200115-53975

CourtBoard of Veterans' Appeals
DecidedDecember 31, 2020
Docket200115-53975
StatusUnpublished

This text of 200115-53975 (200115-53975) 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
200115-53975, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 12/31/20 Archive Date: 12/31/20

DOCKET NO. 200115-53975 DATE: December 31, 2020

ORDER

Entitlement to a disability rating of 70 percent for posttraumatic stress disorder (PTSD) is granted on and after November 19, 2018, subject to the laws and regulations governing the payment of monetary benefits.

Entitlement to a disability rating in excess of 10 percent for left knee degenerative arthritis status post arthroscopic surgery is denied.

Entitlement to a disability rating in excess of 10 percent for right knee strain with patellofemoral pain syndrome and patellar tendinitis is denied.

REMANDED

Service connection for hypertension is remanded.

Service connection for sleep apnea is remanded.

Service connection for erectile dysfunction is remanded.

FINDINGS OF FACT

1. Throughout the period on appeal, the Veteran’s PTSD has been manifested by occupational and social impairment with deficiencies in most areas, but not total occupational and social impairment.

2. For the period on appeal, the Veteran’s left knee degenerative arthritis status post arthroscopic surgery has manifested as painful motion, but not ankylosis, recurrent subluxation or lateral instability, limitation of flexion to 30 degrees, limitation of extension to 10 degrees, dislocated semilunar cartilage, removed semilunar cartilage with symptoms not already rated, or impairment of the tibia or fibula.

3. For the period on appeal, the Veteran’s right knee strain with patellofemoral pain syndrome and patellar tendinitis has manifested as painful motion, but not ankylosis, recurrent subluxation or lateral instability, limitation of flexion to 30 degrees, limitation of extension to 10 degrees, dislocated or removed semilunar cartilage, or impairment of the tibia or fibula.

CONCLUSIONS OF LAW

1. With resolution of reasonable doubt in the Veteran’s favor, on and after November 19, 2018, the criteria for a disability rating of 70 percent, but no higher, for PTSD have been met. 38 U.S.C. §§ 1155, 5107 (2012); 38 C.F.R. §§ 3.102, 4.1-4.14, 4.21, 4.126, 4.130, Diagnostic Code 9411 (2019).

2. For the period on appeal, the criteria for a disability rating in excess of 10 percent for left knee degenerative arthritis status post arthroscopic surgery have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.102, 4.1-4.14, 4.21, 4.40, 4.45, 4.59, 4.71a, Diagnostic Codes 5003-5260 (2019).

3. For the period on appeal, the criteria for a disability rating in excess of 10 percent for right knee strain with patellofemoral pain syndrome and patellar tendinitis have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.102, 4.1-4.14, 4.21, 4.40, 4.45, 4.59, 4.71a, Diagnostic Code 5260.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty in the Army from September 1978 to April 1985. In August 2019, the Veteran submitted a VA Form 20-0996, Decision Review Request: Higher-Level Review (HLR), and requested review of a July 2019 rating decision. In September 2019, the Agency of Original Jurisdiction (AOJ) issued the HLR decision on appeal, which considered the evidence of record at the time of the initial rating decision.

In the January 2020 VA Form 10182, Decision Review Request: Board Appeal, the Veteran elected the Direct Review docket. Therefore, the Board may only consider the evidence of record at the time of the July 17, 2019 rating decision. 38 C.F.R. § 20.301 (2019).

Evidence was added to the claims file during a period of time when new evidence was not allowed. As the Board is deciding the PTSD and knee claims, it may not consider this evidence in its decision with regard to those claims. 38 C.F.R. § 20.300 (2019). The Veteran may file a Supplemental Claim and submit or identify this evidence. 38 C.F.R. § 3.2501 (2019). If the evidence is new and relevant, VA will issue another decision on the claim, considering the new evidence in addition to the evidence previously considered. Id. Specific instructions for filing a Supplemental Claim are included with this decision.

As the Board is remanding the hypertension, sleep apnea, and erectile dysfunction claims for further development, this additional evidence will be considered by the AOJ in the adjudication of those claims.

Neither the Veteran nor his representative have raised any issues with the duty to notify or duty to assist prior to the rating decision on appeal. 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 a duty to assist argument).

Increased Ratings

Disability ratings are determined by applying a schedule of ratings that is based on average impairment of earning capacity. Separate Diagnostic Codes identify the various disabilities. 38 U.S.C. § 1155; 38 C.F.R. Part 4 (2019). Each disability must be viewed in relation to its history and the limitation of activity imposed by the disabling condition should be emphasized. 38 C.F.R. § 4.1.

“Staged” ratings are appropriate for an increased rating claim 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 entitlement to compensation has already been established and an increased rating is at issue, the relevant temporal focus for adjudicating an increased rating claim is on the evidence concerning the state of the disability from the time period one year before the claim was filed until July 17, 2019. Hart, 21 Vet. App. at 509; see also 38 U.S.C. § 5110(b)(3) (2012); 38 C.F.R. § 3.400(o)(2) (2019). VA received notice of the Veteran’s intent to file a claim on November 19, 2018.

Where there is a question as to which of two disability evaluations shall be applied, the higher evaluation is to be assigned if the disability picture more nearly approximates the criteria required for that rating. Otherwise, the lower rating is to be assigned. 38 C.F.R.

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200115-53975, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200115-53975-bva-2020.