200421-82758

CourtBoard of Veterans' Appeals
DecidedAugust 31, 2020
Docket200421-82758
StatusUnpublished

This text of 200421-82758 (200421-82758) 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
200421-82758, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 08/31/20 Archive Date: 08/31/20

DOCKET NO. 200421-82758 DATE: August 31, 2020

ORDER

The 50 percent disability rating for the Veteran’s bilateral pes planus is restored.

A total disability rating based on individual unemployability as a result of service-connected disabilities is denied.

FINDINGS OF FACT

1. An April 2020 rating decision reduced the disability rating assigned for the Veteran’s service-connected bilateral pes planus from 50 percent to 30 percent effective July 1, 2020.

2. At the time of the April 2020 rating decision, the medical evidence did not reflect an improvement in the Veteran’s bilateral pes planus under the ordinary conditions of his life.

3. The Veteran’s service-connected disabilities are not shown to preclude the Veteran from obtaining or maintaining substantially gainful employment.

CONCLUSIONS OF LAW

1. The reduction of the Veteran’s 50 percent rating for bilateral pes planus was not proper. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.105, 3.951(b), 4.71a, Diagnostic Code 5276.

2. The criteria for a total disability rating based on individual unemployability as a result of service-connected disabilities (TDIU) have not been met. 38 U.S.C. §§ 1155, 5103, 5107; 38 C.F.R. §§ 3.340, 3.341, 4.16.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran had active service from August 1961 to August 1962, and from March 1963 to March 1966.

The record reflects that a rating decision was issued in April 2020 as to the reduction of his pes planus. The Veteran timely appealed this rating decision to the Board and requested evidence submission reviewed by a Veterans Law Judge on April 21, 2020. Therefore, the Board may only consider the evidence of record at the time of the agency of original jurisdiction (AOJ) decision on appeal, as well as any evidence submitted by the Veteran within 90 days from receipt of VA Form 10182. 38 C.F.R. § 20.303.

Reduction

The Veteran was originally awarded a 50 percent evaluation for his service-connected bilateral pes planus pursuant to Diagnostic Code 5276 by a July 2017 rating decision. A January 2020 rating decision proposed to reduce his rating from 50 percent to a 30 percent rating. An April 2020 rating decision reduced the rating for his bilateral pes planus to 30 percent effective July 1, 2020. The Veteran asserts that the reduction was improper and that he is entitled to a 50 percent rating.

A veteran’s disability rating shall not be reduced unless an improvement in the disability is shown to have occurred. See 38 U.S.C. § 1155; Greyzck v. West, 12 Vet. App. 288, 292 (1999).

As a preliminary matter, the Board notes that the Veteran does not contend, and the evidence does not reflect, noncompliance with the procedural requirements for rating reductions. See 38 C.F.R. § 3.105(e). Therefore, the Board will focus only upon the propriety of the reduction.

The criteria governing certain rating reductions for certain service-connected disabilities is found in 38 C.F.R. § 3.344. The provisions of 3.344(a) and (b) apply to ratings that have been continued for five years or more. The 50 percent rating for pes planus had been in effect for less than five years at the time the reduction took place. Therefore, the provisions of 38 C.F.R. § 3.344(a) and (b) do not apply. Reexamination disclosing improvement will warrant a rating reduction. 38 C.F.R. § 3.344(c). Nevertheless, in Brown v. Brown, 5 Vet. App. 413 (1993), the Court stated that there are general VA regulations that apply to all rating reductions regardless of whether the rating has been in effect for five years or more. Id. at 420-421.

Specifically, 38 C.F.R. § 4.1 requires that each disability be viewed in relation to its history. 38 C.F.R. § 4.2 establishes that it is the reasonability of the rating specialist to interpret reports of examination in light of the whole recorded history, reconciling the various reports into a consistent picture so that the current rating may accurately reflect the elements of disability present. Furthermore, 38 C.F.R. § 4.13 provides that the rating agency should assure itself that there has been an actual change in the condition, for better or worse, and not merely a difference in the thoroughness of the examination or in use of descriptive terms. Additionally, in any rating reduction case, not only must it be determined that an improvement in a disability has actually occurred, but that such improvement reflects improvement in ability to function under ordinary conditions of life and work. Brown, 5 Vet. App. at 420-21. A claim as to whether a rating reduction was proper must be resolved in the veteran’s favor unless the Board concludes that a preponderance of evidence weighs against the claim. Brown, 5 Vet. App. at 421.

Under Diagnostic Code 5276 for pes planus, a 30 percent rating is assigned for severe bilateral pes planus with objective evidence of marked deformity (pronation, abduction, etc.), pain on manipulation and use accentuated indication of swelling on use, and characteristic callosities. A 50 percent rating, the maximum rating available, is assigned when there is pronounced bilateral pes planus with marked pronation, extreme tenderness of plantar surfaces of the feet, marked inward displacement and severe spasm of the tendo achillis on manipulation, not improved by orthopedic shoes or appliances.

In April 2017, the Veteran was afforded a VA examination. He reported having a pins and needles sensation and pain in his feet. He reported having flare-ups resulting in increased pain. He reported having functional loss that prevent him from walking more than a block without having to stop. The examiner indicated that the Veteran had pain on use of the feet that was accentuated on use. The examiner indicated that the Veteran had pain on manipulation of the feet that was accentuated on manipulation. The examiner indicated that the Veteran did not have marked pronation. The examiner indicated that the Veteran had extreme tenderness of plantar surfaces of both feet. The examiner indicated that the Veteran did not have marked inward displacement and severe spasm of the Achille’s tendon. The examiner indicated that there was no evidence of marked deformity. The examiner indicated that there was no indication of swelling on use. The examiner indicated there the Veteran did have characteristic callouses. The examiner indicated that the Veteran had pain with movement, weight-bearing, and nonweight-bearing.

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Related

Sterling T. Rice v. Eric K. Shinseki
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Blackburn v. Brown
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5 Vet. App. 375 (Veterans Claims, 1993)
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Greyzck v. West
12 Vet. App. 288 (Veterans Claims, 1999)

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200421-82758, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200421-82758-bva-2020.