181128-1525

CourtBoard of Veterans' Appeals
DecidedMarch 19, 2019
Docket181128-1525
StatusUnpublished

This text of 181128-1525 (181128-1525) 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
181128-1525, (bva 2019).

Opinion

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

DOCKET NO. 181128-1525 DATE: March 19, 2019

ORDER

An effective date of August 5, 2011, but no earlier, for the grant of a 70 percent evaluation for schizophrenia is granted.

An effective date of August 5, 2011, but no earlier, for the grant of a total disability rating due to individual unemployability (TDIU) is granted.

FINDINGS OF FACT

1. The earliest pending claims for entitlement to service connection for schizophrenia and for entitlement to a TDIU were August 5, 2011.

2. Evidence of record does not show a factually ascertainable increase in disability warranting assignment of an increased evaluation for schizophrenia or entitlement to a TDIU occurred prior to August 5, 2011.

3. Since August 5, 2011, the Veteran’s schizophrenia has caused occupational and social impairment, with deficiencies in most areas, such as work, school, family relations, judgment, thinking, or mood and prevented substantially gainful employment.

CONCLUSIONS OF LAW

1. The criteria for the assignment of an effective date of August 5, 2011, but no earlier, for the award of a 70 percent evaluation for schizophrenia have been satisfied. 38 U.S.C. § 5110; 38 C.F.R. §§ 3.102, 3.400, 4.130, Diagnostic Code 9205.

2. The criteria for the assignment of an effective date of August 5, 2011, but no earlier, for the award of entitlement to a TDIU have been satisfied. 38 U.S.C. §§ 5107, 5110; 38 C.F.R. §§ 3.102, 3.400, 4.16.

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 had active service in the United States Marines Corps from September 1993 to September 1977. The matters are on appeal from a September 2018 decision, which granted a 70 percent evaluation for schizophrenia and entitlement to a TDIU, effective September 19, 2017.

Earlier Effective Dates

A reasonably raised claim remains pending until there is either recognition of the substance of the claim in a RO decision from which a claimant could deduce that the claim was adjudicated or an explicit adjudication of a subsequent “claim” for the same disability. See Deshotel v. Nicholson, 457 F.3d 1258, 1261 (Fed. Cir. 2006) and Myers v. Principi, 16 Vet. App. 228, 229 (2002); 38 C.F.R. § 3.160(c).

VA law and regulation provide that unless otherwise provided, the effective date of an award of increased evaluation shall be fixed in accordance with the facts found, but shall not be earlier than the date of receipt of the application therefor. 38 U.S.C. § 5110(a); 38 C.F.R. § 3.400. Regulations also provide that the effective date of an evaluation and award of compensation based on a claim for increase will be the date of receipt of the claim or the date entitlement arose, whichever is the later. 38 C.F.R. § 3.400(o)(1).

The Board notes that the effective date of an award of increased compensation may, however, be established at the earliest date as of which it is factually ascertainable that an increase in disability had occurred, if the application for an increased evaluation is received within one year from that date. 38 U.S.C. § 5110(b)(2); 38 C.F.R. § 3.400(o)(2).

Three possible dates may be assigned depending on the facts of a case: (1) if an increase in disability occurs after the claim is filed, the date that the increase is shown to have occurred (date entitlement arose) (38 C.F.R. § 3.400(o)(1)); (2) if an increase in disability precedes the claim by a year or less, the date that the increase is shown to have occurred (factually ascertainable) (38 C.F.R. § 3.400(o)(2)); or (3) if an increase in disability precedes the claim by more than a year, the date that the claim is received (date of claim) (38 C.F.R. § 3.400(o)(2)). See Harper v. Brown, 10 Vet. App. 125, 126 (1997).

Thus, determining an appropriate effective date for an increased rating under the effective date regulations involves an analysis of the evidence to determine (1) when a claim for an increased rating was received and, if possible, (2) when the increase in disability actually occurred. 38 C.F.R. §§ 3.155, 3.400(o)(2).

Under applicable laws and regulations, if an increase in disability occurred within one year prior to the claim, the increase is effective as of the date the increase was “factually ascertainable.” If the increase occurred more than one year prior to the claim, the increase is effective the date of claim. If the increase occurred after the date of claim, the effective date is the date of increase. 38 U.S.C. § 5110(b)(2); Harper v. Brown, 10 Vet. App. 125 (1997); 38 C.F.R. § 3.400 (o)(1) 2); VAOPGCPREC 12-98 (1998). In making this determination the Board must consider all of the evidence, including that received prior to previous final decisions. Hazan v. Gober, 10 Vet. App. 511 (1997).

VA recognizes formal and informal claims. A formal claim is one that has been filed in the form prescribed by VA. See 38 U.S.C. § 5101(a); 38 C.F.R. § 3.151(a). An informal claim may be any communication or action, indicating an intent to apply for one or more benefits under VA law. Thomas v. Principi, 16 Vet. App. 197 (2002); see 38 C.F.R. §§ 3.1(p), 3.155(a). An informal claim must be written, see Rodriguez v. West, 189 F. 3d. 1351 (Fed. Cir. 1999), and it must identify the benefit being sought. Brannon v. West, 12 Vet. App. 32, 34-5 (1998). All filings by a claimant must be construed based on a liberal reading. See Robinson v.

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Related

Robinson v. Shinseki
557 F.3d 1355 (Federal Circuit, 2009)
Deshotel v. Nicholson
457 F.3d 1258 (Federal Circuit, 2006)
McGrath v. Gober
14 Vet. App. 28 (Veterans Claims, 2000)
Myers v. Principi
16 Vet. App. 228 (Veterans Claims, 2002)
Thomas v. Principi
16 Vet. App. 197 (Veterans Claims, 2002)
Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Hatlestad v. Brown
5 Vet. App. 524 (Veterans Claims, 1993)
Harper v. Brown
10 Vet. App. 125 (Veterans Claims, 1997)
Hazan v. Gober
10 Vet. App. 511 (Veterans Claims, 1997)
Brannon v. West
12 Vet. App. 32 (Veterans Claims, 1998)

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181128-1525, Counsel Stack Legal Research, https://law.counselstack.com/opinion/181128-1525-bva-2019.