What we say in paragraph 3.46 is that “we found that Veterans Affairs...knows that most successful reviews and appeals rely on new information or testimony presented by the veteran or the veteran's representative”. So it's a case of, during that appeal process, new information coming forward. We feel that's something the department needs to analyze to determine whether they should be asking for more of that information earlier in the process.
On November 27th, 2014. See this statement in context.