200305-68211

CourtBoard of Veterans' Appeals
DecidedFebruary 26, 2021
Docket200305-68211
StatusUnpublished

This text of 200305-68211 (200305-68211) 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
200305-68211, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 02/26/21 Archive Date: 02/26/21

DOCKET NO. 200305-68211 DATE: February 26, 2021

ORDER

An initial evaluation in excess of 50 percent for posttraumatic stress disorder (PTSD) is denied.

FINDING OF FACT

The Veteran’s PTSD is not shown to have resulted in severe impairment or occupational and social impairment with deficiencies in most areas.

CONCLUSION OF LAW

The criteria for an initial evaluation in excess of 50 percent for PTSD have not been met. 38 U.S.C. § 1155; 38 C.F.R. § 4.130, Diagnostic Code 9411 (as in effect prior to November 7, 1996, and thereafter).

REASONS AND BASES FOR FINDING AND CONCLUSION

1. Initial evaluation in excess of 50 percent, PTSD.

The Veteran asserts that he is entitled to an initial evaluation in excess of 50 percent for PTSD.

In October 2017, the Board granted service connection for an acquired psychiatric disability. That same month, the RO effectuated the Board’s decision. The RO granted service connection for “acquired psychiatric disability, to include dysthymia, anxiety disorder, depressive disorder, adjustment disorder, and/or PTSD,” and assigned a 30 percent evaluation, with an effective date of January 25, 1994.

In April 2018, the Veteran filed a claim for an increased rating. In October 2019, the RO essentially readjudicated the initial evaluation issue de novo, and increased the Veteran’s evaluation to 50 percent, with an effective date of January 25, 1994.

That same month, the Veteran filed a timely AMA Notice of Disagreement, electing for Direct Review Lane. Under the direct review option, no additional evidence received after the issuance of the appealed rating decision may be considered; rather, the Board review is limited to the evidence of record at the time of the October 16, 2019 rating decision.

With regard to the history of the disability in issue, the Veteran is shown to have served in the Persian Gulf theater. He was not treated for psychiatric symptoms during service. Following separation from his second period of active duty, he is first shown to have received treatment for psychiatric symptoms in 1994.

As an initial matter, the RO’s assignment of an effective date for service connection in 1994 appears to have been in error. In a final decision, dated in October 1997, the Board denied a claim for service connection for major depression. In March 1999, the Board’s decision was affirmed by the Court of Appeals for Veterans Claims. In an unappealed and final decision, dated in January 2001, the RO determined that new and material evidence had not been submitted to reopen the claim. In an unappealed and final decision, dated in November 2001, the RO denied a claim for service connection for PTSD. A claim to reopen was not received until May 2003. See Veteran’s claim (VA Form 21-526), received in May 2003. Accordingly, there is no basis for an effective date in 1994. See 38 U.S.C. §§ 7104 (b), 7105 (c); 38 C.F.R. §§ 3.400, 20.1100, 20.1103. In any event, the Board will not disturb this aspect of the RO’s decision at this time. Ultimately, this distinction is immaterial as the evidence of record does not show a rating in excess of 50 percent is warranted at any time since 1994.

Assuming the 1994 effective date, during the course of the appeal, the rating criteria were changed. Specifically, on October 8, 1996, the VA published a final rule, effective November 7, 1996, to amend the section of the Schedule for Rating Disabilities dealing with mental disorders. 61 Fed. Reg. 52695 (Oct. 8, 1996).

In Kuzma v. Principi, 341 F.3d 1327 (Fed. Cir. 2003), the United States Court of Appeals for the Federal Circuit overruled Karnas v. Derwinski, 1 Vet. App. 308 (1991), to the extent it conflicts with the precedents of the Supreme Court and the Federal Circuit. In Karnas, the Court of Appeals for Veterans Claims held that where the law or regulations change while a case is pending, the version most favorable to the claimant applies, absent Congressional intent to the contrary. In VAOPGCPREC 7-2003, the General Counsel held that Karnas is inconsistent with Supreme Court and Federal Circuit precedent insofar as Karnas provides that, when a statute or regulation changes while a claim is pending before the VA or a court, whichever version of the statute or regulation is most favorable to the claimant will govern unless the statute or regulation clearly specifies otherwise. The General Counsel held that the rule adopted in Karnas no longer applies in determining whether a new statute or regulation applies to a pending claim. The General Counsel indicated that pursuant to Supreme Court and Federal Circuit precedent, when a new statute is enacted or a new regulation is issued while a claim is pending before VA, VA must first determine whether the statute or regulation identifies the types of claims to which it applies. If the statute or regulation is silent, VA must determine whether applying the new provision to claims that were pending when it took effect would produce genuinely retroactive effects. If applying the new provision would produce such retroactive effects, VA ordinarily should not apply the new provision to the claim. If applying the new provision would not produce retroactive effects, VA ordinarily must apply the new provision. VAOPGCPREC 7-2003.

Under 38 C.F.R. § 4.71a, Diagnostic Code (DC) 9411 (as in effect prior to November 7, 1996), a 70 percent rating is when the ability to establish and maintain effective or favorable relationships with people was severely impaired, and the psychoneurotic symptoms were of such severity and persistence that there is severe impairment in the ability to obtain or retain employment.

Under DC 9411, (as in effect November 7, 1996), a 70 percent rating is warranted for PTSD manifested by occupational and social impairment with deficiencies in most areas, such as work, school, family relations, judgment, thinking or mood, due to such symptoms as suicidal ideation; obsessional rituals which interfere with routine activities; speech that is intermittently illogical, obscure, or irrelevant; near-continuous panic or depression affecting the ability to function independently, appropriately, and effectively; impaired impulse control (such as unprovoked irritability with periods of violence); spatial disorientation; neglect of personal appearance and hygiene; difficulty in adapting to stressful circumstances (including work or a worklike setting); inability to establish and maintain effective relationships.

The symptoms listed at 38 C.F.R. § 4.130 are not an exclusive or exhaustive list of symptomatology which may be considered for a higher rating claim. Mauerhan v. Principi, 16 Vet. App. 436 (2002).

This appeal was certified to the Board in May 2020, subsequent to the effective date for changes to the applicable regulations, DSM-5 is applicable to this claim. See 70 Fed. Reg. 45,093-94 (Aug. 4, 2014). In such cases, it is not appropriate to discuss global assessment of functioning (GAF) scores. Golden v. Shulkin, 29 Vet. App. 221 (2018).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jandreau v. Nicholson
492 F.3d 1372 (Federal Circuit, 2007)
Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Ray A. Mc Clain v. R. James Nicholson
21 Vet. App. 319 (Veterans Claims, 2007)
Genaro Vazquez-Claudio v. Shinseki
713 F.3d 112 (Federal Circuit, 2013)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)
Karnas v. Derwinski
1 Vet. App. 308 (Veterans Claims, 1991)
Cartright v. Derwinski
2 Vet. App. 24 (Veterans Claims, 1991)
Caluza v. Brown
7 Vet. App. 498 (Veterans Claims, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
200305-68211, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200305-68211-bva-2021.