190907-29404

CourtBoard of Veterans' Appeals
DecidedMarch 31, 2020
Docket190907-29404
StatusUnpublished

This text of 190907-29404 (190907-29404) 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
190907-29404, (bva 2020).

Opinion

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

DOCKET NO. 190907-29404 DATE: March 31, 2020

REMANDED

Entitlement to an initial rating in excess of 10 percent for right wrist osteoarthritis, excluding the period during which a temporary total rating based on convalescence was assigned pursuant to 38 C.F.R. § 4.30, is remanded.

REASONS FOR REMAND

The Veteran served on active duty from July 1982 to September 2004.

This matter is before the Board of Veterans’ Appeals (Board) on appeal from a rating decision issued in August 2019 by a Department of Veterans Affairs (VA) Regional Office (RO).

As an initial matter, the Board finds it necessary to address its jurisdiction over the current appeal and its characterization of the issue on appeal. To facilitate this discussion, the Board will lay out the procedural history of the current appeal. Service connection was granted for right wrist osteoarthritis in a December 2017 rating decision, and the RO assigned a 10 percent rating effective October 30, 2016. The Veteran did not file a notice of disagreement, instead filing a claim for an increased rating for his right wrist osteoarthritis in February 2018. 38 C.F.R. §§ 20.200, 20.201, 20.302 (2018). VA associated new VA treatment records with the file in March 2018 and obtained a new wrist examination in May 2018. 38 C.F.R. § 3.156(b) (2018).

In a June 2018 rating decision, the RO continued the 10 percent rating assigned for the right wrist osteoarthritis. The Veteran again did not appeal, and instead filed another claim for an increased rating and a temporary total rating in September 2018. 38 C.F.R. §§ 20.200, 20.201, 20.302 (2018). In conjunction with the September 2018 claim, a new VA wrist examination was obtained and associated with the file in September 2018. 38 C.F.R. § 3.156(b) (2018). In an October 2018 rating decision, the RO denied entitlement to an increased rating for the right wrist osteoarthritis and entitlement to a temporary total rating based on hospitalization or convalescence. 38 C.F.R. §§ 4.29, 4.30 (2018).

In November 2018, the Veteran requested reconsideration of the October 2018 rating decision, and submitted medical records showing that he was currently off work following a right wrist surgery. A rating decision issued in January 2019 granted a temporary total rating pursuant to 38 C.F.R. § 4.30 for the period from October 17, 2018 to January 1, 2019 and assigned a 10 percent rating from January 1, 2019 forward.

In January 2019 correspondence, the Veteran stated that he should have been assigned a 100 percent rating for a period of one year based on a total replacement of his right wrist joint, and that the failure to do so constituted a clear and unmistakable error. At the same time the Veteran filed another claim for an increased rating for his wrist but did not file a formal notice of disagreement with the decision. 38 C.F.R. §§ 20.200, 20.202, 20.302 (2018). New VA treatment records containing range of motion testing for the wrist were associated with the file in January 2019. 38 C.F.R. § 3.156(b) (2019).

In March 2019, the RO issued another rating decision stating that revision of the ratings assigned for the right wrist was not warranted. That same month the Veteran filed a higher-level review request. 38 C.F.R. §§ 3.2400, 3.2500(a)(1)(i), 3.2601 (2019). The RO issued a higher-level review decision in August 2019, which again stated that revision of the ratings assigned for the right wrist disability was not warranted. In September 2019, the Veteran filed an appeal to the Board concerning right wrist osteoarthritis, requesting a temporary 100 percent based on a right wrist prosthetic placement. 38 C.F.R. §§ 3.2400(a)(1)(ii), 20.201, 20.202 (2019). The Veteran requested direct review of his appeal by the Board. 38 C.F.R. §§ 20.300, 20.301.

As to the question of jurisdiction, as outlined above following the assignment of the initial 10 percent rating for right wrist osteoarthritis in the December 2017 rating decision, the Veteran at no point initiated a legacy appeal of any of the rating decisions addressing the 10 percent rating. Instead, the Veteran’s claim for an increased rating for a right wrist disability remained pending as new and material evidence was repeatedly added to the file following the issuance of each of the rating decisions discussed above. 38 C.F.R. § 3.156(b); see Bond v. Shinseki, 659 F.3d 1362, 1367–68 (Fed. Cir. 2011).

As the Veteran at no point initiated an appeal of the assigned 10 percent rating under the legacy system, the Veteran was not required to withdraw a legacy appeal and elect review under the modernized appeal system. 38 C.F.R. § 3.2400(a)(1), (b)–(c). Instead, the Veteran’s pending claim for an increased rating for right wrist osteoarthritis was continuously readjudicated in light of new and material evidence, until a rating decision readjudicating the claim was issued after February 19, 2019, which the Veteran then properly appealed to the Board pursuant to the modernized review system. 38 C.F.R. §§ 3.2400(a)(1), 19.2(a). As such, the Board properly has jurisdiction over the current appeal under the modernized review system. 38 C.F.R. §§ 3.2400(a), 20.200 (2019).

With respect to the characterization of the issue on appeal, as noted the March 2019 rating decision and the August 2019 higher-level review decision characterized the issue as an assertion of clear and unmistakable error (CUE) in the assigned right wrist rating, likely based on the Veteran’s use of the phrase in January 2019 and March 2019 statements. However, as discussed above the Veteran’s primary contention throughout the period on appeal is that he should be assigned a rating for his right wrist disability based on Diagnostic Code 5053, governing wrist replacements. Thus, the Veteran’s primary disagreement lies with the rating that has been assigned to his wrist disability and is not in fact an assertion of CUE in prior decisions.

Further, as laid out above there has been no prior final decision concerning the rating assigned for the Veteran’s right wrist disability, as none of the prior rating decisions have become final.

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Related

Bond v. SHINSEKI
659 F.3d 1362 (Federal Circuit, 2011)
Stanley J. Palczewski v. R. James Nicholson
21 Vet. App. 174 (Veterans Claims, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
190907-29404, Counsel Stack Legal Research, https://law.counselstack.com/opinion/190907-29404-bva-2020.