200131-59767

CourtBoard of Veterans' Appeals
DecidedJanuary 29, 2021
Docket200131-59767
StatusUnpublished

This text of 200131-59767 (200131-59767) 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
200131-59767, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 01/29/21 Archive Date: 01/29/21

DOCKET NO. 200131-59767 DATE: January 29, 2021

ORDER

Entitlement to an earlier effective date earlier of August 25, 2015 for the grant of a total disability rating based on individual unemployability (TDIU) is granted.

FINDINGS OF FACT

1. In a September 2015 Notification Letter, the Veteran was noted to have filed an Intent to File on August 20, 2015. However, he did not file the actual TDIU claim within a year of this noted intent to file (by August 20, 2016)

2. On August 8, 2016, the Veteran submitted an Intent to File. He then filed a notice of disagreement (NOD) with the effective date for the grant of service connection for his bilateral foot disability.

3. On August 25, 2016, the Veteran filed another Intent to File

4. On October 3, 2016, the Veteran submitted an application for increased compensation based on unemployability.

5. The Veteran did not appeal the initial rating assigned for his service-connected bilateral foot disability.

6. The evidence reasonably shows that the Veteran was unable to secure or follow substantially gainful employment due to his service-connected disabilities within the one-year period preceding the August 25, 2016 claim.

CONCLUSION OF LAW

The criteria for entitlement to an earlier effective date of August 25, 2015, for the grant of a TDIU have been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.340, 3.341, 3.400, 4.16.

REASONS AND BASES FOR FINDINGS AND CONCLUSION

The Veteran served on active duty from January 1973 to July 1975.

In May 2019, the Board granted entitlement to a total disability rating based on individual unemployability (TDIU). In a June 2019 rating decision, the RO implemented the Board’s grant of TDIU and assigned an effective date of August 25, 2016.

In October 2019, the Veteran submitted a VA Form 20-0996, Decision Review Request: Higher-Level Review (HLR), and requested review of a June 2019 rating decision. In November 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 a January 2020 VA Form 10182, Decision Review Request: Board Appeal (Notice of Disagreement) (NOD), the appellant elected the Direct Review option; therefore, the Board may only consider the evidence of record at the time of the agency of original jurisdiction (AOJ) decision on appeal. 38 C.F.R. § 20.301.

1. Entitlement to an earlier effective date of August 25, 2015, for the grant of a total disability rating based on individual unemployability (TDIU) is granted.

The Veteran has been awarded a TDIU effective August 25, 2016, the date VA received his intent to file. However, the Veteran seeks an effective date prior to August 25, 2016, for the award of TDIU. Specifically, the Veteran seeks an effective date of December 31, 2011, the day the Veteran retired. The Veteran’s representative contends that the Veteran’s TDIU claim was underlying an appeal that established service connection for the Veteran’s bilateral foot disability. Thus, the Veteran’s representative argues that the effective date of the TDIU grant should attach to the effective date of the bilateral foot grant. See January 2020 Statement in Support of Claim.

Regarding the assignment of effectives dates, the law provides, generally, that the effective date of an evaluation and award of pension, compensation or dependency and indemnity compensation based on an original claim, a claim reopened after final disallowance, or a claim for increase will be the date of receipt of the claim or the date entitlement arose, whichever is the later. 38 C.F.R. § 3.400. That is, the effective date of an award “shall be fixed in accordance with the facts found, but shall not be earlier than the date of receipt of application therefor.” 38 U.S.C. § 5110 (a).

An exception to 38 C.F.R. § 3.400 provides that in cases involving increases for disability compensation, the effective date will be the earliest date as of which it is factually ascertainable that an increase in disability had occurred if the claim is received within one year from such date; otherwise, the effective date will be the date of receipt of the claim. See 38 U.S.C. § 5110 (b)(2); 38 C.F.R. § 3.400 (o)(2); Harper v. Brown, 10 Vet. App. 125, 126 (1997).

The United States Court of Appeals for Veterans Claims (Court) determined that a TDIU award is an award of increased disability compensation for purposes of assigning an effective date. Wood v. Derwinski, 1 Vet. App. 367, 369 (1991); see also Hurd v. West, 13 Vet. App. 449 (2000); Norris v. West, 12 Vet. App. 413, 420-21 (1999).

To briefly clarify the procedural history, on March 30, 2010, the Veteran indicated that he wanted to reopen his service connection claim for a foot disability.

In a September 2015 Notification Letter, the RO indicated that the Veteran’s Intent to File was received on August 20, 2015. It was noted that the Veteran had one year to submit a completed application.

In a November 2015 Board decision, the Board granted service connection for a bilateral foot disability.

In a July 2016 rating decision, the RO granted service connection for a bilateral foot disability and assigned an evaluation of 50 percent, effective July 30, 2012.

On August 8, 2016, the Veteran filed a VA Form 21-0966 (Intent to File).

On August 25, 2016, the Veteran filed a NOD with regards to the effective date of his bilateral foot disability. The Veteran indicated that the effective date for his service connection claim should date back to March 30, 2010, the date in which he filed a claim to reopen his foot disability.

In addition, on August 25, 2016, the Veteran filed another VA Form 21-0966 (Intent to File).

On October 3, 2016, the Veteran submitted an application for increased compensation based on unemployability.

In December 2016, the RO denied the Veteran’s TDIU claim.

In February 2017, the Veteran submitted an NOD with regards to his TDIU claim.

In November 2017, the RO granted an earlier effective date of March 30, 2010 for the grant of service connection for a bilateral foot disability.

In May 2019, the Board granted entitlement to a TDIU.

In a June 2019 rating decision, the RO assigned an effective date of August 25, 2016, the date in which the Veteran filed his valid VA Form 21-0966 (Intent to File), for the Veteran’s TDIU.

With respect to the multiple Intents to File in the claims file, the Board notes that effective September 25, 2014, if a Veteran submits an intent to file application, the Veteran must submit “a complete application form prescribed by the Secretary” within one year of the submission of the intent to file application. 38 C.F.R. § 3.155 (b).

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Related

Gaston v. SHINSEKI
605 F.3d 979 (Federal Circuit, 2010)
Hurd v. West
13 Vet. App. 449 (Veterans Claims, 2000)
Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Wood v. Derwinski
1 Vet. App. 367 (Veterans Claims, 1991)
Godfrey v. Brown
7 Vet. App. 398 (Veterans Claims, 1995)
Harper v. Brown
10 Vet. App. 125 (Veterans Claims, 1997)
Norris v. West
12 Vet. App. 413 (Veterans Claims, 1999)

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200131-59767, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200131-59767-bva-2021.