190626-10635

CourtBoard of Veterans' Appeals
DecidedFebruary 27, 2020
Docket190626-10635
StatusUnpublished

This text of 190626-10635 (190626-10635) 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
190626-10635, (bva 2020).

Opinion

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

DOCKET NO. 190626-10635 DATE: February 27, 2020

ORDER

Entitlement to a rating in excess of 10 percent for right knee patellofemoral syndrome with degenerative changes is denied.

Entitlement to a rating in excess of 10 percent for left knee patellofemoral syndrome with degenerative changes is denied.

A separate 20 percent rating for a right knee meniscus tear is granted, as of August 18, 2018, subject to the law and regulations governing the payment of monetary benefits.

Entitlement to a temporary total rating based on surgical or other treatment necessitating convalescence following right knee surgery, from September 20, 2018, to December 20, 2018, is granted, subject to the law and regulations governing the payment of monetary benefits.

Entitlement to a temporary total rating based on surgical or other treatment necessitating convalescence following right knee surgery, from February 7, 2019, to May 7, 2019, is granted, subject to the law and regulations governing the payment of monetary benefits.

REMANDED

Entitlement to a total disability rating based on individual unemployability due to service-connected disabilities (TDIU) is remanded.

FINDINGS OF FACT

1. Throughout the course of the appeal, the Veteran's right knee does not exhibit signs of ankylosis, subluxation, or instability, but has always exhibited painful motion.

2. Throughout the course of the appeal, the Veteran's left knee does not exhibit signs of ankylosis, subluxation, or instability, but has always exhibited painful motion.

3. As of August 18, 2018, the Veteran’s service-connected right knee developed a meniscus tear which has been manifested by frequent episodes of joint “locking,” pain, and effusion.

4. The Veteran required treatment and a period of convalescence due to service-connected right knee surgery on September 20, 2018.

5. The Veteran required treatment and a period of convalescence due to service-connected right knee surgery on February 7, 2019.

CONCLUSIONS OF LAW

1. The criteria for entitlement to a rating in excess of 10 percent for right knee patellofemoral syndrome with degenerative changes have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.3, 4.7, 4.40, 4.45, 4.59, 4.71a, Diagnostic Codes 5010-5260.

2. The criteria for entitlement to a rating in excess of 10 percent for left knee patellofemoral syndrome with degenerative changes have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.3, 4.7, 4.40, 4.45, 4.59, 4.71a, Diagnostic Codes 5010-5260.

3. The criteria for a separate 20 percent, but not greater, rating for a right knee meniscus tear consistent with frequent episodes of joint “locking,” pain, and effusion have been met as of August 18, 2018. 38 U.S.C. §§ 1155, 5107(b); 38 C.F.R. §§ 3.102, 4.71a, Diagnostic Code 5258.

4. The criteria for a total temporary rating for a service-connected disability, from September 20, 2018, to December 20, 2018, have been met. 38 U.S.C. § 1155; 38 C.F.R. §§ 4.29, 4.30.

5. The criteria for a total temporary rating for a service-connected disability, from February 7, 2019, to May 7, 2019, have been met. 38 U.S.C. § 1155; 38 C.F.R. §§ 4.29, 4.30.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty from June 1999 to November 2006.

The rating decision on appeal was issued in May 2019. In June 2019, the Veteran elected the modernized review system. 84 Fed. Reg. 138, 177 (Jan. 18, 2019) (to be codified at 38 C.F.R. § 19.2(d)).

The Veteran elected the Direct Review lane. Accordingly, the Board will consider evidence of record as of the May 2019 rating decision.

Increased Rating

Disability ratings are determined by applying the criteria set forth in the VA Schedule for Rating Disabilities, found in 38 C.F.R. Part 4. The percentage ratings are based on the average impairment of earning capacity as a result of a service-connected disability, and separate diagnostic codes identify the various disabilities and the criteria for specific ratings. 38 U.S.C. § 1155; 38 C.F.R. § 4.1.

Disability ratings are determined by evaluating the extent to which a veteran's service-connected disability adversely affects his ability to function under the ordinary conditions of daily life, including employment, by comparing the symptomatology with the criteria set forth in the Schedule for Rating Disabilities (Rating Schedule). 38 U.S.C. § 1155; 38 C.F.R. §§ 4.1, 4.2, 4.10. The percentage ratings in the Rating Schedule represent the average impairment in earning capacity resulting from service-connected diseases and injuries and their residual conditions in civilian occupations. The percentage ratings are generally adequate to compensate for considerable loss of working time from exacerbation or illness proportionate to the severity of the disability.

In disability rating cases, VA assesses the level of disability from the initial grant of service connection or a year prior to the date of application for an increased rating and determines whether the level of disability warrants the assignment of different disability ratings at different times over the course of the claim, a practice that is known as "staged ratings." Fenderson v. West, 12 Vet. App. 119, 126 (1999); Hart v. Mansfield, 21 Vet. App. 505, 509-10 (2007) (holding that staged ratings may be warranted in increased rating claims).

In determining the appropriate rating for musculoskeletal disabilities, particular attention is focused on functional loss of use of the affected part. Factors of joint disability include increased or limited motion, weakened movement, excess fatigability, incoordination, and painful movement, including during flare-ups and after repeated use. DeLuca v. Brown, 8 Vet. App. 202, 206-08 (1995); 38 C.F.R. § 4.45. A finding of functional loss due to pain must be supported by adequate pathology and evidenced by the visible behavior of the claimant. 38 C.F.R. § 4.40.

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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)
Thompson v. McDonald
815 F.3d 781 (Federal Circuit, 2016)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Schafrath v. Derwinski
1 Vet. App. 589 (Veterans Claims, 1991)
DeLuca v. Brown
8 Vet. App. 202 (Veterans Claims, 1995)
Mittleider v. West
11 Vet. App. 181 (Veterans Claims, 1998)
Fenderson v. West
12 Vet. App. 119 (Veterans Claims, 1999)
Correia v. McDonald
28 Vet. App. 158 (Veterans Claims, 2016)

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Bluebook (online)
190626-10635, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190626-10635-bva-2020.