View Information Collection Request (ICR) Package
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View ICR - Agency Submission
COMMENT
Time Remaining
Days
HR
Min
Sec
OMB Control No:
2900-0674
ICR Reference No:
202509-2900-010
Status:
Received in OIRA
Previous ICR Reference No:
202502-2900-012
Agency/Subagency:
VA
Agency Tracking No:
2900-0674
Title:
Notice of Disagreement (NOD)/Appeal to the Board of Veterans' Appeals
Type of Information Collection:
Revision of a currently approved collection
Common Form ICR:
No
Type of Review Request:
Regular
Date Submitted to OIRA:
03/04/2026
Requested
Previously Approved
Expiration Date
36 Months From Approved
04/30/2028
Responses
110,000
119,800
Time Burden (Hours)
55,000
60,305
Cost Burden (Dollars)
0
0
Abstract:
Appellate review of the denial of VA benefits may only be initiated by filing a Notice of Disagreement with the Board. 38 U.S.C. 7105(a). The VA Form 9, "Appeal to Board of Veterans' Appeals," is required to complete a legacy appeal to the Board. The completed form becomes the "substantive appeal" (or "formal appeal"), which is required by 38 U.S.C. 7105(a) and (d)(3) in order to complete an appeal to the Board. Additionally, the proposed information collections allow for withdrawal of services by a representative, requests for changes in hearing dates and methods under 38 U.S.C.7107, and motions for reconsideration pursuant to 38 U.S.C. 7103(a).
Authorizing Statute(s):
US Code:
38 USC 7103(a)
Name of Law: Reconsideration; correction of obvious errors
US Code:
38 USC 7104(e)(2)
Name of Law: Jurisdiction of the Board
US Code:
38 USC 7105(a) and (d)(3)
Name of Law: Filing of notice of disagreement and appeal
US Code:
38 USC 7107
Name of Law: Appeals; dockets; hearings
Citations for New Statutory Requirements:
None
Associated Rulemaking Information
RIN:
Stage of Rulemaking:
Federal Register Citation:
Date:
Not associated with rulemaking
Federal Register Notices & Comments
60-day Notice:
Federal Register Citation:
Citation Date:
90 FR 55244
12/01/2025
30-day Notice:
Federal Register Citation:
Citation Date:
91 FR 8313
02/20/2026
Did the Agency receive public comments on this ICR?
Yes
Number of Information Collection (IC) in this ICR:
1
IC Title
Form No.
Form Name
Decision Review Request: Board Appeal (Notice of Disagreement)
10182
Decision Review Request: Board Appeal (Notice of Disagreement)
Motions for Reconsideration
Requests for Change to Hearing Dates or Methods
VA Form 9 (Legacy)
VA Form 9
Appeal to Board of Veterans' Appeals
Withdrawal of Services by Representative
ICR Summary of Burden
Total Request
Previously Approved
Change Due to New Statute
Change Due to Agency Discretion
Change Due to Adjustment in Estimate
Change Due to Potential Violation of the PRA
Annual Number of Responses
110,000
119,800
0
0
-9,800
0
Annual Time Burden (Hours)
55,000
60,305
0
0
-5,305
0
Annual Cost Burden (Dollars)
0
0
0
0
0
0
Burden increases because of Program Change due to Agency Discretion:
No
Burden Increase Due to:
Burden decreases because of Program Change due to Agency Discretion:
No
Burden Reduction Due to:
Short Statement:
Because the Board is seeking to add a checkbox and remove a checkbox, it is estimated that a respondent’s burden would be unchanged by the requested revisions. The estimates are consistent with those provided in the previously approved collection, because the requested changes to the VA Form 10182 do not add any additional burden to the processing of the form. Rather, the checkbox will eliminate the need to delay issuing decisions in appeals that are otherwise ready for adjudication and send appellants letters of clarification, thereby decreasing the overall administrative burden caused by Williams, supra. The estimated burden hours and estimated number of respondents are those who will use the VA Form 10182. The previously approved collection included estimates for the use of additional forms, including the VA Form 9, which are not being revised at this time.
Annual Cost to Federal Government:
$5,175,500
Does this IC contain surveys, censuses, or employ statistical methods?
No
Does this ICR request any personally identifiable information (see
OMB Circular No. A-130
for an explanation of this term)? Please consult with your agency's privacy program when making this determination.
No
Does this ICR include a form that requires a Privacy Act Statement (see
5 U.S.C. §552a(e)(3)
)? Please consult with your agency's privacy program when making this determination.
No
Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]?
No
Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]?
No
Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)?
No
Is this ICR related to the Pandemic Response?
No
Agency Contact:
Michaelangelo Nanez 202 382-2785 michael.nanez@va.gov
Common Form ICR:
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(a) It is necessary for the proper performance of agency functions;
(b) It avoids unnecessary duplication;
(c) It reduces burden on small entities;
(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;
(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
(f) It indicates the retention periods for recordkeeping requirements;
(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.
(i) It uses effective and efficient statistical survey methodology (if applicable); and
(j) It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Certification Date:
03/04/2026
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