190204-1776

CourtBoard of Veterans' Appeals
DecidedMay 9, 2019
Docket190204-1776
StatusUnpublished

This text of 190204-1776 (190204-1776) 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
190204-1776, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 05/09/19 Archive Date: 05/09/19

DOCKET NO. 190204-1776 DATE: May 9, 2019

ORDER

Entitlement to an earlier effective date than January 17, 2017, for the grant of service connection for left lower extremity radiculopathy, including femoral nerve and sciatic nerve is denied.

Entitlement to an earlier effective date than January 17, 2017 for the grant of service connection for right lower extremity radiculopathy, including femoral nerve and sciatic nerve is denied.

Entitlement to an earlier effective date than January 23, 2017 for award of a 70 percent evaluation of major depressive disorder is denied.

Entitlement to an effective date of January 27, 2017 for the award of a 50 percent evaluation of migraine headaches is granted.

Entitlement to an effective date of February 16, 2017, but not earlier, for the award of a 40 percent evaluation of lumbar strain with intervertebral disc syndrome (IVDS) is granted.

FINDINGS OF FACT

1. The date of claim for service connection for bilateral lower extremity radiculopathy, including femoral nerve and sciatic nerve is January 17, 2017.

2. The date that all criteria were met to establish service connection for bilateral lower extremity radiculopathy is February 16, 2017.

3. In a May 2015 rating decision, the Veteran was assigned an increased rating of 50 percent for major depressive disorder, effective December 12, 2014. The Veteran did not appeal this rating decision and it became final.

4. On January 23, 2017, a claim for an increased rating for major depressive disorder was received from the Veteran.

5. The exact onset of the Veteran’s current symptoms and level of psychiatric disability cannot be determined; however, it was factually ascertainable that any increase in severity of the Veteran’s major depressive disorder occurred more than one year prior to his claim for an increased disability rating.

6. In a May 2015 rating decision, the Veteran’s 30 percent rating for migraine headaches was continued. The Veteran did not appeal this rating decision and it became final.

7. On January 23, 2017, a claim for an increased rating for migraine headaches was received from the Veteran.

8. The exact onset of the Veteran’s current symptoms and level of disability from headaches cannot be determined; however, it was factually ascertainable that any increase in severity of the Veteran’s migraine headaches occurred on or about the date of his claim for an increased disability rating.

9. In a May 2015 rating decision, the Veteran’s 10 percent rating for lumbar strain was continued. The Veteran did not appeal this rating decision and it became final.

10. The date of claim for an increased rating for the service-connected low back disability is January 23, 2017, the date that it is factually ascertainable that the Veteran’s condition increased in severity, i.e. that his limitation of flexion decreased, is February 16, 2017.

CONCLUSIONS OF LAW

1. The criteria for an earlier effective date for service connection of left lower extremity radiculopathy have not been met. 38 U.S.C. §§ 5107, 5110; 38 C.F.R. §§ 3.155, 3.400.

2. The criteria for an earlier effective date for service connection of right lower extremity radiculopathy have not been met. 38 U.S.C. §§ 5107, 5110; 38 C.F.R. §§ 3.155, 3.400.

3. The criteria for an earlier effective for the grant of a 70 percent evaluation of major depressive disorder have not been met. 38 U.S.C. §§ 5107, 5110; 38 C.F.R. §§ 3.155, 3.400.

4. The criteria for an effective date of January 27, 2017, for the grant of a 50 percent evaluation of migraine headaches have been met. 38 U.S.C. §§ 5107, 5110; 38 C.F.R. §§ 3.155, 3.400.

5. The criteria for an effective date of February 16, 2017, but no earlier, for a grant of a 40 percent evaluation of lumbar strain with IVDS have been met. 38 U.S.C. §§ 5107, 5110; 38 C.F.R. §§ 3.155, 3.400.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty in the United States Navy from October 1958 to December 1962.

The Board notes that the rating decision on appeal was issued in January 2019. 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)).

The Veteran 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. Accordingly, the January 2019 AMA rating decision considered the evidence of record as of the date VA received the RAMP election form. The Veteran 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

In assigning effective dates, the general rule is that, except as otherwise provided, 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 a 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. As an exception to the general rule, for direct service connection, the effective date is the day after separation from service or the date entitlement arose, if the claim is received within one year of separation from service; otherwise the general rule applies. 38 U.S.C. § 5110 (b)(1); 38 C.F.R. § 3.400 (b)(2)(i). The date of entitlement is the date the claimant meets the basic eligibility criteria for the benefit.

In assigning effective dates for increases, except as provided in paragraph § 3.400(o)(2) and § 3.401(b), the effective date is date of receipt of claim or date entitlement arose, whichever is later. As an exception to this general rule, § 3.400(o)(2) provides that the effective date is the earliest date of which it is factually ascertainable based on all evidence of record that an increase in disability had occurred if a complete claim or intent to file a claim is received within one year from such date; otherwise the effective date is the date of claim.

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Bluebook (online)
190204-1776, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190204-1776-bva-2019.