190501-7499

CourtBoard of Veterans' Appeals
DecidedNovember 29, 2019
Docket190501-7499
StatusUnpublished

This text of 190501-7499 (190501-7499) 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
190501-7499, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 11/29/19 Archive Date: 11/29/19

DOCKET NO. 190501-7499 DATE: November 29, 2019

ORDER

A rating of 30 percent, the highest rating under the schedule, for the right foot disability is granted.

A rating of 10 percent, but no higher, for the left foot disability is granted.

Service connection for a bilateral ankle condition is denied.

REMANDED

Service connection for bilateral knee conditions is remanded.

FINDINGS OF FACT

1. Resolving reasonable doubt in the Veteran’s favor, the Veteran’s right-foot disability has manifested with slight great-toe hammertoe, clavus in the fourth and fifth toe webs, plantar callosities, moderate splaying of the metatarsals, and pain on walking resulting in functional loss, establishing a disability picture more nearly approximating a severe foot injury.

2. Resolving reasonable doubt in the Veteran’s favor, the Veteran’s left-foot disability has manifested with slight great-toe hammertoe and pain on walking resulting in functional loss, establishing a disability picture more nearly approximating a moderate foot injury.

3. The evidence is insufficient to establish that the Veteran has a current diagnosed condition of the ankles or has pain that creates a functional impairment in earning capacity.

CONCLUSIONS OF LAW

1. The criteria for a rating of 30 percent, the highest rating available under this schedule, for the right foot disability have been met. 38 U.S.C. §§ 1155, 5107(b); 38 C.F.R. §§ 4.3, 4.7, 4.20, 4.71a, Diagnostic Code 5284.

2. The criteria for a rating of 10 percent, but no higher, for the left foot disability have been met. 38 U.S.C. §§ 1155, 5107(b); 38 C.F.R. §§ 4.71a, Diagnostic Code 5284.

3. The criteria for service connection for a left or right ankle disability have not been met. 38 U.S.C. § 1131; 38 C.F.R. § 3.303.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty from January 1976 to October 1978.

On August 23, 2017, the President signed into law the Veterans Appeals Improvement and Modernization Act, Pub. L. No. 115-55 (codified as amended in sections of 38 U.S.C.), 131 Stat. 1105 (2017), also known as the Appeals Modernization Act (AMA). This law creates a new framework for veterans to seek review of a VA decision with which they are dissatisfied. The Board of Veterans’ Appeals (Board) is honoring the Veteran’s choice to participate in the Department of Veterans Affairs (VA) test program, RAMP, the Rapid Appeals Modernization Program.

The Veteran submitted a RAMP election form in February 2018 and selected the supplemental claim lane. Accordingly, a January 2019 rating decision considered the evidence of record as of the date VA received the RAMP election form and evidence received within 30 days thereafter. In May 2019, the Veteran filed a notice of disagreement electing the Board’s direct review of the evidence considered by the Agency of Original Jurisdiction.

The Veteran seeks an increased rating for foot disabilities and service connection for disabilities of the knees and ankles.

A. Increased Rating for Foot Disabilities

Disability evaluations (ratings) are determined by evaluating the extent to which a Veteran’s service-connected disability adversely affects the Veteran’s ability to function under the ordinary conditions of daily life, including employment, by comparing the symptomatology with the criteria set forth in the Schedule for Rating Disabilities (rating schedule). 38 U.S.C. § 1155; 38 C.F.R. §§ 4.1, 4.2, 4.10. Where entitlement to compensation has already been established and an increase in the disability rating is at issue, it is the present level of disability that is of primary concern. See Francisco v. Brown, 7 Vet. App. 55, 58 (1994).

In evaluating a disability, the Board considers the current examination reports in light of the entire record to ensure that the current rating accurately reflects the severity of the condition. Where 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. Reasonable doubt regarding the degree of disability will be resolved in favor of the Veteran. 38 C.F.R. § 4.3.

The Veteran’s bilateral hammertoe, right-foot fourth and fifth toe clavus, right-foot moderate metatarsal splaying, right-foot plantar callosities are currently rated at 30 percent. The foot conditions are not listed in the rating schedule, and therefore they are related analogously under Diagnostic Code (DC) 5276, for acquired flatfoot. 38 C.F.R. §§ 4.20, 4.71. Under DC 5276, a 30-percent rating is warranted where there is bilateral flatfoot to a severe degree, with objective evidence of marked deformity (pronation, abduction, etc.), pain on manipulation and use accentuated, indication of swelling on use, and characteristic callosities. A 50-percent rating, which is the highest rating under this schedule, is warranted where there is bilateral flatfoot to a pronounced degree, with marked pronation, extreme tenderness of plantar surfaces of the feet, marked inward displacement and severe spasm of the tendo achillis on manipulation, and no improvement by orthopedic shoes or appliances. Id.

An evaluation for foot injuries, other, is available under DC 5284. 38 C.F.R. § 4.71a. Under DC 5284, a 10-percent rating is warranted where the foot injury is of a moderate degree; a 20-percent rating is warranted where the foot injury is of a moderately severe degree; and a 30-percent rating, which is the highest rating available under this schedule, is warranted where the foot injury is of a severe degree. Id.

The Veteran seeks a rating higher than the 30 percent currently assigned for both foot disabilities combined.

A VA examination was provided in July 2014. The examiner found that the Veteran’s left foot had a great-toe hammertoe. In the right foot, the Veteran had a great-toe hammertoe, clavus in the fourth and fifth webs, plantar callosities, and post-operative residuals with moderate splaying of the metatarsals. The Veteran did not report having flare ups. The examiner found that the Veteran had pain on movement in both feet, which contributed to functional loss.

In an October 2018 statement, the Veteran wrote that due to his foot disabilities he “can’t move freely.”

Based on the evidence of record, the Board finds that a higher combined rating is warranted.

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Related

Reald v. Shinseki
651 F.3d 1296 (Federal Circuit, 2011)
Brammer v. Derwinski
3 Vet. App. 223 (Veterans Claims, 1992)
Francisco v. Brown
7 Vet. App. 55 (Veterans Claims, 1994)
Allen v. Brown
7 Vet. App. 439 (Veterans Claims, 1995)

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Bluebook (online)
190501-7499, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190501-7499-bva-2019.