19-20 104

CourtBoard of Veterans' Appeals
DecidedSeptember 18, 2019
Docket19-20 104
StatusUnpublished

This text of 19-20 104 (19-20 104) 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
19-20 104, (bva 2019).

Opinion

Citation Nr: 19172616 Decision Date: 09/18/19 Archive Date: 09/18/19

DOCKET NO. 19-20 104 DATE: September 18, 2019

ORDER

An effective date earlier than December 10, 2014, for the grant of service connection for radiculopathy of the left lower extremity is denied.

An initial rating higher than 20 percent for radiculopathy of the left lower extremity is denied.

A total disability rating based on individual unemployability (TDIU) is granted, subject to the regulations governing the payment of monetary awards.

FINDINGS OF FACT

1. Service connection was granted for radiculopathy of the left lower extremity effective December 10, 2014, the day an increased rating claim for a low back disability was received.

2. The level of the Veteran’s radiculopathy of the left lower extremity has not more nearly approximated moderately severe.

3. The Veteran’s service-connected disabilities include posttraumatic stress disorder (PTSD) and adjustment disorder (rated 70 percent disabling prior to August 1, 2016, and 50 percent disabling thereafter); radiculopathy of the left lower extremity (rated 20 percent disabling); low back disability (rated 10 percent disabling); left knee meniscus injury with hyperextension (rated 10 percent disabling); and eczema (rated noncompensably disabling). His combined evaluation for compensation is 80 percent prior to August 1, 2016, and 70 percent thereafter.

4. The evidence is at least evenly balanced as to whether the Veteran’s service-connected disabilities precluded him from securing and following substantially gainful employment consistent with his education and occupational experience.

CONCLUSIONS OF LAW

1. The criteria for an effective date earlier than December 10, 2014, for the grant of service connection for radiculopathy of the left lower extremity are not met. 38 U.S.C. §§ 5110(a), 7105(d)(3); 38 C.F.R. §§ 3.104, 3.155 (in effect prior to March 24, 2015), 3.156, 3.400, 20.302, 20.1103.

2. The criteria for an initial rating higher than 20 percent for radiculopathy of the left lower extremity are not met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.3, 4.7, 4.40, 4.45, 4.59, 4.71a, Diagnostic Code (DC) 8520.

3. With reasonable doubt resolved in favor of the Veteran, the criteria for a TDIU are met. 38 U.S.C. § 1155, 5107, 5110; 38 C.F.R. §§ 4.1-4.7, 4.16.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty from August 2003 to October 2006 and September 2008 to October 2008.

This matter comes before the Board of Veterans’ Appeals (Board) on appeal from a May 2015 rating decision of the Department of Veterans Affairs (VA) Regional Office (RO). In that decision, the RO, in pertinent part, granted service connection for radiculopathy of the left lower extremity and assigned a 20 percent rating effective December 10, 2014. The Veteran timely disagreed with the initial assigned rating and the effective date of the grant of service connection for radiculopathy left lower extremity.

The issue of entitlement to a TDIU has been raised as part and parcel to the Veteran’s claim for a higher initial rating for radiculopathy of the left lower extremity. See Rice v. Shinseki, 22 Vet. App. 447 (2009). Notably, in a March 2014 rating decision, the RO denied entitlement to a TDIU. In a March 2019 Board remand, pertaining to other issues that are not before the Board at this, it remanded the issue of entitlement to a TDIU for further development. Nevertheless, the evidence raises the question whether the Veteran is able to obtain or sustain gainful employment due to his service-connected radiculopathy of the left lower extremity and therefore will be addressed herein.

1. An effective date earlier than December 10, 2014, for the grant of service connection for radiculopathy left lower extremity.

Generally, 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 effective date for an award of disability compensation based on an original claim for direct service connection is the day following separation from active service or the date entitlement arose if a claim is received within one year after separation from service. Otherwise, the effective date is the date of receipt of the claim or the date entitlement arose, whichever is later. 38 U.S.C. § 5110(b)(1); 38 C.F.R. § 3.400(b)(2)(i).

VA amended its adjudication regulations on March 24, 2015, to require that all claims governed by VA’s adjudication regulations be filed on standard forms prescribed by the Secretary, regardless of the type of claim or posture in which the claim arises. See 79 Fed. Reg. 57660 (Sept. 25, 2014). The amendments, however, are only effective for claims and appeals filed on or after March 24, 2015. As the claim in this case was filed prior to that date, the amendments are not applicable in this instance and the regulations in effect prior to March 24, 2015, will be applied in this case.

Under the former legal authority, any communication or action, indicating an intent to apply for one or more benefits under laws administered by VA, from a veteran or his representative, may be considered an informal claim. Such informal claim must identify the benefit sought. Upon receipt of an informal claim, if a formal claim has not been filed, an application form will be forwarded to the claimant for execution. If received within one year from the date it was sent to the veteran, it will be considered filed as of the date of receipt of the informal claim. 38 C.F.R. § 3.155(a) (in effect prior to March 24, 2015).

There is no set form that an informal written claim must take. All that is required is that the communication indicates an intent to apply for one or more benefits under the laws administered by VA, and identify the benefits sought. Rodriguez v. West, 189 F.3d 1351 (1999).

The Veteran contends that he is entitled to an effective date prior to December 10, 2014, for the grant of service connection for radiculopathy of the left lower extremity. For the following reasons, an effective date earlier than December 10, 2014, for the award of service connection for radiculopathy of the left lower extremity is not warranted.

On December 10, 2014, the Veteran’s claim for an increased rating for the low back was received. See VA 21-0820 report of general information dated December 2014.

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19-20 104, Counsel Stack Legal Research, https://law.counselstack.com/opinion/19-20-104-bva-2019.