190705-12644

CourtBoard of Veterans' Appeals
DecidedMarch 31, 2020
Docket190705-12644
StatusUnpublished

This text of 190705-12644 (190705-12644) 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
190705-12644, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 03/31/20 Archive Date: 03/31/20

DOCKET NO. 190705-12644 DATE: March 31, 2020

ORDER

Entitlement to a 100 percent disability rating prior to May 13, 2019, for post-traumatic stress disorder, major depressive disorder, and anxiety disorder (mental disorders) is denied.

Entitlement to a 70 percent disability rating from May 13, 2019, for mental disorders is granted.

Entitlement to a total disability rating based on individual unemployability (TDIU) is denied.

FINDINGS OF FACT

1. Prior to May 13, 2019, the Veteran’s mental disorders are manifested as occupational and social impairment with deficiencies in most areas.

2. From May 13, 2019, the Veteran’s mental disorders are manifested as occupational and social impairment with deficiencies in most areas.

3. The Veteran’s mental disorders does not preclude him from securing or following substantially gainful employment.

CONCLUSIONS OF LAW

1. The criteria for evaluation for a 100 percent disability rating prior to May 13, 2019, for mental disorders have not been met. 38 U.S.C. § § 1155, 5107(b); 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.10; 4.130, Diagnostic Code (DC) 9411.

2. The criteria for evaluation to a 70 percent disability rating from May 13, 2019, for mental disorders have been met. 38 U.S.C. § § 1155, 5107(b); 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.10; 4.130, DC 9411.

3. The criteria for entitlement to a TDIU have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.102, 3.159, 3.340, 3.341, 4.16.

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. This decision has been written consistent with the new AMA framework.

The Veteran served active duty service from May 1968 to May 1970.

A June 2019 rating decision was issued under AMA. 38 C.F.R. § 20.104(d). The Veteran appealed this decision and elected a direct review by the Board of Veterans’ Appeals (Board).

The Board acknowledges that 38 C.F.R. § 3.105 (e) sets forth certain procedural requirements for reductions in disability compensation ratings. Although generally a reduction is void ab initio if the AOJ reduces a veteran’s disability rating without following these requirements, see Kitchens v. Brown, 7 Vet. App. 320, 325 (1995), where a reduced rating would not result in a decrease or discontinuance of the current compensation payments, there are no procedural requirements. VAOPGCPREC 71-91 (Nov. 1991).

Here, the AOJ did not issue the Veteran a rating action proposing the reduction in his disability rating for his mental disorders. However, such notice was not required. At the time that the AOJ issued the June 2019 rating decision, the combined evaluation for the Veteran’s service-connected disabilities was 100 percent. Despite the rating reduction, the Veteran’s overall compensation did not decrease. The lack of notice prior to the reduction, as typically required by 38 C.F.R. § 3.105 (e), does not, void the reduction. See VAOPGCPREC 71-91 (Nov. 1991). The Board will only adjudicate whether the Veteran is entitled to an increased disability rating. This is not prejudicial to the Veteran because the Board finds below that a 70 percent rating is warranted for the entire appeal period.

Increased Rating

1. Entitlement to a 100 percent disability rating prior to May 13, 2019, for mental disorders is denied.

Disability evaluations are determined by comparing a veteran’s present symptoms with the criteria set forth in the VA’s Schedule for Rating Disabilities (rating schedule), which is based on average impairment in earning capacity. 38 U.S.C. § 1155; 38 C.F.R. Part 4. When a question arises as to which of two ratings apply under a single diagnostic code, the higher evaluation is assigned if the disability more closely approximates the criteria for the higher rating. 38 C.F.R. § 4.7. As such, the Board must consider all potentially applicable DCs when rating a Veteran’s disability. However, evaluation of the same manifestation of the same disability under various diagnoses, otherwise known as “pyramiding,” is to be avoided. 38 C.F.R. § 4.14; Esteban v. Brown, 6 Vet. App. 259, 261 (1994).

Staged ratings are appropriate for an increased rating claim when the factual findings show distinct time periods where the service-connected disability exhibits symptoms that would warrant different ratings. Hart v. Mansfield, 21 Vet. App. 505 (2007). The Veteran’s disability should be viewed in relation to its history. 38 C.F.R. § 4.1; Schafrath v. Derwinski, 1 Vet. App. 589 (1995).

Disability evaluations are determined by applying VA’s rating schedule. 38 U.S.C. § 1155; 38 C.F.R. § 4.1. Each service-connected disability is rated based on criteria identified by DC. 38 C.F.R. § 4.27. When reasonable doubt arises as to the degree of disability the issue will be resolved in favor of the claimant. 38 C.F.R. § 4.3.

The Veteran’s mental disorders are rated at 38 C.F.R. § 4.130, DC 9411 under a General Rating Formula for Mental Disorders. A 50 percent rating is warranted for occupational and social impairment with reduced reliability and productivity due to such symptoms as: flattened affect; circumstantial, circumlocutory, or stereotyped speech; panic attacks more than once a week; difficulty in understanding complex commands; impairment of short-term and long-term memory (e.g., retention of only highly learned material, forgetting to complete tasks); impaired judgment; impaired abstract thinking; disturbances of motivation and mood; difficulty in establishing and maintaining effective work and social relationships.

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Related

Thun v. Shinseki
572 F.3d 1366 (Federal Circuit, 2009)
Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Brian J. Hart v. Gordon H. Mansfield
21 Vet. App. 505 (Veterans Claims, 2007)
Dennis M. Thun v. James B. Peake
22 Vet. App. 111 (Veterans Claims, 2008)
Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Genaro Vazquez-Claudio v. Shinseki
713 F.3d 112 (Federal Circuit, 2013)
Schafrath v. Derwinski
1 Vet. App. 589 (Veterans Claims, 1991)
Esteban v. Brown
6 Vet. App. 259 (Veterans Claims, 1994)
Kitchens v. Brown
7 Vet. App. 320 (Veterans Claims, 1995)

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Bluebook (online)
190705-12644, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190705-12644-bva-2020.