190812-19280

CourtBoard of Veterans' Appeals
DecidedNovember 27, 2019
Docket190812-19280
StatusUnpublished

This text of 190812-19280 (190812-19280) 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
190812-19280, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 11/27/19 Archive Date: 11/27/19

DOCKET NO. 190812-19280 DATE: November 27, 2019

ORDER

Entitlement to an evaluation in excess of 50 percent for migraine headaches is denied.

Entitlement to total disability rating based upon individual unemployability (TDIU) to include on an extraschedular basis is denied.

FINDINGS OF FACT

1. The Veteran’s service-connected migraine headaches are currently evaluated at 50 percent, the maximum schedular rating available.

2. The Veteran did not meet the schedular criteria for a TDIU, and the preponderance of the evidence is against a finding that the Veteran’s service-connected disabilities does not present an exceptional or unusual disability picture productive of marked interference with employment or frequent periods of hospitalization.

CONCLUSIONS OF LAW

1. The criteria for entitlement to a disability rating in excess of 50 percent for service-connected migraine headaches have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. § 4.124, Diagnostic Code 8100.

2. The criteria for entitlement to a TDIU to include on an extraschedular basis have not been met. 38 U.S.C. § 1155; 38 C.F.R. § § 3.340, 3.341, 4.16, 4.19.

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. The Board is honoring the Veteran’s choice to participate in VA’s test program, RAMP, the Rapid Appeals Modernization Program.

In December 2018, the Veteran submitted a RAMP election form, selecting the Higher-Level Review lane for his appeal. Accordingly, the February 2019 RAMP rating decision considered the evidence of record as of the date VA received the RAMP election form. The Veteran timely appealed this RAMP rating decision to the Board and requested direct review of the evidence considered by the Agency of Original Jurisdiction (AOJ).

Evidence was added to the claims file during a period of time when new evidence was not allowed. Therefore, the Board may not consider this evidence. 38 C.F.R. § 20.300. The Veteran may file a Supplemental Claim and submit or identify this evidence. 38 C.F.R. § 3.2501. If the evidence is new and relevant, VA will issue another decision on the claim, considering the new evidence in addition to the evidence previously considered. Id. Specific instructions for filing a Supplemental Claim are included with this decision.

The Veteran served in active duty with the Navy from April 1964 to May 1965. This matter is on appeal from a September 2016 and November 2017 rating decision. The Veteran did not request a hearing.

In February 2018, the RO requested the Director of Compensation Service give an opinion for TDIU on an extraschedular basis in relation to the Veteran’s service-connected migraine headaches. In March 2018, the Director of Compensation Service issued an advisory opinion.

This appeal has been advanced on the Board’s docket pursuant to 38 C.F.R. § 20.900(c). 38 U.S.C. § 7107(a)(2).

Increased Rating

In general, disability ratings are determined by applying the VA’s Schedule for Rating Disabilities (Rating Schedule). See 38 C.F.R. Part 4. The percentage ratings contained in the Rating Schedule represent, as far as can practicably be determined, the average impairment in earning capacity resulting from diseases and injuries incurred or aggravated during military service and their residual conditions in civil occupations. See 38 U.S.C. § 1155; 38 C.F.R. § 4.1.

The percentage ratings contained in the Rating Schedule represent, as far as can practically be determined, the average impairment in earning capacity resulting from such disease or injury and their residual conditions in civilian occupations. 38 U.S.C. § 1155; 38 C.F.R. § 4.1. VA has a duty to acknowledge and consider all regulations which are potentially applicable through the assertions and issues raised in the record, and to explain the reasons and bases for its conclusion. See Schafrath v. Derwinski, 1 Vet. App. 589 (1991).

If two disability evaluations are potentially applicable, the higher evaluation will be assigned if the disability picture more nearly approximates the criteria for that rating; otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7. All reasonable doubt as to the degree of disability will be resolved in favor of the claimant. 38 C.F.R. § 4.3.

Where entitlement to compensation has already been established and an increase in the disability rating is at issue, the primary concern is the present level of disability. Francisco v. Brown, 7 Vet. App. 55, 58 (1994). However, the Board must also consider staged ratings. Staged ratings are not appropriate in this matter as the evidence establishes that the Veteran’s service-connected disability largely remained stable and constant. Hart v. Mansfield, 21 Vet. App. 505, 509–10 (2007).

The evaluation of the same disability under several diagnostic codes, known as pyramiding, must be avoided; however, separate ratings may be assigned for distinct disabilities resulting from the same injury so long as the symptomatology for one condition is not duplicative of or overlapping with the symptomatology of the other. Esteban v. Brown, 6 Vet. App. 259, 262 (1994); 38 C.F.R. § 4.14.

The Veteran is competent to report symptoms and experiences observable by his senses. See Jandreau v. Nicholson, 492 F.3d 1372, 1377 (Fed. Cir. 2007); 38 C.F.R. § 3.159(a).

Migraine Headaches

The Veteran is currently rated at 50 percent disabling for migraine headaches under Diagnostic Code 8100.

Under 38 C.F.R. § 4.124a

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Esteban v. Brown
6 Vet. App. 259 (Veterans Claims, 1994)
Sabonis v. Brown
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Francisco v. Brown
7 Vet. App. 55 (Veterans Claims, 1994)
Johnson v. Brown
7 Vet. App. 95 (Veterans Claims, 1994)
Shipwash v. Brown
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190812-19280, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190812-19280-bva-2019.