190605-9715

CourtBoard of Veterans' Appeals
DecidedJune 16, 2020
Docket190605-9715
StatusUnpublished

This text of 190605-9715 (190605-9715) 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
190605-9715, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 06/16/20 Archive Date: 06/16/20

DOCKET NO. 190605-9715 DATE: June 16, 2020

ORDER

Entitlement to an increased rating in excess of 20 percent for a right knee strain from July 26, 2018 to November 7, 2018 is denied.

Entitlement to an increased rating in excess of 40 percent for lumbar strain with degenerative arthritis of the spine is denied.

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

REMANDED

Entitlement to an increased rating in excess of 10 percent for right knee strain from November 7, 2018 is remanded.

FINDINGS OF FACT

1. From July 26, 2018 to November 7, 2018, the Veteran’s right knee is manifest by forward flexion limited to 30 degrees.

2. Throughout the period on appeal, the Veteran’s lumbar strain is manifest by forward flexion limited to 30 degrees.

3. Throughout the period on appeal, the severity, frequency, and duration of the Veteran’s PTSD symptoms did not more closely approximate occupational and social impairment with deficiencies in most areas.

CONCLUSIONS OF LAW

1. The criteria for a disability rating in excess of 20 percent for right knee strain from July 26, 2018 to November 7, 2018 have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.71a, Diagnostic Code 5260.

2. The criteria for a disability rating in excess of 40 percent for lumbar strain have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.71a, Diagnostic Codes 5242-5237.

3. The criteria for a disability rating in excess of 50 percent for PTSD have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.126, 4.130, Diagnostic Code 9411.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

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 Veteran served on active duty from November 2008 to November 2016.

This appeal comes to the Board of Veterans’ Appeals (Board) from November 2018 and January 2019 rating decisions issued by a Department of Veterans Affairs (VA) Regional Office (RO).

The Veteran filed his claims of increased ratings for his service-connected lumbar strain and right knee strain in August 2018 and filed his claim of service connection for posttraumatic stress disorder (PTSD) in October 2018. The agency of original jurisdiction (AOJ) granted an increased rating for the Veteran’s lumbar strain to 40 percent and denied an increased rating in excess of 10 percent for the Veteran’s right knee strain under the legacy appeals system in November 2018. In the January 2019 rating decision, the AOJ granted service connection for PTSD and assigned an initial 50 percent rating. In December 2018 and February 2019, the Veteran filed notice of disagreements (NODs) with the ratings assigned for his service-connected right knee, lumbar strain and PTSD under the legacy system. In May 2019, the AOJ corrected the effective dates assigned to the claims to accurately reflect the date the Veteran filed his claim of service connection for PTSD and the evidence showing increase in severity for his service-connected lumbar strain and right knee strain. The Veteran subsequently filed a timely AMA Notice of Disagreement in June 2019 indicating disagreement with the ratings assigned to each claim. As the Veteran chose the Direct Review Board Review Option without a Board hearing on the Notice of Disagreement, the Board will consider the evidence of record at the time of the November 2018 and January 2019 rating decisions. See 38 C.F.R. §§ 20.202, 20.301.

Increased Rating

Disability ratings are determined by applying a schedule of ratings that is based on average impairment of earning capacity. Separate diagnostic codes identify the various disabilities. 38 U.S.C. § 1155; 38 C.F.R., Part 4. Each disability must be viewed in relation to its history and the limitation of activity imposed by the disabling condition should be emphasized. 38 C.F.R. § 4.1.

When considering the propriety of the initial evaluation assigned, consideration of the medical evidence since the effective date of the award of service connection is required. See Fenderson v. West, 12 Vet. App. 199, 125-26 (1999). The Board will consider whether separate ratings may be assigned for separate periods of time based on facts found, a practice known as “staged ratings,” whether it is an initial rating case or not. See Hart v. Mansfield, 21 Vet. App. 505, 509-10 (2007).

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 for that rating. Otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7.

Importantly, the evaluation of the same disability under various diagnoses is to be avoided. 38 C.F.R. § 4.14. However, when it is not possible to separate the effects of the service-connected disability from a nonservice-connected condition, such signs and symptoms must be attributed to the service-connected disability. Mittleider v. West, 11 Vet. App. 181, 182 (1998); 38 C.F.R. § 3.102.

When evaluating musculoskeletal disabilities based on limitation of motion, 38 C.F.R. § 4.40 requires consideration of functional loss caused by pain or other factors listed in that section that could occur during flare-ups or after repeated use and, therefore, not be reflected on range-of-motion testing. 38 C.F.R. § 4.45 requires consideration also be given to less movement than normal, more movement than normal, weakened movement, excess fatigability, incoordination, and pain on movement. See DeLuca v. Brown, 8 Vet. App. 202 (1995); see also Mitchell v. Shinseki, 25 Vet. App. 32, 44 (2011). Nonetheless, even when the background factors listed in § 4.40 or 4.45 are relevant when evaluating a disability, the rating is assigned based on the extent to which motion is limited, pursuant to 38 C.F.R. § 4.71a; a separate or higher rating under § 4.40 or 4.45 itself is not appropriate. See Thompson v.

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Related

Brian J. Hart v. Gordon H. Mansfield
21 Vet. App. 505 (Veterans Claims, 2007)
Tyra K. Mitchell v. Eric K. Shinseki
25 Vet. App. 32 (Veterans Claims, 2011)
Russell W. Burton v. Eric K. Shinseki
25 Vet. App. 1 (Veterans Claims, 2011)
Genaro Vazquez-Claudio v. Shinseki
713 F.3d 112 (Federal Circuit, 2013)
Thompson v. McDonald
815 F.3d 781 (Federal Circuit, 2016)
Esteban v. Brown
6 Vet. App. 259 (Veterans Claims, 1994)
DeLuca v. Brown
8 Vet. App. 202 (Veterans Claims, 1995)
Mittleider v. West
11 Vet. App. 181 (Veterans Claims, 1998)
Arms v. West
12 Vet. App. 188 (Veterans Claims, 1999)

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190605-9715, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190605-9715-bva-2020.