180524-519

CourtBoard of Veterans' Appeals
DecidedJanuary 15, 2019
Docket180524-519
StatusUnpublished

This text of 180524-519 (180524-519) 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
180524-519, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 01/15/19 Archive Date: 01/14/19

DOCKET NO. 180524-519 DATE: January 15, 2019

ORDER

Entitlement to an effective date earlier than August 1, 2017, for a 70 percent rating for major depressive disorder is denied.

Entitlement to a total disability rating based on individual unemployability (TDIU) is denied.

FINDINGS OF FACT

1. VA received a claim for an increased rating for major depressive disorder on August 1, 2017; a factually ascertainable increase in the severity of the Veteran’s major depressive disorder to 70 percent is not shown within the year prior.

2. The Veteran meets the schedular requirements for individual unemployability.

3. The Veteran’s service-connected disability does not render him unable to secure or follow a substantially gainful occupation.

CONCLUSIONS OF LAW

1. The criteria for an effective date earlier than August 1, 2017, for the award of a 70 percent rating for major depressive disorder have not been met. 38 U.S.C. § 5107, 5110; 38 C.F.R. § 3.102, 3.400, 4.7, 4.130, Diagnostic Code (DC) 9434.

2. The criteria for individual unemployability have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.340, 3.341, 4.1, 4.16.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

On August 23, 2017, the President signed into law the Veterans Appeals Improvement and Modernization Act, Pub. L. No. 115-55 (to be codified as amended in scattered sections of 38 U.S.C.), 131 Stat. 1105 (2017), also known as the Appeals Modernization Act (AMA). This law creates a new framework for Veterans dissatisfied with VA’s decision on their claim to seek review. The Veteran chose to participate in VA’s test program RAMP, the Rapid Appeals Modernization Program. This decision has been written consistent with the new AMA framework.

The Veteran served on active duty from April 1964 to September 1965. The Veteran selected the Higher-Level Review lane when he submitted the RAMP election form. Accordingly, the April 2018 RAMP rating decision considered the evidence of record as of the date VA received the RAMP election form. The Veteran timely appealed this RAMP rating decision to the Board and requested evidence submission with the opportunity to submit evidence within 90 days of the notice of disagreement. As that time has passed, the Board will proceed to adjudicate the issues on appeal.

1. Entitlement to an effective date earlier than August 1, 2017, for the increased rating of 70 percent for major depressive disorder

The Veteran contends that he should be assigned an earlier effective date for the award of a70 percent rating for his major depressive disorder.

Except as otherwise provided, the effective date of an evaluation and award of compensation based on an original claim, a claim reopened after final disallowance, or a claim for increase will be the date of receipt of the claim or the date entitlement arose, whichever is later. 38 U.S.C. § 5110 (2012); 38 C.F.R. § 3.400 (2017).

An exception to this rule provides that the effective date of an award for increased disability compensation shall be the earliest date as of which it is factually ascertainable that an increase in disability has occurred, if the claim is received within one year from such date; otherwise, it is the date of receipt of the claim. 38 U.S.C. § 5110 (b)(2); 38 C.F.R. § 3.400 (o)(2). “[A]n increase in a veteran’s service-connected disability must have occurred during the one-year period prior to the date of the veteran’s claim in order to receive the benefit of an earlier effective date.” Gaston v. Shinseki, 605 F.3d 979, 984 (Fed. Cir. 2010) (discussing 38 U.S.C. § 5110 (b)(2) and 38 C.F.R. § 3.400 (o)(2)). If the increase in disability is shown to have occurred after the date of claim, the effective date is the date of increase. See 38 U.S.C. §5110 (b)(2); Harper v. Brown, 10 Vet. App. 125 (1997); 38 C.F.R. § 3.400 (o)(1); VAOPGCPREC 12-98 (1998).

Prior to March 25, 2015, a claim could be either a formal or informal written communication “requesting a determination of entitlement, or evidencing a belief in entitlement, to a benefit.” See 38 C.F.R. § 3.1 (p) (2014). Effective March 24, 2015, however, VA amended its adjudication regulations to require that all claims governed by VA’s adjudication regulations be filed on standard forms prescribed by the Secretary. See 79 Fed. Reg. 57,660 (Sept. 25, 2014). This rulemaking also eliminated the constructive receipt of VA reports of hospitalization or examination and other medical records as informal claims for increase, and revised 38 C.F.R. § 3.400 (o)(2). The instant claim was received on August 1, 2017.

The General Rating Formula for Mental Disorders at 38 C.F.R. § 4.130, DC 9434 provides the following ratings for mental disorders such as major depressive disorder:

A 70 percent 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; obsessional rituals which interfere with routine activities; speech intermittently illogical, obscure, or irrelevant; 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 worklike setting); inability to establish and maintain effective relationships.

This list of symptoms is meant to reflect examples of symptoms that would warrant a particular evaluation, but are not meant to be exhaustive. The Board need not find all or even some of the symptoms to award a specific evaluation. Mauerhan v. Principi, 16 Vet. App. 436, 442 (2002); see also Vazquez-Claudio v. Shinseki, 713 F.3d 112, 117 (Fed. Cir. 2013) (explaining that the symptoms that could give rise to a given rating are those in like kind, i.e., of similar duration, severity, and frequency, to those provided in the non-exhaustive lists).

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Related

Gaston v. SHINSEKI
605 F.3d 979 (Federal Circuit, 2010)
Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Genaro Vazquez-Claudio v. Shinseki
713 F.3d 112 (Federal Circuit, 2013)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Wood v. Derwinski
1 Vet. App. 190 (Veterans Claims, 1991)
Hatlestad v. Brown
5 Vet. App. 524 (Veterans Claims, 1993)
Harper v. Brown
10 Vet. App. 125 (Veterans Claims, 1997)

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180524-519, Counsel Stack Legal Research, https://law.counselstack.com/opinion/180524-519-bva-2019.