180820-143

CourtBoard of Veterans' Appeals
DecidedNovember 8, 2018
Docket180820-143
StatusUnpublished

This text of 180820-143 (180820-143) 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
180820-143, (bva 2018).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 11/08/18 Archive Date: 11/07/18

DOCKET NO. 180820-143 DATE: November 8, 2018 ORDER Entitlement to an effective date earlier than October 22, 2009, for the award of service connection for posttraumatic stress disorder (PTSD) is denied. Entitlement to an initial rating in excess of 70 percent for service-connected PTSD from October 22, 2009 to May 24, 2018, is denied. Entitlement to a total disability rating based on individual unemployability (TDIU) is granted, effective October 22, 2009. FINDINGS OF FACT 1. The Veteran’s initial claim for service connection for PTSD was received on October 22, 2009, and this date represents the earliest possible effective date for the award of service connection for PTSD. 2. The preponderance of the evidence fails to demonstrate that the Veteran’s service-connected PTSD was manifested by total occupational and social impairment from October 22, 2009 to May 24, 2018. 3. Resolving all reasonable doubt in the Veteran’s favor, she has been unable to secure or follow a substantially gainful occupation as a result of her service-connected PTSD. CONCLUSIONS OF LAW 1. The criteria for an effective date earlier than October 22, 2009, for the award of service connection for PTSD are not met. 38 U.S.C. § 5110(a) (2012); 38 C.F.R. §§ 3.1(p), (r), 3.151(a), 3.159, 3.400(b)(2) (2017). 2. The criteria for an initial rating in excess of 70 percent for service-connected PTSD from October 22, 2009 to May 24, 2018, are not met. 38 U.S.C. §§ 1155, 5107 (2012); 38 C.F.R. §§ 3.102, 4.1, 4.3, 4.7, 4.126, 4.130, Diagnostic Code 9411 (2017). 3. The criteria for a TDIU are met, effective October 22, 2009. 38 U.S.C. §§ 1155, 5107 (2012); 38 C.F.R. §§ 3.102, 4.16 (2017). 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 Board is honoring the Veteran’s choice to participate in VA’s test program RAMP, the Rapid Appeals Modernization Program. The Veteran served in the Air National Guard from May 1978 to February 1980. On May 24, 2018, the Veteran selected the Higher-Level Review lane when she submitted her RAMP election form. Accordingly, the August 2018 RAMP rating decision considered the evidence of record as of the date VA received the RAMP election form. The Veteran timely appealed the August 2018 RAMP rating decision to the Board and requested direct review of the evidence considered by the Agency of Original Jurisdiction (AOJ). 1. Entitlement to an effective date earlier than October 22, 2009, for the award of service connection for PTSD In general, except as otherwise provided, the effective date of an evaluation based on an original claim will be the date of receipt of the claim or the date entitlement arose, whichever is the later. 38 U.S.C. § 5110(a); 38 C.F.R. § 3.400. Effective March 24, 2015, 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). These amendments are applicable with respect to claims and appeals filed on or after March 24, 2015, and, therefore, are not applicable in the present case. Id. at 57,686. Under the former regulations applicable in this case, any communication indicating intent to apply for a benefit under the laws administered by the VA may be considered an informal claim provided it identifies, but not necessarily with specificity, the benefit sought. See 38 C.F.R. § 3.155(a). To determine when a claim was received, the Board must review all communications in the claims file that may be construed as an application or claim. See Quarles v. Derwinski, 3 Vet. App. 129, 134 (1992). Upon receipt of an informal claim, if a formal claim has not been filed, the AOJ will forward an application form to the claimant for execution. If the AOJ receives a complete application from the claimant within one year from the date it was sent, the AOJ will consider it filed as of the date of receipt of the informal claim. 38 C.F.R. § 3.155. The United States Court of Appeals for Veterans Claims (Court) has explained that, in an original claim for service connection, the date entitlement arose is governed by the date the claim is received, not the date of the medical evidence submitted to support a claim. See McGrath v. Gober, 14 Vet. App. 28 (2000). By way of background, the Veteran submitted an informal claim for service connection for PTSD that was received on October 22, 2009. In a February 2018 rating decision, the AOJ granted service connection for PTSD, effective October 22, 2009, the date her informal claim was received. In her May 2018 notice of disagreement, the Veteran asserted that an earlier effective date was warranted; however, no argument supporting that contention was offered. In reviewing the claims file, the Board observes no communication received by VA prior to her October 22, 2009 claim that can be interpreted as an informal service-connection claim for PTSD, and the Veteran does not identify any prior communication she believes should be interpreted as a claim. As such, October 22, 2009, is the earliest effective date allowable under the applicable criteria discussed above. 38 C.F.R. §§ 3.400(b)(2). The law and regulations governing effective dates preclude the assignment of an effective date earlier than the date she filed her service-connection claim, October 22, 2009. As such, her claim for an earlier effective date must be denied. 2. Entitlement to an initial rating in excess of 70 percent for service-connected PTSD from October 22, 2009 to May 24, 2018. Effective October 22, 2009, the Veteran was assigned an initial rating of 70 percent for PTSD under 38 C.F.R. § 4.130, Diagnostic Code 9411. She contends that she is entitled to a higher initial disability rating for PTSD. Disability evaluations are determined by evaluating the extent to which a veteran’s service-connected disability adversely affects her ability to function under the ordinary conditions of daily life, including employment, by comparing her symptomatology with the criteria set forth in the Schedule for Rating Disabilities.

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180820-143, Counsel Stack Legal Research, https://law.counselstack.com/opinion/180820-143-bva-2018.