190806-25316

CourtBoard of Veterans' Appeals
DecidedMay 29, 2020
Docket190806-25316
StatusUnpublished

This text of 190806-25316 (190806-25316) 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
190806-25316, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 05/29/20 Archive Date: 05/29/20

DOCKET NO. 190806-25316 DATE: May 29, 2020

ORDER

Entitlement to a restoration of a 30 percent rating evaluation for posttraumatic headache disorder, is granted; however, entitlement to an increased rating in excess of 30 percent is denied.

Entitlement to a restoration of a 10 percent rating evaluation for traumatic brain injury (TBI), is granted; however, entitlement to an increased rating in excess of 10 percent is denied.

Entitlement to a 10 percent disability rating for multiple noncompensable service-connected disabilities pursuant to 38 C.F.R. § 3.324, is denied.

FINDINGS OF FACT

1. The Veteran’s 30 percent rating for posttraumatic headache disorder was in effect for more than 5 years at the time of the rating reduction, and the evidence does not establish sustained improvement under the normal circumstances of life and work.

2. The Veteran’s 10 percent rating for TBI was in effect for more than 5 years at the time of the rating reduction, and the evidence does not establish sustained improvement under the normal circumstances of life and work.

3. Throughout the appeal period, the Veteran’s posttraumatic headache disorder has been manifested by migraines characteristic of prostrating attacks occurring on an average once a month over the last several months.

4. Throughout the appeal period, the Veteran’s TBI has been manifested by facets of cognitive impairment and other residuals of TBI, of no more than mild severity; TBI residuals warranting a score of “2” or more to show impairment in one or more facets have not been shown.

5. For the applicable appeal period, the Veteran is in receipt of a compensable disability rating.

CONCLUSIONS OF LAW

1. The reduction in rating for posttraumatic headache disorder, effective October 1, 2019, was improper and restoration to the prior rating is warranted. 38 U.S.C. §§ 1155, 5107, 5112; 38 C.F.R. §§ 3.105, 3.344, 3.655, 4.71a Diagnostic Code 8100.

2. The reduction in rating for TBI, effective October 1, 2019, was improper and restoration to the prior rating is warranted. 38 U.S.C. §§ 1155, 5107, 5112; 38 C.F.R. §§ 3.105, 3.344, 3.655, 4.71a Diagnostic Code 8045.

3. The criteria for an increased rating in excess of 30 percent for posttraumatic headache disorder have not been met. 38 U.S.C. §§ 1155, 5103(a), 5103A, 5107; 38 C.F.R. §§ 3.159, 3.321, 4.87, Diagnostic Code 8100.

4. The criteria for an increased rating in excess of 10 percent for TBI have not been met. 38 U.S.C. §§ 1155, 5103(a), 5103A, 5107; 38 C.F.R. §§ 3.159, 3.321, 4.87, Diagnostic Code 8045.

5. For the applicable appeal period, the criteria for entitlement to a 10 percent disability evaluation for multiple noncompensable service-connected disabilities have not been met. 38 U.S.C. § 1155; 38 C.F.R. § 3.324.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served in the U.S. Army on active duty from May 1977 to May 1980. In a July 2019 rating decision, the Regional Office (RO) denied the Veteran’s claims, and in August 2019 the Veteran filed a VA Form 10182 requesting an appeal by way of evidence submission. Accordingly, the Board will consider the evidence of record submitted within 90 days of the election of the Evidence Submission lane.

Rating Reductions

In rating reductions, when VA contemplates reducing an evaluation for a veteran’s service-connected disability or disabilities, it must follow specific procedural steps prior to such discontinuance. 38 C.F.R. § 3.105(e). As enumerated in 38 C.F.R. § 3.105(e), “[w]here the reduction in evaluation of a service-connected disability or employability status is considered warranted and the lower evaluation would result in a reduction or discontinuance of compensation payments currently being made, a rating proposing the reduction or discontinuance will be prepared setting forth all material facts and reasons.” Id. In addition, “[t]he beneficiary will be notified at his or her latest address of record of the contemplated action and furnished detailed reasons therefore and will be given 60 days for the presentation of additional evidence to show that compensation payments should be continued at their present level.” Id. The beneficiary also will receive notification that “he or she will have an opportunity for a pre-determination hearing,” 38 C.F.R. § 3.105(i), and thereafter, a “final rating action will be taken and the award will be reduced or discontinued effective the last day of the month in which a 60-day period from the date of notice to the beneficiary of the final rating action expires.” See 38 C.F.R. §§ 3.105(e); 3.500(r). In addition to satisfying the procedures outlined above, the RO must gather evidence to establish that a rating reduction is proper.

Pertinent to the instant case, according to 38 C.F.R. § 3.344(a), titled “[e]xamination reports indicating improvement,” applies to disability ratings which have continued at the same level for 5 years or more, which is applicable in this case. See 38 C.F.R. § 3.344(c). 38 C.F.R. § 3.344(a) states that “[e]xaminations less full and complete than those on which payments were authorized or continued will not be used as a basis of reduction” and “though material improvement in the physical or mental condition is clearly reflected the rating agency will consider whether the evidence makes it reasonably certain that the improvement will be maintained under the ordinary conditions of life.”

Herein, and as discussed in greater detail below the Veteran’s 30 percent rating for posttraumatic headache disorder was in effect since December 3, 2004 and the Veteran’s 10 percent rating for traumatic brain injury was in effect since September 29, 2010.

A rating cannot be reduced unless improvement is shown to have occurred. 38 U.S.C. § 1155.

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Bruce W. Pierce v. Anthony J. Principi
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Bluebook (online)
190806-25316, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190806-25316-bva-2020.