Becoming a VA-accredited VSO representative vs. an independent claims agent
There are two common non-lawyer routes to VA accreditation. A VSO representative is accredited through a VA-recognized veterans service organization and never charges claimants. An independent claims agent applies directly to OGC, passes the exam, and may charge fees within VA's rules (38 CFR 14.629(a)-(b); 14.636(b)).
Route 1: VSO representative
- Who recommends you: a recognized organization files VA Form 21 for you. The form is signed by you and by the organization's certifying official (14.629(a); VA Form 21).
- What the organization certifies: that you are of good character and reputation and have shown an ability to represent claimants. You must also be a member in good standing, or a paid employee working at least 1,000 hours a year, or accredited with another recognized organization (cross-accreditation), or meet the county or tribal veterans service officer criteria (14.629(a)(1)-(2)).
- Federal employment: you may not be employed in any civil or military department or agency of the United States (14.629(a)(3)). VA Form 21 asks about this (item 9A) (VA Form 21).
- Fees: none. Under the statute, a VSO representative must certify that "no fee or compensation of any nature will be charged" (38 U.S.C. 5902(b)). VA Form 21 includes an agreement not to charge or accept any fee or gratuity (VA Form 21). VA calls VSO services "always free" (VA.gov FAQs).
- Recertification: the organization must recertify you within five years of initial accreditation or the last recertification (14.629(a)).
- No independent practice: your authority comes through the organization. Claimants usually appoint the organization as a whole on VA Form 21-22 (14.631(a); VA.gov FAQs).
Recognized organizations include national, state, tribal, and regional or local organizations that meet VA's recognition requirements (38 CFR 14.628). OGC's Accreditation Search lists them.
Route 2: independent claims agent
- Apply on VA Form 21a, pass OGC's character-and-fitness review, and score 75% or more on the written exam (14.629(b)). See how to apply.
- Complete CLE: 3 hours in the first year, then 3 hours by year 3 and every 2 years after (14.629(b)(1)(iii)-(iv)).
- Fees are allowed only within 38 U.S.C. 5904 and 38 CFR 14.636. That generally means after notice of the initial decision (14.636(c)). You may also represent claimants for free.
Side by side
| VSO representative | Claims agent | |
|---|---|---|
| Application | VA Form 21, filed by the organization | VA Form 21a, filed by you |
| VA exam | Not required by 14.629(a), except county/tribal officers (approved training and exam) | Required, 75% to pass |
| Fees | Never | Allowed within 14.636 |
| Federal employees | Barred by 14.629(a)(3) | Generally barred (OGC fact sheet) |
| Ongoing requirement | Organization recertifies at least every 5 years | CLE plus annual good-standing certification |
Sources: 38 CFR 14.629; 14.636; OGC fact sheet.
Can you be both?
An accredited agent who is also a VSO representative may receive fees only when properly appointed in their individual capacity as an agent under 14.631, not when acting for the organization (14.636(b)).
Check yourself
Original practice questions that passed an independent fact-check against current eCFR and U.S. Code text. They are not actual exam questions.
1. A recognized veterans service organization wants VA to accredit one of its long-time members as a representative. The member works full time as a civilian employee of the U.S. Department of Defense. Under 38 CFR 14.629(a), may the organization certify the member for accreditation?
- A. Yes, because the member is a member in good standing of the organization, which satisfies the requirement.
- B. Yes, as long as the member also works at least 1,000 hours a year for the organization.
- C. No. The designee must not be employed in any civil or military department or agency of the United States.
- D. Yes, if the member's federal supervisor consents in writing to the outside representation work.
Show answer and explanation
Answer: C. Section 14.629(a) requires the organization to certify each of the (a)(1) through (a)(3) criteria. Paragraph (a)(3) requires that the designee 'Is not employed in any civil or military department or agency of the United States.' Good-standing membership or hours worked satisfy only (a)(2) and do not cure the federal-employment bar, and the rule has no supervisor-consent exception.
Source: 38 CFR 14.629(a)(3)
2. Under 38 CFR 14.629(a), how often must a recognized organization's certifying official file VA Form 21 to certify that each of its accredited representatives continues to meet the accreditation criteria?
- A. Annually, on each anniversary of the date the representative was first accredited by VA
- B. Every three years, together with proof that the representative completed continuing legal education
- C. Within five years after initial accreditation through that organization or its most recent recertification
- D. Only when the representative transfers to, or is cross-accredited by, a different organization
Show answer and explanation
Answer: C. Section 14.629(a) requires recertification on VA Form 21 not later than five years after initial accreditation through the organization or the most recent recertification. The annual reporting duty in 14.629(b)(4) applies to agents and attorneys, not to VSO representatives.
Source: 38 CFR 14.629(a)
More practice: 12 sample questions · free quiz
Frequently asked questions
How do I become a VA-accredited VSO representative?
Join or work for a VA-recognized organization that will recommend you. Its certifying official files VA Form 21 with OGC (38 CFR 14.629(a); VA Form 21).
Do VSO representatives take the claims agent exam?
Not under 14.629(a). The organization certifies your qualifications. County and tribal veterans service officers recommended by a state organization must complete approved training and an examination (14.629(a)(2)(ii)).
Can VSO representatives get paid?
They may be paid employees of the organization, but they may not charge claimants any fee (38 U.S.C. 5902(b); 38 CFR 14.636(b)).
Sources
Checked October 4, 2026. Primary sources unless marked SECONDARY.
- 38 CFR 14.629, Requirements for accreditation (eCFR)
- 38 CFR 14.628, Recognition of organizations (eCFR)
- 38 CFR 14.631, Powers of attorney (eCFR)
- 38 CFR 14.636, Payment of fees (eCFR)
- VA Form 21, Application for Accreditation as Service Organization Representative (PDF, March 2023 revision)
- 38 U.S.C. 5902, Recognition of representatives of organizations (Cornell LII)
- VA.gov, VA accredited representative FAQs
- VA OGC Accreditation Search (attorneys, claims agents, VSO representatives)
- VA OGC fact sheet, How to Apply for VA Accreditation (PDF)