191217-50006

CourtBoard of Veterans' Appeals
DecidedSeptember 29, 2020
Docket191217-50006
StatusUnpublished

This text of 191217-50006 (191217-50006) 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
191217-50006, (bva 2020).

Opinion

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

DOCKET NO. 191217-50006 DATE: September 29, 2020

ORDER

Entitlement to an initial evaluation in excess of 30 percent disabling for service-connected posttraumatic stress disorder (PTSD) prior to August 13, 2019, is granted.

FINDING OF FACT

Throughout the appeal period, the Veteran’s service-connected PTSD has been manifested by occupational and social impairment with deficiencies in most areas.

CONCLUSION OF LAW

The criteria for establishing entitlement to an initial evaluation of 70 percent disabling, but no higher, for the Veteran’s service-connected posttraumatic stress disorder (PTSD) prior to August 13, 2019 has been shown. 38 U.S.C. §§ 1155, 5107 (2014); 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.126, 4.130, Diagnostic Code 9411 (2018).

REASONS AND BASES FOR FINDING AND CONCLUSION

On August 23, 2017, the President signed into law the Veterans Appeals Improvement and Modernization Act, Pub. L. No. 115-55 (to be codified as amended in scattered sections of 38 U.S.C.), 131 Stat. 1105 (2017), also known as the Appeals Modernization Act (AMA). This decision has been written consistent with the new AMA framework.

The Veteran had honorable active duty service with the United States Air Force from May 2008 to September 2008 and from September 2008 to March 2009.

As a preliminary matter, the Board observes that the Veteran was granted service connection for PTSD pursuant to an August 2018 rating decision. An evaluation of 30 percent disabling was assigned, effective February 16, 2018. Thereafter, the Veteran filed a claim for an increased rating on August 13, 2019. In a subsequent rating decision, dated September 11, 2019, an evaluation of 70 percent disabling was assigned, effective August 13, 2019.

In his VA Form 10182 Notice of Disagreement, dated December 2019, the Veteran disputed the assigned effective date for the assigned evaluation of 70 percent disabling only. Specifically, he contends that the noted evaluation is warranted throughout the appeal period. The Veteran requested direct review of the evidence considered by the Board of Veterans Appeals.

While the Board recognizes that the Veteran re-characterized the issue as one of entitlement to an earlier effective date for the assignment of a 70 percent evaluation, the Board is already considering whether a higher rating is warranted at any time prior to August 13, 2019 – thus addressing the date of entitlement to a higher rating. As the Veteran’s dispute is adequately addressed by the issue as stated above, the Board will adjudicate the Veteran’s claim as limited to the period prior to August 13, 2019.

Duty to Assist and to Notify

VA is required to notify a claimant of what information or evidence is necessary to substantiate the claim; what subset of the necessary information or evidence, if any, the claimant is to provide; and what subset of the necessary information or evidence, if any, the VA will attempt to obtain. 38 C.F.R. § 3.159(b) (2018). Copies of compliant VCAA notices were located in the claim’s file.

VA’s duty to assist includes providing a thorough and contemporaneous medical examination, especially where it is necessary to determine the current level of a disability. Peters v. Brown, 6 Vet. App. 540, 542 (1994).

In this case, neither the Veteran nor his representative has raised any issues with the duty to notify or duty to assist. See Scott v McDonald, 789 F.3d 1375, 1381 (Fed. Cir. 2015) (holding that “the Board’s obligation to read filings in a liberal manner does not require the Board... to search the record and address procedural arguments when the veteran fails to raise them before the Board.”); Dickens v. McDonald, 814 F.3d 1359, 1361 (Fed. Cir. 2016) (applying Scott to duty to assist argument).

Thus, upon careful review of the file, the Board finds that all necessary development has been accomplished, and therefore appellate review may proceed without prejudice to the Veteran. See Bernard v. Brown, 4 Vet. App. 384 (1993).

Increased Ratings, Generally

Disability ratings are determined by applying the criteria set forth in the VA Schedule for Rating Disabilities. 38 C.F.R. Part 4 (2018). The Board determines the extent to which a veteran’s service-connected disability adversely affects his ability to function under the ordinary conditions of daily life, and the assigned rating is based, as far as practicable, upon the average impairment of earning capacity in civil occupations. 38 U.S.C. § 1155 (2014); 38 C.F.R. §§ 4.1, 4.10 (2018). Where entitlement to compensation has already been established and an increase in the assigned evaluation is at issue, it is the present level of disability that is of primary concern. Francisco v. Brown, 7 Vet. App. 55, 58 (1994). Although the recorded history of a particular disability should be reviewed in order to make an accurate assessment under the applicable criteria, the regulations do not give past medical reports precedence over current findings. Id.

The Court has held that staged ratings are appropriate for initial rating and increased rating claims when the factual findings show distinct time periods where the service-connected disability exhibits symptoms that would warrant different ratings. Hart v. Mansfield, 21 Vet. App. 505 (2007).

When all the evidence is assembled, the Board is responsible for determining whether the evidence supports the claim or is in relative equipoise, with the Veteran prevailing in either event, or whether a preponderance of the evidence is against the claim, in which case, the claim is denied. See Gilbert v. Derwinski, 1 Vet. App. 49 (1990).

Entitlement to an evaluation in excess of 30 percent disabling for service-connected posttraumatic stress disorder (PTSD) prior to August 13, 2019.

The Veteran contends that his service-connected PTSD warrants a higher evaluation. For the reasons stated more fully below, the Board finds that the evidence supports a higher evaluation of 70 percent disabling throughout the appeal period.

Review of the record indicates that the Veteran’s service-connected psychiatric condition is currently evaluated under 38 C.F.R. § 4.130, Diagnostic Code 9411 (2018).

The General Rating Formula for Mental Disorders, including Diagnostic Codes 9411 and 9413, provide the following ratings for psychiatric disabilities:

A 30 percent evaluation is provided for occupational and social impairment with occasional decrease in work efficiency and intermittent periods of inability to perform occupational tasks (although generally functioning satisfactorily, with routine behavior, self-care, and conversation normal), due to such symptoms as: depressed mood, anxiety, suspiciousness, panic attacks (weekly or less often), chronic sleep impairment, mild memory loss (such as forgetting names, directions, recent events). Id.

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Related

Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Brian J. Hart v. Gordon H. Mansfield
21 Vet. App. 505 (Veterans Claims, 2007)
Genaro Vazquez-Claudio v. Shinseki
713 F.3d 112 (Federal Circuit, 2013)
Scott v. McDonald
789 F.3d 1375 (Federal Circuit, 2015)
Dickens v. McDonald
814 F.3d 1359 (Federal Circuit, 2016)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Bernard v. Brown
4 Vet. App. 384 (Veterans Claims, 1993)
Peters v. Brown
6 Vet. App. 540 (Veterans Claims, 1994)
Francisco v. Brown
7 Vet. App. 55 (Veterans Claims, 1994)

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191217-50006, Counsel Stack Legal Research, https://law.counselstack.com/opinion/191217-50006-bva-2020.