181206-1150

CourtBoard of Veterans' Appeals
DecidedMarch 19, 2019
Docket181206-1150
StatusUnpublished

This text of 181206-1150 (181206-1150) 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
181206-1150, (bva 2019).

Opinion

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

DOCKET NO. 181206-1150 DATE: March 19, 2019

ORDER

An effective date of July 7, 2016, but no earlier, for a 100 percent rating for loss of use of lower extremities is granted.

FINDING OF FACT

From July 7, 2016, the diminished functioning of the bilateral lower extremities has equated to loss of use of the bilateral feet and of the bilateral legs.

CONCLUSION OF LAW

The criteria for entitlement to an effective date of July 7, 2016, for the grant of a 100 percent rating for loss of use of lower extremities have been met. 38 U.S.C. §§ 1155, 5103(a), 5103A, 5107; 38 C.F.R. §§ 3.400, 4.71a, Diagnostic Code 5110.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Board notes that the rating decision on appeal was issued in March 2018. In May and December 2018, the Veteran elected the modernized review system. 84 Fed. Reg. 138, 177 (Jan. 18, 2019) (to be codified at 38 C.F.R. § 19.2(d)).

The assignment of effective dates of awards is generally governed by 38 U.S.C. § 5110 and 38 C.F.R. § 3.400. Except as otherwise provided, the effective date of an evaluation and an award of compensation based on an original claim or 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. If the increase became ascertainable more than one year prior to the date of receipt of the claim, then the proper effective date would be the date of claim. In a case where the increase became ascertainable after the filing of the claim, then the effective date would be the date of increase. See Harper v. Brown, 10 Vet. App. 125 (1997).

The “date of the claim” means the date of the application based upon which benefits are awarded, not the original claim for service connection. See Sears v. Principi, 16 Vet. App. 244, 246-47 (2002), aff’d, 349 F.3d 1326 (Fed. Cir. 2003). In this context, it should be noted that the provisions of 38 U.S.C. § 5110 also refer to the date an application is received. While the term “application” is not defined in the statute, the regulations use the terms “claim” and “application” interchangeably, and they are defined broadly to include “a formal or informal communication in writing requesting a determination of entitlement, or evidencing a belief in entitlement, to a benefit.” 38 C.F.R. §§ 3.1(p), 3.155; Servello v. Derwinski, 3 Vet. App. 196, 198 (1992).

In a March 2018 rating decision, the Agency of Original Jurisdiction (AOJ) granted service connection for loss of use of bilateral lower extremities (associated with degenerative disc disease of the lumbar spine), and assigned a 100 percent rating, effective January 18, 2018, pursuant to 38 C.F.R. § 4.71a, Diagnostic Code (DC) 5110. (The Board notes that service connection is also in effect for traumatic brain injury with traumatic encephalitis and Parkinson’s disease.) The Veteran asserts that an earlier effective date is warranted for the 100 percent rating assigned.

In a November 2018 rating decision, the AOJ denied an earlier effective date for the 100 percent rating as it was determined that as of January 18, 2018, which the AOJ determined was the date of his claim, the functioning of his bilateral lower extremities was so diminished that amputation by prosthesis would equally serve him, and prior to this date loss of use was not shown.

A 100 percent rating is warranted for loss of use of both feet under DC 5110. 38 C.F.R. § 4.71a, DC 5110. Additionally, a rating under DC 5110 does not preclude entitlement to special monthly compensation (SMC). 38 C.F.R. §§ 4.71a, DC 5110 at superscript 1. The Board notes that in March 2018, the AOJ granted SMC per 38 U.S.C. § 1114(o) and 38 C.F.R. § 3.350(e) based on loss of use of bilateral lower extremities, effective January 18, 2018. Although such is not in appellate status, should an earlier effective date be granted per DC 5110, the SMC per §§ 1114(o), 3.350(e) would be assigned from the same date.

The first question in this appeal is whether loss of use of the lower extremities is shown prior to January 18, 2018, and whether an effective date is warranted prior to such date. To determine whether an effective date is warranted, a look at the procedural history is necessary.

The Veteran’s bilateral lower extremities were previously separately rated 40 percent disabling in contemplation of radiculopathy associated with the lumbar spine, per 38 C.F.R. § 4.71a, DC 8520. Such ratings were assigned in a November 2015 rating decision, effective October 2, 2015.

On February 9, 2017, the Veteran filed an increased rating claim for, in pertinent part, neurological and movement disorders. In an August 2, 2017 rating decision, the AOJ, in pertinent part, granted service connection for bradykinesia and tremors, left and right lower extremities, assigning separate 10 percent ratings, and a 30 percent rating for balance impairment, effective June 9, 2016. Such ratings are still in effect.

On November 6, 2017, the Veteran filed a claim asserting that the August 2017 rating decision was in error as it failed to grant loss of use of bilateral lower extremities. In a January 17, 2018 rating decision, the AOJ denied increased ratings for radiculopathy of the bilateral lower extremities. On January 18, 2018, the Veteran requested reconsideration of the August 2017 rating decisions and specifically sought a rating for loss of use of bilateral lower extremities.

Based on the above, the Board has determined that the Veteran’s claim for loss of use of the lower extremities stems from his February 9, 2017 claim in which he was claiming neurological and movement disorders. Also, the 100 percent rating assigned in the March 2018 rating decision stems from the Veteran’s request for reconsideration of the August 2017 rating decision and his November 2017 assertion that a rating was warranted for loss of use of the bilateral lower extremities. It is also noted that during such periods additional medical evidence was associated with the claims folder pertaining to the lower extremities.

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Related

Servello v. Derwinski
3 Vet. App. 196 (Veterans Claims, 1992)
Harper v. Brown
10 Vet. App. 125 (Veterans Claims, 1997)
Sears v. Principi
16 Vet. App. 244 (Veterans Claims, 2002)

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Bluebook (online)
181206-1150, Counsel Stack Legal Research, https://law.counselstack.com/opinion/181206-1150-bva-2019.