191209-48658

CourtBoard of Veterans' Appeals
DecidedSeptember 29, 2020
Docket191209-48658
StatusUnpublished

This text of 191209-48658 (191209-48658) 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
191209-48658, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 09/29/20 Archive Date: 09/29/20

DOCKET NO. 191209-48658 DATE: September 29, 2020

ORDER

The 60-percent rating for a chronic lumbosacral strain with intravertebral disc syndrome with (IVDS) is restored, effective January 1, 2020, subject to the law and regulations governing payment of monetary benefits.

FINDING OF FACT

The Veteran’s chronic lumbosacral strain with IVDS did not materially improve under the ordinary conditions of daily life and work from January 1, 2020.

CONCLUSION OF LAW

The reduction from 60 percent to 20 percent for chronic lumbosacral strain with IVDS was not warranted; the criteria for restoration of a 60 percent rating for the disability, from January 1, 2020, have been met. 38 U.S.C. §§ 1155; 38 C.F.R. §§ 3.105, 3.344, 4.2, 4.10, 4.13.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty from June 1982 to June 1985.

This matter comes before the Board of Veterans’ Appeals (Board) on appeal from an October 8, 2019 rating decision issued by the Department of Veterans Affairs (VA) Regional Office (RO) in Los Angeles, California.

The Veteran timely appealed this Appeals Modernization Act (AMA) rating decision to the Board and requested Direct Review of the evidence considered by the Agency of Original Jurisdiction (AOJ). Based on the Veteran’s choice to pursue a direct review of his appeal, the Board will decide the appeal “based on the evidence of record at the time of the prior decision,” in this case, the October 2019 rating decision.

Rating Reduction

There is no question that a disability rating may be reduced; however, the circumstances under which rating reductions can occur are specifically limited and carefully circumscribed by regulations promulgated by the VA Secretary. Dofflemyer v. Derwinski, 2 Vet. App. 277, 280 (1992). In Brown v. Brown, 5 Vet. App. 413, 420 (1993), the U.S. Court of Appeals for Veterans Claims (Court) interpreted the provisions of 38 C.F.R. § 4.13 to require that in any rating reduction case it must be ascertained, based upon a review of the entire recorded history of the disorder, whether the evidence reflects an actual change in the disability and whether the examination reports reflecting such change are based upon thorough examinations. Moreover, 38 C.F.R. §§ 4.2 and 4.10 provide that in any rating reduction case, not only must it be determined that an improvement in a disability has actually occurred, but also that improvement in a disability actually reflects improvement in the veteran’s ability to function under the ordinary conditions of life and work.

When the evidence indicates that a disability has stabilized to the point that a particular rating has continued for a long period of time (five years or more), and an examination indicates improvement in the disability, the rating agency must review the entire record of examinations and the medical-industrial history in order to ascertain whether the recent examination is full and complete, including all special examinations indicated as a result of general examination and the entire case history. Examinations less full and complete than those on which payments were authorized or continued will not be used as a basis of reduction. In arriving at a determination that there is material improvement in a physical or mental disability, the rating agency must consider whether the improvement will be maintained under the ordinary conditions of life. 38 C.F.R. § 3.344.

The provisions of 38 C.F.R. § 3.344(a) and (b) apply to ratings which have continued for long periods at the same level (five years or more). They do not apply to disabilities which have not become stabilized and are likely to improve. Reexaminations disclosing improvement, physical or mental, in these disabilities will warrant a reduction in rating. 38 C.F.R. § 3.344(c).

In an October 2016 rating decision, the AOJ granted service connection at 60 percent disabling for the Veteran’s chronic lumbosacral strain with IVDS, effective July 27, 2016.

The AOJ then proposed to reduce the 60 percent rating to 20 percent in a July 2019 rating decision. In a July 2019 letter, the Veteran was given due process notice of the proposed reduction in the rating for his chronic lumbosacral strain with IVDS. The letter also apprised him of his right to submit additional evidence to contest the reduction and request a pre-determination hearing. The AOJ therefore complied with the provisions of 38 C.F.R. § 3.105(e).

In an October 2019 rating decision, the AOJ effectuated the proposed reduction and assigned a 20 percent rating for the Veteran’s chronic lumbosacral strain with IVDS, effective January 1, 2020, the first day of the month after the 60-day notification period of this decision. The Veteran perfected an appeal as to this reduction.

The Board must now decide whether the reduction from 60 percent to 20 percent was proper. Since the 60 percent rating in this case was in effect from July 27, 2016, to December 31, 2019, a period of less than five years, the provisions of 38 C.F.R. § 3.344 are not applicable. See Brown, 5 Vet. App. at 417.

The Veteran’s service-connected lumbar spine disability with IVDS is evaluated under 38 C.F.R. § 4.71a, Diagnostic Code (DC) 5243. Under DC 5243, the Formula for Rating Intervertebral Disc Syndrome Based on Incapacitating Episodes, a 20 percent rating is warranted for incapacitating episodes having a total duration of at least two weeks but less than four weeks during the past 12 months. A 40 percent disability rating is warranted for incapacitating episodes having a total duration of at least four weeks, but less than six weeks during the past 12 months; and a 60 percent disability rating is warranted for incapacitating episodes having a total duration of at least six weeks during the past 12 months. 38 C.F.R. § 4.71a. An "incapacitating episode" for purposes of totaling the cumulative time is defined as "period of acute signs and symptoms due to intervertebral disc syndrome that requires bed rest prescribed by a physician and treatment by a physician." 38 C.F.R. § 4.71a, DC 5243, Formula for Rating Intervertebral Disc Syndrome Based on Incapacitating Episodes, Note 1.

The Notes following the General Rating Formula for Diseases and Injuries of the Spine provide further guidance in rating diseases or injuries of the spine.

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Related

Tyra K. Mitchell v. Eric K. Shinseki
25 Vet. App. 32 (Veterans Claims, 2011)
Russell W. Burton v. Eric K. Shinseki
25 Vet. App. 1 (Veterans Claims, 2011)
Thompson v. McDonald
815 F.3d 781 (Federal Circuit, 2016)
Dofflemyer v. Derwinski
2 Vet. App. 277 (Veterans Claims, 1992)
Brown v. Brown
5 Vet. App. 413 (Veterans Claims, 1993)
DeLuca v. Brown
8 Vet. App. 202 (Veterans Claims, 1995)
Correia v. McDonald
28 Vet. App. 158 (Veterans Claims, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
191209-48658, Counsel Stack Legal Research, https://law.counselstack.com/opinion/191209-48658-bva-2020.