180926-402

CourtBoard of Veterans' Appeals
DecidedMarch 18, 2019
Docket180926-402
StatusUnpublished

This text of 180926-402 (180926-402) 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
180926-402, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 03/18/19 Archive Date: 03/18/19

DOCKET NO. 180926-402 DATE: March 18, 2019

ORDER

Entitlement to total disability rating based upon individual unemployability due to service-connected disabilities (TDIU) prior to February 8, 2018, is denied.

FINDING OF FACT

The most probative evidence of record does not show that it is factually ascertainable that the Veteran was unable to secure or follow a substantially gainful occupation due to his service-connected disabilities in the one-year period prior to the February 8, 2018, claim for entitlement to a TDIU.

CONCLUSION OF LAW

The criteria for entitlement to a TDIU, prior to February 8, 2018, have not been met. 38 U.S.C. §§ 1155, 5103A, 5107; 38 C.F.R. §§ 3.340, 3.341, 4.16.

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 served on active duty from June 1945 to May 1946 and from February 1952 to August 1952.

This appeal is from an April 2018 rating decision of the Department of Veterans Affairs (VA) Regional Office (RO). A timely notice of disagreement with the April 2018 denial of entitlement to a TDIU was received in June 2018.

The Veteran selected the Higher-Level Review lane when he submitted the RAMP election form. Accordingly, the September 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 direct review of the evidence considered by the Agency of Original Jurisdiction (AOJ).

The Board is cognizant that the United States Court of Appeals for Veterans Claims (Court) has held that a claim for a total rating based on individual unemployability due to a service-connected disability (TDIU), either expressly raised by the Veteran or reasonably raised by the record, is part of the claim for an increased rating. See Rice v. Shinseki, 22 Vet. App. 447 (2009). However, in this case the Veteran is rated as 100 percent disabled and is in receipt of special monthly compensation ( under 38 U.S.C. § 1114 (k) from February 8, 2018. While the award of SMC under 38 U.S.C. § 1114 (k) is independent of, and in addition to, any other compensation provided, including under 38 U.S.C. § 1114(s), the combined rate of compensation may not exceed the monthly rate set forth in 38 U.S.C. § 1114 (l). The record establishes that effective from March 1, 2018, the Veteran’s compensation rate adjustment with SMC pursuant to 38 U.S.C. § 1114 (k) was $3,079.47. The monthly rate set forth in 38 U.S.C. § 1114 (l) in effect from March 1, 2018 was $3,327.00. An award of SMC under 38 U.S.C. § 1114 (s) would be $2,993.00 and, if combined with the SMC payable under 38 U.S.C. 1114 (k), would exceed the limit specified at 38 U.S.C. § 1114 (l). Therefore, the award of a TDIU from February 8, 2018, would result in no further benefit, the issue of entitlement to a TDIU from February 8, 2018 is rendered moot, and the Board need not consider the issue of entitlement to a TDIU from February 8, 2018. See Buie v. Shinseki, 24 Vet. App. 242, 250 (2011); Bradley v. Peake, 22 Vet. App. 280, 294 (2008).

1. Entitlement to a TDIU Prior to February 8, 2018

The Veteran contends that he is entitled to a TDIU prior to February 8, 2018. Specifically, the Veteran stated that he has not been able to obtain employment due to his inability to hear customers. See Correspondence received June 2018.

The AOJ found that the Veteran has not worked since 2001.

The AOJ further found that the schedular requirements for entitlement to a TDIU have been met since March 6, 2009.

By way of history, the Veteran’s claim for entitlement to a TDIU was received on February 8, 2018. See VA Form 21-8940, Veteran’ Application for Increased Compensation Based on Unemployability, received in February 2018. In an April 2018 rating decision, the RO increased the Veteran’s evaluation of bilateral hearing loss from 60 percent disabling to 100 percent disabling, granted entitlement to special monthly compensation based on deafness of both ears from February 8, 2018, and determined that the issue of entitlement to individual unemployability was moot. The present claim arises from the Veteran’s disagreement with the determination that entitlement to a TDIU was moot prior to February 8, 2018. See Notice of Disagreement, received June 2018.

Under the governing law, a claim for entitlement to a TDIU is a claim for increased compensation, and the effective date rules for increased compensation apply to a TDIU claim. See Hurd v. West, 13 Vet. App. 449 (2000). Therefore, an effective date of a TDIU claim may be awarded during the one-year period prior to receipt of the claim if it is factually ascertainable that an increase in disability had occurred during that one-year period. Otherwise, the effective date will be the date of the claim or the date entitlement arose, whichever is later. 38 C.F.R. § 3.400 (o) (2). In this case, because the Veteran’s claim for entitlement to a TDIU was received on February 8, 2018, an effective date for the grant of a TDIU may be assigned during the period from February 9, 2017, through February 7, 2018, if it is factually ascertainable that an increase in disability occurred during that period. Otherwise, the effective date will be February 8, 2018, or the date entitlement arose, whichever is later.

A TDIU may be granted where a veteran is unable to secure or follow a substantially gainful occupation as a result of a single service-connected disability ratable at 60 percent or higher, or as a result of two or more service-connected disabilities, provided at least one disability is ratable at 40 percent or higher, and there is sufficient additional service-connected disability to bring the combined rating to 70 percent or more. 38 U.S.C. § 1155; 38 C.F.R. §§ 3.340, 3.341, 4.16 (a).

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Related

Hurd v. West
13 Vet. App. 449 (Veterans Claims, 2000)
Gary D. Bradley v. James B. Peake
22 Vet. App. 280 (Veterans Claims, 2008)
Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Geib v. Shinseki
733 F.3d 1350 (Federal Circuit, 2013)
Jimmy H. Floore v. Eric K. Shinseki
26 Vet. App. 376 (Veterans Claims, 2013)
Scott v. McDonald
789 F.3d 1375 (Federal Circuit, 2015)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Moore v. Derwinski
1 Vet. App. 356 (Veterans Claims, 1991)
Buie v. Shinseki
24 Vet. App. 242 (Veterans Claims, 2010)

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180926-402, Counsel Stack Legal Research, https://law.counselstack.com/opinion/180926-402-bva-2019.