Agency Information Collection Activity: Application for Disability Compensation Benefits (VA Form 21-526EZ)

## Comment on the Proposed Simplification of VA Form 21-526EZ Re: Agency Information Collection Activity: Application for Disability Compensation Benefits (VA Form 21-526EZ) Docket ID: VA-2026-VACO-0001 OMB Control No. 2900-0747; 91 FR 37497 (June 23, 2026); FR Doc. 2026-12555 Submitted via Regulations.gov August 2026 To the Veterans Benefits Administration: The Veteran Benefit Desk is an independent publication founded by a veteran. We document how VA disability compensation works in practice, we track VA form versions, and we publish research built from FOIA records and VA's own data. We know Form 21-526EZ well, and we know the veterans who struggle with it. This comment responds to the notice at 91 FR 37497 [1] and to the questions VA asked under the Paperwork Reduction Act [2]. First, credit where it is due. Shortening this form from 15 pages to 5, and the average completion time from 25 minutes to 15, is a worthwhile goal [3]. Nearly two million people file this form every year [4]. For many of them it is their first contact with the claims system, and they are doing it without help. If VA gets this right, it matters more than almost any other paperwork change the agency could make. But we want to be direct about the risk. A shorter form is not automatically an easier form. Much of the current form's length is not waste. It is the explanation that keeps a veteran from filing the wrong kind of claim, missing an effective date, or making an election that costs them money. If the redesign cuts pages by cutting that explanation, veterans will not spend less time on their claims. They will spend more time confused, in the wrong lane, or fixing mistakes after the fact. Our recommendations, in short: 1. Publish the proposed new form so the public can actually review it. 2. Let veterans mark what type of claim they are making for each condition. 3. Keep secondary claims understandable. 4. Simplify the toxic exposure questions by using data VA already has, not by deleting them. 5. Keep new claims and claims for increase clearly separate. 6. Do not lose the evidence notice the current form delivers. 7. Keep the warnings about retired pay and separation pay. 8. Keep the roadmap to other forms and to intent to file. 9. Show how the 15 minute estimate was tested. 10. Measure accessibility on its own, not through page count. 11. Keep clearly labeled copies of the old versions. ## 1. Publish the proposed form The notice describes the burden reduction as already done. It says burden "has decreased" because the form went from 15 pages to 5 [3]. But the proposed five page form is not in the docket materials we could locate [5]. That leaves the public in a strange position: VA is asking whether the collection is clear and useful [2], and the public cannot read the document it is being asked about. We ask VA to post the draft form, ideally with a comparison against the current version, and give people a real chance to react before it is final. ## 2. Let veterans mark the type of claim Anyone who has sat with the current form knows where it gets hard: the part where you list each condition and explain how it relates to your service. Veterans who know the system understand that "how it relates" means picking a theory. Direct. Secondary. Presumptive. Aggravation. An increase. Compensation under 38 U.S.C. 1151. Veterans who are new to the system do not know those categories exist. So give them a checklist. For each condition, let the veteran mark one: it happened in service; it was caused or made worse by a condition VA already service connected [6]; the law presumes it from exposure or where they served [7]; it existed before service and service itself made it worse; it is already service connected and has gotten worse; it was caused by VA care under 38 U.S.C. 1151 [8]; or they are not sure. That one change makes the form shorter and clearer at the same time, and it hands VA better routing information the moment the claim arrives. ## 3. Keep secondary claims understandable Secondary claims are hard for someone filing for the first time, because the veteran is not saying the condition started in service. The claim is that one service connected condition caused or worsened another, like a knee that gave out because a service connected ankle changed the way they walk [6]. The current instructions include a secondary claim example that does real work. If that example does not survive the cut, another clear explanation needs to take its place. ## 4. Simplify toxic exposure the right way The current form walks through Gulf War hazards, herbicides, asbestos, mustard gas, radiation, and Camp Lejeune water. It is long because the law is long. But for many of these claims, VA and the Defense Department already hold service, deployment, and location records that bear on exposure. We have pulled VBA's monthly PACT Act decision data through FOIA: more than three and a half million decisions since August 2022, including more than a million denials [9]. At that volume, every confusing exposure question gets multiplied two million times a year. The way to shorten this section is to prefill or verify what the government already holds, wherever those records are reliable and sufficient, and ask the veteran only for what the veteran alone knows. Deleting questions does not remove the confusion. It just moves it from the form to the phone line. ## 5. Keep new claims and increases separate This one form covers both a first claim and a request for a higher rating [1]. Those are different situations. A veteran whose service connected knee has gotten worse should not have to figure out how to say that in a table built for new conditions. The claim type checklist above fixes this at almost no cost in space. ## 6. Do not lose the evidence notice The first pages of the current 21-526EZ are not really the application. They are the notice VA is required by law to give every claimant about what evidence is needed and who is responsible for getting it [10]. If those pages are removed to hit a page target, the legal duty does not go away, and neither does the veteran's need to know what to submit. VA should say plainly where that notice will live under the new design: in the form, in a companion sheet, or on screen before filing. Silence on this point would be a real problem. ## 7. Keep the money warnings The sections about military retired pay, separation pay, and severance pay look like padding. They are not. The elections behind them run into the waiver and concurrent receipt rules [11], and getting them wrong costs veterans real money that is painful to unwind. Shorten the explanation if needed, but keep a clear warning in front of the veteran at the moment they make the choice. ## 8. Keep the roadmap, including intent to file The current form tells veterans when they need a different or additional form: unemployability, dependents, adapted housing, Aid and Attendance, certain mental health claims. It also points to intent to file, which can lock in an earlier effective date while the veteran gathers evidence [12]. Mistakes about effective dates can cost a veteran substantial retroactive benefits and can be difficult to correct after filing. All of this guidance can shrink to one tight list instead of pages of prose, and the online version can surface it automatically based on the veteran's answers. But it has to survive somewhere the veteran will actually see it before filing. ## 9. Show the homework on the 15 minute estimate Fifteen minutes may be accurate for a veteran filing one straightforward condition. It is hard to believe for a veteran filing six conditions on three different theories. The PRA requires burden estimates to be supportable and forms to be written in plain, coherent, and unambiguous terminology [13]. So show the testing. Who was in the room? How many were filing for the first time? How many had no representative? How many were older, or used the paper version, or have visual or cognitive disabilities? If the testers were mostly people who already know the claims system, the number is not telling VA what it thinks it is telling them. ## 10. Measure accessibility on its own The notice promises to preserve accessibility across VA.gov and paper [1]. Good. Make that a measured requirement under Section 508 [14]: screen reader compatibility, properly tagged fillable fields, sensible navigation, readable type and contrast. A 5 page form a veteran cannot use is worse than a 15 page form they can. ## 11. Keep the old versions findable We run a free Form Version Checker because outdated VA forms keep circulating online, and filing an obsolete version can cause processing problems or a request to resubmit on the current version [15]. Superseded versions of 21-526EZ should stay available and clearly marked as superseded, the way OMB's own records preserve the history of this collection [16]. Veterans revisiting old claims, accredited representatives, and researchers all need to know exactly what the form said at a given time. ## Closing We want this redesign to succeed. The test of the new 21-526EZ is not whether it is 5 pages. It is whether a veteran filing alone, for the first time, can tell what they are claiming, what evidence VA needs, and what else applies to them, and get it right the first time. Publish the draft, show the testing, and keep the notices and warnings that carry legal and financial weight. Do that, and this could be one of the most useful paperwork changes VA has made in years. Thank you for the opportunity to comment. Respectfully submitted, The Veteran Benefit Desk veteranbenefitdesk.com admin@veteranbenefitdesk.com ## Sources [1] Agency Information Collection Activity: Application for Disability Compensation Benefits, 91 FR 37497 (June 23, 2026), FR Doc. 2026-12555, OMB Control No. 2900-0747. https://www.federalregister.gov/d/2026-12555 [2] 44 U.S.C. 3506(c)(2)(A). https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title44-section3506&num=0&edition=prelim [3] 91 FR 37497 ("Burden has decreased due to the shortening of the length of the form from 15 to 5 pages, further reducing the respondent burden from 25 minutes to 15 minutes"). [4] 91 FR 37497 (Estimated Number of Respondents: 1,997,592 per year; Estimated Annual Burden: 499,398 hours). [5] Regulations.gov, Docket VA-2026-VACO-0001, document VA-2026-VACO-0001-0207 (no supporting documents attached as of our last check on August 10, 2026). https://www.regulations.gov/document/VA-2026-VACO-0001-0207 [6] 38 CFR 3.310 (disabilities that are proximately due to or aggravated by service connected disease or injury). https://www.ecfr.gov/current/title-38/chapter-I/part-3/subpart-A/section-3.310 [7] See 38 U.S.C. 1112, 1116, 1119 (https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title38-section1116&num=0&edition=prelim); Public Law 117-168 (PACT Act), https://www.govinfo.gov/app/details/PLAW-117publ168 [8] 38 U.S.C. 1151. https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title38-section1151&num=0&edition=prelim [9] The Veteran Benefit Desk, PACT Act Claims Report (monthly VBA grant and denial data obtained under FOIA and checked against VA's public PACT Act dashboard). https://veteranbenefitdesk.com/research/pact-act-claims [10] 38 U.S.C. 5103 (https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title38-section5103&num=0&edition=prelim); 38 CFR 3.159(b), https://www.ecfr.gov/current/title-38/chapter-I/part-3/subpart-A/section-3.159 [11] 38 U.S.C. 5304, 5305 (https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title38-section5304&num=0&edition=prelim); 10 U.S.C. 1414, https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title10-section1414&num=0&edition=prelim [12] 38 CFR 3.155 (intent to file a claim for benefits). https://www.ecfr.gov/current/title-38/chapter-I/part-3/subpart-A/section-3.155 [13] 44 U.S.C. 3506(c)(3). https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title44-section3506&num=0&edition=prelim [14] 29 U.S.C. 794d (Section 508 of the Rehabilitation Act). https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title29-section794d&num=0&edition=prelim [15] The Veteran Benefit Desk, Form Version Checker. https://veteranbenefitdesk.com/tools/form-version-checker [16] OMB, PRA Search (historical versions of OMB Control No. 2900-0747). https://www.reginfo.gov/public/do/PRASearch