191226-58548

CourtBoard of Veterans' Appeals
DecidedSeptember 29, 2020
Docket191226-58548
StatusUnpublished

This text of 191226-58548 (191226-58548) 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
191226-58548, (bva 2020).

Opinion

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

DOCKET NO. 191226-58548 DATE: September 29, 2020

ORDER

Entitlement to restoration of a 20 percent rating for lumbar spine disability is granted.

Entitlement to a rating in excess of 20 percent for lumbar spine disability is denied.

Entitlement to a rating in excess of 10 percent for right lower extremity radiculopathy of the sciatic nerve is denied.

FINDINGS OF FACT

1. At the time of the reduction, the record did not establish that a material improvement in the Veteran's lumbar spine disability actually occurred which resulted in an improvement in his ability to function under the ordinary conditions of life and work.

2. The probative evidence of record does not show that the Veteran’s lumbar spine disability has manifested to forward flexion to 30 degrees or less; or presented favorable or unfavorable ankylosis of the entire thoracolumbar spine or incapacitating episodes of intervertebral disc syndrome (IVDS).

3. The probative evidence of record does not show that the Veteran’s radiculopathy of the right lower extremity has manifested to moderate or severe incomplete paralysis or complete paralysis.

CONCLUSIONS OF LAW

1. The criteria for entitlement to restoration of a 20 percent rating for a lumbar spine disability have been met. 38 U.S.C. § 1155; 38 C.F.R. §§ 3.105(e), 3.344, 4.3, 4.7, 4.71(a), Diagnostic Code (DC) 5242.

2. The criteria for entitlement to a disability rating in excess of 20 percent for a lumbar spine disability have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.40, 4.45, 4.59, 4.71, 4.71a, DC 5242, DC 5243.

3. The criteria for entitlement to a disability rating in excess of 10 percent for right lower extremity radiculopathy of the sciatic nerve have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.40, 4.45, 4.59, 4.71, 4.124a, DC 8520.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty in the United States Army from November 1979 through October 1983 with additional service that included periods of active duty for training and inactive duty for training.

The issue comes before the Board of Veterans’ Appeals (Board) on appeal from an October 2019 rating decision by the Department of Veterans Affairs (VA) Regional Office (RO).

In December 2019, the Veteran submitted VA Form 10182 (NOD), selecting a hearing with a Veterans Law Judge. A February 2020 Board letter notified the Veteran that his appeal had been placed on the Hearing docket. The Board may only consider the evidence of record at the time of the agency of original jurisdiction (AOJ) decision on the issue on appeal; evidence submitted by the appellant or his representative at the hearing, to include testimony provided at the hearing; and evidence submitted by the appellant or his or her representative within 90 days following the hearing. 38 C.F.R. § 20.302(a). In the event that the hearing request is withdrawn, the Board’s decision will be based on a review of evidence of record at the time of the AOJ’s decision on the issue or issues on appeal and evidence submitted by the appellant or his or her representative within 90 days following receipt of the withdrawal. 38 C.F.R. § 20.302(b).

In a February 2020 letter from the Veteran’s representative, the Veteran waived his request for a hearing before the Board.

Entitlement to restoration of a 20 percent rating for a lumbar spine disability

The Veteran contends that the RO improperly reduced his rating for his service-connected lumbar spine.

The Veteran sought an increased disability rating for his service-connected lumbar spine disability, then rated as 20 percent disabling under DC 5242, in September 2019. In an October 2019 rating decision, the regional office reduced the Veteran’s disability rating from 20 percent to 10 percent, effective September 12, 2019.

Rating Reductions

Where a reduction in an evaluation of a service-connected disability is considered warranted and the lower evaluation would result in a reduction or discontinuance of compensation payments currently being made, a rating proposing the reduction or discontinuance must be prepared setting forth all material facts and reasons. In addition, the RO must notify the Veteran at the Veteran’s latest address that he or she has 60 days to present additional evidence showing that compensation should be continued at the present level. 38 C.F.R. § 3.105(e). The procedural framework and safeguards set forth in 38 C.F.R. § 3.105 governing rating reductions are required to be followed by VA before it issues any final rating reduction. See Brown v. Brown, 5 Vet. App. 413, 418 (1993).

A disability rating may not be reduced unless the evidence demonstrates that an improvement in the disability has occurred. 38 U.S.C. § 1155. In cases where ratings have not continued for long periods at the same level (five years or more) or to disabilities which have not become stabilized and are likely to improve, reexaminations disclosing improvement in these disabilities will warrant a rating reduction. 38 C.F.R. § 3.344(c). Without regard to whether a rating has been in effect for five years or more, a rating reduction is warranted only where the evidence contains thorough medical examinations demonstrating an actual improvement in disability. See 38 C.F.R. § 4.13. With any rating-reduction case not only must it be determined that an improvement in a disability has actually occurred but also that the improvement actually reflects an improvement in the veteran’s ability to function under the ordinary conditions of life and work. Brown v. Brown, 5 Vet. App. 413, 421 (1993). Specifically, it is necessary to ascertain, based upon a review of the entire recorded history of the condition, whether the evidence accurately reflects the elements of disability present. 38 C.F.R. § 4.2. Likewise, in such cases, the Board must establish, by a preponderance of the evidence and in compliance that a rating reduction is warranted. 38 C.F.R. § 3.344; Green v. Nicholson, 21 Vet. App. 512 (2006).

Here, as the rating reduction does not reduce the overall total compensation payable to the Veteran, the due process protections of 38 C.F.R.

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191226-58548, Counsel Stack Legal Research, https://law.counselstack.com/opinion/191226-58548-bva-2020.