190731-36966

CourtBoard of Veterans' Appeals
DecidedNovember 30, 2020
Docket190731-36966
StatusUnpublished

This text of 190731-36966 (190731-36966) 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
190731-36966, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 11/30/20 Archive Date: 11/30/20

DOCKET NO. 190731-36966 DATE: November 30, 2020

ORDER

The reduction in the rating for residual prostate cancer status post prostatectomy, effective October 1, 2019, was proper.

Entitlement to a disability rating in excess of 20 percent for residual prostate cancer status post prostatectomy, from October 1, 2019, is denied.

FINDINGS OF FACT

1. A January 2016 rating decision granted service connection for residual prostate status post prostatectomy to include erectile dysfunction and assigned a 100 percent rating, effective October 7, 2015.

2. An April 2018 rating decision proposed to reduce the rating for service-connected residual prostate cancer status post prostatectomy.

3. A July 2019 rating decision reduced the rating for service-connected residual prostate cancer status post prostatectomy from 100 percent to 20 percent, effective October 1, 2019.

4. As of October 1, 2019, the 100 percent disability rating for prostate cancer had been in effect for less than five years.

5. At the time of the rating reduction, prostate cancer was in remission with no local recurrence or metastasis or cancer treatment.

6. As of October 1, 2019, voiding dysfunction was the predominant residual disability manifested by daytime voiding interval between one and two hours, or awakening to void three to four times per night, but not requiring use of appliance or wearing of absorbent materials that must be changed two to four times per day.

CONCLUSIONS OF LAW

1. The rating reduction for residual prostate cancer status post prostatectomy was proper, and restoration of a 100 percent disability rating, effective from October 1, 2019, is not warranted. 38 U.S.C. § 1155; 38 C.F.R. §§ 3.105, 3.344, 4.115b, Diagnostic Code 7528.

2. From October 1, 2019, the criteria for a disability rating in excess of 20 percent for residual prostate cancer status post prostatectomy have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.102, 3.321, 4.3, 4.7, 4.115a, 4.115b, Diagnostic Code 7528.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty from May 1966 to May 1968.

This appeal comes to the Board of Veterans’ Appeals (Board) from a July 2019 rating decision of a Department of Veterans Affairs (VA) Regional Office (RO).

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 selected the Direct Review lane without a Board hearing when he opted into the AMA review system by submitting a VA Form 10182 (Decision Review Request: Board (Notice of Disagreement)) in July 2019. Accordingly, the Board will consider the evidence of record at the time of the July 2019 rating decision on the issues on appeal.

1. Whether the reduction in the rating for residual prostate cancer status post prostatectomy, effective October 1, 2019, was proper.

Consistent with VA policy, the Veteran was sent for re-examination as prostate cancer is deemed to be a condition that might improve. Following a VA examination on March 2018, the Agency of Original Jurisdiction (AOJ) undertook the procedural steps to reduce the Veteran’s rating for prostate cancer. The Veteran desires his rating be returned to 100 percent.

The provisions of 38 C.F.R. § 3.105(e) allow for the reduction in rating of a service-connected disability when warranted by the evidence, but only after following certain procedural guidelines. The AOJ must issue a rating action proposing the reduction and setting forth all material facts and reasons for the reduction. The Veteran must then be given 60 days to submit additional evidence and to request a predetermination hearing. Then, a rating action will be taken to effectuate the reduction, if warranted. 38 C.F.R. § 3.105(e). The effective date of the reduction will be the last day of the month in which a 60-day period from the date of notice to the Veteran of the final action expires. 38 C.F.R. § 3.105(e), (i)(2)(i).

In this case, the AOJ satisfied the procedural requirements of 38 C.F.R. § 3.105(e) for the rating reduction for the Veteran’s service-connected residual prostate cancer status post prostatectomy from 100 percent, effective October 1, 2019.

Specific requirements must be met in order for VA to reduce certain ratings assigned for service-connected disabilities. See 38 C.F.R. § 3.344; see also Dofflemyer v. Derwinski, 2 Vet. App. 277 (1992). The requirements for reduction of ratings in effect for five years or more are set forth at 38 C.F.R. § 3.344 (a) and (b), which prescribe that only evidence of sustained material improvement under the ordinary conditions of life, as shown by full and complete examinations, can justify a reduction; these provisions prohibit a reduction on the basis of a single examination. Brown v. Brown, 5 Vet. App. 413, 417-18 (1993). In contrast, when disabilities that are likely to improve, that is disabilities for which a rating has been in effect for less than five years, re-examinations disclosing improvement in disabilities will warrant a rating reduction. 38 C.F.R. § 3.344(c).

At the time of the July 2019 rating decision, the Veteran’s residual prostate cancer had been continuously rated at 100 percent for less than five years. As such, the provisions of 38 C.F.R. §§ 3.344(a) and (b) are not applicable in this case.

A rating reduction is not proper unless a veteran’s disability shows actual improvement in his or her ability to function under the ordinary conditions of life and work. See Faust v. West, 13 Vet. App. 342, 349 (2000). In considering the propriety of a reduction, the Board must focus on the evidence available to the RO at the time the reduction was effectuated (although post-reduction medical evidence may be considered in the context of considering whether actual improvement was demonstrated). Dofflemyer v. Derwinski, 2 Vet. App. 277, 281-82 (1992). A veteran need not demonstrate that retention of the higher rating is warranted; rather, it must be shown by a preponderance of the evidence that the reduction was warranted. See Brown v. Brown, 5 Vet. App. 413, 418 (1993).

The question of whether a disability has improved involves consideration of the applicable rating criteria. Prostate cancer was rated under 38 C.F.R.

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Related

Faust v. West
13 Vet. App. 342 (Veterans Claims, 2000)
Dofflemyer v. Derwinski
2 Vet. App. 277 (Veterans Claims, 1992)
Brown v. Brown
5 Vet. App. 413 (Veterans Claims, 1993)

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Bluebook (online)
190731-36966, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190731-36966-bva-2020.