181017-593

CourtBoard of Veterans' Appeals
DecidedJanuary 18, 2019
Docket181017-593
StatusUnpublished

This text of 181017-593 (181017-593) 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
181017-593, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 01/18/19 Archive Date: 01/18/19

DOCKET NO. 181017-593 DATE: January 18, 2019

ORDER

Entitlement to a total disability rating based on individual unemployability due to service-connected disabilities (TDIU) for the period prior to October 16, 2018 is denied.

FINDING OF FACT

For the pendency of the appeal, prior to October 16, 2018, the Veteran was not precluded due to the impact of his service-connected disabilities from securing and following substantially gainful employment.

CONCLUSION OF LAW

The criteria for entitlement to TDIU for the period prior to October 16, 2018 have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.340, 3.34, 4.16(a), 4.16(b); Bowling v. Principi, 15 Vet. App. 1, 10 (2001).

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 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 January 1978 to April 1990. The Veteran selected the Higher-Level Review lane when he submitted the RAMP election form. Accordingly, the October 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 the option of direct review of the evidence considered by the Agency of Original Jurisdiction (AOJ).

The Veteran submitted evidence during a period of time when new evidence was not allowed. Therefore, the Board may not consider this evidence. The Veteran may submit this evidence, along with a Supplemental Claim. If the new evidence is relevant, VA will issue another decision on the claim, considering the new evidence in addition to the evidence previously considered. Specific instructions for filing a Supplemental Claim are included with this decision.

TDIU

VA will grant TDIU when the evidence shows that a veteran is precluded by reason of a service-connected disability or disabilities from obtaining and following substantially gainful employment consistent with his education and occupational experience. See 38 C.F.R. §§ 3.340, 3.341, 4.16. The relevant issue is not whether the veteran is unemployed or has difficulty obtaining employment, but whether the veteran is capable of performing the physical and mental acts required by employment. Van Hoose v. Brown, 4 Vet. App. 361, 363 (1993). Advancing age, any impairment caused by conditions that are not service-connected, and prior unemployability status must be disregarded when determining whether a veteran is currently unemployable. 38 C.F.R. §§ 4.16(a), 4.19.

TDIU may be assigned when the schedular rating is less than total, where, if there is only one disability, the disability is rated at 60 percent or more, or where, if there are two or more disabilities, at least one disability is rated 40 percent or more and there is sufficient additional disability to bring the combined rating to 70 percent or more. 38 C.F.R. § 4.16(a). Disabilities of one or both upper extremities, or one or both lower extremities, including the bilateral factor, disabilities resulting from a common etiology or a single accident, and disabilities affecting a single body system such as orthopedic disabilities, will be considered as one disability for TDIU purposes. Where the percentage requirements for TDIU are not met, a total disability rating may nevertheless be assigned on an extraschedular basis when the veteran is unable to secure or follow a substantially gainful occupation as a result of his or her service-connected disability or disabilities. 38 C.F.R. § 4.16(b). The Board is precluded from assigning a TDIU rating on an extraschedular basis in the first instance. Instead, the Board must refer any claim that meets the criteria for referral for consideration of entitlement to TDIU on an extraschedular basis to the Director of Compensation and Pension Service. See Bowling v. Principi, 15 Vet. App. 1, 10 (2001).

Entitlement to TDIU for the period prior to October 16, 2018 is denied

The Veteran filed his claim seeking entitlement to TDIU on August 14, 2014. For the period from that date to August 1, 2015, the Veteran was in receipt of a 40 percent rating for L5 spondylolysis and spondylolisthesis, a 40 percent rating for right knee limitation of extension, a 30 percent rating for left knee limitation of extension, a 10 percent rating for tinnitus, and a noncompensable rating for left knee and right elbow scars, for a total combined rating of 80 percent. Effective August 1, 2015, the rating for L5 spondylolysis and spondylolisthesis was reduced to 10 percent, while the rating for right knee limitation of extension was reduced to a noncompensable rating, and the rating for left knee limitation of extension was reduced to a 10 percent rating; this reduced the total combined rating from 80 percent to 30 percent, effective August 1, 2015. Thereafter, effective October 1, 2015, the Veteran was granted service connection for an acquired psychiatric disorder, and assigned a disability rating of 70 percent, which increased the total combined rating from 30 percent back up to 80 percent. Effective March 9, 2016, the Veteran was awarded a temporary 100 percent rating for convalescence following his left knee total arthroplasty. Before that 100 percent total rating ended, he was then awarded a temporary 100 percent rating for convalescence following his right knee total arthroplasty. That temporary 100 percent rating was discontinued on May 1, 2018. From that date, he was in receipt of separate 30 percent ratings for residuals of left and right knee arthroplasty. He was also in receipt of a 20 percent rating for L5 spondylolysis and spondylolisthesis, so the total combined rating of his disabilities from May 1, 2018 was 90 percent. Most recently, effective October 16, 2018, the rating for L5 spondylolysis and spondylolisthesis was increased to 40 percent, and the Veteran was also awarded separate 20 percent ratings for right and left lower extremity radiculopathy. This increased the total combined rating for the Veteran’s service-connected disabilities to 100 percent. (As no single service-connected disability is rated as 100 percent disabling as of October 16, 2018, notwithstanding the combined 100 percent rating, the TDIU claim is moot from that date onwards.)

In summation, for the periods from August 1, 2014 to August 1, 2015, from October 1, 2015 to March 9, 2016, and from May 1, 2018 to October 16, 2018, the Veteran met the schedular requirements for the grant of TDIU.

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Related

Gary D. Bradley v. James B. Peake
22 Vet. App. 280 (Veterans Claims, 2008)
Van Hoose v. Brown
4 Vet. App. 361 (Veterans Claims, 1993)
Bowling v. Principi
15 Vet. App. 1 (Veterans Claims, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
181017-593, Counsel Stack Legal Research, https://law.counselstack.com/opinion/181017-593-bva-2019.