200422-79472

CourtBoard of Veterans' Appeals
DecidedJune 30, 2020
Docket200422-79472
StatusUnpublished

This text of 200422-79472 (200422-79472) 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
200422-79472, (bva 2020).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 06/30/20 Archive Date: 06/30/20

DOCKET NO. 200422-79472 DATE: June 30, 2020

ORDER

Entitlement to a compensable rating for right pinky flexor tendonitis with contracture is denied.

Entitlement to a rating in excess of 10 percent for right middle finger flexor tendonitis with contracture is denied.

Entitlement to a rating in excess of 10 percent for right index finger flexor tendonitis with contracture is denied.

Entitlement to a compensable rating for graft donor site right forearm and 4th finger amputation scars is denied.

Entitlement to a rating in excess of 10 percent for posttraumatic amputation, distal tip of right ring finger with osteoarthritis and flexor tendonitis with contracture is denied.

FINDINGS OF FACT

1. The Veteran's right pinky flexor tendonitis with contracture has not resulted in ankylosis.

2. The Veteran's right middle finger flexor tendonitis with contracture has not resulted in ankylosis.

3. The Veteran’s right index finger flexor tendonitis with contracture has not resulted in ankylosis.

4. The Veteran’s graft donor site right forearm and 4th finger amputation scars are not manifested by an area or areas of 144 square inches (929 sq. cm.) or greater and are not unstable or painful.

5. The Veteran’s posttraumatic amputation, distal tip of right ring finger with osteoarthritis and flexor tendonitis with contracture has not resulted in metacarpal resection (more than one-half the bone lost).

CONCLUSIONS OF LAW

1. The criteria for a compensable rating for right pinky flexor tendonitis with contracture are not met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.59, 4.71a, Diagnostic Codes (DCs) 5009, 5230.

2. The criteria for a rating in excess of 10 percent for right middle finger flexor tendonitis with contracture are not met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.59, 4.71a, DCs 5009, 5229.

3. The criteria for a rating in excess of 10 percent for right index finger flexor tendonitis with contracture are not met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.59, 4.71a, DCs 5009, 5229.

4. The criteria for a compensable rating for graft donor site right forearm and 4th finger amputation scars are not met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.59, 4.118, DC 7802.

5. The criteria for a rating in excess of 10 percent for posttraumatic amputation, distal tip of right ring finger with osteoarthritis and flexor tendonitis with contracture are not met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.59, 4.71a, DC 5155.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran had active military service from November 1963 to November 1965.

The Veteran’s claim was decided in March 2020 rating decision. In April 2020, the Veteran timely appealed that decision to the Board of Veterans’ Appeals (Board) and requested direct review of the evidence considered by the Agency of Original Jurisdiction (AOJ). Direct review entails adjudication on an identical record; no additional development takes place. Therefore, the Board will only consider evidence of record at the time of the March 2020 decision on appeal; however, additional argument may be considered. 38 C.F.R. § 20.300.

Increased Ratings

Disability ratings are determined by applying the criteria set forth in VA’s Schedule for Rating Disabilities. Ratings are based on the average impairment of earning capacity. Individual disabilities are assigned separate diagnostic codes. See 38 U.S.C. § 1155; 38 C.F.R. § 4.1. Where entitlement to compensation has already been established, and an increase in the disability rating is at issue, the present level of disability is of primary concern. Although a rating specialist is directed to review the recorded history of a disability in order to make a more accurate evaluation, the regulations do not give past medical reports precedence over current findings. See Francisco v. Brown, 7 Vet. App. 55 (1994); 38 C.F.R. § 4.2. Staged ratings are, however, 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. The relevant focus for adjudicating an increased rating claim is on the evidence concerning the state of the disability from the time period one year before the claim was filed until VA makes a final decision on the claim. See generally Hart v. Mansfield, 21 Vet. App. 505 (2007). Where there is a question as to which of two evaluations shall be applied, the higher evaluation will be assigned if the disability picture more nearly approximates the criteria required for that rating; otherwise, the lower rating will be assigned. See 38 C.F.R. § 4.7.

In determining the degree of limitation of motion, several regulatory provisions are taken into consideration: the provisions of 38 C.F.R. § 4.40 concerning lack of normal endurance, functional loss due to pain, and pain on use and during flare-ups; the provisions of 38 C.F.R. § 4.45 concerning weakened movement, excess fatigability, and incoordination; and the provisions of 38 C.F.R. § 4.10 concerning the effects of the disability on the veteran’s ordinary activity. See DeLuca v. Brown, 8 Vet. App. 202 (1995). The evaluation of the same disability under various diagnoses is to be avoided. 38 C.F.R. § 4.14.

38 C.F.R. § 4.40 allows for consideration of functional loss due to pain and weakness causing additional disability beyond that reflected on range of motion measurements. Under 38 C.F.R. § 4.45, functional loss due to weakened movement, excess fatigability, and incoordination must also be considered. See DeLuca, 8 Vet. App. at 206-07.

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