210107-135732

CourtBoard of Veterans' Appeals
DecidedApril 30, 2021
Docket210107-135732
StatusUnpublished

This text of 210107-135732 (210107-135732) 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
210107-135732, (bva 2021).

Opinion

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

DOCKET NO. 210107-135732 DATE: April 30, 2021

ORDER

Entitlement to an effective date prior to May 11, 2011, for the award of service connection for posttraumatic stress disorder (PTSD) is denied.

REMANDED

Entitlement to an initial disability rating in excess of 50 percent for PTSD is remanded.

Entitlement to a total disability rating based on individual unemployability due to service-connected disabilities (TDIU) is remanded.

FINDING OF FACT

The Veteran’s claim for entitlement to service connection for PTSD was received by the Regional Office (RO) on May 11, 2011.

CONCLUSION OF LAW

The criteria for an effective date prior to May 11, 2011, for the award of service connection for PTSD are not met. 38 U.S.C. §§ 5107, 5110, 5121; 38 C.F.R. §§ 3.102, 3.151, 3.155, 3.160, 3.400.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty from October 1963 to October 1967.

The decision on appeal was issued in May 2020 and constitutes an initial decision; therefore, the modernized review system applies. In the January 2021 VA Form 10182, Decision Review Request: Board Appeal, the Veteran elected the Evidence Submission docket. 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 with, or within 90 days from receipt of, the VA Form 10182. 38 C.F.R. § 20.303.

Effective Date

In general, the effective date of an evaluation and award of compensation based on an original claim, a claim reopened after final disallowance, or a claim for increase will be the date of receipt of the claim or the date entitlement arose, whichever is later. 38 U.S.C. § 5110(a); 38 C.F.R. § 3.400.

Effective March 24, 2015, VA amended its regulations to require that all claims governed by VA’s adjudication regulations be filed on a standard form. The amendments also, inter alia, eliminate the constructive receipt of VA reports of hospitalization or examination and other medical records as informal claims to reopen. See 79 Fed. Reg. 57,660 (Sept. 25, 2014), codified as amended at 38 C.F.R. §§ 3.151, 3.155 (2016). The amended regulations, however, apply only to claims filed on or after March 24, 2015. Because this claim was initiated prior to that date, the former regulations apply.

In some cases, a report of examination or hospitalization may be accepted as an informal claim for benefits. 38 C.F.R. § 3.157(b) (2014). The date of outpatient or hospital examination or date of admission to a VA hospital will be accepted as the date of receipt of a claim when such reports relate to examination or treatment of a disability for which service connection has previously been established or when a claim specifying the benefit sought is received within one year from the date of such examination, treatment or hospital admission. 38 C.F.R. § 3.157(b) (2014).

After careful consideration of the evidence, any reasonable doubt remaining is resolved in favor of the Veteran. 38 C.F.R. § 4.3. If the evidence for and against a claim is in equipoise, then the claim will be granted. A claim will be denied only if the preponderance of the evidence is against the claim. See 38 U.S.C. § 5107; Gilbert v. Derwinski, 1 Vet. App. 49, 56 (1990).

The evidence below focuses on the most salient and relevant evidence and on what this evidence shows or fails to show. The Veteran should not assume that the Board has overlooked pieces of evidence that are not specifically discussed herein. See Timberlake v. Gober 14 Vet. App. 122 (2000). The law requires only that the Board provide reasons for rejecting evidence favorable to the Veteran.

1. Entitlement to an effective date prior to May 11, 2011, for the award of service connection for PTSD

The Veteran contends that he should be granted an earlier effective date than May 11, 2011, for the award of service connection for his PTSD.

The Veteran filed a claim for PTSD on May 11, 2011. In a March 2013 rating decision, the RO denied the Veteran’s claim. The Veteran filed a Notice of Disagreement in June 2013 and a Statement of the Case was issued in January 2016. The Veteran perfected his appeal to the Board and the issue was remanded in September 2018 for an examination to determine the nature and etiology of his PTSD. In March 2020, the RO granted service connection for PTSD with a 50 percent disability rating from May 11, 2011, the date of his claim.

As an initial matter, the Board notes that the Veteran did not file a claim within one year after separation from service. Therefore, he is not entitled to an effective date from the day following separation from military service.

The Board has thoroughly reviewed the evidence of record to determine if the Veteran filed a claim, an informal claim, or expressed a written intent to file a claim for service connection for PTSD prior to May 11, 2011.

The Board notes that even if medical records related to PTSD were associated with the claim prior to May 11, 2011, such records cannot constitute an informal claim under 38 C.F.R. § 3.155, because treatment records alone do not indicate an intent to apply for service connection benefits. 38 C.F.R. § 3.155(a). Although 38 C.F.R. § 3.157(a) provides for a report of examination or hospitalization by VA to be accepted as an informal claim for benefits (without any indication of intent to apply for benefits) in certain instances, none of these instances are applicable here. As previously mentioned, the mere mention of a condition in a medical record alone cannot be construed as a claim for service connection. See MacPhee v. Nicholson, 459 F.3d 1323, 1326-27 (Fed. Cir. 2006).

Based on the foregoing, the Board finds that the VA received a formal or informal claim for PTSD on May 11, 2011. As previously noted, an effective date is assigned based on the date of the claim or the date entitlement arose, whichever is later. In the present case, even if entitlement arose prior to May 11, 2011, the date of the Veteran’s claim is the latter of the two dates.

The Board acknowledges that the Veteran’s claim regarding an increased rating for his PTSD is being remanded, in part, to obtain a new examination.

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Related

Timberlake v. Gober
14 Vet. App. 122 (Veterans Claims, 2000)
Sterling T. Rice v. Eric K. Shinseki
22 Vet. App. 447 (Veterans Claims, 2009)
Gilbert v. Derwinski
1 Vet. App. 49 (Veterans Claims, 1990)

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Bluebook (online)
210107-135732, Counsel Stack Legal Research, https://law.counselstack.com/opinion/210107-135732-bva-2021.