190531-77529

CourtBoard of Veterans' Appeals
DecidedAugust 31, 2020
Docket190531-77529
StatusUnpublished

This text of 190531-77529 (190531-77529) 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
190531-77529, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 08/31/20 Archive Date: 08/31/20

DOCKET NO. 190531-77529 DATE: August 31, 2020

ORDER

Readjudication of the claim of service connection for migraine headaches is warranted; to that extent only, the appeal is granted.

REMANDED

Entitlement to service connection for migraine headaches is remanded.

FINDING OF FACT

New evidence received since the final December 2011 rating decision is relevant to the issue of entitlement to service connection for migraine headaches.

CONCLUSION OF LAW

The criteria for readjudicating the claim of service connection for migraine headaches have been met. 38 C.F.R. § 3.156(d).

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 (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 Department of Veterans Affairs (VA) decisions on their claim to seek review. This decision has been written consistent with the new AMA framework as the Veteran filed a VA Form 10182 Notice of Disagreement in response to a Statement of the Case issued after the implementation of the new law went into effect.

The Veteran served on active duty for training (ACDUTRA) from September 1990 to January 1991 with additional periods of ACDUTRA and inactive duty for training (INACDUTRA).

This matter comes before the Board of Veterans’ Appeals (Board) on appeal from a July 2018 rating decision by a VA Regional Office (RO), which denied the Veteran’s application to readjudicate her claim of service connection for migraine headaches. A Notice of Disagreement under the legacy framework was received in December 2019. VA published a statement of the case (SOC) in May 2019 to which the Veteran responded with an AMA Notice of Disagreement in May 2019. A clarification letter was sent to the Veteran in August 2019 to better understand what issues she sought to be appealed. The Veteran clarified her wishes in a new AMA Notice of Disagreement in August 2019. As the Veteran chose the Direct Review Board Review Option in the August 2019 Notice of Disagreement, the Board will consider only the evidence of record at the time of the July 2018 rating decision. See 38 C.F.R. § 20.202.

Evidence was added to the claims file following the July 2018 rating decision; namely, a lay statement from the Veteran’s daughter in support of the migraine headaches claim. As the Board is readjudicating and remanding the claim of entitlement to service connection for migraine headaches for further development, this additional evidence will be considered by the RO in the adjudication of the merits of the claim.

1. Whether new and relevant evidence has been submitted to readjudicate the claim of service connection for migraines headaches.

The Veteran contends that she submitted evidence with her petition to readjudicate her claim for service connection for migraine headaches that is new and relevant, and warrants readjudication of the issue on appeal.

VA will readjudicate a claim if new and relevant evidence is presented or secured. 38 C.F.R. § 3.156(d). “Relevant evidence” is evidence that tends to prove or disprove a matter in issue. 38 C.F.R. § 3.2501(a)(1)).

The Veteran first filed her service connection claim for migraine headaches in July 2010. She was denied service connection for migraines in a December 2011 rating decision. The RO determined that the evidence submitted failed to support a finding that the condition occurred in or was caused by service. The evidence of record at the time of the December 2011 rating decision included the Veteran’s service treatment records (STRs), VA and private treatment records, service personnel records, and lay statements. In the December 2011 rating decision, the RO noted that the Veteran’s records were negative for any complaint, diagnosis, or treatment for migraines. Based on this evidence, the claim was denied.

The Veteran was notified of the December 2011 rating decision and of her appellate rights, but she did not submit a Notice of Disagreement within a year of the December 2011 rating decision. In general, rating decisions that are not timely appealed are final. See 38 U.S.C. § 7105; 38 C.F.R. § 20.1103. There was also no new and material evidence received within one year of the issuance of the decision. Therefore, the December 2011 rating decision is final. 38 U.S.C. § 7105; 38 C.F.R. §§ 3.156(b), 20.200, 20.201, 20.302, 20.1103.

In June 2018, the Veteran filed to reopen the previously denied claim of service connection for migraine headaches. The Veteran submitted new evidence in support of her claim in the form of VA treatment records and lay statements from the Veteran. Included in these treatment records is a diagnosis of migraine headaches as well as statements by the Veteran as to having the migraines for years prior to the official diagnosis. The formal diagnosis of migraine headaches is evidence that tends to prove a matter in issue, specifically the requirement the Veteran have the current disability being sought for service connection. As such, the new evidence is relevant, and the Board finds readjudication of the claim of service connection for migraine headaches is warranted.

REASONS FOR REMAND

1. Entitlement to service connection for migraine headaches is remanded.

The Veteran asserts she is entitled to service connection for migraine headaches.

Under AMA, remands are limited to pre-decisional duty to assist errors and “correction of any error by the agency of original jurisdiction in satisfying a regulatory or statutory duty, if correction of the error would have a reasonable possibility of aiding in substantiating the appellant’s claim.” 38 C.F.R. § 20.802(a).

As detailed above, the Veteran served on ACDUTRA from September 1990 to January 1991 with multiple subsequent periods of ACDUTRA and INACDUTRA. Notably, a June 1995 Report of Medical History documented the Veteran’s report of frequent headaches. Private treatment records dated in March 2010 document the Veteran’s report of headaches. These notations pre-date several periods of her ACDUTRA service. To this end, service connection may be granted for disability resulting from either disease or injury incurred or aggravated during active duty for training ACDUTRA. With respect to time periods of INACDUTRA, service connection may only be granted for disability due to injury (and not disease) so incurred or aggravated. 38 U.S.C. §§ 101(24), 106, 1110, 1131.

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Cite This Page — Counsel Stack

Bluebook (online)
190531-77529, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190531-77529-bva-2020.