Citation Nr: 1008969 Decision Date: 03/09/10 Archive Date: 03/17/10 DOCKET NO. 07-06 884 ) DATE ) ) On appeal from the Department of Veterans Affairs Regional Office in Portland, Oregon THE ISSUE Entitlement to an increased rating for bilateral flat feet with transverse arch, plantar warts, calluses, partial second toe amputations and exostectomies, post neuroma excision right third interspace, currently rated as 50 percent disabling. REPRESENTATION Veteran represented by: Disabled American Veterans WITNESS AT HEARING ON APPEAL Veteran ATTORNEY FOR THE BOARD A. Willett, Counsel INTRODUCTION The Veteran had active service from June 1958 to February 1969. This matter came before the Board of Veterans' Appeals (Board) on appeal from decisions by the Department of Veterans Affairs (VA) Portland, Oregon, Regional Office (RO). A hearing was held at the RO before the undersigned Veterans Law Judge in March 2009. The Board notes that the Veteran's representative, in January 2010, submitted a Post-Remand Brief suggesting that another remand is necessary due to the RO's failure to comply with the Board's April 2009 remand orders. In particular, the representative suggests that a response from the Compensation and Pension Service is not found in the claims folder, nor are responses from the Veteran's former employers. To the contrary, the October 2009 response from Compensation and Pension is in the claims folder, as are October 2007 and July 2009 statements from the Veteran's former employers. The Board, therefore, will proceed with final adjudication of this claim. Please note this appeal has been advanced on the Board's docket pursuant to 38 C.F.R. § 20.900(c) (2009). 38 U.S.C.A. § 7107(a)(2) (West 2002). FINDINGS OF FACT The Veteran's bilateral flat feet with transverse arch, plantar warts, calluses, partial second toe amputations and exostectomies, post neuroma excision right third interspace, is assigned a 50 percent rating, the maximum schedular rating available under 38 C.F.R. § 4.71a, Diagnostic Code 5276, and the evidence does not show an exceptional or unusual disability picture with such related factors as marked interference with employment or frequent periods of hospitalization as to render impractical the application of the regular schedular standards. CONCLUSION OF LAW The criteria for an evaluation in excess of 50 percent for bilateral flat feet with transverse arch, plantar warts, calluses, partial second toe amputations and exostectomies, post neuroma excision right third interspace, on a schedular and extraschedular basis, have not been met. 38 U.S.C.A. §§ 1155, 5107 (West 2002); 38 C.F.R. §§ 3.321, 4.71a, Diagnostic Code 5276 (2009). REASONS AND BASES FOR FINDINGS AND CONCLUSION The Veteran is seeking a rating in excess of 50 percent for his service-connected bilateral flat feet. Disability evaluations are determined by the application of VA's Schedule for Rating Disabilities, which sets forth separate rating codes for various disabilities. 38 U.S.C.A. § 1155; 38 C.F.R. Part 4. Generally, a disability must be considered in the context of the whole recorded history. 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 38 C.F.R. §§ 4.1, 4.2; Francisco v. Brown, 7 Vet. App. 55 (1994). Where there is a question as to which of two evaluations apply, assigning a higher of the two where the disability picture more nearly approximates the criteria for the next higher rating, is appropriate. 38 C.F.R. § 4.7. Moreover, staged ratings are appropriate in any increased-rating claim in which distinct time periods with different ratable symptoms can be identified. Hart v. Mansfield, 21 Vet. App. 505 (2007). Pyramiding, the evaluation of the same disability, or the same manifestation of a disability, under different diagnostic codes, is to be avoided. 38 C.F.R. § 4.14. It is possible, however, for a Veteran to have separate and distinct manifestations attributable to the same injury, which would permit a rating under several diagnostic codes. The critical element permitting the assignment of multiple ratings under several diagnostic codes is that none of the symptomatology for any one of the conditions is duplicative or overlapping with the symptomatology of the other condition. Esteban v. Brown, 6 Vet. App. 259, 261-62 (1994). When there is an approximate balance of positive and negative evidence regarding any issue material to the determination of a matter, the Secretary shall give the benefit of the doubt to the claimant. 38 U.S.C.A. § 5107(b); 38 C.F.R. § 3.102; see also Gilbert v. Derwinski, 1 Vet. App. 49 (1990). In a rating decision, dated in August 1978, the RO originally granted service connection for bilateral pes planus, pursuant to a Board decision dated in June 1978. The RO assigned an evaluation of 30 percent pursuant to 38 C.F.R. § 4.71a, Diagnostic Code 5276. In October 1997, a 50 percent rating was awarded. The Veteran filed this claim in June 2005 seeking an evaluation in excess of 50 percent. Under 38 C.F.R. § 4.71a, Diagnostic Code 5276, a maximum 50 percent rating is warranted for bilateral acquired flatfoot with pronounced; marked pronation, extreme tenderness of plantar surfaces of the feet, marked inward displacement and severe spasm of the tendo achilles on manipulation, not improved by orthopedic shoes or appliances. The Veteran's disability is characterized as bilateral flat feet with transverse arch, plantar warts, calluses, partial second toe amputations and exostectomies, post neuroma excision right third interspace. The Board notes that the Veteran's amputation is contemplated in the currently assigned 50 percent rating, and a separate rating is therefore not warranted. Under Diagnostic Code 5172, a 20 percent rating is permitted with the removal (by amputation) of the 1st metatarsal head. The VA examination of November 2007 and other records contained in the claims folder show that the amputations of the Veteran's second toes on both feet were described as distal amputations. Accordingly, a separate rating is not permitted here. Because 50 percent is the maximum schedular rating under DC 5276, the Veteran's bilateral pes planus disability has already been assigned the maximum schedular rating available. As there is no legal basis upon which to award a higher schedular evaluation, that aspect of the Veteran's appeal must be denied. Sabonis v. Brown, 6 Vet. App. 426 (1994). In April 2009, however, this issue was remanded for extraschedular consideration. The question of an extraschedular rating is a component of the Veteran's claim for an increased rating. See Bagwell v. Brown, 9 Vet. App. 337 (1996). Under 38 C.F.R. § 3.321(b), an extraschedular evaluation may be assigned in exceptional cases where the schedular evaluations are found to be inadequate. The governing norm in such cases is a finding that the case presents such an exceptional or unusual disability picture with such related factors as marked interference with employment or frequent periods of hospitalization as to render impractical the application of the regular schedular standards. The evidence of record in this case raised the issue of entitlement to a higher rating on an extra-schedular basis. The VA examination report dated in November 2007 contains an opinion that "The patient's conditions would be considered moderately severe. It certainly would not allow him to work in his usual and customary field [of] security because of the demands of being on his feet. The only type of work that the patient would be considered eligible for would be sedentary work; however, that would require retraining." In light of this, submission to the Compensation and Pension service for extraschedular consideration under 38 C.F.R. § 3.321 (b)(1) was accomplished in September 2009. In October 2009, the Director of the Compensation and Pension Service submitted a narrative statement finding that the Veteran's "service connected flat feet do no markedly interfere with the Veteran's ability to work. His inability to work is a result of his numerous nonservice-connected disabilities." The basis for this finding was noted, based upon a review of the record, as the many non service connected disabilities: status post radical prostatectomy for adenocarcinoma in 1997, with recurrence in 2002, treated with radiation and chemotherapy; venous insufficiency with stasis dermatitis and ulcers; status post bilateral arthroscopies of the knees for meniscal and ligament injuries; L5-S1 radiculopathy; status post left ankle fracture; status post right femoral fracture with hemiarhtroplasty; glaucoma and Bowen's disease of the skin of the left helix and nasal area. This finding was based upon a review of the Veteran's voluminous body of medical evidence spanning many years. Also of note are the 2007 and 2009 VA Forms 21-4192 from the Veteran's former employer showing that he was terminated in July 2002, not due to any disability, but due to a "reduction in staff." And, his Social Security Administration records show that his Social Security Disability status is based upon bilateral hip and left knee disabilities. While the Board acknowledges that the Veteran's bilateral pes planus is a severe disability, the severity is contemplated in the currently assigned 50 percent schedular rating. The record simply does not support a finding that the Veteran's disability is manifested by an exceptional or unusual disability picture with such related factors as marked interference with employment or frequent periods of hospitalization as to render impractical the application of the regular schedular standards. A rating in excess of 50 percent for bilateral flat feet with transverse arch, plantar warts, calluses, partial second toe amputations and exostectomies, post neuroma excision right third interspace, is not warranted. The Board notes that when there is an approximate balance of positive and negative evidence regarding any issue material to the determination of a matter, the benefit of the doubt will be given to the claimant. 38 U.S.C.A. § 5107(b); 38 C.F.R. § 3.102. In reaching this conclusion, the Board has considered the applicability of the benefit-of-the-doubt doctrine. Because the evidence here is not in equipoise, and, in fact, the absence of evidence to support the claim suggests that the preponderance of the evidence is against the Veteran's claim, the benefit-of-the-doubt doctrine is not applicable. See Gilbert v. Derwinski, 1 Vet. App. 49, 55-57 (1990); Ortiz v. Principi, 274 F.3d 1361 (Fed. Cir. 2001). There is simply no basis upon which to grant the Veteran's claim. Duties to Notify and Assist VA fulfilled its duties to notify and assist the Veteran in the development of his claim. Sufficient evidence is available to reach a decision and the Veteran is not prejudiced by appellate review at this time. Upon receipt of a complete or substantially complete application for benefits, VA is required to notify the claimant of the information and evidence not of record that is necessary to substantiate the claim; and to indicate which information and evidence VA will obtain and which information and evidence the claimant is expected to provide. 38 U.S.C.A. § 5103(a); 38 C.F.R. § 3.159(b). The U.S. Court of Appeals for Veterans Claims has held that VCAA notice should be provided to a claimant before the initial RO decision on a claim. Pelegrini v. Principi, 18 Vet. App. 112 (2004). However, if VCAA notice is provided after the initial decision, such a timing error can be cured by subsequent readjudication of the claim, as in a Statement of the Case (SOC) or Supplemental SOC (SSOC). Mayfield v. Nicholson, 20 Vet. App. 537, 543 (2006). The VCAA notice requirements apply to all five elements of a service connection claim: (1) Veteran status; (2) existence of disability; (3) connection between service and the disability; (4) degree of disability; and (5) effective date of benefits where a claim is granted. Dingess v. Nicholson, 19 Vet. App. 473, 484 (2006). VA sent the Veteran a letter in January 2006 informing him of what was necessary to establish his claim, including the evidence necessary to establish an extraschedular rating under 38 C.F.R. § 3.321, as well as what evidence he was expected to provide, and what VA would obtain on his behalf. This letter and subsequent readjudication of the appeal satisfied the requirements of 38 C.F.R. § 3.159(b)(1), as well as the requirements of Dingess v. Nicholson, supra, e.g., as to potential downstream issues such as disability rating and effective date. VA's duty to notify the Veteran was met in this case. VA also has a duty to assist the Veteran in substantiating his claim under 38 C.F.R. § 3.159(c), (d). Here, the Veteran's statements, his service treatment records, post-service treatment records, several VA examination reports, Social Security Administration records and the October 2009 report from the Director of Compensation and Pension Service have been associated with the claims folder. The Veteran was also afforded a Travel Board hearing, and the March 2009 transcript is of record. The Veteran has not notified VA of any additional relevant evidence. In fact, in November 2009, he submitted a statement confirming that he has no additional evidence to submit. VA has done everything reasonably possible to assist the Veteran. A remand for further development of this claim would serve no useful purpose. VA has satisfied its duties to notify and assist the Veteran and further development is not warranted. ORDER Entitlement to an increased rating for bilateral flat feet with transverse arch, plantar warts, calluses, partial second toe amputations and exostectomies, post neuroma excision right third interspace, currently rated as 50 percent disabling, is denied, including on an extraschedular basis. ____________________________________________ MARJORIE A. AUER Veterans Law Judge, Board of Veterans' Appeals Department of Veterans Affairs