10-11 974

CourtBoard of Veterans' Appeals
DecidedSeptember 6, 2018
Docket10-11 974
StatusUnpublished

This text of 10-11 974 (10-11 974) is published on Counsel Stack Legal Research, covering Board of Veterans' Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
10-11 974, (bva 2018).

Opinion

Citation Nr: 18132493 Decision Date: 09/06/18 Archive Date: 09/06/18

DOCKET NO. 10-11 974 DATE: September 6, 2018 ORDER Entitlement to an initial disability rating in excess of 70 percent for posttraumatic stress disorder (PTSD) is denied. FINDING OF FACT At no point during the appeal period has the Veteran’s service-connected PTSD been manifested by symptoms of the type and extent, frequency and/or severity to indicate total occupational and social impairment. CONCLUSION OF LAW The criteria for a disability rating in excess of 70 percent for service-connected PTSD have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.7, 4.130, Diagnostic Code 9411.

REASONS AND BASES FOR FINDING AND CONCLUSION The Veteran served on a period of initial active duty training from July 1964 to December 1964 he served on a period of active duty from December 1967 to April 1969, to include service in the Republic of Vietnam. This matter comes before the Board of Veterans’ Appeals (Board) on appeal from a May 2008 rating decision by a Department of Veterans Affairs (VA) Regional Office (RO) in which granted service connection for PTSD and assigned an initial disability rating of 50 percent effective January 26, 2007 (the date of claim). Ultimately, a disability rating of 70 percent was assigned for the Veteran’s service-connected PTSD back to January 2007. In July 2007 the Board rendered a decision on the Veteran’s claim for an increased disability rating for PTSD and granted entitlement to a 70 percent rating back to the initial date of service connection in 2017. At this time the Board also remanded the issue of entitlement to a total disability rating based on individual unemployability (TDIU). In February 2018 the United States Court of Appeals for Veterans Claims (Court) vacated the Board’s decision in as much as a 100 percent schedular disability rating was not granted for the Veteran’s PTSD and remanded the case pursuant to a Joint Motion for Remand (JMR). In February 2018 a separate Board decision granted entitlement to TDIU effective back to the date of service connection for PTSD in 2007; thus, the Veteran is receiving the 100 percent rate of compensation for the entire period on appeal. Disability ratings are determined by applying the criteria set forth in the VA Schedule for Rating Disabilities (Rating Schedule) and are intended to represent the average impairment of earning capacity resulting from disability. 38 U.S.C. § 1155; 38 C.F.R. § 4.1. Pursuant to the General Rating Formula for Mental Disorders, a 50 percent disability rating is warranted where there is occupational and social impairment with reduced reliability and productivity due to such symptoms as: flattened affect; circumstantial, circumlocutory, or stereo-typed speech; panic attacks more than once a week; difficulty in understanding complex commands; impairment of short and long-term memory (e.g., retention of only highly learned material, forgetting to complete tasks); impaired judgment; impaired abstract thinking; disturbances of motivation and mood; difficulty in establishing and maintaining effective work and social relationships. 38 C.F.R. § 4.130. A 70 percent disability rating is warranted where there is occupational and social impairment with deficiencies in most areas, such as work, school, family relations, judgment, thinking, or mood, due to such symptoms as: suicidal ideation; obsessive rituals which interfere with routine activities; intermittently illogical obscure, or irrelevant speech; near-continuous panic or depression affecting the ability to function independently, appropriately and effectively; impaired impulse control (such as unprovoked irritability with periods of violence); spatial disorientation; neglect of personal appearance and hygiene; difficulty in adapting to stressful circumstances (including work or a work like setting); inability to establish and maintain effective relationships. Id. A 100 percent rating is warranted where there is total occupational and social impairment, due to such symptoms as: gross impairment in thought processes or communication; persistent delusions or hallucinations; grossly inappropriate behavior; persistent danger of hurting self or others; intermittent inability to perform activities of daily living (including maintenance of minimal personal hygiene); disorientation to time or place; memory loss for names of close relatives, own occupation, or own name. Id. The symptoms recited in the criteria in the rating schedule for evaluating mental disorders are “not intended to constitute an exhaustive list, but rather are to serve as examples of the type and degree of the symptoms, or their effects, that would justify a particular rating.” Mauerhan v. Principi, 16 Vet. App. 436, 442 (2002). In adjudicating a claim for an increased rating, the adjudicator must consider all symptoms of a claimant’s service-connected mental condition that affect the level of occupational or social impairment. Id. at 443. When evaluating a mental disorder, the rating agency shall consider the frequency, severity, and duration of psychiatric symptoms, length of remissions, and the Veteran’s capacity for adjustment during periods of remission. 38 C.F.R. § 4.126(a). The rating agency shall assign an evaluation based on all the evidence of record that bears on occupational and social impairment rather than solely on the examiner’s assessment of the level of disability at the moment of the examination. Id. When evaluating the level of disability from a mental disorder, the rating agency will consider the extent of social impairment, but shall not assign an evaluation solely on the basis of social impairment. 38 C.F.R. § 4.126(b). The record includes Global Assessment of Functioning (GAF) scores that clinicians have assigned. The GAF was a scale reflecting the psychological, social, and occupational functioning on a hypothetical continuum of mental health illness. See Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition (DSM-IV); Carpenter v. Brown, 8 Vet. App. 240 (1995). Clinicians dealing with mental health issues currently use the Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition (DSM-5). Given the procedural posture of this appeal, the DSM-5 applies. See 80 Fed. Reg. 14308 (Mar. 19, 2015) (DSM-5 applies to claims received by VA or pending before the agency of original jurisdiction on or after August 4, 2014). The Court has noted that the DSM-5 eliminated GAF scores because of their conceptual lack of clarity and questionable psychometrics in routine practice, and further stated that an adjudicator is not permitted to rely on evidence that the American Psychiatric Association itself finds lacking in clarity and usefulness. The Court explained symptoms should be the primary focus when assigning a rating for a psychiatric disorder and clarified that the use of numerical GAF scores as a shortcut for gauging psychiatric impairment would be error. Further noted was that the adequacy of medical examinations has never depended upon the use or inclusion of GAF scores. Golden v. Shulkin, 29 Vet. App. 221 (2018). Given the above, the Board finds the GAF scores in this case lack any probative value and as a result will not be further discussed.

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Related

Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Carpenter v. Brown
8 Vet. App. 240 (Veterans Claims, 1995)
Mittleider v. West
11 Vet. App. 181 (Veterans Claims, 1998)

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Bluebook (online)
10-11 974, Counsel Stack Legal Research, https://law.counselstack.com/opinion/10-11-974-bva-2018.