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Updated Apr 13, 2022

In This Section
This section contains the following topics:
Topic
Topic Name
1
2

1.  General Information on Veteran Status Based on Merchant Marine Service

Introduction
This topic contains general information on Veteran status based on Merchant Marine service, including

Change Date

 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 Discharge or Release from Active Duty, 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

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).

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. 11201–11204.

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 website at www.uscg.mil/nmc/.

2.  Merchant Marine Service Verification Required for a VA Claim

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

Change Date

 September 21, 2018

X.i.5.A.2.a.  Forms Required for a Merchant Marine Claim
Notify the claimant that benefits may not be paid without a discharge document.
  • If there is a Veterans Assistance Discharge System (VADS) record or other evidence of Merchant Marine service, inform the claimant that VA cannot pay benefits until the claimant provides a DD Form 214 or DD Form 1300. Assist the claimant by developing the claim pending receipt of a discharge document.
  • If there is no evidence of Merchant Marine service, 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.
Notes:
  • If there is a VADS record or a discharge document, establish a claim.  Otherwise, send an information letter under end product 400.
  • 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.  Correct Voyage Entries and Release Dates on DD Form 214
The DD Form 214 issued should show the
  • entered on date as December 7, 1941, or the date of the earliest voyage, and
  • released from active duty (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.c.  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.
Note:  A DD Form 1300 is valid even without pay grade information or a Social Security number (SSN).

X.i.5.A.2.d.  Establishing a Merchant Marine Claim
During claims establishment, update the corporate record by entering the beginning and ending dates of the three earliest voyages, unless the claim was established based on a VADS 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, enter the three longest voyages.
Reference:  For more information on establishing a claim based on a VADS entry, see M21-1, Part X, Subpart i, 5.A.2.a.

X.i.5.A.2.e.  VADS Entries Prior to January 1, 2015
Prior to January 1, 2015, the Department of Defense (DoD) sent paper copies of DD Forms 214 to the VADS unit at the Austin Data Processing Center.
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.
Important:  For paper copies of DD Forms 214 sent to the VADS unit prior to 2015, it is not necessary to clarify the separation reason code if it is DEV.  Consider the service satisfactory unless other evidence of record reveals otherwise.
If SAT is shown in Item 26, SEPARATION CODE, on a paper copy of the DD Form 214, 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.  VADS Entries Beginning January 1, 2015
Beginning on January 1, 2015, DoD terminated the practice of sending paper copies of DD Form 214 and began electronically transmitting pertinent discharge data to the VADS unit at the Austin Data Processing Center.
If it is apparent that discharge data for Merchant Marine service was transmitted to VADS on or after January 1, 2015, then proper development for the separation reason code is required if it is not satisfactory service, or SAT.
Note:  If using a paper copy of DD Form 214 to verify service, and SAT is shown in Item 26, SEPARATION CODE, 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.g.  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.b.