200401-75488

CourtBoard of Veterans' Appeals
DecidedFebruary 26, 2021
Docket200401-75488
StatusUnpublished

This text of 200401-75488 (200401-75488) 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
200401-75488, (bva 2021).

Opinion

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

DOCKET NO. 200401-75488 DATE: February 26, 2021

ORDER

Entitlement to a disability rating higher than 30 percent for service-connected adjustment disorder with anxiety prior to July 11, 2018 is denied.

FINDINGS OF FACT

1. The Department of Veterans Affairs (VA) received the Veteran’s intent to file a claim for compensation on August 9, 2016, and received his original claim of service connection for a psychiatric disorder within one year of receipt of his intent to file a claim.

2. In a February 2017 rating decision issued under the legacy system, the Agency of Original Jurisdiction (AOJ) granted service connection and a 10 percent rating for adjustment disorder with anxiety, effective August 9, 2016; the Veteran perfected an appeal under the legacy system as to the issue of entitlement to a higher initial rating.

3. In March 2018, the Veteran opted into the modernized review system, also known as the Appeals Modernization Act (AMA), by submitting a Rapid Appeals Modernization Program (RAMP) election form and selecting the higher-level review (HLR) lane.

4. In an April 2018 RAMP HLR decision, the AOJ granted a higher 30 percent rating for the service-connected psychiatric disorder, effective August 9, 2016.

5. The Veteran continuously pursued his higher rating appeal by timely filing for administrative review of AMA rating decisions.

6. The AOJ issued a RAMP supplemental claim decision in December 2019 that granted a higher 70 percent rating for service-connected adjustment disorder with anxiety, effective July 11, 2018.

7. During the period prior to July 11, 2018, the severity, frequency, and duration of the Veteran’s symptoms of adjustment disorder with anxiety did not more closely approximate occupational and social impairment with reduced reliability and productivity.

CONCLUSION OF LAW

During the period prior to July 11, 2018, the criteria for a disability rating in excess of 30 percent for adjustment disorder with anxiety have not been met. 38 U.S.C. §§ 1155, 5107, 5110; 38 C.F.R. §§ 3.2500, 4.1, 4.3, 4.7, 4.126, 4.130, Diagnostic Code 9440.

REASONS AND BASES FOR FINDINGS AND CONCLUSION

In December 2019, the Veteran submitted a VA Form 20-0996, Decision Review Request: Higher-Level Review (HLR), requested review of a December 2019 rating decision that granted a higher 70 percent rating for service-connected adjustment disorder with anxiety, effective July 11, 2018, and contended that an earlier effective date was warranted for the higher rating. In March 2020, the AOJ issued the HLR decision on appeal, which considered the evidence of record at the time of the initial rating decision. Therefore, the Board may only consider the evidence of record at the time of the initial rating decision. 38 C.F.R. § 20.301.

In the April 2020 VA Form 10182, Decision Review Request: Board Appeal, the Veteran elected the Direct Review docket.

1. Entitlement to an earlier effective date prior to July 11, 2018 for the award of a 70 percent rating for adjustment disorder with anxiety

The Veteran contends that a higher 70 percent disability rating for service-connected adjustment disorder with anxiety, associated with rectal outlet dysfunction with change in bowel habits, should be effective from August 9, 2016, the date of service connection for this disability. See December 2019 request for HLR and April 2020 notice of disagreement. In these documents, the Veteran's representative contended that the evidence of record, including private examinations from ASC Psychological Clinic, demonstrates that he met the criteria for a 70 percent rating for adjustment disorder with anxiety and specific phobia from the date of his August 9, 2016 intent to file a claim. Previously, the representative contended that a higher initial rating of 50 or 70 percent should be assigned for the service-connected psychiatric disorder. See February 2017 notice of disagreement.

In the April 2020 notice of disagreement, the Veteran's representative asserted that the issue on appeal is entitlement to an earlier effective date for a 70 percent rating for anxiety.

As discussed below, the Board finds that the Veteran timely and continuously pursued his appeal for a higher initial rating for adjustment disorder with anxiety since his August 2016 claim, and thus the issue on appeal is entitlement to a rating higher than 30 percent during the period prior to July 11, 2018.

Unless specifically provided otherwise, the effective date of an award based on an initial claim, or a supplemental claim, of compensation, dependency and indemnity compensation, or pension, 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)(1). For purposes of determining the effective date of an award under this section, the date of application shall be considered the date of the filing of the initial application for a benefit if the claim is continuously pursued by filing any of the following, either alone or in succession: a request for higher-level review, a supplemental claim, or a notice of disagreement on or before the date that is one year after the date on which the agency of original jurisdiction issues a decision. 38 U.S.C. § 5110 (a)(2); 38 C.F.R. § 3.2500 (c), (h).

Except as otherwise provided by other provisions of this part, including § 3.400, the effective date will be fixed in accordance with the date of receipt of the initial claim or date entitlement arose, whichever is later, if a claimant continuously pursues an issue by timely filing in succession any of the available review options as specified in paragraph (c) of this section within one year of the issuance of the decision. 38 C.F.R. § 3.2500 (h)(1). For supplemental claims received more than one year after the date on which the agency of original jurisdiction issues notice of a decision, the effective date will be fixed in accordance with the date entitlement arose, but will not be earlier than the date of receipt of the supplemental claim. 38 C.F.R. § 3.2500 (h)(2).

The effective date of an award of increased compensation shall be the earliest date as of which it is ascertainable that an increase in disability had occurred, if application is received within one year from such date. 38 U.S.C. § 5110 (b)(3); 38 C.F.R. § 3.400 (o).

A specific claim in the form prescribed by VA must be filed in order for benefits to be paid or furnished to any individual under the laws administered by VA. 38 U.S.C. § 5101 (a); 38 C.F.R. § 3.151 (a).

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Related

McGrath v. Gober
14 Vet. App. 28 (Veterans Claims, 2000)
Genaro Vazquez-Claudio v. Shinseki
713 F.3d 112 (Federal Circuit, 2013)

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Bluebook (online)
200401-75488, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200401-75488-bva-2021.