191125-45691

CourtBoard of Veterans' Appeals
DecidedJune 30, 2020
Docket191125-45691
StatusUnpublished

This text of 191125-45691 (191125-45691) 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
191125-45691, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 06/30/20 Archive Date: 06/30/20

DOCKET NO. 191125-45691 DATE: June 30, 2020

ORDER

Entitlement to an evaluation in excess of 40 percent for a service-connected thoracolumbar spine disability is denied.

REMANDED

Entitlement to a total disability rating based on individual unemployability due to service-connected disabilities (TDIU) is remanded.

FINDING OF FACT

There is no evidence in the record of unfavorable ankylosis of the thoracolumbar spine at any time during the period on appeal.

CONCLUSION OF LAW

The criteria for an evaluation in excess of 40 percent for a service-connected thoracolumbar spine disability have not been met. 38 U.S.C. §§ 1155, 5107(b); 38 C.F.R. §§ 3.102, 4.1-4.10, 4.97, Diagnostic Code 5237.

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 (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 created a new framework for veterans dissatisfied with VA’s decision on their claim to seek review. The Veteran chose to participate in VA’s test program, RAMP, the Rapid Appeals Modernization Program. This decision has been written consistent with the new AMA framework.

The Veteran served on active duty with the United States Air Force from November 1990 to November 1994 and with the United States Navy from February 2004 to January 2008.

The Veteran selected the Higher-Level Review lane when he submitted the RAMP election form in June 2018. Accordingly, the April 2019 RAMP rating decision considered all evidence of record prior to the issuance of the RAMP rating decision by the Agency of Original Jurisdiction (AOJ). The Veteran timely appealed this RAMP rating decision to the Board in November 2019 and requested the direct review docket, which allows the Board to review only the evidence considered by the AOJ.

As an initial matter, the Board notes the Veteran has filed an informal Motion to Advance on the Docket (AOD) due to homelessness. He submitted a statement in support of this request written by a friend in July 2019, at whose house the Veteran currently resides temporarily. The statement indicates the Veteran’s housing situation is unstable, as the friend is selling the house to move out of state, at which point in time, the Veteran will experience homelessness. The Board finds that this is good or sufficient cause to advance the case on the docket. Thus, the AOD Motion is granted. See 38 C.F.R. § 20.800(c).

Increased Rating

Disability ratings are determined by applying the criteria set forth in the VA Schedule for Rating Disabilities and are intended to represent the average impairment of earning capacity resulting from disability. 38 U.S.C. § 1155; 38 C.F.R. § 4.1. When there is a question as to which of two ratings apply, VA will assign the higher of the two where the disability picture more nearly approximates the criteria for the next higher rating; otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7.

Disabilities must be viewed in relation to their entire history. 38 C.F.R. § 4.1. VA is required to interpret reports of examination in light of the whole recorded history, reconciling the various reports into a consistent picture so that the current rating may accurately reflect the elements of disability. 38 C.F.R. § 4.2. Any reasonable doubt regarding the degree of disability will be resolved in favor of the claimant. 38 C.F.R. § 4.3. VA is also required to evaluate functional impairment on the basis of lack of usefulness and the effects of the disabilities upon the claimant’s ordinary activity. 38 C.F.R. § 4.10; see generally Schafarth v. Derwinski, 1 Vet. App. 589 (1991).

Entitlement to an evaluation in excess of 40 percent for a service-connected thoracolumbar spine disability

The Veteran’s thoracolumbar spine disability is currently rated as 40 percent disabling under Diagnostic Code (DC) 5237. Spine disabilities are typically rated under the same general formula, except for intervertebral disc syndrome (IVDS), which has an alternate rating formula for incapacitating episodes. 38 C.F.R. § 4.71a, DCs 5235-5243.

Under the General Rating Formula for Diseases or Injuries of the Spine, a 40 percent evaluation is warranted for forward flexion of the thoracolumbar spine of 30 degrees or less. A 50 percent rating is assigned for unfavorable ankylosis of the entire thoracolumbar spine, and a 100 percent rating is assigned for unfavorable ankylosis of the entire spine. All of these evaluations under the general formula for rating spine injuries consider the disabilities with or without symptoms such as pain (whether or not it radiates), stiffness, or aching in the area of the spine affected by residuals of injury or disease.

The Formula for Rating IVDS Based on Incapacitating Episodes provides a 40 percent disability rating for IVDS with incapacitating episodes having a total duration of at least 4 weeks but less than 6 weeks during the past 12 months. A 60 percent disability rating is warranted for IVDS with incapacitating episodes having a total duration of at least 6 weeks during the past 12 months. 38 C.F.R. § 4.71a, DC 5243. Note (1) to the IVDS rating schedule provides that, for purposes of ratings under DC 5243, an incapacitating episode is a period of acute signs and symptoms due to IVDS that requires bed rest prescribed by a physician and treatment by a physician. Id.

In determining the appropriate evaluation for musculoskeletal disabilities, particular attention is focused on functional loss of use of the affected part. Under 38 C.F.R. § 4.40, functional loss may be due to pain, a finding of which must be supported by adequate pathology and evidenced by visible behavior on motion. Johnston v. Brown, 10 Vet. App. 80, 85 (1997). Weakness is as important as limitation of motion, and a part that becomes painful on use must be regarded as seriously disabled. Under 38 C.F.R. § 4.45, factors of joint disability also include increased or limited motion, weakness, fatigability, or painful movement, swelling, deformity or disuse atrophy. Where functional loss is alleged due to pain upon motion, VA must consider the provisions of 38 C.F.R. § 4.40 and § 4.45.

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Related

Tyra K. Mitchell v. Eric K. Shinseki
25 Vet. App. 32 (Veterans Claims, 2011)
Schafrath v. Derwinski
1 Vet. App. 589 (Veterans Claims, 1991)
DeLuca v. Brown
8 Vet. App. 202 (Veterans Claims, 1995)
Johnston v. Brown
10 Vet. App. 80 (Veterans Claims, 1997)

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191125-45691, Counsel Stack Legal Research, https://law.counselstack.com/opinion/191125-45691-bva-2020.