191121-44920

CourtBoard of Veterans' Appeals
DecidedDecember 31, 2019
Docket191121-44920
StatusUnpublished

This text of 191121-44920 (191121-44920) 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
191121-44920, (bva 2019).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 12/31/19 Archive Date: 12/31/19

DOCKET NO. 191121-44920 DATE: December 31, 2019

ORDER

Entitlement to an effective date of March 1, 2019, but no earlier, for the award of additional dependent compensation for the Veteran’s spouse is granted.

FINDING OF FACT

On June 24, 2019, and within one year of the February 27, 2019 rating decision, the RO received VA From 21-686c, Declaration of Status of Dependents, from the Veteran identifying his spouse.

CONCLUSION OF LAW

The criteria for an effective date of March 1, 2019, but no earlier, for the award of additional dependent compensation for the Veteran’s spouse have been met. 38 U.S.C. §§ 1115, 5101, 5110 (2012); 38 C.F.R. §§ 3.4, 3.31, 3.204, 3.400, 3.401 (2017).

REASONS AND BASES FOR FINDING AND CONCLUSION

The administrative decision on appeal was issued in August 2019. In November 2019, the Veteran elected Direct Review under the modernized review system. 84 Fed. Reg. 138, 177 (Jan. 18, 2019) (to be codified at 38 C.F.R. § 19.2(d)).

The Board notes that the issues of entitlement to service connection for bilateral hearing loss, tinnitus, degenerative joint disease of the lumbosacral spine, right shoulder osteoarthritis, and hypertension are also on appeal to the Board and will be addressed in a separate decision.

Entitlement to an effective date prior to July 1, 2019 for the award of additional dependent compensation for the Veteran’s spouse.

The Veteran claims that an effective date prior to July 1, 2019 is warranted for the award of additional dependent compensation for his spouse. Specifically, he contends that his spouse should be added to his award effective February 28, 2005, the date his combined rating met or exceeded 30 percent.

Veterans having a service-connected disability that is compensated at 30 percent or more may be entitled to additional compensation for each dependent. 38 U.S.C. § 1115. The effective date of such an award will be the latest of the following dates: (1) the date of claim; (2) the date the dependency arises; (3) the effective date of the qualifying disability rating provided evidence of dependency is received within a year of notification of such rating action; or (4) the date of commencement of the Veteran’s award. 38 C.F.R. § 3.401(b).

The “date of claim” for additional compensation for dependents is the date of the Veteran’s marriage or birth/adoption of a child, if evidence of the event is received within a year of the event; otherwise, the date notice is received of the dependent’s existence, if evidence is received within a year of the VA request. 38 C.F.R. § 3.401(b)(1). An award of additional compensation on account of dependents based on the establishment of a disability rating in the percentage evaluation specified by law for the purpose shall be payable from the effective date of such rating; but only if proof of dependents is received within one year from the date of notification of such rating action. 38 U.S.C. § 5110(f).

The earliest that the additional award of compensation for a dependent spouse can occur is the first day of the month following the effective date. 38 C.F.R. § 3.31.

In Sharp v. Shinseki, 23 Vet. App. 267, 276 (2009), the Veterans Court held that entitlement to additional compensation for dependents is premised on any rating decision establishing compensation under § 1114 and rating the disability not less than 30 percent. The Court further held that the effective date for additional compensation for dependents shall be the same as the date of the rating decision giving rise to such entitlement, irrespective of any previous grant of § 1115 benefits, if proof of dependents is submitted within one year of notice of the rating action. While the Court held that there can be “multiple rating decisions that establish entitlement to additional dependency compensation,” the Court still required that proof of dependent status be submitted within one year of notice of rating action.

Turning to the evidence of record, in a January 1995 rating decision, the RO awarded service-connected benefits with a noncompensable rating. The RO continued a noncompensable rating in a February 2002 rating decision. In a June 2005 rating decision, the RO awarded service-connected benefits with a combined 20 percent rating, effective February 28, 2005. Because the Veteran had a combined rating of less than 30 percent, he was not entitled to additional compensation for dependents at the time the January 1995, February 2002, and June 2005 rating decisions were issued.

In a January 2006 rating decision, the RO awarded service-connected benefits with a combined 40 percent rating, effective February 28, 2005, making the Veteran eligible to receive compensation for dependents. A January 2006 notification letter shows that the Veteran was informed that he was being paid as a single veteran with no dependents. VA Form 21-8767 (Disability Compensation Award Attachment – Important Information) was attached to the notification letter and contained additional information on factors concerning his benefits.

A March 2006 rating decision denied service-connected benefits and an April 2006 letter informed the Veteran that his compensation payment would continue unchanged.

In a March 2016 rating decision, the RO awarded service-connected benefits with a combined 60 percent rating, effective December 30, 2015. A March 2016 notification letter shows that the Veteran was informed that he was being paid as a single veteran with no dependents. The letter notified the Veteran that he may be eligible for additional benefits based on dependency and that retroactive benefits could be paid if a dependency claim was submitted within one year and to notify the VA if he had any dependents.

In April 2018, the Veteran opted into the Rapid Appeals Modernization Program (RAMP) and a Higher Level Review rating decision was issued on February 27, 2019. A March 2019 notification letter shows the Veteran was informed that he was being paid as a single Veteran with no dependents and that he must notify the VA of any changes with his spouse or children.

In March 2019, the Veteran expressed disagreement with the rate of his payment, noting that he had been married for nearly sixty years.

On June 24, 2019, the Veteran submitted VA Form 21-686c (Application Request to Add and/or Remove Dependents), listing his spouse and the date of marriage in June 1961.

In an August 2019 administrative decision, VA granted the Veteran’s claim for additional dependency, adding his spouse to his award effective June 24, 2019, the date he submitted the June 2019 dependency form, with additional compensation beginning July 1, 2019.

In August 2019, the Veteran filed a supplemental claim for an earlier effective date for the award of additional dependent compensation for his spouse, indicating that he had reported his marriage on a December 1994 VA Form 21-526 (Veteran’s Application for Compensation or Pension).

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Related

Pamela J. Sharp v. Eric K. Shinseki
23 Vet. App. 267 (Veterans Claims, 2009)
Ashley v. Derwinski
2 Vet. App. 62 (Veterans Claims, 1992)
Mason v. Brown
8 Vet. App. 44 (Veterans Claims, 1995)

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Bluebook (online)
191121-44920, Counsel Stack Legal Research, https://law.counselstack.com/opinion/191121-44920-bva-2019.