190426-18074

CourtBoard of Veterans' Appeals
DecidedMarch 31, 2021
Docket190426-18074
StatusUnpublished

This text of 190426-18074 (190426-18074) 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
190426-18074, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 03/31/21 Archive Date: 03/31/21

DOCKET NO. 190426-18074 DATE: March 31, 2021

ORDER

A 70 percent disability rating, but no higher, is granted for schizoaffective disorder, bipolar type, subject to the law and regulations governing the award of monetary benefits.

REMANDED

Entitlement to a total disability rating based upon individual unemployability due to service-connected disability (TDIU) is remanded.

FINDING OF FACT

For the period on appeal, the Veteran’s service-connected schizoaffective disorder, bipolar type was manifested by occupational and social impairment with deficiencies in most areas, without total occupational and social impairment.

CONCLUSION OF LAW

The criteria for a 70 percent rating, but no higher, for the Veteran’s schizoaffective disorder, bipolar type have been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.130, Diagnostic Code 9211.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty in the United States Navy from December 1988 through October 1989. The Veteran was discharged, in part, due to his psychiatric disability symptoms.

This case comes to the Board of Veterans’ Appeals (Board) on appeal from a March 2019 rating decision of a Department of Veterans Affairs (VA) Regional Office (RO), which granted service connection for schizoaffective disorder, bipolar type (hereinafter, “psychiatric disability”) and awarded a 10 percent disability rating.

In an April 2019 Notice of Disagreement (VA Form 10182), the Veteran disagreed with the 10 percent rating and requested a Board hearing. That hearing was held before a Veterans Law Judge in October 2020. A transcript of the hearing has been associated with the record.

1. Increased rating for psychiatric disability

Disability evaluations are determined by the application of a schedule of ratings, which is, in turn, based on the average impairment of earning capacity caused by a given disability. 38 U.S.C. § 1155; 38 C.F.R. § 4.1. Separate diagnostic codes identify the evaluations to be assigned to the various disabilities.

Where, as in the present case, the appeal arises from the original assignment of a disability evaluation following an award of service connection, the severity of the disability at issue is to be considered during the entire period from the initial assignment of the disability rating to the present time. See Fenderson v. West, 12 Vet. App. 119 (1999). In evaluating a disability, the Board considers the current examination reports in light of the whole recorded history to ensure that the current rating accurately reflects the severity of the condition. If there is a question as to which of two evaluations shall be applied, the higher evaluation will be assigned if the disability picture more nearly approximates the criteria required for that rating. Otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7.

If different disability ratings are warranted for different periods of time over the life of a claim, “staged” ratings may be assigned. Hart v. Mansfield, 21 Vet. App. 505 (2007); Fenderson, supra. In other words, where the evidence contains factual findings that demonstrate distinct time periods in which the service-connected disability exhibited diverse symptoms meeting the criteria for different ratings during the course of the appeal, the assignment of staged ratings would be necessary.

When there is an approximate balance of positive and negative evidence regarding any issue material to the determination of a matter, the Board shall resolve reasonable doubt in favor of the claimant. Gilbert v. Derwinski, 1 Vet. App. 49 (1990); 38 U.S.C. § 5107; 38 C.F.R. § 3.102.

The Board has reviewed all the evidence in the Veteran’s claims file. Although the Board has an obligation to provide adequate reasons and bases supporting this decision, there is no requirement that the evidence submitted by the Veteran or obtained on his behalf be discussed in detail. Rather, the Board’s analysis below will focus specifically on what evidence is needed to substantiate the claim and what the evidence in the claims file shows, or fails to show, with respect to the claim. See Gonzales v. West, 218 F.3d 1378, 1380-81 (Fed. Cir. 2000); Timberlake v. Gober, 14 Vet. App. 122, 128-30 (2000).

The Veteran’s psychiatric disability is evaluated in accordance with the criteria set forth in 38 C.F.R. § 4.130, Diagnostic Code 9211. Under that code, a 10 percent rating is warranted if the disorder is manifested by occupational and social impairment due to mild or transient symptoms which decrease work efficiency and the ability to perform occupational tasks only during periods of significant stress, or if the symptoms are controlled by continuous medication.

A 30 percent rating is warranted if the disorder is manifested by occupational and social impairment with an occasional decrease in work efficiency and intermittent periods of inability to perform occupational tasks (although generally functioning satisfactorily, with routine behavior, self-care, and conversation normal), due to such symptoms as depressed mood; anxiety; suspiciousness; panic attacks (weekly or less often); chronic sleep impairment; and mild memory loss (such as forgetting names, directions, and recent events).

A 50 percent rating is warranted if the disorder is manifested by occupational and social impairment with reduced reliability and productivity due to such symptoms as flattened affect; circumstantial, circumlocutory, or stereotyped speech; panic attacks (more than once a week); difficulty in understanding complex commands; impairment of short- and long-term memory (e.g., retention of only highly learned material, forgetting to complete tasks); impaired judgment; impaired abstract thinking; disturbances of motivation and mood; and difficulty in establishing and maintaining effective work and social relationships.

A 70 percent rating is warranted if the disorder is manifested by occupational and social impairment with deficiencies in most areas, such as work, school, family relations, judgment, thinking, or mood, due to such symptoms as suicidal ideation; obsessional rituals which interfere with routine activities; speech that is intermittently illogical, obscure, or irrelevant; near-continuous panic or depression affecting the ability to function independently, appropriately, and effectively; impaired impulse control (such as unprovoked irritability with periods of violence); spatial disorientation; neglect of personal appearance and hygiene; difficulty in adapting to stressful circumstances (including work or a work-like setting); and an inability to establish and maintain effective relationships.

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Related

Timberlake v. Gober
14 Vet. App. 122 (Veterans Claims, 2000)
Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Brian J. Hart v. Gordon H. Mansfield
21 Vet. App. 505 (Veterans Claims, 2007)
Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Wood v. Derwinski
1 Vet. App. 190 (Veterans Claims, 1991)
Bernard v. Brown
4 Vet. App. 384 (Veterans Claims, 1993)
Gonzales v. West
218 F.3d 1378 (Federal Circuit, 2000)
Stegall v. West
11 Vet. App. 268 (Veterans Claims, 1998)
Fenderson v. West
12 Vet. App. 119 (Veterans Claims, 1999)

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190426-18074, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190426-18074-bva-2021.