEP) and Veterans Online Application (VONAPP) Direct Connect (VDC).  The form versions included in Veterans Benefits Administration (VBA) applications for electronic submission may significantly lag behind the release of new form versions. 
References:  For more information on

I.i.2.C.1.d.  Reviewing a Submitted VA Form 21-22 or VA Form 21-22a
 
Take the following actions when reviewing a VA Form 21-22 or VA Form 21-22a:
Note:  A VA Form 21-22 received as part of an Integrated Disability Evaluation System (IDES) claim must have the word Veteran replaced with Service Member in Block 1.
 
References:  For more information on

I.i.2.C.1.e.  What Constitutes a Complete VA Form 21-22 or VA Form 21-22a
 
Use the table below to determine whether the VA Form 21-22 or VA Form 21-22a is complete.
 
Form Type
Required Information
  • enough information to identify the Veteran/claimant
  • the name of the service organization
  • signature of the Veteran/claimant with a corresponding date of signature, and
  • signature of the representative acting on behalf of the service organization with a corresponding date of signature. 
Note:  All forms received on or after April 22, 2013, require a Veterans service organization (VSO) signature unless otherwise noted in this block.
 
Exceptions: 
  • Regional offices (ROs) are required to accept a VA Form 21-22 with or without the VSO’s signature if received between June 19, 2012 (the date the first revision of the form containing a VSO signature block was released to the public), and April 21, 2013 (the date the first revision of the form containing the VSO signature block was made available in SEP/VDC). 
  • Due to a technical issue, VA Forms 21-22 submitted through SEP/VDC between March 22, 2015, and May 3, 2015, do not show an electronic signature from the Veteran. The forms without an electronic signature from this period remain valid for VA purposes.
Reference:  For more information on requirements for establishment of POA through VDC/SEP, see M21-1, Part II, Subpart iii, 4.B.1.c. 
  • enough information to identify the Veteran/claimant
  • the name of the individual appointed as the Veteran/claimant’s representative
  • identification of the type of representation
    • attorney
    • agent
    • individual providing representation under 38 CFR 14.630 (claimant and representative signatures and the address of the representative must be provided), or
    • service organization representative
  • signature of the Veteran/claimant with a corresponding date of signature, and
  • signature of the individual providing representation on a one time basis, representative of an accredited VSO, agent, or attorney with a corresponding date of signature. 
References:  For more information on
  • representation by an individual to prepare, present, and prosecute one claim, see 38 CFR 14.630, and
  • requirements regarding who can sign on behalf of an individual deemed incompetent, minor, or otherwise incapacitated person without a guardian, see 38 CFR 14.631(a)(1)(iii).
 
Important:  Completion of Blocks 16A and 16B of VA Form 21-22 is optional.  If completed, there is no need to verify that the specific representative listed in Block 16A is accredited.  This form documents the appointment of the entire service organization listed in Block 15 and does not limit action to a specific representative within the organization.
 
Reference:  For more information on signatures by an official representative of the VSO indicating acceptance of the claimant’s appointment, see 38 CFR 14.631.

I.i.2.C.1.f.  Action Required to Revoke or Change POA
 
Take the following actions when a request to revoke POA is received or a new POA is appointed:
The paper form should be annotated with the reason for revocation and the date the revocation is being processed.  Photocopy the annotated form and provide the copy to the former representative.
 
The electronic copy of VA Form 21-22 or VA Form 21-22a must be edited to show that the POA status has been revoked.  Follow the steps in the table below to properly annotate and identify the revoked form in the eFolder.
 
Step
Action
1
Open the electronic copy of the form.
2
Print the document, selecting Adobe PDF as the printer.
3
Open the document in Adobe Acrobat Pro.
4
Click the ADD TEXT function and click inside the box where the revocation reason and date is entered.
5
Type in the reason for revocation and the date it is being processed.
6
Save the document on your desktop.
7
Print a copy of the annotated form and send to the former representative.
8
Upload the annotated document to the eFolder with the following attributes:
 
In the document field …
Enter …
SUBJECT
Revoked.
CATEGORY – TYPE
the same type as the electronic form being revoked.
SOURCE
Veteran.
DATE OF RECEIPT
the same receipt date as the electronic form being revoked.
 
9
Add a note indicating which POA was revoked.
 
Notes: 
  • Only the most recent POA must be notified when their representation has been revoked.  Do not take action to notify prior POAs that were not previously informed of the revocation.
  • Notice of revocation is not required when representation ends due to the death of the beneficiary, however, the POA must be removed from the record.  If the beneficiary is
    • the Veteran (payee code 00), processing the first notice of death (FNOD) is sufficient, as the FNOD command terminates the POA of record, or
    • a non-payee code 00 beneficiary, the POA must be manually removed from the record using VBMS after processing the notice of death.
References:  For more information on

I.i.2.C.1.g.  Handling an Outdated VA Form 21-22 or VA Form 21-22a
 
Send a development letter requesting completion of the current version of the VA Form 21-22 or VA Form 21-22a, when a claimant submits an outdated version of the form.  With the letter
  • provide the current version of the form for completion, and
  • return the outdated form. 
Important:  If the outdated form was received in the Centralized Mail (CM) portal, print a copy of the form, create the development letter, and associate a copy of the development letter and the mail with the eFolder.
   
Reference:  For more information on handling outdated forms, see M21-1, Part II, Subpart i, 2.B.4.

I.i.2.C.1.h.  Handling an Incomplete VA Form 21-22 or VA Form 21-22a
 
Use the procedure below if VA Form 21-22 or VA Form 21-22a is incomplete.
 
If the VSO is …
Then …
located in the same building as the RO
  • forward the form to the VSO for completion, and
  • check all necessary incomplete items on the form.
  • not located in the same building as the RO, and
  • there is an end product (EP) pending
return the incomplete form to the claimant with a letter listing all necessary items on the for completion.
  • not located in the same building as the RO, and
  • there is no EP pending
  • establish an EP 400 Correspondence
  • return the incomplete form to the claimant with a letter listing all necessary items for completion, and
  • clear the EP 400.
 
Important:  If the incomplete form was received in the CM portal, print a copy of the form, take the appropriate action identified in the table above, then associate the mail with the eFolder.
 
Note:  The VBMS development action Form incomplete can be found under the category GENERAL.
 
Reference:  For more information on VBMS development actions, see the VBMS Core User Guide.

I.i.2.C.1.i.  Acknowledging Receipt of VA Form 21-22 or VA Form 21-22a
 
The current versions of VA Form 21-22 or VA Form 21-22a no longer have multiple copies to be acknowledged and sent to the POA or representative. 
 
Upload the form from the CM portal to the eFolder.  No further action to acknowledge receipt of the form is required.
 
Notes: 
  • The documents uploaded from the CM portal are shown in VBMS.
  • The service organization is able to view the eFolder claims for Veterans or claimants they represent. 
  • Veteran Readiness and Employment Service, Education, Insurance, and Loan Guaranty have access to VBMS.

I.i.2.C.1.j.  Unclear Declaration
 
If a private attorney’s declaration of representation is unclear whether it is limited to a certain claim/appeal or unlimited, write to the attorney and ask for clarification.  Reverse-file any such clarification in the claims folder, or upload to the eFolder, whichever is applicable.

I.i.2.C.1.k.  Handling Appointment Forms/Letters When There Is No Record of a Claims Folder
 
Use the table below to handle the receipt of VA Form 21-22, VA Form 21-22a, or the appointment letter when there is no record of a claims folder or a pending claim.
  
If …
Then update the POA and…
the form/letter indicates a claim for benefits administered by another business line
send the form/letter to the appropriate business line as indicated in M21-1, Part II, Subpart i, 2.D.
there is no indication of a claim for benefits being submitted with the form/letter
associate the form/letter with the eFolder after the Veteran is established in the corporate record.
 

I.i.2.C.1.l.  Processing Claims From a POA Without Appointment Forms/Letters
 
For a POA to be authorized to submit claims on behalf of a claimant, there must be an appointment form or letter executed at the time of claim submission.  A claim filed by an accredited representative of a VSO, agent, non-licensed individual, or attorney prior to the completion of the necessary VA Form 21-22, VA Form 21-22a, or appointment letter is invalid and has no legal effect.    
  
Use the table below to determine how to process claim submissions from a POA when the required appointment form/letter is not of record.
  
If …
Then …
the submitted claim form contains the claimant’s signature
accept the submission as a valid claim.
the submitted claim form does not contain the claimant’s signature
process the submission as a request for application under M21-1, Part II, Subpart iii, 2.G.
the RO subsequently receives an appointment form or letter dated on or before the submission of the claim in question
accept the submission as a valid claim.
 
Reference:  For more information on POA authority to submit claims, see M21-1, Part I, Subpart i, 2.A.4.b.

2.  Updating Electronic Systems for POA

Introduction
 
This topic contains information on updating electronic systems for POA, including

Change Date
 
March 4, 2019

I.i.2.C.2.a.  Required System Updates for Changes in POA Appointments
 
The following system updates are required when a claimant appoints a new representative or revokes a current representative: 
  • VBMS, and
  • Veterans Appeals Control and Locator System (VACOLS) (if there is an active legacy appeal pending at the RO).
References:  For more information on

I.i.2.C.2.b.  Updating the POA and POA Permissions in VBMS
 
Use VBMS to reflect the appointment of a POA, as well as the POA’s permission to change a claimant’s address and/or access to a Veteran’s eFolder. 
 
Navigate to the Veteran’s profile and access the POA screen from the VETERAN drop-down menu.  Click the EDIT GENERAL POA button and make the appropriate selections.
 
Important: 
  • Private attorneys accredited by VA and assigned a POA code will be listed under the VSO option, not Private.
  • Do not allow POA access to the Veteran’s eFolder if the claimant has not provided specific authorization to release all records protected by 38 U.S.C. 7332 (including cases where the claimant has provided a limited authorization).
Exception:  When the POA is appointed to assist the claimant on a specific claim (limited representation), open the specific EP from the CLAIMS drop-down menu and click EDIT CLAIM DETAILS.  Select the POA code and update the POA’s authority to change the claimant’s address and/or access the Veteran’s claim folder (as appropriate).
 
References:  For more information on

I.i.2.C.2.c.  Handling Preexisting Representative Relationships

  
When a claimant files a limited declaration of representation with respect to a particular claim or claims, continue any preexisting representative relationship with a VSO, agent, or other licensed attorney with respect to all other claims unless specifically revoked by the claimant. 
 
Note:  Update the EP in VBMS to reflect the limited representation by adding the limited representative’s POA code to the EP(s) for the particular claim(s) covered by the declaration of representation, as indicated in M21-1, Part I, Subpart i, 2.C.2.b.

I.i.2.C.2.d.  Actions to Take When the POA Code Cannot Be Found

  
  
If the POA was …
Then …
found
  • use POA code 099
  • add a VBMS note explaining the situation and actions taken, and
  • follow the procedure in M21-1, Part I, Subpart i, 2.C.3 to have the POA added to the corporate database.
not found
  • add a VBMS note explaining why the POA could not be updated, and
  • forward the information to the Agent and Attorney Fee Coordinator (AAFC) for follow-up with the POA.  No further action is required.
  
Reference:  For more information on the AAFC’s responsibilities in handling non-accredited POA submissions, see M21-5, Chapter 8, Section A.

3.  POA Codes

Introduction

  
This topic contains information on the POA codes, including
Change Date
  
May 2, 2024

I.i.2.C.3.a. General Information on POA Codes

  
Accredited POAs are assigned an alphanumerical code after validation by OGC.  These POA codes are displayed in the
  • corporate record as either alphanumeric codes or by the name of the organization, and
  • Beneficiary Identification and Records Locator Subsystem using the alphanumeric codes prefixed by a zero.
Most state VSO codes are based on the last two digits of the RO number.  Only one number is used when there is more than one RO to a state.  States not listed have no recognized VSO. 
 
Important:  Private attorneys or agents submitting requests to represent a VA claimant must be verified as accredited by OGC, per 38 CFR 14.629. 
 
Reference:  For a list of accredited VSOs, attorneys, and agents, see the OGC Accreditation Search.

I.i.2.C.3.b.  Adding POA Codes to the Corporate Database

  
Data Architecture is responsible for adding new POA codes to the corporate database.  This occurs when a POA is not located in corporate but is found in the OGC Accreditation Search.
 
Follow the procedures in the table below to have the POA added to the corporate database.
 
Stage
Description
1
Report an issue in the YourIT Service Portal and include the
  • POA code
  • name of agent, attorney, or representative
  • role, such as
    • claims agent
    • an attorney, or
    • VSO representative
  • POA’s contact information (address, phone, fax, and e-mail), and
  • a request to route the ticket to the VBA CORP DA team for processing. 
2
Update the claimant’s profile to include POA code 099 as a placeholder until the corporate database is updated.
 
Note:  YourIT will open a trouble ticket to track the issue.  When the POA code has been added to the corporate database, YourIT will notify the employee who submitted the request and close the ticket.
3
Upon receiving the notification of a newly established POA code, the AAFC will
  • contact the individual attorney or agent to identify any other Veterans or claimants they represent
  • verify the validity of the other client’s VA Form 21-22a, and
  • update all records as necessary. 
Note:  Historically, these individuals may have been assigned a 099 (no exclusive contact) or 066 (exclusive contact) code and will not automatically be displayed for the specific attorney in Share, VBMS, or SEP.
 

I.i.2.C.3.c. Updating an Incorrect Private Attorney/Agent Address in the Corporate Database

  
Claims processors that identify a discrepancy between the private attorney/agent mailing address applied by a VA system (VBMS or otherwise) and the representative’s mailing address found on the OGC Accreditation Search must report the discrepancy to Compensation Service.
 
When identified, the claims processor must
Important:  Overriding the system-generated mailing address will only affect the current letter being generated.  The override process will need to be completed on each letter being sent to the representative until the corporate database is updated to reflect the address listed in the OGC Accreditation Search.
 
Reference:  For more information on adding/editing a representative’s address in VBMS Core, see M21-1, Part I, Subpart i, 2.B.1.g.

I.i.2.C.3.d.  National Organization POA Codes Listed Alphabetically

  
The table below lists the POA codes for National VSOs alphabetically.
 
National Organization Name
POA Code
African American PTSD Association
091
American Legion
074
American Red Cross
075
American Veterans/AMVETS
077
Armed Forces Services Corporation
078
Army and Navy Union, USA
079
Blinded Veterans Association
080
Catholic War Veterans of the U.S.A.
081
Dale K. Graham Veterans Foundation
HW0
Disabled American Veterans
083
Fleet Reserve Association
085
Gila River Indian Community Vet and Family Services Office
JVC
Gold Star Wives of America, Inc.
012
Green Beret Foundation
HTC
Italian American War Veterans of the United States, Inc.
095
Jewish War Veterans of the United States
086
Legion of Valor of the United States of America, Inc.
087
Marine Corps League
088
Military Officers Association of America
A21
National Association for Black Veterans, Inc.
084
National Association of County Veterans Service Officers
064
National Law School Veterans Clinic Consortium FYT
National Montford Point Marine Association, Inc.
JLW
National Veterans Legal Services Program
082
National Veterans Organization of America
094
Navajo Nation Veterans Administration IP4
Navy Mutual Aid Association
093
Paralyzed Veterans of America, Inc.
071
Polish Legion of American Veterans, U.S.A.
003
Swords to Plowshares, Veterans Rights Organization, Inc.
043
The Retired Enlisted Association
007
United Spanish War Veterans of the United States
096
United Spinal Association, Inc.
090
Veterans of Foreign Wars
097
Veterans of the Vietnam War, Inc. & The Veterans Coalition 4R4
Veterans of World War I of the U.S.A., Inc.
098
Veterans’ Voice of America J3C
Vietnam Veterans of America
070
The Wounded Warrior Project
00V
 

I.i.2.C.3.e.  National Organization POA Codes Listed Numerically

  
The table below lists the POA codes for National organizations numerically.
 
POA Code 
National Organization Name 
A21 Military Officers Association of America
FYT National Law School Veterans Clinic Consortium
HTC Green Beret Foundation
HW0 Dale K. Graham Veterans Foundation
IP4 Navajo Nation Veterans Administration
J3C
Veterans’ Voice of America
JLW
National Montford Point Marine Association, Inc.
JVC
Gila River Indian Community Vet and Family Services Office
00V
The Wounded Warrior Project
003
Polish Legion of American Veterans, U.S.A
007
The Retired Enlisted Association
012
Gold Star Wives of America, Inc.
043
Swords to Plowshares, Veterans Rights Organization, Inc.
064
National Association of County Veterans Service Officers
070
Vietnam Veterans of America
071
Paralyzed Veterans of America, Inc.
074
American Legion
075
American Red Cross
077
American Veterans/AMVETS
078
Armed Forces Services Corporation
079
Army and Navy Union, USA
080
Blinded Veterans Association
081
Catholic War Veterans of the U.S.A.
082
National Veterans Legal Services Program
083
Disabled American Veterans
084
National Association for Black Veterans, Inc.
085
Fleet Reserve Association
086
Jewish War Veterans of the United States
087
Legion of Valor of the United States of America, Inc.
088
Marine Corps League
090
United Spinal Association, Inc.
091
African American PTSD Association
093
Navy Mutual Aid Association
094
National Veterans Organization of America
095
Italian American War Veterans of the United States, Inc.
096
United Spanish War Veterans of the United States
097
Veterans of Foreign Wars
098
Veterans of World War I of the U.S.A., Inc.
4R4 Veterans of the Vietnam War, Inc. & The Veterans Coalition
 

I.i.2.C.3.f.  State Organization POA Codes Listed Alphabetically

  
The table below lists the POA codes for State organizations alphabetically by State.
 
State
 State Organization Name POA Code 
Alabama Department of Veterans Affairs 022
American Samoa Veterans Affairs Office 067
Arizona Department of Veterans’ Services 045
Arkansas Department of Veterans Affairs 050
California Department of Veterans Affairs 044
Colorado Division of Veterans Affairs 039
Connecticut Department of Veterans’ Affairs 008
Delaware Commission of Veterans Affairs 060
Florida Department of Veterans Affairs 017
Georgia Department of Veterans Service 016
Guam Office of Veterans Affairs 056
Hawaii Office of Veterans Services 059
Idaho Division of Veterans Services 047
Illinois Department of Veterans Affairs 028
Indiana Department of Veterans Affairs E5L
Iowa Department of Veterans Affairs 033
Kansas Commission on Veterans Affairs 052
Kentucky Center for Veterans Affairs 027
Louisiana Department of Veterans Affairs 021
Maine Veterans’ Services 002
Maryland Department of Veterans Affairs 013
Massachusetts Department of Veterans’ Services 4R3
Michigan Veterans Affairs Agency 8FE
Minnesota Department of Veterans Affairs 035
Mississippi Veterans Affairs Board 023
Missouri Veterans Commission 031
Montana Veterans Affairs Division 036
Nebraska Department of Veterans Affairs 034
Nevada Department of Veterans Services 054
New Hampshire Division of Veteran Services 073
New Jersey Department of Military and Veterans’ Affairs 009
New Mexico Veterans’ Service Commission 040
New York Division of Veterans’ Affairs 006
Northern Mariana Islands Veterans Affairs Office 053
North Carolina Department of Military & Veterans Affairs 018
North Dakota Department of Veterans Affairs 037
Ohio Department of Veterans Services 025
Oklahoma Department of Veterans Affairs 051
Oregon Department of Veterans Affairs 048
Pennsylvania Department of Military and Veterans Affairs 010
Puerto Rico Public Advocate for Veterans Affairs 055
Rhode Island Division of Veterans Affairs 004
South Carolina Division of Veterans Affairs 019
South Dakota Department of Veterans Affairs 038
Tennessee Department of Veterans Services 020
Texas Veterans Commission 049
Utah Office of Veterans Affairs 041
Vermont Veterans Affairs Section, Military Department 005
Virgin Islands Office of Veterans Affairs 302
Virginia Department of Veterans Services 014
Washington Department of Veterans Affairs 046
West Virginia Department of Veterans Assistance 015
Wisconsin Department of Veterans Affairs 030
Wyoming Veterans Commission 869
 

I.i.2.C.3.g.  State Organization POA Codes Listed Numerically

  
The table below lists the POA codes for State organizations numerically.
 
POA Code 
State 
State Organization Name 
E5L
Indiana
Department of Veterans Affairs
002
Maine
Veterans’ Services
004
Rhode Island
Division of Veterans Affairs
005
Vermont
Veterans Affairs Section, Military Department
006
New York
Division of Veterans’ Affairs
008
Connecticut
Department of Veterans’ Affairs
009
New Jersey
Department of Military and Veterans’ Affairs
010
Pennsylvania
Department of Military and Veterans Affairs
013
Maryland
Department of Veterans Affairs
014
Virginia
Department of Veterans Services
015
West Virginia
Department of Veterans Assistance
016
Georgia
Department of Veterans Service
017
Florida
Department of Veterans Affairs
018
North Carolina
Department of Military & Veterans Affairs
019
South Carolina
Division of Veterans Affairs
020
Tennessee
Department of Veterans Services
021
Louisiana
Department of Veterans Affairs
022
Alabama
Department of Veterans Affairs
023
Mississippi
Veterans Affairs Board
025
Ohio
Department of Veterans Services
027
Kentucky
Center for Veterans Affairs
028
Illinois
Department of Veterans Affairs
030
Wisconsin
Department of Veterans Affairs
031
Missouri
Veterans Commission
032
Virgin Islands
Office of Veterans Affairs
033
Iowa
Department of Veterans Affairs
034
Nebraska
Department of Veterans Affairs
035
Minnesota
Department of Veterans Affairs
036
Montana
Veterans Affairs Division
037
North Dakota
Department of Veterans Affairs
038
South Dakota
Department of Veterans Affairs
039
Colorado
Division of Veterans Affairs
040
New Mexico
Veterans’ Service Commission
041
Utah
Office of Veterans Affairs
044
California
Department of Veterans Affairs
045
Arizona
Department of Veterans’ Services
046
Washington
Department of Veterans Affairs
047
Idaho
Division of Veterans Services
048
Oregon
Department of Veterans Affairs
049
Texas
Veterans Commission
050
Arkansas
Department of Veterans Affairs
051
Oklahoma
Department of Veterans Affairs
052
Kansas
Commission on Veterans Affairs
053
Northern Mariana Islands
Veterans Affairs Office
054
Nevada
Department of Veterans Services
055
Puerto Rico
Public Advocate for Veterans Affairs
056
Guam
Office of Veterans Affairs
059
Hawaii
Office of Veterans Services
060
Delaware
Commission of Veterans Affairs
067
American Samoa
Veterans Affairs Office
073
New Hampshire
Division of Veteran Services
4R3 Massachusetts Department of Veterans’ Services
869
Wyoming
Veterans Commission
8FE
Michigan
Veterans Affairs Agency