181201-1461

CourtBoard of Veterans' Appeals
DecidedJune 27, 2019
Docket181201-1461
StatusUnpublished

This text of 181201-1461 (181201-1461) 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
181201-1461, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 06/27/19 Archive Date: 06/27/19

DOCKET NO. 181201-1461 DATE: June 27, 2019

ORDER

Entitlement to an effective date earlier than February 12, 2015, for an increased rating for a right ankle disability is denied.

Entitlement to an effective date earlier than February 12, 2015, for an increased rating for a back disability is denied.

Entitlement to an effective date earlier than February 12, 2015, for service connection for right lower extremity radiculopathy is denied.

REMANDED

Entitlement to service connection for a psychiatric disability, to include as secondary to service-connected back, headache, and ankle disabilities, is remanded.

Entitlement to service connection for sleep apnea, to include as secondary to service-connected back, headache, and right knee disabilities, is remanded.

Entitlement to service connection for a gastrointestinal disability, to include Barret’s Esophagus, stomach indigestion, and GERD, is remanded.

Entitlement to service connection for vertigo, to include as secondary to headaches and tinnitus, is remanded.

Entitlement to a rating in excess of 40 percent for a back disability is remanded.

Entitlement to a rating in excess of 30 percent for headaches is remanded.

Entitlement to an initial rating in excess of 10 percent for right leg radiculopathy is remanded.

Entitlement to a rating in excess of 10 percent for a right ankle sprain is remanded.

Entitlement to a total disability rating based on individual unemployability due to service-connected disabilities (TDIU) is remanded.

FINDINGS OF FACT

1. VA first received the Veteran’s claim for an increased rating for ankle and back disabilities on February 12, 2015. The Veteran established service connection for right lower extremity radiculopathy in connection with the back disability during the adjudication of that claim.

2. No earlier communication of record constitutes a claim for an increased rating for a back or ankle disability or service connection for right lower extremity radiculopathy, and the evidence does not show a factually ascertainable increase in the back or ankle disabilities during the year prior to the claim for increase.

CONCLUSIONS OF LAW

1. The criteria for entitlement to an effective date earlier than February 12, 2015, for an increased rating for a right ankle disability have not been met. 38 U.S.C. §§ 5101, 5110; 38 C.F.R. §§ 3.151, 3.155, 3.400.

2. The criteria for entitlement to an effective date prior to February 12, 2015, for an increased rating for a back disability are not met. 38 U.S.C. §§ 5101, 5110; 38 C.F.R. §§ 3.151, 3.155, 3.400.

3. The criteria for an effective date earlier than February 12, 2015, for service connection for right lower extremity radiculopathy have not been met. 38 U.S.C. §§ 5101, 5110; 38 C.F.R. §§ 3.151, 3.155, 3.400.

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 served on active duty from February 2008 to October 2012. This matter comes before the Board of Veterans’ Appeals (Board) from a September 2015, November 2016, and May 2017 rating decision of the Department of Veterans Affairs (VA) Regional Office (RO) in Seattle, Washington.

The Board notes that the February 2016 notice of disagreement included an earlier effective date claim for service-connected headaches. As the assigned rating for that disability remains unchanged during the appeal period, and the disagreement was to the rating assigned, the Board has characterized this issue as an increased rating claim.

Effective Date

Except as otherwise provided, the effective date of an evaluation and award of compensation based on an original claim or a claim reopened after final disallowance, will be the date of receipt of the claim or the date entitlement arose, whichever is later. 38 C.F.R. § 3.400. For increases in disability compensation, the effective date shall be the earliest date as of which it is factually ascertainable based on all the evidence of record that an increase in disability occurred if a claim or intent to file a claim is received within one year following that date. Otherwise, the effective date of increase shall be the date of receipt of the claim. When medical records indicate an increase in disability, receipt of those medical records may be used to establish effective dates for retroactive benefits based on the facts found of an increase in disability only if a claim for increase is filed within one year of the date of the medical report. 38 U.S.C. § 5110; 38 C.F.R. § 3.400(o).

At the time the increase was made, the regulation provided that the effective date of an increase in disability compensation was the earliest date as of which it is factually ascertainable that an increase in disability occurred if the claim is received within one year of that date. Otherwise, the effective date was the date of receipt of the claim. 38 C.F.R. § 3.400(o).

A specific claim in the form prescribed by VA must be filed in order for benefits to be paid to any individual under the laws administered by VA. 38 U.S.C. § 5110(a); 38 C.F.R. § 3.151(a). A claim is a written communication requesting a determination of entitlement or evidencing a belief in entitlement to a specific benefit. 38 C.F.R. § 3.1(p). If a formal claim is received within one year of an informal claim, it will be considered filed as of the date of receipt of the informal claim. 38 C.F.R. § 3.155. To determine when a claim was received, the Board must review all communications in the claims file that may be construed as an application or claim. Quarles v. Derwinski, 3 Vet. App. 129 (1992).

The Board finds that neither regulation supports the assignment of any earlier effective date.

1. Entitlement to an effective date earlier than February 12, 2015, for an increased rating for an ankle disability

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Related

Stanley J. Palczewski v. R. James Nicholson
21 Vet. App. 174 (Veterans Claims, 2007)
Colvin v. Derwinski
1 Vet. App. 171 (Veterans Claims, 1991)
Harris v. Derwinski
1 Vet. App. 180 (Veterans Claims, 1991)
Quarles v. Derwinski
3 Vet. App. 129 (Veterans Claims, 1992)
Hatlestad v. Derwinski
3 Vet. App. 213 (Veterans Claims, 1992)
Robinette v. Brown
8 Vet. App. 69 (Veterans Claims, 1995)

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181201-1461, Counsel Stack Legal Research, https://law.counselstack.com/opinion/181201-1461-bva-2019.