190503-8504

CourtBoard of Veterans' Appeals
DecidedAugust 31, 2021
Docket190503-8504
StatusUnpublished

This text of 190503-8504 (190503-8504) 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
190503-8504, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 08/31/21 Archive Date: 08/31/21

DOCKET NO. 190503-8504 DATE: August 31, 2021

ORDER

Entitlement to an initial disability rating in excess of 50 percent for posttraumatic stress disorder (PTSD) with unspecified depressive disorder is denied.

Entitlement to service connection for head trauma with loss of consciousness, loss of hair, memory issues and migraines is denied.

FINDING OF FACT

1. The overall evidentiary record shows that the severity of the Veteran's psychiatric disability most closely approximated the criteria for a 50 percent disability evaluation for the period on appeal.

2. The evidence shows that at no point during the period on appeal, did the Veteran have any diagnosable disorder due to head trauma capable of VA compensation.

CONCLUSION OF LAW

1. The criteria for entitlement to an initial disability rating in excess of 50 percent for posttraumatic stress disorder (PTSD) with unspecified depressive disorder have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.102, 4.7, 4.126, 4.130, Diagnostic Code (DC) 9411.

2. The criteria for entitlement to service connection for head trauma with loss of consciousness, loss of hair, memory issues and migraines are not met. 38 U.S.C. §§ 1110, 1131, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.310.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty from October 1982 to August 1988. These matters come before the Board of Veterans' Appeals (Board) on appeal from an April 2019 rating decision of a Department of Veterans Affairs (VA) Regional Office (RO).

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 scattered 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 appealing VA decisions. Therefore, this decision is written consistent with the new AMA framework. Specifically, because the Veteran selected the Direct Review lane, the Board's decision is based on the evidence of record at the time of the April 2019 rating decision on appeal.

The issues on appeal were previously before the Board in January 2020. The Veteran appealed the decision to the United States Court of Appeals for Veterans Claims (Court) which, in a March 2021 Joint Motion for Partial Remand (JMPR), vacated the portion of the Board's January 2020 decision that denied entitlement to service connection for head trauma with loss of consciousness, loss of hair, memory issues and migraines; and, entitlement to an initial disability rating in excess of 50 percent for posttraumatic stress disorder (PTSD) with unspecified depressive disorder, and remanded the claims for action consistent with its decision.

1. Entitlement to an initial disability rating in excess of 50 percent for posttraumatic stress disorder (PTSD) with unspecified depressive disorder

The Veteran is in receipt of a 50 percent disability rating for PTSD, effective October 10, 2018. The Veteran contends she is entitled to a rating in excess of 50 percent for 2019 and early 2020 due to the symptoms from her PTSD. See March 2020 Notice of Disagreement. The Veteran referenced a hospitalization at the Richmond VAMC that she stated was not considered for her January 2020 Board decision. See March 2020 VA Form 21-4138. The Veteran's representative argues that the Veteran's outstanding VA treatment records may support a 70 percent or greater disability evaluation. See March 2021 JMPR.

Under Diagnostic Code 9411, a 50 percent rating is warranted when there is 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. Id.

A 70 percent rating is prescribed when there is evidence of 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 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 inability to establish and maintain effective relationships. Id.

A 100 percent rating is prescribed when there is evidence of total occupational and social impairment due to such symptoms as: gross impairment in thought processes or communication; persistent delusions or hallucinations, grossly inappropriate behavior; persistent danger of hurting self or others; intermittent inability to perform activities of daily living (including maintenance of minimal personal hygiene); disorientation as to time or place; and memory loss for names of close relatives, own occupation, or own name. Id.

The list of symptoms under the rating criteria are meant to be examples of symptoms that would warrant the rating, but are not meant to be exhaustive, and the Board need not find all or even some of the symptoms to award a specific rating. Mauerhan v. Principi, 16 Vet. App. 436, 442-43 (2002). However, a Veteran may only qualify for a given disability rating under § 4.130 by demonstrating the particular symptoms associated with that percentage, or others of similar severity, frequency, and duration, and that such symptoms have resulted in the type of occupational and social impairment associated with that percentage. Vazquez-Claudio v. Shinseki, 713 F.3d 112, 117-18 (Fed. Cir. 2013).

Under the General Formula for Mental Disorders (General Formula), the Board must conduct a "holistic analysis" that considers all associated symptoms, regardless of whether they are listed as criteria. Bankhead v. Shulkin, 29 Vet. App. 10, 22 (2017); 38 C.F.R. § 4.130. The Board must determine whether unlisted symptoms are similar in severity, frequency, and duration to the listed symptoms associated with specific disability percentages. Then, the Board must determine whether the associated symptoms, both listed and unlisted, caused the level of impairment required for a higher disability rating. Vazquez-Claudio v. Shinseki, 713 F.3d 112, 114-118 (Fed. Cir. 2013).

Following a complete review of the appellate record, the Board finds that the Veteran's psychiatric symptoms have not caused the level of impairment required for a disability rating of 70 percent or higher during the period on appeal.

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Related

Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Genaro Vazquez-Claudio v. Shinseki
713 F.3d 112 (Federal Circuit, 2013)
Ouida Wise v. Eric K. Shinseki
26 Vet. App. 517 (Veterans Claims, 2014)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Alemany v. Brown
9 Vet. App. 518 (Veterans Claims, 1996)

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Bluebook (online)
190503-8504, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190503-8504-bva-2021.