181106-852

CourtBoard of Veterans' Appeals
DecidedApril 30, 2019
Docket181106-852
StatusUnpublished

This text of 181106-852 (181106-852) 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
181106-852, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 04/30/19 Archive Date: 04/29/19

DOCKET NO. 181106-852 DATE: April 30, 2019

ORDER

An effective date of March 22, 2016, for the grant of a total disability rating based on unemployability due to service-connected disabilities (TDIU), is granted.

An effective date of March 22, 2016, for the grant of Dependents’ Educational Assistance (DEA) benefits, is granted.

FINDINGS OF FACT

1. It was factually ascertainable by October 15, 2013, that the Veteran’s service-connected acquired psychiatric disorder, lumbar disc disease, and bilateral lower extremity disabilities, rendered her unemployable, and her claim of entitlement to a TDIU was received by VA on March 22, 2016, more than one year later.

2. The assigned effective date for DEA benefits is directly related to the award of a TDIU.

CONCLUSIONS OF LAW

1. The criteria for an effective date earlier of March 22, 2016, for the grant of a TDIU, are met. 38 U.S.C. § 5110(a)(b)(2); 38 C.F.R. §§ 3.340, 3.341(a), 3.400(o), 4.16(a)(b).

2. The criteria for an effective date earlier of March 22, 2016, for the grant of DEA benefits, are met. 38 U.S.C. §§ 3501(a)(1), 5113(a); 38 C.F.R. §§ 3.807(a), 21.3021.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty from April 1992 to July 2004. On May 14, 2018, the Veteran opted to have her claim of entitlement to a TDIU processed under the rapid appeals modernization program (RAMP) and requested a higher-level review. She was informed in an August 2018 letter that the review would be based on the evidence submitted to VA as of the date of her election. Following an October 2018 rating decision, a higher-level review, which granted a TDIU and DEA benefits, each effective October 2, 2018, she appealed to the Board under direct review in November 2018 the issues of entitlement to effective dates earlier than October 2, 2018, for the grants of a TDIU and DEA benefits.

Entitlement to effective dates earlier than October 2, 2018, for the grants of a TDIU and DEA benefits.

Except as otherwise provided, the effective date of an evaluation and award of pension, compensation, or dependency and indemnity 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(a); 38 C.F.R. § 3.400.

The grant of a TDIU is an award of increased disability compensation for purposes of assigning an effective date. See Rice v. Shinseki, 22 Vet. App. 447, 454 (2009), Dalton v. Nicholson, 21, Vet. App. 23, 32-34 (2007); Wood v. Derwinski, 1 Vet. App. 367, 369 (1991). The effective date of an award of increased compensation shall be the earliest date as of which it is ascertainable that an increase in disability had occurred, if the application is received within one year from such date; otherwise, it is the date of receipt of the claim. 38 U.S.C. § 5110(a)(b)(2); 38 C.F.R. § 3.400(o). Thus, the effective date of an award of increased compensation may be assigned up to one year prior to the date of claim, if an ascertainable increase in disability is established during that period. See Hazan v. Gober, 10 Vet. App. 511, 519 (1992); see also Hart v. Mansfield, 21 Vet. App. 505, 509-10 (2007) (noting that “the relevant temporal focus” in an increased rating claim is on “the state of the disability from the time period one year before the claim was filed until VA makes a final decision on the claim”).

Total disability ratings for compensation may be assigned, where the schedular rating is less than 100 percent, when the disabled person is, in the judgment of the rating agency, unable to secure or follow a substantially gainful occupation as a result of one or more service-connected disabilities without regard to advancing age or nonservice-connected disability, provided that, if there is only one such disability, this disability shall be ratable at 60 percent or more, or if there are two or more disabilities, there shall be at least one ratable at 40 percent or more, and sufficient additional disability to bring the combined rating to 70 percent or more. See 38 C.F.R. §§ 3.340, 3.341(a), 4.16(a); Hatlestad v. Brown, 5 Vet. App. 524, 529 (1993) (holding that the central inquiry is whether the Veteran’s service-connected disabilities alone are of sufficient severity to produce unemployability); see also 38 C.F.R. § 4.19 (unemployability associated with advancing age or intercurrent disability may not be used as a basis for a total disability rating). The claimant’s service-connected disabilities, employment history, educational and vocational attainment, and all other factors having a bearing on the issue must be considered. 38 C.F.R. § 4.16 (b).

For purposes of DEA benefits under 38 U.S.C. Chapter 35, the law relevant to the Veteran’s current claim provides that basic eligibility exists where the Veteran was discharged from service under conditions other than dishonorable and has a total disability permanent in nature as a result of a service-connected disability. 38 U.S.C. § 3501 (a)(1); 38 C.F.R. §§ 3.807 (a), 21.3021. With certain exceptions, the effective date for the grant of such award shall, to the extent feasible, correspond to effective dates for awards of disability compensation. 38 U.S.C. § 5113 (a).

The Veteran filed a March 22, 2016, claim of entitlement to a TDIU. No party asserts that there is a claim of entitlement to a TDIU prior to March 22, 2016. She asserted that she was unemployable due to her service-connected acquired psychiatric disorder, left carpal tunnel syndrome, lumbar disc disease, and sciatica of the left lower extremity, and had last worked as a health and/or surgical technician at a VA medical facility in October 2012. In July 2016, the Veteran’s last employer reported that she last worked full-time on October 1, 2012, as a health technician and resigned.

Effective March 22, 2016, the Veteran met the schedular requirements for a TDIU, she had at least one disability ratable at 40 percent or more, and sufficient additional disability to bring the combined rating to 70 percent or more. Her acquired psychiatric disorder was rated as 50 percent disabling and her combined rating was 80 percent. 38 C.F.R. § 4.16(a)

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Related

Brian J. Hart v. Gordon H. Mansfield
21 Vet. App. 505 (Veterans Claims, 2007)
Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Wood v. Derwinski
1 Vet. App. 367 (Veterans Claims, 1991)
Collier v. Derwinski
1 Vet. App. 413 (Veterans Claims, 1991)
Hatlestad v. Brown
5 Vet. App. 524 (Veterans Claims, 1993)
Hazan v. Gober
10 Vet. App. 511 (Veterans Claims, 1997)

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181106-852, Counsel Stack Legal Research, https://law.counselstack.com/opinion/181106-852-bva-2019.