200502-81726

CourtBoard of Veterans' Appeals
DecidedAugust 31, 2021
Docket200502-81726
StatusUnpublished

This text of 200502-81726 (200502-81726) 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
200502-81726, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 08/31/21 Archive Date: 08/31/21

DOCKET NO. 200502-81726 DATE: August 31, 2021

ORDER

The reduction of a disability from 30 percent to 10 percent for a service-connected asthma effective July 1, 2020, was improper, and the restoration of the prior 30 percent rating is granted.

FINDINGS OF FACT

1. At the time of the April 2020 rating decision reducing the disability rating for service-connected asthma disability from 30 percent to 10 percent, effective July 1, 2020, the disability rating of 30 percent had been in effect fewer than five years.

2. At the time of the effective date of the April 2020 rating decision reducing the disability rating for service-connected asthma disability from 30 percent to 10 percent, effective July 1, 2020, a preponderance of the evidence of record did not demonstrate actual improvement in the Veteran's ability to function under the ordinary conditions of life and work.

CONCLUSION OF LAW

The criteria for a restoration of a 30 percent rating for a service-connected asthma disability have been met. 38 U.S.C. § 1155, 5103, 5103A, 5107 (2018); 38 C.F.R. §§ 3.102, 3.105, 3.321, 3.344, 4.1, 4.2, 4.3, 4.7, 4.10, 4.13, 4.97, Diagnostic Code 6602 (2020).

REASONS AND BASES FOR FINDINGS AND CONCLUSION

The Veteran had active military service from June 2008 to December 2008.

This matter comes to the Board of Veterans' Appeals (Board) on appeal from April 2020 rating decision issued by the Department of Veterans Affairs (VA) Regional Office (RO). In May 2020, the Veteran appealed to the Board and elected the direct review option. As such, the Board will consider the evidence of record at the time of the April 2020 rating decision on appeal. 38 C.F.R. § 20.301.

Rating Reduction-Asthma

The Veteran challenges the reduction of the rating for his asthma from 30 percent to 10 percent disabling and contends that his asthma has not improved, but rather has become worse.

In any case involving a rating reduction, the fact-finder must ascertain, based upon a review of the entire record, whether the evidence shows an actual change in the disability and whether the examination reports reflecting such change are based upon a thorough examination.

VA regulations provide for specific notice requirements in instances where a reduction in rating is considered. 38 C.F.R. § 3.105 (e). When a rating reduction is considered and the lower rating would result in a reduction or discontinuance of compensation payments currently being made, a rating proposing the reduction must be prepared and mailed to the Veteran's address of record. 38 C.F.R. § 3.105 (e). A proposed rating decision should set forth all of the material facts and reasons for the proposed reduction. 38 C.F.R. § 3.105 (e). The Veteran must be given 60 days to present additional evidence showing that compensation payments should be continued at the present level. 38 C.F.R. § 3.105 (e).

A reduction of a rating generally must be supported by the evidence on file at the time of the reduction, but pertinent post-reduction evidence favorable to restoring the rating must also be considered. Dofflemeyer v. Derwinski, 2 Vet. App. 277 (1992). If there is an approximate balance of positive and negative evidence regarding any material issue, all reasonable doubt shall be resolved in favor of the Veteran. In other words, a rating reduction must be supported by a preponderance of the evidence. 38 U.S.C. § 5107 (a); Brown v. Brown, 5 Vet. App. 413 (1993).

The provisions of 38 C.F.R. § 3.344 (a) require a review of the entire record of examinations and the medical history to ascertain whether the recent examination was full and complete. 38 C.F.R. § 3.344 (a). Examinations less full and complete than those on which payments were authorized or continued will not be used as a basis of reduction. Ratings will not be reduced on any one examination, except where all the evidence of record clearly warrants the conclusion that sustained improvement has been demonstrated, and it is reasonably certain that any material improvement will be maintained under the ordinary conditions of life. 38 C.F.R. § 3.344. If doubt remains, after according due consideration to all the evidence developed by the several items discussed in 38 C.F.R. § 3.344 (a), the rating agency will continue the rating in effect, citing the former diagnosis with the new diagnosis in parentheses. 38 C.F.R. § 3.344 (b).

The provisions of 38 C.F.R. § 3.344 (a) and 38 C.F.R. § 3.344 (b) apply to ratings which have continued for long periods at the same level, for 5 years or more. 38 C.F.R. § 3.344. They do not apply to disabilities which have not become stabilized and are likely to improve. Reexaminations disclosing improvement, physical or mental, in those disabilities will warrant reduction in rating. 38 C.F.R. § 3.344 (c). Collier v. Derwinski, 2 Vet. App. 247 (1992). Here, the Veteran's service-connected asthma ratings have not continued at the same level for at least 5 years. Consequently, the provisions of 38 C.F.R. § 3.344 (a) and (b) regarding stabilization of ratings do not apply in determining whether the reduction was proper. See 38 C.F.R. § 3.344 (c); Peyton v. Derwinski, 1 Vet. App. 282, 286-87 (1992).

A June 2019 primary care note indicates that the Veteran uses albuterol inhaler about twice a week for asthma. An August 6, 2019 telephone encounter note shows the Veteran called to report that she has been experiencing a nonproductive cough with slight chest tightness for about the last week. It was not an emergency and she denied shortness of breath or wheezing. She stated that she uses her albuterol inhaler one to two times daily now. A September 2019 pulmonary diagnostic study consult note indicate spirometry with evidence of mild airflow obstruction and significant response to bronchodilators. FVC and FEV-1 were within normal limits. FEV-1/FVC was reduced.

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Related

Peyton v. Derwinski
1 Vet. App. 282 (Veterans Claims, 1991)
Collier v. Derwinski
2 Vet. App. 247 (Veterans Claims, 1992)
Dofflemyer v. Derwinski
2 Vet. App. 277 (Veterans Claims, 1992)
Brown v. Brown
5 Vet. App. 413 (Veterans Claims, 1993)

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Bluebook (online)
200502-81726, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200502-81726-bva-2021.