191030-42337

CourtBoard of Veterans' Appeals
DecidedMay 29, 2020
Docket191030-42337
StatusUnpublished

This text of 191030-42337 (191030-42337) 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
191030-42337, (bva 2020).

Opinion

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

DOCKET NO. 191030-42337 DATE: May 29, 2020

ORDER

Entitlement to an effective date earlier than August 30, 2017 for the grant of service connection for right shoulder impingement syndrome with acromioclavicular joint osteoarthritis is denied.

FINDING OF FACT

1. Service connection for a right shoulder disability was last denied in an August 2013 rating decision. The Veteran did not appeal that decision or submit new and material evidence within a year of the decision. The decision became final.

2. In a December 2017 rating decision, the Veteran was granted service connection for a right shoulder disability. The Veteran was assigned an effective date of August 30, 2017, the date of receipt of the claim to reopen.

3. No claim, either formal or informal, alleging entitlement to service connection for a right shoulder disability was presented to VA between the August 2013 rating decision and August 30, 2017.

CONCLUSION OF LAW

The criteria for entitlement to an effective date earlier than August 30, 2017 for the grant of service connection for right shoulder impingement syndrome with acromioclavicular joint osteoarthritis have not been met. 38 U.S.C. § 5110, 5103, 5103A, 5107 (2012); 38 C.F.R. §§ 3.156(c), 3.400 (2019).

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran had active service in the U.S. Army from April 1970 to April 1973 and April 1975 to February 1981.

Entitlement to an effective date earlier than August 30, 2017 for the grant of service connection for right shoulder impingement syndrome with acromioclavicular joint osteoarthritis

The Veteran appeals the denial of an effective date earlier than August 30, 2017 for the grant of service connection for right shoulder impingement syndrome with acromioclavicular joint osteoarthritis. Based on the evidence of record, the Board finds that the currently assigned effective date of August 30, 2017 for the award of service connection is the earliest possible effective date assignable in this case.

In this regard, the evidence shows that the Veteran submitted a claim for service connection for a right shoulder disability in June 1989. In a July 1990 rating decision, service connection for a right shoulder disability was denied. The Veteran was notified of the decision in July 1990. The decision was confirmed in August 1990. The Veteran expressed disagreement with the denial in August 1990. A Statement of the Case was issued in September 1990.

In October 1990, the Veteran requested an extension to respond to his appeal. He was granted a 60-day extension in November 1990. The Veteran did not submit any additional evidence within the applicable time frame nor did he submit a VA Form 9 Substantive Appeal. Rather, the next communication submitted by the Veteran and received by the RO was in October 1992. The July 1990 rating decision became final. 38 C.F.R. §§ 3.156, 20.200-305.

In March 1993, the Veteran submitted a request to reopen his claim for service connection. The RO denied reopening the claim in April 1993 and informed the Veteran of the denial and of his appellate rights. The Veteran did not appeal nor did he submit new and material evidence within one year. The April 1993 rating decision became final. 38 C.F.R. §§ 3.156, 20.200-305.

The Veteran submitted a request to reopen his claim for service connection in December 2008. The claim to reopen was denied in April 2009. The Veteran was notified of the denial and his appellate rights in Apri 2009. He did not appeal that decision or submit new and material evidence within the appeal period. The decision became final. 38 C.F.R. §§ 3.156, 20.200-305.

In a June 2012 statement, the Veteran expressed that he was “requesting an increase for his PTSD, migraine headache, right knee and right shoulder.” The claim to reopen was denied in August 2013. The Veteran was notified of the denial and his appellate rights in September 2013. He did not appeal that decision or submit new and material evidence within the appeal period. The decision became final. 38 C.F.R. §§ 3.156, 20.200-305.

A reopened claim for service connection for a right shoulder disability was received on August 30, 2017.

Section 5110(a) of title 38, U.S. Code, governs the assignment of an effective date for an award of benefits: The effective date of an award based on an original claim, a claim reopened after final adjudication, or a claim for increase, of compensation, dependency and indemnity compensation, or pension, shall be fixed in accordance with the facts found, but shall not be earlier than the date of receipt of application therefor. 38 U.S.C. § 5110(a). The implementing regulation similarly states that except as otherwise provided, the effective date of an evaluation and award of pension, compensation or dependency and indemnity compensation based on an original claim, a claim reopened after final disallowance, or a claim for increase will be the date of receipt of the claim or the date entitlement arose, whichever is the later. See 38 C.F.R. § 3.400.

VA amended its adjudication regulations on March 24, 2015 to require that all claims governed by VA’s adjudication regulations be filed on standard forms prescribed by the Secretary, regardless of the type of claim or posture in which the claim arises. The amendments implement the concept of an intent to file a claim for benefits, which operates similarly to the informal claim process, but requires that the submission establishing a claimant’s effective date of benefits must be received in one of three specified formats. The amendments also eliminate the constructive receipt of VA reports of hospitalization or examination and other medical records as informal claims to reopen under 38 C.F.R. § 3.157. See 38 C.F.R. § 3.1. The amended regulations, however, apply only to claims filed on or after March 24, 2015. Thus, prior to March 24, 2015, the standardized forms were not required.

For the time period prior to March 24, 2015, any communication or action indicating an intent to apply for one or more benefits under laws administered by the VA from a claimant may be considered an informal claim. Such an informal claim had to identify the benefits sought. Upon receipt of an informal claim, if a formal claim has not been filed, an application form was to be forwarded to the claimant for execution. If the application form was received within one year from the date it was sent to the claimant, it would have been considered filed as of the date of receipt of the informal claim. 38 C.F.R. § 3.155(a). To determine when a claim was received, the Board must review all communications in the claims file that may be construed as an application or claim.

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Bluebook (online)
191030-42337, Counsel Stack Legal Research, https://law.counselstack.com/opinion/191030-42337-bva-2020.