If VA denied your family's application to its Program of Comprehensive Assistance for Family Caregivers (PCAFC), cut your stipend level or revoked your designation, you can fight it. A PCAFC appeal offers four routes for decisions issued since February 19, 2019. That letter can land like a door closing on income your household counts on, and it's normal to feel angry or frightened reading it. PCAFC lets the veteran or the caregiver challenge a decision in whole or in part, and every PCAFC decision can go to the Board of Veterans' Appeals. The two firm clocks are one year from the decision notice, for a Higher-Level Review and for a Board appeal.

In This Guide

Start With Your Decision Letter

Before you pick a route, sit down with the letter itself, because two details on it decide everything else: the date the decision was issued and exactly what was decided. A PCAFC decision issued on or after February 19, 2019, has the four routes below; a decision issued before that date follows an older path. Find the date VA sent you notice of the decision, add one year, and write that date somewhere you'll see it. That one-year date is your outer deadline for a Higher-Level Review or a Board appeal.

PCAFC decision letters sent on or after September 28, 2021, include VA Form 10-305, which explains your rights to further review. If you've lost the letter, or you're trying to challenge an older decision and can't remember what it said, you can ask VA for the details of a previous PCAFC decision, such as its date or what was decided, on VA Form 10-306, Request for Information About PCAFC Decisions. Form 10-306 goes to the Veterans Affairs Evidence Intake Center, P.O. Box 5154, Janesville, WI 53547.

It also helps to know what the letter is supposed to contain. Under 38 U.S.C. 1720G(a)(12)(A), as amended by section 125 of the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act (enacted January 2, 2025), VA notifies families of PCAFC decisions using standardized letters, as VA determines appropriate, and the law requires those letters to include all criteria used to determine eligibility and, in the case of a completed evaluation, how those criteria were used to evaluate the information from the assessments. The same section added a veteran being reassessed for eligibility to continue in PCAFC to the people who must receive these notices. If your letter doesn't name the criteria VA applied or explain how it weighed the assessment, write that down, because it tells you what to ask about and what evidence to look for.

If the letter is a denial or a discharge, the same 2025 law added steps VA owes your family on the way out. For a PCAFC denial or discharge on or after July 1, 2025, 38 U.S.C. 1720G(a)(14) requires VA to offer the caregiver enrollment in the Program of General Caregiver Support Services if the veteran meets that program's covered-veteran requirements, to assess the veteran or caregiver for any other VA home- and community-based services program they may be eligible for (storing the veteran's results in the veteran's electronic medical record, accessible to the veteran), and to give the veteran or caregiver written information on each program the assessment identifies, including facilities, eligibility requirements and contact information. For a discharge, the law also requires VA, to the extent practicable, to offer clinically appropriate services under another available VA home- and community-based services program before the discharge, and requires a caregiver support coordinator to provide a smooth and personalized transition to an appropriate VA home- and community-based services program. If your denial or discharge came on or after that date and no one has offered these steps, ask for them in writing.

Which PCAFC Appeal Route Fits Your Letter?

Every situation below can end at the Board, and the Board is a real option from day one, not a last resort you have to earn. What changes from letter to letter is the background you should know before you file. A Supplemental Claim needs new and relevant evidence; a Higher-Level Review is a fresh look at the same record by a higher-level decision maker, with no new evidence.

What your letter says What to know first Routes to consider
Your joint application was denied A family that disagrees with VA's decision on the application can appeal or request a review. Clinical Review or Higher-Level Review if the record already supports you; Supplemental Claim if you have new evidence; Board within one year
Your stipend level was lowered VA says it will not decrease any support based on reassessments, so check what your letter says the decision rests on. Any of the four
Your designation was revoked for cause Benefits continue until the date of revocation, and for fraud that date reaches back to when the fraud began, with overpayment recovery. Any of the four; a lawyer or accredited representative is worth calling early
You were discharged because VA found the veteran no longer eligible The discharge takes effect no earlier than 60 days after VA's advance notice, and benefits then continue for 90 days. Any of the four; use the notice period to gather evidence
You were approved, but the stipend start date looks wrong The stipend can start before approval, on the latest of several dates in 38 CFR 71.40(d). Any of the four, naming the effective date as the decision you disagree with
The decision was issued before February 19, 2019 A different form and process apply. VA Form 10-307 PCAFC Notice of Disagreement

The table rests on these VA sources, one for each row: the joint-application rules, VA's reassessment update, the for-cause revocation rule in 38 CFR 71.45(a), the ineligibility discharge rule in 38 CFR 71.45(b), and the effective-date rule in 38 CFR 71.40(d).

A few of those rows deserve a closer look, because the background changes how you'd argue your case.

A lowered level. VA has suspended required annual PCAFC reassessments during a review of its eligibility criteria, and VA says it will not remove anyone from the program or decrease any support based on reassessments. VA's no-decrease commitment during the PCAFC reassessment suspension covers only removals and decreases based on reassessments, and the suspension is a VA policy that can end. If your level dropped, read your letter closely for what the decision rests on, because we can't tell you why your family's level changed. If the letter leaves you unsure which route fits, the Patient Advocate at your VA medical facility can explain the clinical review process, and the Caregiver Support Line answers questions about the forms used to request review of or appeal a PCAFC decision.

A revocation for cause. Under 38 CFR 71.45(a), VA revokes a Family Caregiver's designation for cause when it finds fraud, finds the caregiver neglected, abused or exploited the veteran, finds safety issues for the veteran the caregiver won't address, or finds the caregiver unwilling to provide personal care services. In a fraud case, VA will seek to recover overpaid benefits back to the date the fraud began, which is why this is the row where a family should get a VA-accredited attorney, agent or Veterans Service Organization representative involved before filing anything.

A discharge for ineligibility. When VA decides the veteran no longer meets the PCAFC requirements, the regulation requires at least 60 days' advance notice before the discharge takes effect, and caregiver benefits then continue for 90 days after the discharge date. VA's 2020 final rule describes that 60-day notice as "an opportunity" to "contest VA’s findings," so treat it as working time, not waiting time.

A start date that looks wrong. Under 38 CFR 71.40(d), the Primary Family Caregiver's stipend runs from the latest of several dates, starting with the date VA received the joint application, and in one 2023 decision the Board moved a family's effective date back to the day the joint application was received. If the caregiver was already caring for the veteran at home when VA received the application, compare that receipt date to the start date in your letter.

The Four PCAFC Appeal Routes Side by Side

Once you know what your letter decided, this is the choice in front of you. Here are the four routes for a PCAFC decision issued on or after February 19, 2019, lined up against each other.

Route How you file Deadline New evidence Who reviews it Can run alongside
VHA Clinical Review In writing, through the Patient Advocate at your VA medical facility Not stated in VA's rights notice or VHA Directive 1041 The review team looks at your appeal and clinical records and may ask for more assessments A different Centralized Eligibility and Appeal Team (CEAT) reviews it; a Veterans Integrated Service Network (VISN) Chief Medical Officer decides A Supplemental Claim or a Higher-Level Review
Supplemental Claim VA Form 20-0995, mailed to the Evidence Intake Center in Janesville, WI Any time Required: new and relevant evidence VA, on the record plus your new evidence Clinical Review only
Higher-Level Review VA Form 20-0996, mailed to the Evidence Intake Center in Janesville, WI Within one year of the date PCAFC gave notice of the decision None A higher-level decision maker Clinical Review only
Board appeal VA Form 10182, mailed to the Board in Washington, DC, or faxed Within one year from the date VA mailed notice of the decision Your choice: direct review of the record, a hearing, or a docket for new evidence The Board of Veterans' Appeals, whose decision is VA's final determination Not a Supplemental Claim or Higher-Level Review; ask the Patient Advocate before pairing it with Clinical Review

The Clinical Review row comes from VHA Directive 1041 and VA Form 10-305; the forms, deadlines, addresses and one-at-a-time rule come from VA's PCAFC rights notice and appeals page; the Board fax line from VA's PCAFC appeals guidance; and the Board's choice of review from 38 CFR 20.202(b).

The VHA Clinical Review Process, Step by Step

This is the route most families have never heard of. The VHA Clinical Review Process (also called the VHA Clinical Appeals Process) is set out in VHA Directive 1041, which gives PCAFC appeals their own procedure in its Appendix G. It is a second look by a different eligibility team, and VA's PCAFC rights notice says the clinical review process continues to be available.

How a first-level Clinical Review works, per VHA Directive 1041:

1
Step 1

The veteran, the veteran's surrogate or the caregiver starts the appeal in writing, through the Patient Advocate at the VA medical facility

2
Step 2

The appeal goes to a CEAT at the VISN level that is not the team that made the original decision. That team reviews the appeal and the clinical records and may ask for more assessments

3
Step 3

A VISN Chief Medical Officer decides the appeal

4
Step 4

Under VHA Directive 1041, a first-level PCAFC Clinical Review decision is to be made and communicated within 45 business days of the Patient Advocate receiving the appeal, and the decision letter explains how to file a second-level appeal

If the first-level PCAFC Clinical Review goes against you, the second-level appeal is submitted in writing to the VISN Patient Advocate Coordinator. A CEAT that neither made the original eligibility decision nor reviewed the first-level appeal reviews the second-level appeal, and VHA Directive 1041 again sets 45 business days from when the VISN Patient Advocate Coordinator receives it, though an external review can extend that and you're supposed to be told if it does. The second-level decision is the last step inside the clinical process, and a decision that comes out of Clinical Review can be appealed to the Board.

Two honest cautions about timing. The 45-business-day figures are the directive's targets, not a promise: VA's Caregiver Support Program says review and appeal requests are handled in the order received and that it cannot give an exact timeline for completing one. And VA Form 10-305 says the clinical process "will work in tandem with the two additional VHA review options", the Supplemental Claim and the Higher-Level Review, so Clinical Review can run alongside one of those two. The form doesn't describe running Clinical Review at the same time as a Board appeal, so ask the Patient Advocate before you try to combine those two.

Supplemental Claim: When You Have New Evidence

If something important never made it into VA's file, such as a new doctor's letter about how much hands-on help the veteran needs, a Supplemental Claim is the route built for it. A PCAFC Supplemental Claim is filed on VA Form 20-0995, requires new and relevant evidence, and can be filed at any time. Mail it to the Veterans Affairs Evidence Intake Center, P.O. Box 5154, Janesville, WI 53547.

"Any time" is a kindness, but it comes with a trade-off. Once you file a Supplemental Claim, you need a decision on it, or to withdraw it, before you can file a Board appeal on the same decision. A decision on the Supplemental Claim can itself go to the Board.

Higher-Level Review and the Board

Here's the short version of these two lanes for a PCAFC decision; our guide to appealing a VA claim denial covers how each one works for VA claims in general.

A Higher-Level Review suits a family that's confident the record VA already has supports them, and that the decision maker simply read it wrong. A PCAFC Higher-Level Review is filed on VA Form 20-0996, and a higher-level decision maker reviews your case without new evidence. For a PCAFC decision, you must request it within one year of the date PCAFC gave notice of the decision, and it goes to the same Evidence Intake Center address in Janesville.

The Board suits a family ready to take the case to VA's final decision maker. A PCAFC appeal to the Board of Veterans' Appeals is filed on VA Form 10182 within one year from the date VA mailed notice of the decision, to the Board of Veterans' Appeals, P.O. Box 27063, Washington, DC 20038. You can also fax a PCAFC Board appeal to 844-678-8979. On the form, you choose how the Board looks at your case: direct review of the record without new evidence, a Board hearing with the chance to add evidence, or a docket for submitting new evidence without a hearing, under 38 CFR 20.202(b). A Board decision is VA's final determination on an issue. That finality is the point of going there, and it's also why an accredited representative's read on your file before you choose a docket is worth the call.

If your household is leaning on the stipend while you wait, plan for the wait honestly: VA's Caregiver Support Program says it can't give an exact timeline for completing any PCAFC review or appeal. Every PCAFC decision can reach the Board because of the 2021 Beaudette v. McDonough order, in which the U.S. Court of Appeals for Veterans Claims enjoined VA from denying Board review of future Caregiver Program decisions.

You Can Only Run One of the Three at a Time

This rule trips up families who want to throw everything at a bad decision at once. For a single PCAFC decision, you can pursue only one of a Supplemental Claim, a Higher-Level Review or a Board appeal at a time. Once you pick one, VA says you must get a decision on it, or withdraw it, before you file another.

VA gives its own example: after a Supplemental Claim on a denied VA Form 10-10CG application, the family has to receive the decision on that claim, or withdraw it, before filing a Board appeal.

If Your Decision Is From Before February 19, 2019

Older decisions still have a way in. For a PCAFC decision issued before February 19, 2019, VA directs families to file VA Form 10-307, a PCAFC Notice of Disagreement, and VHA first issues a Statement of the Case before the matter goes on to the Board. If you aren't sure of the old decision's date, request it on Form 10-306 first, and call the Caregiver Support Line with questions about which form to use.

What We Can't Tell You, and Who Can

There are two things nearly every family in your position wants to know, and we can't give you a sourced answer to either, so we won't guess.

The first is whether the stipend keeps paying while a review or appeal is pending. The second is whether there's a deadline to start a Clinical Review. VA's rights notice, its PCAFC appeals page and VHA Directive 1041 describe the routes, forms and decision timeframes, and we could not find either answer in them., Ask the Patient Advocate at your VA medical facility or the Caregiver Support Line, write down who told you what and when, and ask for it in writing if you can.

Getting Help With a PCAFC Appeal

You don't have to do this paperwork alone. A Veterans Service Organization representative, an attorney or an agent accredited by VA can help with an individual PCAFC claim or appeal. Our guide to free VA claims help and how to spot pension poaching explains how to tell an accredited helper from a sales pitch.

VA's Caregiver Support Line, 1-855-260-3274, answers questions about the forms used to request review of or appeal a PCAFC decision, and can tell you where a request is in the review or appeal process., The line is staffed Monday through Friday, 8:00 a.m. to 8:00 p.m. Eastern Time, and it is not a crisis line. If this is all becoming too much and you're having thoughts of suicide, call 988 and press 1, text 838255, or chat at VeteransCrisisLine.net, any hour of any day.

If the Appeal Doesn't Work

A denial at every level isn't the end of VA help for your family. One path back is a new joint application on VA Form 10-10CG, filed by the veteran and caregiver together. The PCAFC effective-date rules in 38 CFR 71.40(d) include start dates for a Family Caregiver reapplying with the same veteran after a revocation or discharge, and for the day after a joint application is denied.

The other path is the Program of General Caregiver Support Services (PGCSS), for caregivers of veterans who don't qualify for PCAFC. A General Caregiver needs no application or clinical evaluation, and gets training and technical support, information about caregiver services, counseling and respite care for the veteran, but not the monthly stipend. To get PGCSS support, the veteran has to be enrolled in VA health care. Our guide to VA caregiver support when you don't qualify for the stipend walks through it.

Frequently Asked Questions

Who can file a PCAFC appeal, the veteran or the caregiver?

Either one. VA says a veteran or a caregiver who disagrees with a PCAFC decision, in whole or in part, can ask VA to review it or appeal it. For the VHA Clinical Review Process, VHA Directive 1041 also lets the veteran's surrogate start the appeal in writing through the Patient Advocate.

Should we ask for a reassessment instead of appealing a lower stipend level?

They do different jobs. During the PCAFC reassessment suspension, VA says it still starts reassessments for families who ask to be considered for a higher stipend level, or when there's evidence the veteran needs more personal care. A reassessment request isn't one of the four review routes VA lists for a PCAFC decision, so if you want the lowered decision itself looked at again, file a review or appeal.

Can I appeal more than one PCAFC decision?

Yes. You can challenge more than one PCAFC decision, say a denial and a later effective-date decision, but you must identify each decision you're appealing. The one-route-at-a-time rule applies to each decision separately.

What if the Board rules against us?

Under 38 U.S.C. 7266(a), a final Board decision can be taken to the U.S. Court of Appeals for Veterans Claims by filing a notice of appeal with that court within 120 days after notice of the Board's decision is issued.

Learn More

Find personalized help deciding which PCAFC review to file at brevy.com.


The information on Brevy.com is for educational purposes only and is not a substitute for professional legal, financial, or medical advice. Rules vary by state and program and change frequently. Always verify with the relevant agency or a qualified professional. Brevy is not a law firm, financial advisor, or healthcare provider.

Still have questions?

Brevy answers from this guide and every other guide here, and can check what you qualify for.

BC

Brevy Care Team

Expert eldercare guidance from Brevy's team of healthcare professionals and researchers.