200224-66794

CourtBoard of Veterans' Appeals
DecidedJanuary 29, 2021
Docket200224-66794
StatusUnpublished

This text of 200224-66794 (200224-66794) 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
200224-66794, (bva 2021).

Opinion

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

DOCKET NO. 200224-66794 DATE: January 29, 2021

ORDER

Entitlement to an initial rating of 70 percent, but no higher, prior to January 9, 2014, for posttraumatic stress disorder (PTSD) is granted.

Entitlement to an initial rating in excess of 70 percent since January 9, 2014, for PTSD is denied.

Entitlement to total disability rating based on individual unemployability (TDIU) prior to January 9, 2014, is granted.

FINDINGS OF FACT

1. For the entire appeal period, the Veteran’s PTSD is most appropriately characterized by occupational and social impairment with deficiencies in most areas.

2. From April 27, 2012, the Veteran’s CAD has precluded him from securing or following a substantially gainful occupation.

CONCLUSIONS OF LAW

1. Prior to January 9, 2014, the criteria for an evaluation in excess of 70 percent, but no higher, for PTSD have been met. 38 U.S.C. §§ 1155, 5103, 5103A, 5107(b); 38 C.F.R. §§ 3.102, 3.159, 4.1-4.7, 4.10, 4.126, 4.130, Diagnostic Code 9411.

2. For the entire appeal period, the criteria for an evaluation in excess of 70 percent for PTSD have not been met. 38 U.S.C. §§ 1155, 5103, 5103A, 5107(b); 38 C.F.R. §§ 3.102, 3.159, 4.1-4.7, 4.10, 4.126, 4.130, Diagnostic Code 9411.

3. From April 27, 2012, the criteria for entitlement to TDIU have been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.340, 3.341, 4.3, 4.16.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

On August 23, 2017, the President signed into law the Veterans Appeals Improvement and Modernization Act, Pub. L. No. 115-55 (codified as amended in scattered sections of 38 U.S.C.), 131 Stat. 1105, also known as the Appeals Modernization Act (AMA). This law creates a new framework for Veterans dissatisfied with the Department of Veterans Affairs’ (VA’s) decision on their claim to seek review. The Board is honoring the Veteran’s choice to participate in VA’s test program, RAMP, the Rapid Appeals Modernization Program.

The Veteran had active duty service from September 1966 to September 1968. The Veteran selected the Higher-Level Review lane when he submitted the RAMP election form in September 2018. Accordingly, the March 2019 RAMP rating decision considered the evidence of record as of the date VA received the RAMP election form. In a VA Form 10182 (Decision Review Request: Board Appeal (Notice of Disagreement)) dated and received in February 2020, the Veteran elected the AMA modernized review system, requesting the option for direct review by a Veterans Law Judge with the Board of Veterans’ Appeal (Board) (placing the case on the Board’s Direct Review docket).

The Board has re-characterized the Veteran’s separate claims for an earlier effective date and an increased rating for his PTSD as one claim for an increased rating. These claims are entirely overlapping as the Veteran contends that evidence supports an initial 70 percent evaluation for his PTSD from April 27, 2012, the date service connection for PTSD was granted. See February 2020 notice of disagreement. The adjudication of the increased rating claim will encompass all effective date concerns.

1. Entitlement to an initial rating in excess of 30 percent prior to January 9, 2014 and in excess of 70 percent thereafter for PTSD.

Disability evaluations are determined by comparing a Veteran’s present symptomatology with criteria set forth in the Department of Veterans Affairs (VA) Schedule for Rating Disabilities (Rating Schedule), which is based on average impairment in earning capacity. 38 U.S.C. § 1155; 38 C.F.R. Part 4. When a question arises as to which of two ratings apply under a particular diagnostic code, the higher evaluation is assigned if the disability more closely approximates the criteria for the higher rating. 38 C.F.R. § 4.7. After careful consideration of the evidence, any reasonable doubt remaining is resolved in favor of the Veteran. 38 C.F.R. § 4.3. The Veteran’s entire history is reviewed when making disability evaluations. See generally, 38 C.F.R. § 4.1; Schafrath v. Derwinski, 1 Vet. App. 589 (1995).

Where the veteran is appealing the rating for an already established service-connected condition, his present level of disability is of primary concern. See Francisco v. Brown, 7 Vet. App. 55, 58 (1994). However, when an appeal is based on the assignment of an initial rating for a disability, following an initial award of service connection for this disability, the rule articulated in Francisco does not apply. Fenderson v. West, 12 Vet. App. 119 (1999). 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).

The regulations for rating mental disorders are found in 38 C.F.R. §§ 4.125-4.130. The Board notes that PTSD is evaluated under Diagnostic Code 9411 which is rated according to the General Rating Formula for Mental Disorders.

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

A 50 percent rating is provided for occupational and social impairment with reduced reliability and productivity due to such symptoms as: flattened affect; circumstantial, circumlocutory, or stereotyped speech; panic attacks more than once a week; difficulty in understanding complex commands; impairment of short- and long-term memory (e.g., retention of only highly learned material, forgetting to complete tasks); impaired judgment; impaired abstract thinking; disturbances of motivation and mood; difficulty in establishing and maintaining effective work and social relationships.

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Related

Brian J. Hart v. Gordon H. Mansfield
21 Vet. App. 505 (Veterans Claims, 2007)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Schafrath v. Derwinski
1 Vet. App. 589 (Veterans Claims, 1991)
Francisco v. Brown
7 Vet. App. 55 (Veterans Claims, 1994)
Fenderson v. West
12 Vet. App. 119 (Veterans Claims, 1999)
Buie v. Shinseki
24 Vet. App. 242 (Veterans Claims, 2010)

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200224-66794, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200224-66794-bva-2021.