190517-6028

CourtBoard of Veterans' Appeals
DecidedJune 25, 2019
Docket190517-6028
StatusUnpublished

This text of 190517-6028 (190517-6028) 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
190517-6028, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 06/25/19 Archive Date: 06/24/19

DOCKET NO. 190517-6028 DATE: June 25, 2019

ORDER

Entitlement to an effective date of July 1, 2009, for the grant of a total disability rating based on individual unemployability (TDIU) is granted.

FINDING OF FACT

1. VA received the Veteran’s formal claim for a TDIU on August 28, 2012; however, a claim for a TDIU was raised as part-and-parcel of the Veteran’s claim for a higher initial rating for posttraumatic stress disorder (PTSD).

2. Resolving reasonable doubt in the Veteran’s favor, the Veteran’s service-connected disabilities have precluded him from maintaining substantially gainful occupation since July 1, 2009.

CONCLUSION OF LAW

The criteria for an earlier effective date of July 1, 2009, for the grant of a TDIU have been met. 38 U.S.C. § 5107(b); 38 C.F.R. §§ 3.1, 3.340, 3.341, 4.16, 4.19.

REASONS AND BASES FOR FINDING AND CONCLUSION

On August 23, 2017, the President signed into law the Veterans Appeals Improvement and Modernization Act, Pub. L. No. 115-55 (to be 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 Veterans dissatisfied with VA’s decision on their claim to seek review. The Board is honoring the Veteran’s choice to participate in VA’s test program, RAMP, the Rapid Appeals Modernization Program.

The Veteran served on active duty from January 1955 to October 1958. The Veteran selected the Higher-Level Review lane when he submitted the RAMP election form in November 2018. Accordingly, the February 2019 rating decision considered the evidence of record as of the date VA received the RAMP election form. The Veteran timely appealed this RAMP decision to the Board and requested direct review of the evidence considered by the Agency of Original Jurisdiction (AOJ).

The Veteran submitted a request for direct review in May 2019.

This appeal has been advanced on the Board’s docket pursuant to 38 C.F.R. § 20.900 (c).

1. Entitlement to an effective date of July 1, 2009, for the grant of a TDIU is granted.

The Veteran seeks entitlement to an effective date prior to August 28, 2012, for a TDIU. He and his attorney contend an effective date of July 1, 2009, is warranted based on it being the effective date of the award of service connection for his PTSD from which he sought a higher initial rating.

A claim for TDIU may be filed as a freestanding claim. In addition, TDIU may be an element of a claim for an increased disability rating when unemployability is raised by the record. See Rice v. Shinseki, 22 Vet. App. 447 (2009). Except as otherwise provided, the effective date of 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; 38 C.F.R. § 3.400. A TDIU claim is one for increased compensation; therefore, the effective date rules for increased compensation apply to a TDIU claim. Rice v. Shinseki, 22 Vet. App. 447, 454 (2009); Hurd v. West, 13 Vet. App. 449, 451-52 (2000). The effective date of an award for increased disability compensation shall be the earliest date as of which it is factually ascertainable that an increase in disability has occurred, if the claim is received within one year from such date; otherwise, it is the date of receipt of the claim. 38 U.S.C. § 5110 (b)(2); 38 C.F.R. § 3.400 (o)(2); see also Hazan v. Gober, 10 Vet. App. 511 (1997) (requiring VA to consider the evidence of disability during the period one year prior to the application in order to determine when a factually ascertainable increase in disability occurred).

A “claim” is defined as a formal or informal communication, in writing, requesting a determination of entitlement, or evidencing a belief in entitlement to a benefit. 38 C.F.R. § 3.1 (p). In general, “date of receipt” means the date on which a claim, information, or evidence was received by VA. 38 C.F.R. § 3.1 (r).

Total disability ratings for compensation may be assigned when a veteran is unable to secure and follow a substantially gainful occupation. 38 U.S.C. § 1155; 38 C.F.R. §§ 3.340, 3.341, 4.16. If the schedular rating is less than total, a total disability evaluation can be assigned based on individual unemployability if the Veteran is unable to secure or follow a substantially gainful occupation as a result of service connected disability provided that if there is only one such disability, this disability shall be ratable at 60 percent or more; if there are two or more disabilities, there shall be at least one disability ratable at 40 percent or more, and sufficient additional disability to bring the combined rating to 70 percent or more. 38 C.F.R. § 4.16 (a).

In this case, the Veteran’s claim for service connection for PTSD was received July 1, 2009. In February 2010, the RO denied the Veteran’s claim. In an August 2012 Board decision, service connection for an acquired psychiatric disorder to include PTSD, depression and anxiety, was granted. In August 2012, the RO implemented the Board’s grant of service connection effective July 1, 2009, with a 30 percent evaluation. In August 2012, the Veteran filed a notice of disagreement with the assigned evaluation. In a December 2015 Board decision, the Board denied entitlement to an initial rating in excess of 30 percent for service-connected acquired psychiatric disorder and remanded entitlement to a TDIU. The Veteran appealed the Board decision to the United States Court of Appeal for Veterans Claims (Court). In June 2016, pursuant to a Joint Motion for Partial Remand (JMR), the Court vacated the December 2015 Board decision and remanded the claims for action consistent with the terms of the JMR.

In August 2016, the Board remanded those issues pursuant to the terms of the JMR. Thereafter, in a December 2016 rating decision, the RO granted an initial 50 percent rating for the Veteran’s acquired psychiatric disorders, effective from the July 1, 2009, grant of service connection. In a March 2018 Board decision, an initial 70 percent rating for acquired psychiatric disorder was granted, effective from the July 1, 2009, grant of service connection. Additionally, the Board found the Veteran was entitled to a TDIU based on his service-connected disabilities.

In April 2018, the RO implemented the Board’s grant of entitlement to a TDIU effective August 28, 2012. In October 2018, the Veteran filed a notice of disagreement with the effective date assigned for his TDIU. In February 2019, after enrollment in RAMP, the RO denied entitlement to an earlier effective date for TDIU.

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Related

Hurd v. West
13 Vet. App. 449 (Veterans Claims, 2000)
Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Van Hoose v. Brown
4 Vet. App. 361 (Veterans Claims, 1993)
Hatlestad v. Brown
5 Vet. App. 524 (Veterans Claims, 1993)
Harper v. Brown
10 Vet. App. 125 (Veterans Claims, 1997)
Hazan v. Gober
10 Vet. App. 511 (Veterans Claims, 1997)

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190517-6028, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190517-6028-bva-2019.