Proposed Changes to VA Form 10182: Notice of Disagreement
Document text
Page 1
Wesley A. McCauley
Admitted to the United States Court of
Appeal for Veterans Claims
Putting veterans and their families in charge ®
2025-December-11
VIA: DIRECT UPLOAD TO REGULATIONS.GOV
U.S Department of Veterans’ Affairs
Office of Information Technology, Data Governance and Analytics
c/o Dorothy Glasgow
Acting, VA PRA Clearance Officer
810 Vermont Avenue, N.W.
Washington, D.C. 20420
Re: Public Comments Concerning
F.R. Doc. No. 2025-21703; OMB Control No. 2900-0674
Dear Sir/Madame:
United Veteran’s Disability, LLC provides these comments in response
to the proposed collection of certain information by the VA concerning VA Form
10182, Decision Review Request: Board Appeal (Notice of Disagreement).
United Veteran’s Disability, LLC is a Veteran’s advocacy firm owned by
a VA accredited agent. Our office frequently provides representation before the
Wesley@unitedforvets.com 100 North Patterson Street
Phone: (229) 270-1571 Page 1 of 3 Suite 52
Unitedforvets.us Valdosta, Georgia 31601
Page 2
Board of Veterans’ Appeals, which entails completing VA’s Notice of
Disagreement form.
We fully support removal of the checkbox from Part III, number 11,
which states: “Check here if you are appealing a denial of benefits by the
Veterans Health Administration (VHA).” We agree that this adds a burden to
the appellant that serves little to no value to the Board.
We further fully support creation of a checkbox enabling the appellant
to waive their right to switch dockets, in accordance with Williams v.
McDonough, 37 Vet. App. 305, 310-311 (2024). Currently, the Board has
developed a “VLJS Docket Switch Waiver Letter” which it routinely sends to
appellants, requesting a waiver of their right to change dockets. This has
increased the administrative burden on the Board. It also adds delay in the
adjudication of appeals, especially for cases that have been advanced on the
Board’s docket. Often times, our office has waived the right to change dockets
in advance, concurrently with the Notice of Disagreement, but BVA staff
nonetheless solicit for a waiver. This is creating unnecessary work for the
Board and Appellants.
In sum, enabling appellants to waive their right to change dockets in
accordance with Williams as part of their Notice of Disagreement will not only
reduce the burden on the Board, but it will also enable appellants to obtain a
decision from the Board faster. We thus fully support this proposed
amendment.
Page 2 of 3
Page 3
Lastly, our office strongly suggests a continuation page be added for Part
II, section A (Specific Issue(s)). This would enable appellants to list issues
better, as it is not uncommon for a NOD to contain more than five issues.
Thank you for your consideration of these comments. Should you require
additional information, please do not hesitate to contact us.
Godspeed,
Wesley A. McCauley
Chief Executive Officer
POA I9A; Accreditation Number 50884
“The veterans benefit system is designed to award ‘entitlements to a
special class of citizens, those who risked harm to serve and defend their
country’. This entire scheme is imbued with special beneficence from a grateful
sovereign”, Barrett v. Principi 363 F.3d 1316, 1320 (Fed. Cir. 2004).
Page 3 of 3