- Privately completed Disability Benefits Questionnaires (DBQs) are an important part of the VA disability claims process. They give veterans the ability to submit non-VA medical evidence in a format that identifies the specific information the VA uses to rate claims. This can be particularly helpful when VA examinations are delayed or when specialized evaluations are needed. Under federal regulation, DBQs completed by licensed professionals are considered competent medical evidence.
- The M21-1 Adjudication Procedures Manual provides internal guidance on how to assess the authenticity of privately completed DBQs. One provision, M21-1, Part IV, Subpart ii, Chapter 3, Section A.1.g, lists several indicators that may warrant further review of a DBQ. One such indicator involves the provider being located more than 100 miles from the veteran’s residence, particularly when the provider claims to have conducted an in person examination or maintains a treatment relationship. However, the guidance does not state that distance alone is a reason to disregard a DBQ. In fact, the same provision emphasizes that privately completed DBQs should generally be accepted at face value.
- If an adjudicator were to rely solely on the provider’s distance from the veteran as a basis for assigning reduced weight to a DBQ, without identifying other concerns such as inconsistencies, unverifiable credentials, or claims of a treatment relationship, this would raise important questions about how the M21-1 guidance is being interpreted. The 100-mile indicator is intended to signal the potential need for additional scrutiny in certain contexts, not to serve as a stand-alone threshold for questioning the validity of a DBQ.
- To support fair adjudication, DBQs should be evaluated based on their content and the qualifications of the provider, rather than on geographic factors alone. Veterans may consider submitting supporting documentation to clarify how and where an exam was conducted when distance might otherwise raise questions. Applying M21-1 guidance in context allows adjudicators to balance the need for accurate evidence review with the VA’s duty to consider all competent, relevant medical evidence submitted by claimants.
If you are having difficulty having your medical evidence considered by the VA or if you need assistance with your claim generally, we may be able to help. Please contact us at (813) 537-6060.
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