190611-36915

CourtBoard of Veterans' Appeals
DecidedFebruary 27, 2020
Docket190611-36915
StatusUnpublished

This text of 190611-36915 (190611-36915) 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
190611-36915, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 02/27/20 Archive Date: 02/27/20

DOCKET NO. 190611-36915 DATE: February 27, 2020

ORDER

New and relevant evidence having been submitted, readjudication of the claim for entitlement to an effective date earlier than December 1, 2013, for additional compensation benefits for a dependent spouse for Veterans’ Administration (VA) compensation purposes is granted.

Entitlement to an effective date earlier than December 1, 2013, for additional compensation benefits for a dependent spouse for VA compensation purposes is denied.

FINDINGS OF FACT

1. New evidence was received after the January 2019 denial that is relevant to the issue of entitlement to an effective date earlier than December 1, 2013, for the inclusion of the Veteran’s spouse as a dependent for VA compensation purposes.

2. VA did not receive needed evidence regarding the Veteran’s spouse until November 5, 2013.

CONCLUSIONS OF LAW

The criteria for readjudicating the claim for entitlement to service connection for entitlement to an effective date earlier than December 1, 2013, for the inclusion of the Veteran’s spouse as a dependent for VA compensation purposes have been met. 38 C.F.R. §§ 3.156(d); 3.2501(a)(1).

1. The criteria for an effective date earlier than December 1, 2013, for the inclusion of the Veteran’s spouse as a dependent for VA compensation purposes have not been met. 38 U.S.C. §§ 5101, 5110, 7104; 38 C.F.R. §§ 3.1, 3.4, 3.50, 3.205, 3.213, 3.401.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty with the United States Air Force from November 1965 to February 1969.

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. This decision has been written consistent with the new AMA framework. The Veteran has selected the Direct Review process.

In March 2019, the Veteran filed a supplemental claim for entitlement to an effective date earlier than December 1, 2013, for the inclusion of the Veteran’s spouse as a dependent for VA compensation purposes. The Board of Veterans’ Appeals previously denied the Veteran’s claim in January 2019. The Veteran included a Civilian Health and Medical Program of the Department of Veterans Affairs (CHAMPVA) card listing the Veteran’s spouse with an effective date of April 9, 2011.

The VA issued a May 2019 decision stating no additional evidence was submitted. The Veteran appealed the May 2019 decision directly to the Board, electing the “direct review” process. No favorable findings were issued.

New and Relevant Evidence

VA will readjudicate a claim if new and relevant evidenced is presented or secured. AMA, Pub. L. No. 115-55, § 5108, 131 Stat. 1105, 1109. “Relevant evidence” is evidence that tends to prove or disprove a matter in issue. AMA, Pub. L. No. 115-55, § 101(35), 131 Stat. 1105, 1105.

The question in this case is whether the Veteran submitted evidence after the supplemental claim for entitlement to an effective date earlier than December 1, 2013, for the inclusion of the Veteran’s spouse as a dependent for VA compensation purposes, and if so, whether that evidence is new and relevant to his claim.

The Veteran submitted a CHAMPVA card listing the Veteran’s spouse with an effective date of April 9, 2011, the date of the Veteran’s marriage. The CHAMPVA card was not previously before the record and suggests potential notice of the Veteran’s marriage. Therefore, this statement is relevant evidence that tends to prove or disprove a matter in issue and readjudication of the claim for entitlement to an effective date earlier than December 1, 2013, for the inclusion of the Veteran’s spouse as a dependent for VA compensation purposes is warranted.

Earlier Effective Date

The Veteran seeks entitlement to an effective date earlier than December 1, 2013, for the addition of his spouse as his dependent. He argues that he has been married since 2011 and he placed VA on notice of this marriage once his spouse was granted CHAMPVA benefits.

Unless specifically provided otherwise, the effective date of an award based on an original claim, a claim reopened after final adjudication, or a claim for increase, of compensation, dependency and indemnity compensation, or pension, shall be fixed in accordance with the facts found, but shall not be earlier than the date of receipt of application therefore. 38 U.S.C. § 5110(a).

An award of additional compensation on account of dependents based on the establishment of a disability rating in the percentage evaluation specified by law for the purpose shall be payable from the effective date of such rating; but only if proof of dependents is received within one year from the date of notification of such rating action. 38 U.S.C. § 5110(f). An additional amount of compensation may be payable for a spouse, child, and/or dependent parent where a Veteran is entitled to compensation based on disability evaluated as 30 percent or more disabling. 38 U.S.C. § 1115; 38 C.F.R. § 3.4(b)(2).

Regarding additional compensation for dependents, the effective date will be the latest of the following dates: (1) Date of claim. This term means the following, listed in their order of applicability: (i) Date of Veteran’s marriage, or birth of his or her child, or, adoption of a child, if the evidence of the event is received within 1 year of the event; otherwise (ii) Date notice is received of the dependent’s existence, if evidence is received within 1 year of the Department of Veterans Affairs request. (2) Date dependency arises. (3) Effective date of the qualifying disability rating provided evidence of dependency is received within 1 year of notification of such rating action. (4) Date of commencement of Veteran’s award. 38 C.F.R. § 3.401(b).

Regarding “establishing entitlement to a higher rate of pension, compensation, or dependency and indemnity compensation based on the existence of a dependent, VA will require evidence which satisfies the requirements of § 3.204.” 38 C.F.R. § 3.213(a). In this regard, 38 C.F.R. § 3.204 provides as follows:

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190611-36915, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190611-36915-bva-2020.