190521-6312

CourtBoard of Veterans' Appeals
DecidedNovember 27, 2019
Docket190521-6312
StatusUnpublished

This text of 190521-6312 (190521-6312) 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
190521-6312, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 11/27/19 Archive Date: 11/27/19

DOCKET NO. 190521-6312 DATE: November 27, 2019

ORDER

Entitlement to an earlier effective date prior to August 24, 2018 for the assignment of a 40 percent rating for chronic fatigue syndrome (CFS) is denied.

Entitlement to an earlier effective date of January 15, 2014 for the assignment of a 50 percent rating for posttraumatic stress disorder (PTSD) is granted.

FINDINGS OF FACT

1. In an April 2016 rating decision, the Regional Office (RO) granted entitlement to service connection for CFS with a noncompensable rating, effective January 15, 2014, and entitlement to service connection for PTSD with a 30 percent rating, effective January 15, 2014.

2. A September 2018 rating decision granted the Veteran an increased disability rating for CFS from noncompensable to 40 percent, effective August 24, 2018; and an increased disability rating for PTSD from 30 percent to 50 percent, effective July 29, 2016.

3. Prior to August 24, 2018, the Veteran’s CFS with inability to focus, muscle and joint aches, and memory loss was not manifested by debilitating fatigue, cognitive impairments, or other signs and symptoms which are nearly constant and restrict daily activities to 50 to 75 percent of the pre-illness level, or; which wax and wane, resulting in periods of incapacitation of at least four but less than six weeks total duration per year.

4. From January 15, 2014, it is factually ascertainable that the Veteran’s PTSD was shown to be productive of occupational and social impairment with reduced reliability and productivity.

CONCLUSIONS OF LAW

1. The criteria for entitlement to an earlier effective date for the evaluation of CFS have not been met. 38 U.S.C. §§ 1155, 5103, 5103A, 5107; 38 C.F.R. §§ 3.102, 3.321, 4.1, 4.3, 4.7, 4.10, 4.14, 4.88a, 4.88b, Diagnostic Code (DC) 6354.

2. The criteria for an effective date of January 15, 2014 for the disability rating of 50 percent for PTSD are met. 38 U.S.C. §§ 1155, 5103, 5103A, 5107; 38 C.F.R. §§ 3.159, 3.321, 4.7, 4.130, 4.132, DC 9411.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty, including from February 1992 to June 1992, July 1999 to March 2000, and from March 2003 to April 2004, including service in Bosnia-Herzegovina and Iraq. This case comes before the Board of Veterans’ Appeals (Board) on appeal of a May 2019 rating decision by the Department of Veterans Affairs (VA) Regional Office (RO) in St. Petersburg, Florida.

In April 2018, the Veteran selected the Higher-Level Review lane when he opted in to the Appeals Modernization Act (AMA) review system by submitting a Rapid Appeals Modernization Program (RAMP) election form. The Veteran timely appealed the subsequent May 2019 AMA rating decision to the Board and requested direct review of the evidence considered by the AOJ.

Evidence was added to the claims file during a period of time when new evidence was not allowed. Therefore, the Board may not consider this evidence. 38 C.F.R. § 20.300. The Veteran may file a Supplemental Claim and submit or identify this evidence. 38 C.F.R. § 3.2501. If the evidence is new and relevant, VA will issue another decision on the claim, considering the new evidence in addition to the evidence previously considered. Id. Specific instructions for filing a Supplemental Claim are included with this decision.

Earlier Effective Date

Generally, the effective date of an evaluation and award of compensation based on an original claim, a claim reopened after 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; 38 C.F.R. § 3.400. Regarding a claim for an increased rating, if the increase is factually ascertainable within one year prior to the receipt of the claim, the rating will be effective as of the date of increase. If the increase occurred more than one year prior to receipt of the claim, the rating will be effective as of the date of the claim. 38 U.S.C. § 5110(b)(2); Harper v. Brown, 10 Vet. App. 125; 38 C.F.R. § 3.400(o)(1), (2); 63 Fed. Reg. 56704.

In an April 2016 rating decision, the RO granted entitlement to service connection for PTSD with a 30 percent disability rating and for CFS with a noncompensable disability rating. Both disability ratings were granted an effective date of January 15, 2014 which is one year prior to the Veteran’s Application for Disability Compensation. See 38 U.S.C. § 5110(b)(2); 38 C.F.R. § 3.400.

1. CFS

A September 2018 rating decision granted the Veteran an increased disability rating for CFS from noncompensable to 40 percent effective August 24, 2018. A May 2019 RAMP rating decision denied the Veteran’s request for an earlier effective date of the 40 percent disability rating.

The Veteran asserts that he is entitled to an earlier effective date of January 15, 2014 for his 40 percent evaluation for CFS assigned from August 24, 2018. The Board looks to the relevant evidence of record from January 15, 2014 to August 24, 2018 to determine whether the Veteran is entitled to an effective date earlier than August 24, 2018 for the increase in rating to 40 percent for CFS.

The Veteran’s CFS is rated under DC 6354. Under DC 6354, ratings are provided for CFS consisting of debilitating fatigue, cognitive impairments (such as inability to concentrate, forgetfulness, confusion), or a combination of other signs and symptoms. Specific to the case at hand, a 40 percent rating is warranted for signs and symptoms of chronic fatigue syndrome that are nearly constant and restrict routine daily activities to 50 to 75 percent of the pre-illness level, or; the signs and symptoms wax and wane, resulting in periods of incapacitation of at least four but less than six weeks total duration per year. Id.

The Board has reviewed all the medical evidence of record and finds that an effective date earlier than August 24, 2018 for a rating of 40 percent is not warranted.

In his January 2015 VA Form 21-526EZ Application for Disability Compensation, the Veteran stated that he was and is always fatigued following his return from Iraq.

The Veteran underwent a VA CFS examination in October 2015. The Veteran reported the onset of his CFS as after return from Iraq in 2004 and said it has worsened about 50 percent since then. He said he wakes up fatigued and has interrupted sleep, but he is never incapacitated. He reported not taking medication. The Veteran’s debilitating fatigue did not reduce daily activity level to less than 50 percent of pre-illness level.

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Related

Angel S. Nieves-Rodriguez v. James B. Peake
22 Vet. App. 295 (Veterans Claims, 2008)
Harper v. Brown
10 Vet. App. 125 (Veterans Claims, 1997)

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Bluebook (online)
190521-6312, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190521-6312-bva-2019.