190307-4595

CourtBoard of Veterans' Appeals
DecidedSeptember 30, 2019
Docket190307-4595
StatusUnpublished

This text of 190307-4595 (190307-4595) 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
190307-4595, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 09/30/19 Archive Date: 09/30/19

DOCKET NO. 190307-4595 DATE: September 30, 2019

ORDER

Entitlement to an effective date earlier than April 25, 2017, for an increased 70 percent rating for posttraumatic stress disorder (PTSD) is denied.

A rating in excess of 70 percent from April 25, 2017 to March 18, 2019 for PTSD is denied.

Entitlement to a total disability rating based on individual unemployability (TDIU) is granted.

FINDINGS OF FACT

1. The Veteran’s claim for an increased disability rating for PTSD was received by VA on April 25, 2017; there is no indication that a claim was received earlier than that date, nor is it factually ascertainable that an increase in severity warranting a 70 percent or higher rating occurred during the year prior to filing his claim.

2. At no time during the pendency of the appeal has the Veteran’s PTSD manifested in total social and occupational impairment.

3. The Veteran’s service-connected disabilities have precluded substantially gainful employment.

CONCLUSIONS OF LAW

1. The criteria for an effective date earlier than April 25, 2017, for an increased 70 percent rating for PTSD, have not been met. 38 U.S.C. §§ 5107, 5110; 38 C.F.R. §§ 3.102, 3.400.

2. For the entire appeal period, the criteria for a rating in excess of 70 percent for PTSD have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.102, 3.159, 3.321, 4.1, 4.3, 4.126, 4.130, Diagnostic Code 9411.

3. The requirements for a TDIU are met. 38 U.S.C. § 1155; 38 C.F.R. §§ 3.340, 3.341, 4.16.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Board notes that the rating decision on appeal was issued in February 2018. In April 2019, the Veteran elected the modernized review system.

The Veteran had active service from March 1969 to March 1971, July 1978 to April 1984, and January 1991 to July 1991. The Veteran selected the Direct Review lane when he opted into the Appeals Modernization Act (AMA) review system by submitting Form 10182 within 60 days of the Statement of the Case (SOC) for an increased rating for PTSD, which was issued on March 18, 2019 after implementation of the AMA. See VA Claims and Appeals Modernization, 84 Fed. Reg. 138, 171 (Jan. 18, 2019) (to be codified at 38 C.F.R. § 3.2400(c)(2)). Thus, the Veteran has properly opted into the modernized review system.

The Board further finds that the issue of entitlement to a TDIU is properly before the Board. In this regard, under the AMA, in order for the Board to take jurisdiction over a claim for a TDIU as part and parcel of a rating issue on appeal—in this case, PTSD—the evidence of unemployability must (1) be submitted prior to the AOJ decision or during an applicable 90-day evidence submission period; and (2) pertain to the period on appeal. As those criteria have been met, the issue of entitlement to a TDIU is properly before the Board.

Finally, the Board observes that the agency of original jurisdiction (AOJ) issued a SOC in January 2019 that denied service connection for ulcerative colitis and denied entitlement to a TDIU. The Veteran filed a VA Form 10182 on March 7, 2019 attempting to request Direct Review of these issues by the Board under the AMA. However, as the AMA had not yet been implemented at the time of the January 2019 SOC, the issues are ineligible for AMA review by the Board. Accordingly, while the Board has taken jurisdiction over the issue of entitlement to a TDIU under AMA as an issue part and parcel with the increased rating claim for PTSD under Rice v. Shinseki, 22 Vet. App. 447 (2009), the issue of service connection for ulcerative colitis is not before the Board.

A. Effective Date – PTSD

An award of direct service connection will be effective on the day following separation from active military service or the date on which entitlement arose if the claim is received within one year of separation from service. Otherwise, except as specifically provided, the effective date of an evaluation and award for 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.

Effective dates for increased evaluations for disability compensation are addressed under 38 C.F.R. § 3.400(o)(2), which provides that the effective date of an increased rating shall be the earliest date as of which it is factually ascertainable that an increase in disability occurred if the application was received within one year from such date. However, the exception articulated in 38 C.F.R. § 3.400(o)(2) only applies where an increase in disability precedes a claim for an increased disability rating; otherwise, the effective date is determined by the general rule outlined above. Hazan v. Gober, 10 Vet. App. 511 (1997); Servello v. Derwinski, 3 Vet. App. 196 (1992).

Effective March 24, 2015, VA amended its adjudication regulations to require that all claims governed by VA’s adjudication regulations be filed on standard forms prescribed by the Secretary. See 79 Fed. Reg. 57,660 (Sept. 25, 2014). This rulemaking also eliminated the constructive receipt of VA reports of hospitalization or examination and other medical records as informal claims for increase and revised 38 C.F.R. § 3.400(o)(2). These amendments are applicable with respect to claims and appeals filed on or after March 24, 2015. Id. at 57,686.

By way of history, in a June 2003 rating decision, the AOJ denied service connection for PTSD. The Veteran did not appeal the decision and it became final. In a rating decision issued in May 2012, the AOJ confirmed and continued the previous denial of service connection for PTSD. The Veteran did not appeal the decision and it became final. In August 2013, the Veteran filed a claim to reopen, and in a July 17, 2015 rating decision, the AOJ granted service connection for PTSD and awarded a temporary total rating from September 1, 2010, and a 30 percent rating from October 1, 2010. The Veteran did not appeal the decision and it too became final.

On April 25, 2017, VA received the Veteran’s intent to file a claim for compensation as reflected in the May 2017 notification letter. In December 2017, the Veteran filed a VA Form 21-526b, Veteran Supplemental Claim, for an increased PTSD rating. Based on the findings of the February 2018 VA examination, VA, in a February 2018 rating decision, increased the Veteran’s disability rating from 30 percent to 70 percent disabling, effective April 25, 2017.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Genaro Vazquez-Claudio v. Shinseki
713 F.3d 112 (Federal Circuit, 2013)
Servello v. Derwinski
3 Vet. App. 196 (Veterans Claims, 1992)
Hazan v. Gober
10 Vet. App. 511 (Veterans Claims, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
190307-4595, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190307-4595-bva-2019.