Starting a VA Claims Agent Practice: Your First 90 Days

A new VA claims agent practice needs six things in its first 90 days: a record of your accreditation date and the deadlines that run from it, a first-year CLE course on the calendar, a fee agreement that meets 38 C.F.R. § 14.636(g), a clean process for the 21-22a and the claims file, a deadline list kept by issue, and a place to keep client records safely. Most of it is set up once and reused on every case.

This is a practice-setup guide written for agents who have just been accredited, including those who sat VA's August 25, 2026 examination. It is not legal advice, and the regulations' own text controls. The author is not a VA-accredited representative; VA Claim Commander is software and does not represent veterans.

Days 1 to 7: the accreditation paperwork

Your accreditation notice is the start date for most of your standing obligations, so keep it where you can find it.

• Save the notice and its date. Under 38 C.F.R. § 14.629, the notification of accreditation is your authority to prepare, present, and prosecute claims before an agency of original jurisdiction or the Board (§ 14.629(d)). The CLE deadlines below are counted from the date of initial accreditation.
• Check your listing. Look yourself up in VA's Accreditation Search, linked from the OGC accreditation page. Claimants and VA staff use it, and your 21-22a has to match it.
• Calendar the annual certification. Each year you report every court, bar, or federal or state agency where you are admitted to practice, with identification numbers, and certify good standing. Any change in that status has to be reported within 30 days (§ 14.629(b)(4)).
• Read the standards of conduct once, closely. 38 C.F.R. § 14.632 requires competent representation, defined as "the knowledge, skill, thoroughness, and preparation necessary for the representation," and reasonable diligence and promptness, including responding promptly to VA requests for information (§ 14.632(b)). It prohibits, among other things, delaying a claim without good cause and disclosing information VA provided for representation without the claimant's authorization (§ 14.632(c)). Accreditation can be canceled for violating them (§ 14.633).

Days 1 to 30: schedule the first-year CLE

Under § 14.629(b)(1)(iii), you need 3 hours of state-bar-approved CLE within the first 12 months after initial accreditation, covering representation before VA, claims procedures, basic eligibility, the right to appeal, disability compensation, dependency and indemnity compensation, and pension. Then 3 more hours on veterans benefits law and procedure no later than 3 years after accreditation, and every 2 years after that (§ 14.629(b)(1)(iv)).

Book the first course early. It is the one deadline in your first year that has nothing to do with a client, so it is the easiest to let slide. You certify completion in writing to the Office of the General Counsel with the course title, date and time, and provider. The details are in VA CLE requirements for claims agents.

Days 1 to 30: decide how you will charge

Fees shape which cases a new practice can take, so settle this before the first client.

• When a fee can attach. Under § 14.636(c)(1)(i), an agent may charge only for representation provided after the agency of original jurisdiction issues notice of an initial decision on the claim. Preparing and filing an original claim is not billable to the claimant under that rule. In practice, a new agent's paid work is supplemental claims, higher-level reviews, and Board appeals after a decision.
• What the agreement must say. It must be in writing, signed by both of you, and include the veteran's name, the claimant's name if different, any disinterested third-party payer, the VA file number, and the specific terms for determining the fee. It must clearly say whether VA is to pay you directly from past-due benefits (§ 14.636(g)).
• Filing. A copy goes to VA within 30 days of signing: a direct-pay agreement to the agency of original jurisdiction, any other agreement to the Office of the General Counsel (§ 14.636(g)(3)).
• Direct pay. VA withholds and pays the fee directly only if it does not exceed 20 percent of past-due benefits and is contingent on a favorable result, among other conditions, and VA takes an assessment of 5 percent of the fee, capped at $100 (§ 14.636(h)).
• Reasonableness. A fee of 20 percent or less is presumed reasonable when your representation continued through the award; a fee above 33 1/3 percent is presumed unreasonable (§ 14.636(f)(1)).

Write one template agreement now and have every element checked against the regulation. The full walk-through is in VA fee agreements for accredited agents and attorneys, and the free fee agreement checklist runs through each element.

Days 15 to 60: your first case, in order

The first case teaches you the order of work. A sequence that holds up:

1. 1The appointment. File VA Form 21-22a, signed by the claimant and by you. Without your signature the appointment is invalid, and VA recognizes only one representative on a claim at a time (§ 14.631). Before it is signed, walk the claimant through the authorization for records protected by 38 U.S.C. § 7332; without it, those records are withheld from you.
2. 2The fee agreement, signed the same day if you are charging, and filed within 30 days.
3. 3The claims file. Request a copy on VA Form 20-10206, or ask for read-only electronic access under §§ 1.600 through 1.603. See how to get a client's C-file as a representative.
4. 4The decision. Read the decision you are challenging issue by issue: what was granted, what was denied, the reasons given, and the evidence VA listed. Note the date VA issued notice of the decision, because the review deadlines run from it (§ 3.2500).
5. 5The file review. Work outward from the decision through the evidence that matters to each denied issue. See how to review a VA C-file.
6. 6The lane. Choose for each issue between a supplemental claim with new and relevant evidence, a higher-level review on the same record, or a Board appeal. See choosing a review lane.
7. 7The argument and the filing. Draft the rebuttal from the decision's own reasons, assemble the evidence, and file on the right form: 20-0995, 20-0996, or 10182. See how to write a rebuttal to a VA denial.
8. 8The diary. Record what was filed, when, and how VA confirmed it. If your representation is ever questioned, this is the record you will reach for.

Days 30 to 90: build the deadline list by issue

Keep deadlines by issue, not by client. One veteran can have several decisions on file, each with its own one-year clock. The clocks a new practice needs from the start:

Put C&P exam dates on the same calendar. A missed exam can decide a claim. The free appeal deadline calculator counts the review windows from a decision date.

Days 30 to 90: records, confidentiality, and tools

A claims file holds medical records, Social Security numbers, and service history, and § 14.632(c) bars disclosing information VA provided for representation without the claimant's authorization. Before you hold your first file, decide:

• Where client files live, who can open them, and whether they are encrypted when stored.
• What you send to outside tools, including AI tools. Read the vendor's terms on storage, retention, and model training before any client information goes in. See using AI in a VA practice.
• What happens when representation ends. Keep a record of what you returned or retained, and when.

On tools: a new agent with five cases can run on a spreadsheet, a document folder per veteran, and a calendar. The point to switch is usually when deadlines on second and third issues start hiding, or when reading claims files of thousands of pages becomes the bottleneck. How to choose VA claims software has a neutral checklist and the questions to ask any vendor.

What not to do in year one

• Charge for work done before notice of the initial decision.
• File a fee agreement late, or with the wrong office.
• Let a 21-22a go in with only the claimant's signature.
• Track one deadline per client and miss the second issue's clock.
• Paste client records into a tool whose terms you have not read.
• Let the first-year CLE slip past 12 months. Accreditation is canceled when a § 14.629 requirement is no longer met (§ 14.633(b)).

Frequently asked questions

What should a new VA claims agent do first?

Save the accreditation notice and its date, confirm your listing in VA's Accreditation Search, put the first-year CLE and the annual certification on your calendar, read the standards of conduct in 38 C.F.R. § 14.632, and write a fee agreement template that meets § 14.636(g) before you take the first client.

When can a new VA claims agent start charging fees?

Only for representation provided after VA issues notice of the initial decision on the claim, under a written fee agreement signed by both parties and filed within 30 days (38 C.F.R. § 14.636(c) and (g)). Work on an original claim before that decision is not billable to the claimant under the rule.

How soon does a new claims agent need CLE?

Within the first 12 months after initial accreditation: 3 hours of state-bar-approved CLE covering the topics § 14.629(b)(1)(iii) lists. The next 3 hours are due no later than 3 years after accreditation, then every 2 years.

How does a new agent get a client's claims file?

File a VA Form 21-22a signed by the claimant and the agent, then request a copy of the file on VA Form 20-10206 or ask the regional office for read-only electronic access under 38 C.F.R. §§ 1.600 through 1.603. Check the 38 U.S.C. § 7332 authorization on the 21-22a first, or protected records will be withheld.

Does a new VA claims agent need practice management software?

Not on day one. A small caseload can run on a spreadsheet, a folder per veteran, and a calendar kept by issue. Software starts to pay for itself when deadlines on older issues get hard to see or when reading large claims files takes most of the week.