210406-149959

CourtBoard of Veterans' Appeals
DecidedApril 30, 2021
Docket210406-149959
StatusUnpublished

This text of 210406-149959 (210406-149959) 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
210406-149959, (bva 2021).

Opinion

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

DOCKET NO. 210406-149959 DATE: April 30, 2021

ORDER

An earlier effective date of August 19, 2018, for the 70 percent evaluation assigned to posttraumatic stress disorder (PTSD) and generalized anxiety disorder (anxiety) is granted.

FINDING OF FACT

1. In an October 2019 rating decision, the RO granted an increased evaluation of 70 percent for the Veteran’s PTSD and anxiety, effective August 19, 2019.

2. The evidence of record reflects the Veteran met the criteria for a 70 percent evaluation for PTSD beginning August 19, 2018.

CONCLUSION OF LAW

The criteria for an effective date of August 19, 2018, for the evaluation of 70 percent for PTSD and anxiety, has been met. 38 U.S.C. §§ 5103, 5107, 5110; 38 C.F.R. §§ 3.400, 20.302, 20.1103.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served honorably in the United States Marine Corps from May 1966 to May 1970. For his meritorious service, the Veteran was awarded (among other decorations) the Combat Action Ribbon, Air Medal, Vietnam Campaign Medal, and Vietnam Service Medal.

This case comes before the Board of Veterans’ Appeals (Board) on appeal from a November 2020 rating decision issued by the Department of Veterans Affairs (VA) Regional Office (RO).

On August 23, 2017, the President signed into law the Veterans Appeals Improvement and Modernization Act, also known as the Appeals Modernization Act (AMA). 38 C.F.R. § 20.301. This law creates a new framework for Veterans dissatisfied with VA’s decision on their claim to seek review.

On July 10, 2020, the Veteran filed VA Form 20-0996 Request for Higher Level Review. The Veteran noted the specific issue he was appealing was the effective date award. The RO issued a rating decision in November 2020, denying an earlier effective date for the 70 percent evaluation for PTSD and anxiety. In the April 2021 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 (AOJ) decision on appeal. 38 C.F.R. § 20.301.

1. An earlier effective date of August 19, 2018 for the 70 percent evaluation assigned to PTSD and anxiety is granted.

The Veteran is seeking an effective date earlier than August 19, 2019 for his 70 percent evaluation assigned to PTSD and anxiety.

Unless specifically provided otherwise in the statute, the effective date of an award based on an original claim for compensation benefits shall 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. For increased rating claims, an effective date for an increase may be granted up to one year prior to the claim if it is factually ascertainable that an increase in disability occurred during that period. Harper v. Brown, 10 Vet. App. 125 (1997); 38 C.F.R. § 3.400 (o)(2); VAOPGCPREC 12-98 (Sept. 23, 1998). A reopened claim is any application for a benefit received after final disallowance of an earlier claim. 38 C.F.R. § 3.160 (e).

Regarding the award of an increased rating for compensation, the effective date shall be the earliest date that it is factually ascertainable that an increase in disability had occurred, if a claim is received within one year from that date. 38 U.S.C. § 5110 (b)(2); 38 C.F.R. § 3.400 (o)(2). The increase in disability must have occurred during the one-year period prior to the date of the Veteran’s claim in order to receive the benefit of an earlier effective date. See Gaston v. Shinseki, 605 F.3d 979 (Fed. Cir. 2010).

Briefly, the procedural history of the Veteran’s claim must be addressed. A February 2019 Board decision granted entitlement to service connection for PTSD. An April 2019 rating decision was issued for service connection for PTSD, granting a 10 percent evaluation, effective March 26, 2013. The Veteran filed an August 2019 claim seeking an increased evaluation for PTSD. In an October 2019 rating decision, the Veteran was granted an evaluation of 70 percent for PTSD and anxiety, effective August 19, 2019, the date he filed the claim for an increased evaluation.

The Veteran contends his 70 percent evaluation should date back to his original effective date for service connection for PTSD and anxiety, March 26, 2013. Unfortunately, the Veteran failed to file a notice of disagreement to the October 2019 rating decision, instead the Veteran filed VA Form 20-0996, Decision Review Request, Higher Level Review. The April 2019 rating decision became final. See 38 U.S.C. § 7105 (c); 38 C.F.R. § 20.1103.

The Board acknowledges the Veteran’s contention that his earlier VA examination in August 2014 was inadequate. The Veteran reported in his Request for Higher Level Review that the Veterans Law Judge stated the VA examination should be “tossed out.” The February 2019 Board decision granted entitlement to service connection for PTSD and found the VA opinion was entitled no probative weight in the determination to grant entitlement to service connection for PTSD. The Veteran underwent an informal conference in November 2020, and he contends he was never properly evaluated, and his higher evaluation should go back to the date he first filed his claim.

Given the above, the Veteran is seeking an earlier effective date stemming from a final rating decision. Only a request for revision based on clear and unmistakable error (CUE) can result in the assignment of an effective date earlier than the date of a final decision, as free-standing claims for earlier effective dates vitiate the rule of finality. Rudd v. Nicholson, 20 Vet. App. 296 (2006). The Veteran has not asserted CUE in this case.

To raise a valid CUE claim, the Veteran must first identify the alleged error in fact or in law with some degree of specificity and then provide persuasive reasons as to why the result, to which reasonable minds could not differ, would have been manifestly different but for that error. See Fugo v. Brown, 6 Vet. App. 40, 43-44 (1993). The Veteran may raise CUE at any time. See 38 C.F.R. § 3.105(a). However, as CUE has not been asserted here and the April 2019 rating decision is final, the Board is bound by the laws and regulations that apply to Veterans’ claims and cannot address the Veteran’s contentions that his 70 percent evaluation for PTSD should date back to the original effective date of March 26, 2013.

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Related

Gaston v. SHINSEKI
605 F.3d 979 (Federal Circuit, 2010)
Mauerhan v. Principi
16 Vet. App. 436 (Veterans Claims, 2002)
Michael T. Rudd v. R. James Nicholson
20 Vet. App. 296 (Veterans Claims, 2006)
Genaro Vazquez-Claudio v. Shinseki
713 F.3d 112 (Federal Circuit, 2013)
Fugo v. Brown
6 Vet. App. 40 (Veterans Claims, 1993)
Harper v. Brown
10 Vet. App. 125 (Veterans Claims, 1997)

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Bluebook (online)
210406-149959, Counsel Stack Legal Research, https://law.counselstack.com/opinion/210406-149959-bva-2021.