180923-514

CourtBoard of Veterans' Appeals
DecidedFebruary 28, 2019
Docket180923-514
StatusUnpublished

This text of 180923-514 (180923-514) 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
180923-514, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 02/28/19 Archive Date: 02/28/19

DOCKET NO. 180923-514 DATE: February 28, 2019

ORDER

An initial 70 percent disability rating, and no higher, for posttraumatic stress disorder (PTSD) is granted.

FINDINGS OF FACT

1. Since the grant of service connection, the Veteran’s PTSD has been manifested by occupational and social impairment with deficiencies in areas such as work, thinking and mood due to such symptoms as: depressed mood; anxiety; suspiciousness; panic attacks more than once a week; chronic sleep impairment; impaired impulse control (such as unprovoked irritability with periods of violence); difficulty in adapting to stressful circumstances (including work or a work-like setting); and the inability to establish and maintain effective relationships.

2. The Veteran’s PTSD has not caused more severe manifestations that more nearly approximate total occupational and social impairment.

CONCLUSION OF LAW

The criteria for an initial disability rating disability of 70 percent, and no higher, for PTSD have been met. 38 U.S.C. § 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.40, 4.45, 4.59, 4.71a, Diagnostic Code (DC) 9411.

REASONS AND BASES FOR FINDING AND CONCLUSION

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 had active service from December 2008 to August 2017.

This matter comes before the Board of Veterans’ Appeals (Board) on appeal from a March 2018 rating decision issued by the Department of Veterans Affairs (VA) Regional Office (RO) in Roanoke which granted service connection for PTSD, assigning a 50 percent disability rating effective August 25, 2017. Thereafter, the Veteran submitted a timely notice of disagreement as to the March 2016 rating decision.

In May 2018, the Veteran selected the Higher-Level Review lane when he submitted his RAMP election form. Accordingly, the July 2018 RAMP rating decision considered the evidence of record as of the date VA received the RAMP election form. In September 2018, the Veteran timely appealed to the Board and requested the evidence submission lane, submitting a January 2018 prison treatment record.

Legal Criteria

Disability ratings are determined by the application of the facts presented to VA’s Schedule for Rating Disabilities. 38 C.F.R. Part 4. The percentage ratings contained in the Rating Schedule represent, as far as can be practicably determined, the average impairment in earning capacity resulting from diseases and injuries incurred or aggravated during service and the residual conditions in civilian occupations. 38 U.S.C. § 1155; 38 C.F.R. §§ 3.321(a), 4.1.

In rating the severity of a particular disability, it is essential to consider its history. 38 C.F.R. § 4.1; Peyton v. Derwinski, 1 Vet. App. 282 (1991). Where there is a question as to which of two ratings shall be applied, the higher rating will be assigned if the disability picture more nearly approximates the criteria required for the higher rating. Otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7.

The Veteran’s PTSD is rated under DC 9411. Pursuant to DC 9411, a 50 percent rating is assigned when there is occupational and social impairment with reduced reliability and productivity due to such symptoms as: flattened affect; circumstantial, circumlocutory, or stereotyped, 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.

A 70 percent rating is warranted when there is occupational and social impairment with deficiencies in most areas, such as work, school, family relations, judgment, thinking, 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 work-like setting); and the inability to establish and maintain effective relationships.

A 100 percent rating is warranted if there is total occupational and social impairment, due to such symptoms as: gross impairment in thought processes or communication; persistent delusions or hallucinations; gross 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. 38 C.F.R. § 4.71a, DC 9400, General Rating Formula for Mental Disorders.

Symptoms listed in VA’s general rating formula for 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 (2002).

According to the applicable rating criteria, when evaluating a mental disorder, the frequency, severity, and duration of psychiatric symptoms, the length of remissions, and the Veteran’s capacity for adjustment during periods of remission must be considered. In addition, the rating must be 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. Further, when rating the level of disability from a mental disorder, the extent of social impairment is considered, but a rating cannot be assigned solely on the basis of social impairment. 38 C.F.R. § 4.126.

Analysis

The Veteran contends that he should be assigned a higher rating for his PTSD. Specifically, the Veteran is seeking a 70 percent disability rating for his PTSD. The AOJ found that the Veteran’s PTSD results in occupational and social impairment with reduced reliability and productivity and assigned a 50 percent rating under DC 9411.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Peyton v. Derwinski
1 Vet. App. 282 (Veterans Claims, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
180923-514, Counsel Stack Legal Research, https://law.counselstack.com/opinion/180923-514-bva-2019.