210204-133580, 210204-133580

Veteran executed a VA Form 21-22 POA and a written fee agreement with attorney S.D. on June 4, 2012 (20% contingent, direct-pay specified).
S.D. filed a Notice of Disagreement in September 2012 challenging an August 2012 RO denial of the low-back claim.
S.D. submitted a letter withdrawing representation on February 16, 2015; the withdrawal was accepted by VA (RO notified March 26, 2015).
The low-back claim was ultimately granted by the RO in December 2020 (award effective April 18, 2011), producing past-due benefits.
Veteran elected Direct Review under the AMA in February 2021; AOJ initially authorized withholding 20% of past-due benefits for S.D.'s fee.
Board found S.D. entitled to direct payment only for the period when he was the Veteran’s representative (May 7, 2012–February 16, 2015), noting the Veteran was unrepresented for ~4+ years and pursued post-2015 development himself.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether attorney is eligible for direct payment of fees from past-due benefits and for what period	Veteran: fee award was calculated using an incorrect representation period; fees should be limited to when S.D. actually represented him	S.D./AOJ: valid June 2012 fee agreement and POA supported direct payment of 20% of past-due benefits	Board: S.D. is eligible for direct payment but only for May 7, 2012–Feb 16, 2015

None — the decision cites statutes and VA regulations only (no reported cases were relied upon).