190627-10837

CourtBoard of Veterans' Appeals
DecidedFebruary 27, 2020
Docket190627-10837
StatusUnpublished

This text of 190627-10837 (190627-10837) 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
190627-10837, (bva 2020).

Opinion

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

DOCKET NO. 190627-10837 DATE: February 27, 2020

ORDER

Entitlement to an effective date prior to April 21, 2017 for the grant of entitlement to a total disability rating based on individual unemployability (TDIU) is denied.

Entitlement to an effective date prior to April 21, 2017 for the grant of eligibility to Dependents’ Educational Assistance (DEA) under 38 U.S.C. Chapter 35, is denied.

FINDINGS OF FACT

1. The Veteran’s service-connected disabilities did not preclude gainful employment consistent with her education and occupational experience prior to April 21, 2017.

2. Entitlement to DEA benefits arose on April 21, 2017.

CONCLUSIONS OF LAW

1. The criteria for the grant of TDIU prior to April 21, 2017 have not been met. 38 U.S.C. § 1155, 5107; 38 C.F.R. § 3.158, 3.340, 3.341, 4.15, 4.16, 4.19.

2. The criteria for an effective date experience prior to April 21, 2017 for eligibility for DEA benefits have not been met. 38 U.S.C. §§ 3501, 3510, 5113; 38 C.F.R. §§ 3.807(a), 21.3021.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran had active service from May 2000 to November 2006.

On August 23, 2017, 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), was signed into law. That 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.

In April 2019, the Agency of Original Jurisdiction (AOJ) granted the Veteran’s claims for TDIU and DEA as of April 21, 2017. See rating decision, April 18, 2019. In response, the Veteran submitted a VA Form 10182, an appeal to the Board of Veterans Appeal, using the Direct Review lane, in June 2019. See Decision Review Request: Board Appeal (Notice of Disagreement), received by VA June 27, 2019.

1. TDIU

The Veteran asserts than an earlier effective date is warranted for the grant of TDIU, which was granted effective April 21, 2017, in an April 2019 rating decision. See rating decision, April 18, 2019. Specifically, the Veteran generally asserts that TDIU is warranted as of October 2015. See Decision Review Request: Board Appeal (Notice of Disagreement), received by VA June 27, 2019. Specific argument in support of this appeal has not been provided.

The Veteran filed her claim for TDIU in July 2018. In the claim, the Veteran stated that she last worked full time in January 2016 and had to quit her job because the work environment was “exasperating” her service-connected sinus disability, for which she had to take two courses of antibiotics. See claim, received by VA July 6, 2018.

VA will grant TDIU when the evidence shows that a Veteran is precluded, by reason of service-connected disability, from obtaining and maintaining any form of gainful employment consistent with his or her education and occupational experience. See 38 C.F.R. §§ 3.340, 3.341, 4.16. Under the applicable regulations, benefits based on individual unemployability are granted only when it is established that the service-connected disability or disabilities are so severe, standing alone, as to prevent the retaining of gainful employment.

Substantially gainful employment is defined as work which is more than marginal and which permits the individual to earn a living wage. Moore v. Derwinski, 1 Vet. App. 356 (1991). In Faust v. West, 13 Vet. App. 342 (2000), the U.S. Court of Veterans Appeals (now the U.S. Court of Appeals for Veterans Claims) (Court) defined substantially gainful employment as “an occupation that provides an annual income that exceeds the poverty threshold for one person, irrespective of the number of hours or days that the Veteran actually works and without regard to the Veteran’s earned annual income.”

In Moore, the Court discussed the meaning of “substantially gainful employment.” In this context, it noted the following standard announced by the United States Federal Court of Appeals in Timmerman v. Weinberger, 510 F.2d 439, 442 (8th Cir. 1975): “It is clear that the claimant need not be a total ‘basket case’ before the courts find that there is an inability to engage in substantial gainful activity. The question must be looked at in a practical manner, and mere theoretical ability to engage in substantial gainful employment is not a sufficient basis to deny benefits. The test is whether a particular job is realistically within the physical and mental capabilities of the claimant.” Id. at 359.

Under 38 C.F.R. § 4.16, if there is only one such disability, it must be rated at least 60 percent disabling to qualify for benefits based on individual unemployability. If there are two or more such disabilities, there shall be at least one disability ratable at 40 percent or more, and sufficient additional disability to bring the combined rating to 70 percent or more. See 38 C.F.R. § 4.16(a). Where these percentage requirements are not met, entitlement to benefits on an extraschedular basis may be considered when a Veteran is unable to secure and follow a substantially gainful occupation by reason of service-connected disability, and consideration is given to the Veteran’s background, including his or her employment and educational history. See 38 C.F.R. § 4.16(b).

The Veteran is presently service-connected for sinusitis, evaluated as noncompensable from November 13, 2006, and as 50 percent disabling from April 21, 2017; chronic sinusitis headaches, evaluated as 50 percent disabling from April 21, 2017; posttraumatic stress disorder (PTSD), evaluated as 30 percent disabling from May 7, 2009, and as 50 percent disabling from April 21, 2017; and left ear hearing loss, evaluated as noncompensable from November 13, 2006.

As such, the Veteran’s combined rating was 10 percent from November 13, 2006, 30 percent from May 7, 2009, and 90 percent from April 21, 2017.

Prior to April 21, 2017, the Veteran’s combined rating was 30 percent. At a 30 percent evaluation, the Veteran’s service-connected disabilities did not render her eligible for TDIU under the schedular percentage requirements contemplated by VA regulation. See 38 C.F.R. §§ 3.340, 3.341, 4.16(a).

For those Veterans who fail to meet the percentage standards, TDIU nevertheless may be assigned when it is found that the service-connected disabilities are sufficient to produce unemployability. Such cases are referred to the Director, Compensation Service, for extra-schedular consideration. 38 C.F.R. § 4.16(b).

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Related

Davidson v. SHINSEKI
581 F.3d 1313 (Federal Circuit, 2009)
Jandreau v. Nicholson
492 F.3d 1372 (Federal Circuit, 2007)
Faust v. West
13 Vet. App. 342 (Veterans Claims, 2000)
James P. Barr v. R. James Nicholson
21 Vet. App. 303 (Veterans Claims, 2007)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Moore v. Derwinski
1 Vet. App. 356 (Veterans Claims, 1991)
Van Hoose v. Brown
4 Vet. App. 361 (Veterans Claims, 1993)

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190627-10837, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190627-10837-bva-2020.