200610-90481

CourtBoard of Veterans' Appeals
DecidedApril 30, 2021
Docket200610-90481
StatusUnpublished

This text of 200610-90481 (200610-90481) 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
200610-90481, (bva 2021).

Opinion

Citation Nr: AXXXXXXXX Decision Date: 04/30/21 Archive Date: 04/30/21

DOCKET NO. 200610-90481 DATE: April 30, 2021

ORDER

A reduction in rating for prostate cancer residuals from 100 percent to 40 percent disabling, effective July 1, 2020, was proper.

FINDINGS OF FACT

1. As of December 12, 2019, the Veteran’s prostate cancer has been in remission, with no recurrence or metastasis of the disease.

2. The Veteran’s prostate cancer residuals were not productive of current cancer treatment, leakage or incontinence requiring the use of an appliance or the wearing of absorbent materials which must be changed more than four times per day, or renal dysfunction; they were productive of daytime voiding interval less than one hour and/or awakening to void five or more times per night.

CONCLUSION OF LAW

The reduction in rating for prostate cancer residuals was proper. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.105(e), (i), 3.344(c), 4.1, 4.115a, 4.115b, Diagnostic Code (DC) 7528.

REASONS AND BASES FOR FINDINGS AND CONCLUSION

The Veteran served on active duty in the United States Air Force from June 1964 to December 1971.

In the June 2020 VA Form 10182, Decision Review Request: Board Appeal, the Veteran elected the Direct Review docket. Therefore, the Board may only consider the evidence of record at the time of the agency of original jurisdiction’s (AOJ) April 2020 Rating Decision. 38 C.F.R. § 20.301.

1. A reduction in the rating for prostate cancer residuals from 100 percent to 40 percent, effective July 1, 2020, was proper

The Veteran disputes the reduction in his rating for the residuals of his prostate cancer, from 100 percent to 40 percent effective July 1, 2020. The Board finds that the reduction was proper and based on the symptomology of the Veteran’s prostate cancer residuals, the current 40 percent disability rating is appropriate.

Generally, a disability rating will not be reduced unless an improvement in the disability is shown to have occurred. 38 U.S.C. § 1155. When VA makes a rating reduction without following the applicable regulations, the reduction is void ab initio. Greyzck v. West, 12 Vet. App. 288, 292 (1999). In considering the propriety of a reduction, the Board must focus on the evidence available to the Regional Office (RO) at the time the reduction was effectuated, although post-reduction evidence may be considered to determine whether the condition had demonstrated actual improvement. See Dofflemyer v. Derwinski, 2 Vet. App. 277, 281-282 (1992).

For reduction of ratings in place for at least five years, additional protections apply. Rating agencies are to handle cases affected by change of medical findings or diagnosis, so as to produce the greatest degree of stability of disability evaluations consistent with the laws and VA regulations governing disability compensation and pension. It is essential that the entire record of examinations and the medical-industrial history be reviewed to ascertain whether the recent examination was full and complete, including all special examinations indicated as a result of general examination and the entire case history. This applies to treatment of intercurrent diseases and exacerbations, including hospital reports, bedside examinations, examinations by designated physicians, and examinations in the absence of, or without taking full advantage of, laboratory facilities and the cooperation of specialists in related lines. 38 C.F.R. § 3.344(a). Here, the rating was not in place for five years, as the 100 percent rating was awarded September 8, 2015 and the reduction took effect on July 1, 2020.

Examinations less full and complete than those on which payments were authorized or continued will not be used as a basis of reduction. Moreover, though material improvement in the physical condition is clearly reflected the rating agency will consider whether the evidence makes it reasonably certain that the improvement will be maintained under the ordinary conditions of life. If doubt remains, after according due consideration to all the evidence developed, the rating agency will continue the rating in effect. 38 C.F.R. § 3.344(b).

The provisions of 38 C.F.R. § 3.105(e) allow for a rating reduction when warranted by the evidence, but only after following certain procedural guidelines. The RO must issue a rating action proposing the reduction and setting forth all material facts and reasons for the reduction. The Veteran must then be given 60 to submit additional evidence and 30 days from the date of the proposed reduction to request a predetermination hearing. Then, a rating action will be taken to effectuate the reduction. The effective date of the reduction must be after the last day of the month in which a 60-day period from the notice of the rating action ends. 38 C.F.R. § 3.105(e), (i).

VA reduced the Veteran’s evaluation to 40 percent effective July 1, 2020 in a rating decision dated April 9, 2020. He was notified of the reduction in a letter dated December 20, 2019 and was given full notice of the proposed reduction in compliance with 38 C.F.R. § 3.105(e). The evidence was clear that his cancer was in remission and was no longer being treated, see December 2019 VA examination. He was afforded a full and complete VA examination, and its findings were consistent with the entirety of his treatment records. He has provided no evidence or argument against the finding that his cancer was in remission and was no longer being treated. For these reasons, the Board finds that the Veteran’s reduction in rating for prostate cancer was in accordance with the procedures set forth under 38 C.F.R. § 3.105 and was proper.

The Board now turns to the 40 percent rating assigned for the residuals of the Veteran’s prostate cancer and finds that the 40 percent disability rating is appropriate for the symptomology shown.

Disability evaluations are determined by application of the criteria set forth in the VA’s Schedule for Rating Disabilities, which is based on average impairment in earning capacity. 38 U.S.C. § 1155; 38 C.F.R. Part 4. An evaluation of the level of disability present must also include consideration of the functional impairment of the Veteran’s ability to engage in ordinary activities, including employment. 38 C.F.R. § 4.10.

When a question arises as to which of two ratings apply under a particular diagnostic code, the higher evaluation is assigned if the disability more closely approximates the criteria for the higher rating. 38 C.F.R.

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Related

Schafrath v. Derwinski
1 Vet. App. 589 (Veterans Claims, 1991)
Dofflemyer v. Derwinski
2 Vet. App. 277 (Veterans Claims, 1992)
Greyzck v. West
12 Vet. App. 288 (Veterans Claims, 1999)

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200610-90481, Counsel Stack Legal Research, https://law.counselstack.com/opinion/200610-90481-bva-2021.