200410-77315

CourtBoard of Veterans' Appeals
DecidedFebruary 26, 2021
Docket200410-77315
StatusUnpublished

This text of 200410-77315 (200410-77315) 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
200410-77315, (bva 2021).

Opinion

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

DOCKET NO. 200410-77315 DATE: February 26, 2021

ORDER

Entitlement to an effective date of January 10, 2016, but no earlier, for the grant of a total disability rating based on individual unemployability (TDIU) is granted.

FINDING OF FACT

The most probative evidence demonstrates that the Veteran service-connected disabilities rendered him incapable of securing and following a substantially gainful employment from January 10, 2016.

CONCLUSION OF LAW

From January 10, 2016, the criteria for entitlement to an assignment of total disability rating based on individual unemployability (TDIU) are met. 38 U.S.C. §§ 5103A, 5107, 5110; 38 C.F.R. §§ 3.102, 3.340, 3.341, 4.16(b), 3.400.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran had active service from August 1982 to August 2005.

This matter comes before the Board of Veteran's Appeals (Board) on appeal of a March 2020 rating decision of a Department of Veteran's Affairs (VA) Regional Office of the Veteran's Benefits Administration, which is the Agency of Original Jurisdiction (AOJ).

The Veteran’s claim for a TDIU had its onset in the Legacy system. The Veteran filed an Application for Increased Compensation Based on Unemployability on October 14, 2016, which was denied in a March 4, 2017 rating decision. The Veteran filed a Notice of Disagreement on July 20, 2017, electing review by a Decision Review Officer. A March 2020 rating decision granted entitlement to a TDIU, effective September 14, 2016, and a March 2020 Statement of the Case (SOC) was issued.

The Veteran elected to appeal this issue to the Board by submitting a VA Form 10182 Board Appeal on April 10, 2020, selecting the direct review docket. As this is a Direct Review appeal under the Appeals Modernization Act (AMA) review system, the record closed on the date of the prior AMA decision, March 9, 2020.

1. Entitlement to an effective date earlier than September 14, 2016, for a total disability rating based on individual unemployability (TDIU)

Total disability ratings for compensation may be assigned, where the schedular rating is less than total, when the disabled person is, in the judgment of the rating agency, unable to secure or follow a substantially gainful occupation as a result of service-connected disabilities. 38 C.F.R. §§ 3.340, 3.341; 38 C.F.R. § 4.16(a).

A TDIU may be assigned where the schedular rating is less than total, when it is found that the disabled person is unable to secure or follow a substantially gainful occupation as a result of a single service-connected disability ratable at 60 percent or more, or as a result of two or more disabilities, provided at least one disability is ratable at 40 percent or more, and there is sufficient additional service-connected disability to bring the combined rating to 70 percent or more. 38 C.F.R. §§ 3.340, 3.341, 4.16(a).

With regard to the date of entitlement, the term "date entitlement arose" is not defined in the current statute or regulation. However, it is the date when the Veteran meets the requirements for the benefits sought, which is determined on a "facts found" basis. 38 U.S.C. § 5110 (a); McGrath v. Gober, 14 Vet. App. 28, 35 (2000). An effective date generally can be no earlier than the "facts found." DeLisio v. Shinseki, 25 Vet. App. 45 (2011). These "facts found" include the date the disability first manifested and the date entitlement to benefits was authorized by law and regulation. For instance, if a Veteran filed a claim for benefits for a disability before he actually had the disability, the effective date for benefits can be no earlier than the date the disability first manifested. Ellington v. Peake, 541 F.3d 1364, 1369-70 (Fed. Cir. 2008).

The AOJ granted the Veteran's claim to establish a TDIU, effective from September 14, 2016, the date of his Intent to File, which was followed by his application for a TDIU on October 14, 2016. The AOJ found that this was a full grant of the benefits sought regarding this issue. On April 15, 2020, the Veteran filed a timely Notice of Disagreement claiming entitlement to an earlier effective date. Contrary to the AOJ's finding, the TDIU allowance was not a full grant of the benefits sought, as the TDIU claim was filed during the pendency of the Veteran's appeal under the Legacy system seeking an increased evaluation for certain service-connected disabilities, and thus, a TDIU may be assigned as early as the Veteran's filing of these underlying claims. More specifically, the Board notes that a July 27, 2015, claim for increased rating for the Veteran’s depressive disorder was still pending at the time of the March 2017 rating decision that denied the Veteran’s October 2016 TDIU claim, and thus, can serve as the basis for considering entitlement to TDIU as far back as July 27, 2015. A request for a TDIU is not a separate claim for benefits, but rather an attempt to obtain an appropriate rating for a disability or disabilities, either as part of the initial adjudication of a claim or, as part of a claim for increased compensation if entitlement to the disability upon which TDIU is based has already been found to be service connected. Rice v. Shinseki, 22 Vet. App. 447 (2009). The Board finds that the issue seeking an earlier effective date for a TDIU is properly before the Board as part and parcel of the Veteran's contemporaneous claims seeking an increased evaluation for his service-connected disabilities.

Prior to January 28, 2013, the Veteran did not meet the threshold schedular percentage requirements for the award of a TDIU under the provisions of 38 C.F.R. § 4.16(a) as none of his service-connected disabilities were rated as 40 percent disabling or greater. Where the combined rating percentage requirements are not met, entitlement to the benefits may still be considered on an extraschedular basis when the Veteran is unable to secure and follow a substantially gainful occupation by reason of service-connected disabilities. 38 C.F.R. § 4.16(b). However, the Veteran was still working full-time and did not assert that he was precluded from maintaining a substantially gainful occupation so referral for extraschedular consideration was not warranted.

As of January 28, 2013, the Veteran’s service-connected lumbar spine disability was rated at 60 percent and his combined disability rating was 90 percent, thereby meeting the threshold criteria for a schedular TDIU. However, he was still working full-time and did not assert that he was precluded from maintaining a substantially gainful occupation. The record shows that the Veteran worked full time in substantially gainful employment through January 9, 2016. Therefore, the claim for an earlier effective date for a TDIU is denied prior to January 10, 2016, without further analysis. 38 C.F.R. §§ 3.340

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Related

Ellington v. Peake
541 F.3d 1364 (Federal Circuit, 2008)
McGrath v. Gober
14 Vet. App. 28 (Veterans Claims, 2000)
Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Lawrence Delisio v. Eric K. Shinseki
25 Vet. App. 45 (Veterans Claims, 2011)

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Bluebook (online)
200410-77315, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200410-77315-bva-2021.