Caseflow: AMA Intake | 21-22a Intake - Limited POA

[shanear]

We need to support issue-based POAs for all AMA review types. The "21-22a" form is the mechanism veterans will use for designating a POA for a specific issue(s).

For appeals, we will need to process this form and store the issue based POA however the queue team decides we should do it.

For HLRs and SCs, we need to be able to process this form because they will need to split an EP into two EPs if a veteran requests a POA for only some of the issues on their review. We will need to maintain the links between these EPs and the review in Caseflow, and there is not a good way to do this in VBMS alone.

Lets begin investigating what it would take for Intake to be responsible for intaking the 21-22a too.

Mural for how it should work in Queue:
https://app.mural.co/t/workqueue2001/m/workqueue2001/1524163475348/3f583e97fd628f81eb05d516c829d3aced02fd57

Notes

• It is possible to change the "Limited POA" for EPs in VBMS. However, this requires changing each EP individually.
• @laurjpeterson is it possible to change the "Limited" (appeal based) POA on appeals in Caseflow?

Open Questions

• We need to ask AMO who should be responsible for processing this form and if there is an SOP for it.

requires https://github.com/department-of-veterans-affairs/ruby-bgs/issues/58

[shanear]

Had a meeting with @amprokop and @laurjpeterson yesterday where we aligned on the plan in the mural.

[suzchap]

Starting to wrap my head around this and have some basic questions... maybe @laurjpeterson knows?

1. Are we incorporating 21-22 and 21-22a or just 21-22a?

2. If a Veteran wants to apply a POA to just one issue out of multiple, how do we know which issue? I don't see a way to specify this on either the 21-22a or on the AMA forms.

[amprokop]

1. will require a manual step. Intaking the 21-22a probably will require a
   staff member to look at issues on open appeals and decide what to apply it
   to.

On Thu, Aug 16, 2018 at 16:52 Suzanne Chapman [e-mail]
wrote:

Starting to wrap my head around this and have some basic questions...
maybe @laurjpeterson https://github.com/laurjpeterson knows?

1.

Are we incorporating 21-22 and 21-22a or just 21-22a?
2.

If a Veteran wants to apply a POA to just one issue out of multiple,
how do we know which issue? I don't see a way to specify this on either the
21-22a or on the AMA forms.

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[laurjpeterson]

1. Just the 21-22a.
2. I agree with Alex's response, based on what we know now. Honestly, it seems hard to do! Since BVA folks process form 21-22a's today, perhaps this is something we could do some research on / ask how they currently know which issues have another POA based on the form.

[suzchap]

Thanks to you both for quick responses!

1. Ah so it sounds like there's nowhere that we know of where the Veteran would specify X issue should be connected to Y POA. Yes, we should do some research on that. Who should I ask about that -- or are you going to ask @laurjpeterson?

[amprokop]

One more suggestion: I'd love to pursue a solution here that works for both
AMA and legacy appeals, if possible. In my fuzzy imagined scenario where
Caseflow Intake handles 21-22a forms, there are a few possibilities:

1. Save the 21-22a information in the Caseflow DB and then display it on
   the Case Details page for every AMA/legacy appeal with that appellant
2. Allow the staff member to immediately associate 21-22a rep choice with
   specific issues on AMA/legacy appeals (which then may trigger an appeal
   split)

I could also envision something like 1. is the first pass at 22-21a
handling, and 2. is the second pass.

Just some unvetted thoughts here :)

On Fri, Aug 17, 2018 at 09:51 Suzanne Chapman [e-mail]
wrote:

Thanks to you both for quick responses!

1. Ah so it sounds like there's nowhere that we know of where the
   Veteran would specify X issue should be connected to Y POA. Yes, we should
   do some research on that. Who should I ask about that -- or are you going
   to ask @laurjpeterson https://github.com/laurjpeterson?

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[amprokop]

Oh, super sorry to just spew words here— just one more thought that I've
verbalized a few times but never written down on GitHub — one scenario that
I think is crucial to correctly handle:

1. Veteran starts an appeal for PTSD with American Legion as the
   representative
2. Veteran submits a 21-22a stating "Attorney B will represent me for all
   mental health-related issues"
3. Veteran starts an appeal for another mental health issue

How do we ensure that Attorney B, rather than American Legion, is
representing the Veteran for both appeals?

On Fri, Aug 17, 2018 at 1:59 PM, Alex Prokop [e-mail] wrote:

One more suggestion: I'd love to pursue a solution here that works for
both AMA and legacy appeals, if possible. In my fuzzy imagined scenario
where Caseflow Intake handles 21-22a forms, there are a few possibilities:

1. Save the 21-22a information in the Caseflow DB and then display it on
   the Case Details page for every AMA/legacy appeal with that appellant
2. Allow the staff member to immediately associate 21-22a rep choice with
   specific issues on AMA/legacy appeals (which then may trigger an appeal
   split)

I could also envision something like 1. is the first pass at 22-21a
handling, and 2. is the second pass.

Just some unvetted thoughts here :)

On Fri, Aug 17, 2018 at 09:51 Suzanne Chapman [e-mail]
wrote:

Thanks to you both for quick responses!

1. Ah so it sounds like there's nowhere that we know of where the
   Veteran would specify X issue should be connected to Y POA. Yes, we should
   do some research on that. Who should I ask about that -- or are you going
   to ask @laurjpeterson https://github.com/laurjpeterson?

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[nicholasholtz]

@amprokop The sitaution you described here https://github.com/department-of-veterans-affairs/caseflow/issues/6206#issuecomment-413944714 shouldn't happen.

First, the 21-22a is limited to a particular claim (or appeal):

Per 38 CFR s 14.630, it is not permissible to make an individual a rep for a category of current and future disabilities:

§14.630 Authorization for a particular claim.
(a) Any person may be authorized to prepare, present, and prosecute one claim.

This ^ is not changed in the proposed draft regs.

[nicholasholtz]

Also, you will never see a situation where an entire VSO is appointed pursuant to a 21-22a. This is also due to 38 CFR s 14.630, and what is on the form. The form 21-22a is solely for the appointment of an individual:

And, as s 14.630 says, it limits it to a "person" to represent on a single claim.

Now, you may see a situation where a single person from a different VSO is appointed for a particular claim. Imagine this scenario:

I have an appeal for issues A and B. I am represented by DAV. However, I decide that I want my good buddy @amprokop, who works for, say, VFW, to represent me for issue B. I could file a 21-22a and identify @amprokop as the individual in box 7a and note in box 7b that he is a VSO rep from VFW:

@laurjpeterson FYI

[amprokop]

Aha! Thanks for the correction, Nicholas.

On Fri, Aug 17, 2018 at 4:19 PM, nicholas holtz [e-mail]
wrote:

Also, you will never see a situation where an entire VSO is appointed
pursuant to a 21-22a. This is also due to 38 CFR s 14.630, and what is on
the form. The form 21-22a is solely for the appointment of an individual
:
[image: image]
https://user-images.githubusercontent.com/16781398/44286906-b7c7e800-a238-11e8-81d9-1656002213ac.png

And, as s 14.630 says, it limits it to a "person" to represent on a single
claim.

Now, you may see a situation where a single person from a different VSO is
appointed for a particular claim. Imagine this scenario:

I have an appeal for issues A and B. I am represented by DAV. However, I
decide that I want my good buddy @amprokop https://github.com/amprokop,
who works for, say, VFW, to represent me for issue B. I could file a 21-22a
and identify @amprokop https://github.com/amprokop as the individual in
box 7a and note in box 7b that he is a VSO rep from VFW:

[image: image]
https://user-images.githubusercontent.com/16781398/44286986-168d6180-a239-11e8-9aec-bdb2d2796c30.png

@laurjpeterson https://github.com/laurjpeterson FYI

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[amprokop]

In that case, we can just apply the 21-22a representative directly to an
issue.

On Fri, Aug 17, 2018 at 6:27 PM, Alex Prokop [e-mail] wrote:

Aha! Thanks for the correction, Nicholas.

On Fri, Aug 17, 2018 at 4:19 PM, nicholas holtz [e-mail]
wrote:

Also, you will never see a situation where an entire VSO is appointed
pursuant to a 21-22a. This is also due to 38 CFR s 14.630, and what is on
the form. The form 21-22a is solely for the appointment of an
individual:
[image: image]
https://user-images.githubusercontent.com/16781398/44286906-b7c7e800-a238-11e8-81d9-1656002213ac.png

And, as s 14.630 says, it limits it to a "person" to represent on a
single claim.

Now, you may see a situation where a single person from a different VSO
is appointed for a particular claim. Imagine this scenario:

I have an appeal for issues A and B. I am represented by DAV. However, I
decide that I want my good buddy @amprokop https://github.com/amprokop,
who works for, say, VFW, to represent me for issue B. I could file a 21-22a
and identify @amprokop https://github.com/amprokop as the individual
in box 7a and note in box 7b that he is a VSO rep from VFW:

[image: image]
https://user-images.githubusercontent.com/16781398/44286986-168d6180-a239-11e8-9aec-bdb2d2796c30.png

@laurjpeterson https://github.com/laurjpeterson FYI

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[shanear]

Confirmed with AMO that the 21-22a is the only way to set a "Limited POA" (claim based POA)