190114-1923

CourtBoard of Veterans' Appeals
DecidedMay 21, 2019
Docket190114-1923
StatusUnpublished

This text of 190114-1923 (190114-1923) 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
190114-1923, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 05/21/19 Archive Date: 05/21/19

DOCKET NO. 190114-1923 DATE: May 21, 2019

ORDER

An effective date earlier than October 7, 2016, for the grant of a 50 percent rating for posttraumatic stress disorder (PTSD) is denied.

An effective date earlier than November 29, 2017, for the grant of a 20 percent rating for a right shoulder disability is denied.

Specially adapted housing (SAH) is denied.

A special home adaptation grant (SHA) is denied.

FINDINGS OF FACT

1. The Veteran served on active duty from May 1981 to March 1991, he has been rated at 100 percent disabled based on unemployability since July 2016 and at a 100 percent schedular rating since November 2017.

2. In June 2017, the Regional Office (RO) granted service connection for PTSD and assigned a 30 percent rating effective August 6, 2009. Subsequently, the RO increased the rating to 50 percent effective November 29, 2017, the date the Veteran filed a claim for a total disability rating based on individual unemployability (TDIU).

3. For the period from August 6, 2009, to October 7, 2016, PTSD was manifested by depressed mood, anxiety, and sleep impairment, as well as forgetfulness, and intrusive thoughts; there is no evidence of occupational and social impairment with reduced reliability and productivity.

4. In May 2012, the RO granted service connection for a right shoulder disability and assigned a 10 percent rating effective February 25, 2012. In March 2018, the RO increased the rating to 20 percent effective November 29, 2017, the date the Veteran filed a claim for a TDIU.

5. For the period from February 25, 2012, to November 29, 2017, the right shoulder disability was manifested by pain, but not nonunion or dislocation of the clavicle or scapula, a humerus impairment, ankylosis, or limitation of motion functionally limited to shoulder level or less.

6. It is not factually ascertainable that there was an increase in the Veteran’s right shoulder disability in the one-year period prior to the November 29, 2017, claim for TDIU.

7. The Veteran does not have a permanent and total service-connected disability due to loss or loss of use of both lower or upper extremities, blindness plus anatomical or loss of use of one lower extremity, loss or loss of use of one lower extremity together with residuals of organic disease or injury or loss of use of one upper extremity affecting balance or propulsion, full thickness or subdermal burns resulting in contracture, or amyotrophic lateral sclerosis.

8. The Veteran does not have a permanent and total service-connected disability which includes the anatomical loss or loss of use both hands or is due to deep partial thickness burns or full thickness or subdermal burns resulting in contracture or is due to residuals of an inhalation injury; and he is not service-connected for blindness in both eyes.

CONCLUSIONS OF LAW

1. The criteria for an effective date earlier than October 7, 2016, for the grant of a 50 percent rating for PTSD have not been met. 38 U.S.C. § 5110 (2012); 38 C.F.R. §§ 3.1, 3.151, 3.155, 3.400 (2018).

2. The criteria for an effective date earlier than November 29, 2017, for the grant of a 20 percent rating for a right shoulder disability have not been met. 38 U.S.C. § 5110 (2012); 38 C.F.R. §§ 3.1, 3.151, 3.155, 3.400 (2018).

3. The criteria for establishing eligibility for financial assistance for SAH have not been met. 38 U.S.C. § 2101(a) (2012); 38 C.F.R. §§ 3.350, 3.809 (2018).

4. The criteria for establishing eligibility for financial assistance for SHA have not been met. 38 U.S.C. § 2101(b) (2012); 38 C.F.R. §§ 3.350, 3.809a (2018).

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

As a procedural matter, the rating decision on appeal was issued in December 2018. In October 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)). He selected the Higher-Level Review lane when he opted in to the Appeals Modernization Act (AMA) review system by submitting a Rapid Appeals Modernization Program (RAMP) election form in October 2018. Accordingly, the December 2018 AMA rating decision considered the evidence of record as of the date VA received the RAMP election form. He timely appealed this rating decision to the Board and requested direct review of the evidence considered by the Agency of Original Jurisdiction (AOJ).

Effective Date Claims

The pertinent provisions of 38 C.F.R. § 3.400 clarify that, except as otherwise provided, 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. Specifically, as to claims for increase, 38 C.F.R. § 3.400 provides that the effective date of an evaluation and award of compensation based on a claim for increase will be the date as of which it is factually ascertainable that an increase in disability had occurred if claim is received within 1 year from such date, otherwise, date of receipt of claim. 38 C.F.R. § 3.400(o).

The law and regulations provide that the effective date for an increase will be as follows: If the increase 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 award 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).

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.

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.

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Related

Harper v. Brown
10 Vet. App. 125 (Veterans Claims, 1997)
Doucette v. Shulkin
28 Vet. App. 366 (Veterans Claims, 2017)

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190114-1923, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190114-1923-bva-2019.