Veterans may claim benefts for disabilities connected to their military service subject to statutory and regulatory requirements. When the Department of Veterans Affairs (VA) denies a benefts claim, that decision generally becomes fnal after the veteran exhausts the opportunity for direct appeal. But a statutory exception permits the veteran to seek collateral review at any time on grounds of “clear and unmistakable error.” We must decide whether that exception allows relief from a VA decision applying an agency regulation that, although unchallenged at the time, is later deemed contrary to law. We hold that it does not.
*Briefs of amici curiae urging reversal were fled for Disabled American Veterans by Robert V. Chisholm; for Military-Veterans Advocacy, Inc., et al. by Michael E. Joffre, William H. Milliken, and John B. Wells; for the National Law School Veterans Clinic Consortium by Angela K. Drake; for the National Veterans Legal Services Program et al. by Liam J. Mont gomery; for Swords to Plowshares et al. by Amy Rose and Tyrone Collier; and for United States Senators Ted Cruz et al. by Jennifer L. Mascott and R. Trent McCotter.
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I
A
“The law entitles veterans who have served on active duty in the United States military to receive benefts for disabilities caused or aggravated by their military service.” Shin seki v. Sanders, 556 U. S. 396, 400 (2009); see 38 U. S. C. § 1110. A veteran seeking such benefts must frst fle a claim with the VA. § 5101(a)(1)(A). A regional offce of the VA then determines whether the veteran satisfes all legal prerequisites, including the requirement that military service caused or aggravated the disability. § 511(a); see 38 CFR § 3.100(a) (2021). To that end, the statute governing wartime service imposes a “[p]resumption of sound condition”: If a veteran's disability was not noted at the time of entry into service, then the veteran is presumptively entitled to benefts unless the VA shows by a heightened burden of proof that the disability “existed before . . . and was not aggravated by such service.” 38 U. S. C. § 1111. After applying this and other statutory and regulatory requirements, the regional offce issues an initial decision granting or denying benefts. §§ 511(a), 5104(a).
A veteran dissatisfed with this decision may challenge it through several layers of direct review. As a general rule, the veteran may appeal within one year to the VA's Board of Veterans' Appeals (Board). §§ 7105(b)(1), 7104(a). If the Board also denies relief, the veteran may seek further review outside the agency. Such review was once limited to constitutional and certain statutory claims, but since 1988 Congress has generally allowed veterans 120 days to appeal any Board decision to the Court of Appeals for Veterans Claims (Veterans Court). See Henderson v. Shinseki, 562 U. S. 428, 432, and n. 1 (2011); §§ 7252(a), 7261(a), 7266(a). A veteran dissatisfed with that court's decision may seek review of any legal issue in the Federal Circuit and ultimately in this Court. § 7292; 28 U. S. C. § 1254(1).
Page Proof Pending Publication GEORGE v. McDONOUGH After this direct appeal process, the benefts decision generally becomes “fnal and conclusive and may not be reviewed by any other offcial or by any court.” 38 U. S. C. § 511(a); see § 7104(a). Still, the veteran enjoys a few limited options for seeking collateral review in exceptional circumstances. E. g., § 5108(a) (supplemental claim based on new and relevant evidence); § 503(a) (discretionary relief based on administrative error); § 5110(g) (increase of benefts based on subsequent liberalizing legal change).
This case concerns one such exception to fnality: At any time, a veteran may ask the Board or regional offce to revise a fnal benefts decision on grounds of “clear and unmistakable error.” § 5109A (regional offce); § 7111 (the Board); 38 CFR §§ 3.105, 20.1400–20.1411 (2021). This form of collateral review was frst adopted by regulation roughly 100 years ago. Since at least 1928, the VA and its predecessor agencies have allowed revision of an otherwise fnal decision when “obviously warranted by a clear and unmistakable error.” Veterans' Bureau Reg. No. 187, pt. 1, § 7155 (1928); see 38 CFR § 3.105(a) (Cum. Supp. 1963) (“Previous determinations . . . will be accepted as correct in the absence of clear and unmistakable error”). In 1997, Congress codifed this form of review in the statute we interpret today. 111 Stat. 2271.
B
Kevin George joined the Marine Corps in 1975 after experiencing multiple schizophrenic episodes. He did not initially disclose that history, and a medical examination noted no mental disorders at the time he entered service. But less than a week into training, George had another episode and was hospitalized. A few months later, the Navy's Central Physical Evaluation Board found that his schizophrenia made him unft for duty and was not aggravated by service. App. to Brief for Petitioner 12a–15a. George was then medically discharged.
Later that year, George applied for veterans' disability benefts based on his schizophrenia. A VA regional offce Page Proof Pending Publication denied his claim after concluding that his condition predated his military service and was not aggravated by it. The Board agreed and denied George's appeal in 1977. In so ruling, neither the regional offce nor the Board expressly discussed the VA's burden of proof under the presumption of sound condition.
In 2014, George asked the Board to revise that fnal decision on grounds of “clear and unmistakable error.”
U. S. C. § 7111. In particular, he claimed that the Board erred by applying a later invalidated regulation to deny his claim for benefts without holding the VA to its full burden of proof to rebut the statutory presumption of sound condition. For more than 40 years, including George's time in service, a VA regulation provided that the agency could rebut the presumption simply by showing, according to a heightened burden of proof, that a disability predated service. See 26 Fed. Reg. 1580 (1961); 38 CFR § 3.304(b) (1976). In 2003, however, the VA concluded that this regulation conficted with the statute, which it now understood to require an additional showing (by the same burden of proof): that the veteran's condition was not later aggravated by service. VA Op. Gen. Counsel Precedent (VA Op.) 3–2003 (July 16, 2003).
The VA recognized that it seemed “illogical” to require an additional showing with “no obvious bearing upon the presumed fact of whether the veteran was in sound condition when he or she entered service.” Id., at 8. But it explained that the statutory text nonetheless “compel[led]” this reading. Ibid. Based on this about-face, the VA confessed error in a pending case applying the regulation, and the Federal Circuit agreed that this “diffcult to parse” and “somewhat self-contradictory” statute rendered the regulation “incorrect.” Wagner v. Principi, 370 F. 3d 1089, 1093, 1097 (2004). The VA ultimately amended the regulation to resolve the issue going forward. 70 Fed. Reg. 23027 (2005). The Board denied George's claim for collateral relief, and the Veterans Court affrmed. The Federal Circuit also affrmed, concluding that the application of a later invalidated Page Proof Pending Publication GEORGE v. McDONOUGH regulation does not fall into the narrow category of “clear and unmistakable error” permitting revision of a fnal decision under 38 U. S. C. §§ 5109A and 7111. 991 F. 3d 1227 (2021). We granted certiorari. 595 U. S. ––– (2022).
II
A
This case turns on the meaning of the 1997 statute subjecting a fnal veterans' benefts decision to collateral review on grounds of “clear and unmistakable error.” 111 Stat. 2271 (38 U. S. C. §§ 5109A, 7111). Neither this statute nor any other defnes this term—indeed, it appears nowhere else in the entire United States Code. The modifers “clear” and “unmistakable” indicate that this is a narrow category excluding some forms of error cognizable in other contexts. The statutory structure similarly suggests a narrow category because this form of review functions as a limited exception to fnality, in contrast to the broad provision of one direct appeal for “[a]ll questions” in a case. § 7104(a). But beyond those general contours, the statute itself does not identify the specifc ways in which this category is narrower than garden-variety “error.”
Fortunately, a robust regulatory backdrop flls in the details. Where Congress employs a term of art “ ` “obviously transplanted from another legal source,” ' it ` “brings the old soil with it.” ' ” Taggart v. Lorenzen, 587 U. S. –––, ––– (2019). That principle applies here. In 1997, Congress used an unusual term that had a long regulatory history in this very context. It enacted no new “defnition” or other provision indicating any departure from the “same meaning” that the VA had long applied. Hall v. Hall, 584 U. S. 59, 73 (2018). We therefore agree with the Federal Circuit that Congress “codif[ied] and adopt[ed] the [clear-and-unmistakable-error] doctrine as it had developed under” prior agency practice. Cook v. Principi, 318 F. 3d 1334, 1344 (2002) (en banc). That longstanding VA practice reveals Page Proof Pending Publication Page Proof Pending Publication several respects in which the clear-and-unmistakable category is a “very specifc and rare kind of error” narrower than error simpliciter. 38 CFR § 20.1403(a).
Most important for present purposes, the history reveals that this category of error does not encompass a subsequent “change in law . . . or a change in interpretation of law.” 38 CFR § 3.105 (Cum. Supp. 1963). And for good reason: During the many years when clear and unmistakable error was purely a creature of regulation, the governing statutes generally did not allow “[n]ew or recently developed facts or changes in the law” to “provide a basis for revising a fnally decided case.” Russell v. Principi, 3 Vet. App. 310, 313 (1992) (en banc) (citing 38 U. S. C. §§ 5108, 7104). To stay within that statutory constraint, authorities dating back to 1928 confrm that “[a] determination that there was a `clear and unmistakable error' must be based on the record and the law that existed at the time of the prior [VA] decision.” Vet. App., at 314 (emphasis added); see 38 CFR § 20.1403(b) (similar); Veterans' Bureau Reg. No. 187, pt. 1, § 7155 (requiring “clear and unmistakable error shown by the evidence in fle at the time the prior decision was rendered”). So, for example, the VA's failure to apply an existing regulation to undisputed record evidence could constitute clear and unmistakable error. E. g., Myler v. Derwinski, 1 Vet. App. 571, 574–575 (1991). But a subsequent legal change could not, because “only the `law that existed at the time' of the prior adjudication . . . can be considered” in this posture. Damrel v. Brown, 6 Vet. App. 242, 246 (1994). Or as the Veterans Court summed up, shortly before the enactment of the 1997 statute: A “new interpretation of law . . . from a case decided in 1993 could not possibly be the basis of [clear and unmistakable] error in 1969,” as “a simple recitation of the time sequence” should “make . . . clear.” Berger v. Brown, 10 Vet. App. 166, 170 (1997).
The invalidation of a prior regulation constitutes a “change in interpretation of law” under historical agency practice. GEORGE v. McDONOUGH Drawing on decades of history, the VA succinctly explained nearly 30 years ago that review for clear and unmistakable error provides “no authority . . . for retroactive payment of benefts when,” as in this case, a court later “invalidates a VA interpretation or regulation” after a benefts decision becomes fnal. VA Op. 9–94, ¶6, p. 5 (Mar. 25, 1994). Under this practice and the statute codifying it, the Board is instead simply “performing its assigned task when it applies a regulation as promulgated by the [VA],” because that regulation legally binds agency adjudicators. VA Op. 25–95, ¶4, p. 2 (Dec. 6, 1995); see 38 U. S. C. § 7104(c) (“The Board shall be bound in its decisions by the regulations of the Department”). To be sure, when a previously applied regulation is later invalidated, relief may be warranted for “error” in a case still on direct appeal. E. g., Wagner, 370 F. 3d, at 1092, 1097. But on collateral review of a fnal decision, the more limited category of “[c]lear and unmistakable error does not include the otherwise correct application of a statute or regulation where, subsequent to the Board decision challenged, there has been a change in the interpretation of the statute or regulation.” 38 CFR § 20.1403(e).1 The applicability of this principle does not depend on the reason why the agency changed course: A change based on the conclusion that a prior interpretation was wrong is still a changed interpretation. Defned by this regulatory history, the statutory term “clear and unmistakable error” does not encompass a claim like George's. When the Board decided George's appeal in 1977, it followed the then-applicable 1961 regulation, as it was statutorily obligated to do. See 38 U. S. C. § 7104(c). Decades later, the VA and the Federal Circuit rejected that 1As should be clear from our explanation, the principal dissent is wrong to attribute to the Court the view that an agency decision in these circumstances is “infected by no error of any kind.” Post, at 759 (opinion of Gorsuch, J.). The issue in this case is the distinction between “errors” cognizable on direct appeal and clear and unmistakable errors cognizable on collateral review. Throughout his opinion, Justice Gorsuch elides that distinction.
Page Proof Pending Publication regulation based on a new interpretation of the “sound condition” provision. We express no view on the merits of that change in interpretation, which are not before us. But because it is a change, it cannot support a claim of clear and unmistakable error in the Board's routine 1977 application of the prior regulation. Put differently, the correct application of a binding regulation does not constitute “clear and unmistakable error” at the time a decision is rendered, even if that regulation is subsequently invalidated.
B
George offers several responses. He generally concedes the premise that the 1997 statute codifed the longstanding regulatory practice defning “clear and unmistakable error.” He takes issue primarily with the conclusion that this practice forbids his claim. In George's view, the VA has “distorted” its own history by glossing over a handful of “prelegislation Veterans Court opinions” that he claims “point in [his] direction.” Brief for Petitioner 26, 41. But across a century of review for clear and unmistakable error, George can muster only one case sustaining a claim that arguably resembles his. See Look v. Derwinski, 2 Vet. App. 157 (1992) (approving collateral relief on two grounds, including a later invalidated regulation, without discussing the change- in-interpretation principle). And even that case is ambiguous, as portions of the opinion may instead “suggest that the [subsequent] invalidation of regulations does not have retroactive effect in `fnally' disallowed claims.” VA Op. 9– 94, ¶5, p. 4 (emphasis added) (citing Look, 2 Vet. App., at 164). Regardless, the case remains an outlier that “no court has cited” on this point “[i]n the 30 years since,” as the Government notes without rebuttal from George. Brief for Respondent 38.
This is thin stuff. One uncertain outlier does not come close to moving the mountain of contrary regulatory authority. See supra, at 746–748. When we say that a statute Page Proof Pending Publication GEORGE v. McDONOUGH adopts a term of art, we mean that it captures “the state of [a] body of law,” not every errant decision of arguable relevance. Federal Republic of Germany v. Philipp, 592 U. S. 169, 180 (2021). Even if George could pluck from the crowd a few stray decisions pointing his way, that would not show a “ `settled' meaning” that we can infer “Congress had . . . in mind when it enacted” this statute. Return Mail, Inc. v. Postal Service, 587 U. S. –––, ––– (2019). Instead, the mainstream of agency practice settles that a clear-andunmistakable-error claim cannot rest on a subsequent change in interpretation.
George alternatively argues that the VA erred in applying this principle to his situation. In his view, it is wrong to describe a later decision invalidating a regulation as a “change in interpretation of law.” But we think that is a perfectly natural way to characterize a decision announcing a new reading of a statute—much as the VA and Federal Circuit did in the decisions on which George now relies. VA Op. 3–2003, ¶¶3, 8, pp. 2, 5 (adopting a new “interpretation” to replace the prior “interpretation refected in VA's regulations”); Wagner, 370 F. 3d, at 1092 (discussing that “change in agency interpretation”). We have occasionally used similar language ourselves. E. g., Gonzalez v. Crosby, 545 U. S. 524, 536–537 (2005) (referring to “[t]he change in the law worked by” our precedent “interpret[ing] the AEDPA statute of limitations”). As the Federal Circuit has explained, a lack of “accuracy” in a prior statutory interpretation “does not negate the fact that” it is an “initial interpretation.” Jordan v. Nicholson, 401 F. 3d 1296, 1298 (2005). In short, a misinterpretation is still an interpretation, and a correction of that interpretation is a change. So the VA's application of the change-in-interpretation label to claims like George's hardly refects an “atypical” use of language, despite his arguments to the contrary. Brief for Petitioner 18.
Ordinary language aside, George tries to bolster his position with analogies to precedent from other contexts. He Page Proof Pending Publication invokes an array of cases explaining that a judicial decision states what the statute “always meant,” Rivers v. Roadway Express, Inc., 511 U. S. 298, 313, n. 12 (1994), and an unauthorized regulation is a “ `nullity,' ” Dixon v. United States, 381 U. S. 68, 74 (1965). True enough. Those general principles, however, do not dispose of the issue before us. Assume George is right that the “sound condition” provision always required the VA to show that the veteran's condition was not later aggravated by service and that the 1961 regulation conficted with that requirement. We would still have to decide whether the Board's application of that binding regulation is the kind of “clear and unmistakable error” for which collateral relief is available under 38 U. S. C. §§ 5109A and 7111. For the reasons we have explained, it is not.
And while George suggests otherwise, there is nothing incongruous about a system in which this kind of error—the application of a since-rejected statutory interpretation—cannot be remedied after fnal judgment. On the contrary, and as the lower courts have explained, the VA's longstanding approach is consistent with the general rule that “[t]he new interpretation of a statute can only retroactively [a]ffect decisions still open on direct review.” Disabled American Vet erans v. Gober, 234 F. 3d 682, 698 (CA Fed. 2000) (citing Harper v. Virginia Dept. of Taxation, 509 U. S. 86, 97 (1993)); see also Smith v. West, 11 Vet. App. 134, 138 (1998) (“ `New legal principles, even when applied retroactively, do not apply to cases already closed' ” (quoting Reynoldsville Casket Co. v. Hyde, 514 U. S. 749, 758 (1995); alteration omitted)). That limitation serves important interests in fnality, preventing narrow avenues for collateral review from ballooning into “substitute[s] for ordinary error correction through appeal.” Harrington v. Richter, 562 U. S. 86, 102– 103 (2011); see also United Student Aid Funds, Inc. v. Es pinosa, 559 U. S. 260, 270 (2010) (an “exception to fnality” should not be read to “swallow the rule”). So the VA's approach to collateral relief is not unusual. Here as elsewhere, Page Proof Pending Publication GEORGE v. McDONOUGH litigants must overcome a “stron[g]” “presumption of validity” when “otherwise fnal decisions . . . are collaterally attacked.” Fugo v. Brown, 6 Vet. App. 40, 44 (1993).2 George also leans on what he describes as “the plain meaning of th[e] words” clear and unmistakable error. Reply Brief 2. As he puts it: “Looking at the 1977 Board's decision today, the legal error is clear. It is unmistakable.” Id., at 1. (This is the thrust of Justice Gorsuch's position too. See post, at 758–760 (dissenting opinion).) We share the Government's doubt about how natural it is to say that the Board “commit[ted] `clear and unmistakable error' by faithfully applying a VA regulation that was found to be invalid more than 25 years later.” Brief for Respondent 33. More fundamentally, though, this argument is inconsistent with George's well-taken concessions elsewhere that “the [clearand-unmistakable-error] statutes track preexisting Veterans Court case law” and other agency practice defning a “deeply rooted” regulatory standard. Reply Brief 8; Brief for Petitioner 6. The real question is not what might be called clear and unmistakable error in the abstract, but what was the “prevailing understanding” of this term of art “under the law that Congress looked to when codifying” it. Reply Brief 2, 4; see West Virginia Univ. Hospitals, Inc. v. Casey, 499 U. S. 83, 92, n. 5 (1991) (terms of art “depart from ordinary meaning”). To the extent they diverge, the historical meaning controls.
2The principal dissent claims that this conclusion conficts with the governing statute's present-tense statement that a VA decision “ `is subject' to later `revision' ” on collateral review. Post, at 760 (opinion of Gorsuch, J.). But it would make little sense for Congress to pass a statute stating that a decision “was” subject to revision. The statute's use of the present tense refers to the time at which relief may be sought. It says nothing about the scope of the category of clear and unmistakable errors meriting relief, as fxed by the regulatory history. So we think there are good reasons why neither George nor any of his amici makes this argument. Page Proof Pending Publication More modestly, George seeks to distinguish the statutory meaning from the prior practice on just one point. Because Congress did not expressly enact the specifc regulatory principle barring collateral relief for subsequent changes in interpretation, he insists that the principle did not carry over to the statute. But this argument, too, misses the mark. The point of the old-soil principle is that “when Congress employs a term of art,” that usage itself suffces to “ `adop[t] the cluster of ideas that were attached to each borrowed word' ” in the absence of indication to the contrary. FAA v. Cooper, 566 U. S. 284, 292 (2012). Here, the governing statute “is silent” on a host of matters ranging from the defnition of clear and unmistakable error to “the specifc procedures that govern a [collateral] claim.” Disabled American Veterans, 234 F. 3d, at 694, 696 (citing 38 U. S. C. § 7111). And we take the statutory “silence” on the details of prior regulatory practice to “l[eave] the matter where it was pre[codifcation].” Kucana v. Holder, 558 U. S. 233, 250 (2010). We decline George's invitation to gerrymander out this one feature of the prior practice.
* * * The invalidation of a VA regulation after a veteran's benefts decision becomes fnal cannot support a claim for collateral relief based on clear and unmistakable error. We affrm the judgment of the Court of Appeals.
It is so ordered.