Citation Nr: 1031399 Decision Date: 08/20/10 Archive Date: 08/24/10 DOCKET NO. 08-10 008A ) DATE ) ) On appeal from the Department of Veterans Affairs Regional Office in St. Petersburg, Florida THE ISSUES 1. Whether a January 1973 rating decision was clearly and unmistakably erroneous in denying a disability rating in excess of 10 percent disabling for service-connected schizophrenia. 2. Entitlement to an effective date earlier than August 30, 2001, for individual unemployability (TDIU). REPRESENTATION Veteran represented by: Karl A. Kazmierczak, Esq. WITNESS AT HEARING ON APPEAL Veteran ATTORNEY FOR THE BOARD J. Alsup, Counsel INTRODUCTION The Veteran served on active duty from July 1969 to December 1971. Service in Vietnam is evidenced in the record. This matter comes before the Board of Veterans' Appeals (the Board) on appeal from a March 2007 rating decision of the Department of Veterans Affairs (VA) Regional Office (RO) in St. Petersburg, Florida, which denied the Veteran's claims contending there was clear and unmistakable error (CUE) in a January 1973 rating decision denying a disability rating in excess of 10 percent for service-connected schizophrenia, and denying entitlement to TDIU from December 4, 1971. The Veteran disagreed and perfected an appeal. In July 2008, the Veteran and his representative presented evidence and testimony in support of his claims at a hearing at the RO before a local hearing officer. In January 2010, the Veteran and his attorney presented evidence and testimony in support of the Veteran's claims at a hearing at the RO before the undersigned Veterans Law Judge (VLJ). Transcripts of those hearings have been associated with the Veteran's VA claims folder. FINDINGS OF FACT 1. A January 4, 1973, VA rating decision determined that the Veteran was 10 percent disabled for schizophrenia, latent type, depression, under 38 C.F.R. § 4.132, Diagnostic Code 9205 (1972). 2. It is not undebateable that Dr. M.R.'s August 1973 report would necessarily result in a conclusion that the evidence "militated in support of the claim" for a disability rating in excess of a 10 percent disability rating. 3. The Veteran remained employed until August 30, 2001. CONCLUSIONS OF LAW 1. The January 1973 rating decision did not contain CUE. 38 C.F.R. § 3.105 (2009). 2. Entitlement to an effective date earlier than August 30, 2001, for TDIU benefits is not warranted. 38 U.S.C.A. § 5110; 38 C.F.R. §§ 3.340, 3.400(o)(2) (2009). REASONS AND BASES FOR FINDINGS AND CONCLUSION The Veteran and his attorney primarily contend that the RO committed CUE in a January 1973 rating decision that denied the Veteran a disability rating in excess of 10 percent when the evidence then before the RO clearly established entitlement to a higher percentage. The Veteran has consistently argued that he does not disagree with the weight given evidence of record by the RO at the time of the 1973 rating decision, but rather contends that the RO failed to consider all of the favorable evidence of record at that time. The Veteran's specific contention is that the RO failed to consider an August 1972 report by Dr. M.R., Ph.D., a clinical psychologist who was then treating the Veteran, and further contends that if the RO had considered the evidence, the resulting disability rating would have been manifestly different. Intertwined with the Veteran's contention of CUE is the argument that had the RO considered the August 1972 report, then TDIU would have been warranted. The Veteran's attorney has also raised as bases for CUE the contentions that the Veteran was never informed of or ever received appellate rights from the RO following the January 1973 rating decision and was never given a medical examination to substantiate his claim. See January 2010 hearing transcript at pages 9 and 11. In addition, the Veteran essentially contends that the evidence establishes that he is entitled to an effective date earlier than August 30, 2001, for TDIU benefits. The Board will first address preliminary matters and then render a decision on the issue on appeal. Duties to notify and assist The provisions of the Veterans Claims Assistance Act of 2000 (VCAA), Pub. L. No. 106-475, 114 Stat. 2096 (2000) are applicable to all claims filed on or after the date of enactment, November 9, 2000, or filed before the date of enactment and not yet final as of that date. Therefore, the VCAA is generally applicable to this case. See Holliday v. Principi, 14 Vet. App. 280 (2000) [the Board must make a determination as to the applicability of the various provisions of the VCAA to a particular claim]. VCAA provides that upon receipt of a substantially complete application for benefits, VA must notify the claimant what information or evidence is needed in order to substantiate the claim and it must assist the claimant by making reasonable efforts to get the evidence needed. 38 U.S.C.A. §§ 5103(a), 5103A; 38 C.F.R. § 3.159(b); see Quartuccio v. Principi, 16 Vet. App. 183, 187 (2002). The notice required must be provided to the claimant before the initial unfavorable decision on a claim for VA benefits, and it must (1) inform the claimant about the information and evidence not of record that is necessary to substantiate the claim; (2) inform the claimant about the information and evidence that VA will seek to provide; and (3) inform the claimant about the information and evidence the claimant is expected to provide. 38 U.S.C.A. §§ 5103(a); 38 C.F.R. § 3.159(b)(1). However, the United States Court of Appeals for Veterans Claims (the Court) has held that VCAA is not applicable to CUE claims. The first claim in this case alleges that the RO committed CUE in connection with the January 1973 rating decision which denied a disability rating in excess of 10 percent for service-connected schizophrenia. CUE claims are requests for revision of previous decisions and are fundamentally different from any other kind of action in the VA adjudicative process. See Livesay v. Principi, 15 Vet. App. 165 (2001). A litigant alleging CUE is not pursuing a claim for benefits, but rather is collaterally attacking a final decision. Thus, a Veteran seeking a revision of a final decision based upon CUE is not a "claimant" as defined by 38 U.S.C.A. § 5100. The Court also held that "there is nothing in the text or the legislative history of VCAA to indicate that VA's duties to assist and notify are now, for the first time, applicable to CUE motions." Id. at 179. Therefore, the Board finds that VA's duties to notify and assist imposed by the VCAA are not applicable to claims of CUE. See also 38 C.F.R. § 20.1411(c) and (d) (2009). The Board additionally notes that a CUE claim generally does not involve the submission of evidence beyond what already resides in the claims folder. The outcome in this case, therefore, is determined from an analysis of the evidence contained in the claims folder as of January 1973. Thus, remand for further evidentiary development will serve no purpose in this instance. The Board observes that with regard to the contentions raised at the January 2010 hearing regarding the RO's failure to provide the Veteran with a medical examination to substantiate his claim and the failure to provide the Veteran with notice of his appellate rights, the Court has held that VA's breach of a duty to assist cannot form the basis for a claim of CUE. See Baldwin v. West, 13 Vet. App. 1, 5 (1999); Caffrey v. Brown, 6 Vet. App. 377 (1994). Furthermore, any assertion by the Veteran that the RO's failure to obtain a medical opinion regarding this issue constituted CUE cannot survive. See Cook v. Principi, 318 F.3d 1334 (Fed. Cir. 2002) (any breach of VA's duty to assist the veteran in the development of his claim cannot constitute a basis for CUE). Last, with regard to the issue of CUE, the Board finds that general due process considerations have been satisfied. See 38 C.F.R. § 3.103 (2009). As noted in the Introduction above, the Veteran and his representative have presented evidence and argument on this matter at a July 2008 RO formal hearing and at the January 2010 hearing before the undersigned VLJ. With regard to the issue of an earlier effective date for TDIU, the Board observes that in a November 2002 rating decision, the RO granted TDIU benefits effective January 24, 2002. In a statement received by the RO December 2002, the Veteran disagreed with the effective date and contended that the effective date should be "8/30/01 since that is the last day I was able to work according to SSA [Social Security Administration]." In a rating decision dated January 2004, the RO assigned an effective date for TDIU of August 30, 2001. In addition, as noted, the Veteran also contends that he is entitled to TDIU effective in 1973. The Veteran was not specifically informed of the evidence needed to establish an earlier effective date for TDIU benefits after TDIU benefits had been granted. However, the United States Court of Appeals for the Federal Circuit and the United States Court of Appeals for Veterans Claims (Court) have held that once benefits have been granted the Veteran's claim is substantiated and additional notice is not required, and, therefore, any defect in the notice is not prejudicial. Hartman v. Nicholson, 483 F.3d 1311 (Fed. Cir. 2007); Goodwin v. Peake, 22 Vet.App. 128 (2008). See also Dunlap v. Nicholson, 21 Vet. App. 112 (2007). The Board also observes that the Veteran has not contended, nor does the record indicate, that his claim for an earlier effective date has been prejudiced by a lack of notice of what evidence is required to establish the claim. The Court has held that where a claim has been substantiated after the enactment of the VCAA, the appellant bears the burden of demonstrating any prejudice from defective VCAA notice with respect to the downstream elements. See Goodwin v. Peake, 22 Vet.App. at 137. For those reasons, the Board finds that the Veteran's claim was not prejudiced for lack of notice. With regard to VA's duty to assist, the Board notes that an earlier effective date is a matter of record; generally, the effective date of TDIU benefits will be the earliest date as of which it is factually ascertainable that an increase in disability had occurred if the claim is received within 1 year from such date otherwise, the date will be the date of receipt of claim. See 38 U.S.C.A. § 5110; 38 C.F.R. § 3.400(o) (2009); see also Hazan v. Gober, 10 Vet. App. 511 (1997); Servello v. Derwinski, 3 Vet. App. 196 (1992). As is discussed in more detail below, the claim for TDIU benefits is a complex one. However, because the Veteran's earlier effective date is a matter of record, the Board observes that further evidentiary development will not assist the Veteran's claim. In addition, the Board observes that the Veteran was provided numerous VA psychological examinations and VA obtained numerous private medical records identified by the Veteran, both of which, as is discussed below, date back prior to the earliest possible effective date for TDIU. In addition, the record reveals that the RO obtained records from the SSA regarding the Veteran's service-connected disability. The Board additionally observes that all appropriate due process concerns have been satisfied. See 38 C.F.R. § 3.103 (2009). To that end, the Board observes that the Veteran has been represented by legal counsel or a service representative throughout the pendency of the claims. As noted in the Introduction, the Veteran and his attorney presented evidence and testimony at a hearing before the undersigned VLJ. The Board will therefore proceed to a decision on the merits. Whether a January 1973 rating decision was clearly and unmistakably erroneous in denying a rating greater than 10 percent disabling for service-connected schizophrenia. Pertinent Law and Regulations Finality of RO decisions In general, VA rating decisions are final. See 38 U.S.C.A. § 7105 (West 2002); 38 C.F.R. §§ 3.104, 20.1103 (2009). A final decision cannot be reopened unless new and material evidence is presented. 38 U.S.C.A. § 5108 (West 2002); 38 C.F.R. § 3.156 (2009). In the alternative, a final decision may be subject to revision on the basis of CUE, as provided in 38 C.F.R. § 3.105. See 38 C.F.R. § 3.104(a) (2009). CUE The Court has propounded a three-pronged test to determine whether CUE is present in a prior determination. First, either the correct facts, as they were known at the time, were not before the adjudicator (i.e., more than a simple disagreement as to how the facts were weighed or evaluated) or the statutory or regulatory provisions extant at the time were incorrectly applied. Second, an error occurred based on the record and the law that existed at the time of the prior adjudication in question. Finally, the error must be "undebatable" and of the sort "which, had it not been made, would have manifestly changed the outcome at the time it was made." Bouton v. Peake, 23 Vet. App. 70 (2008). See also Damrel v. Brown, 6 Vet. App. 242, 245 (1994); Russell v. Principi, 3 Vet. App. 310, 313-14 (1992) (en banc). In Fugo v. Brown, 6 Vet. App. 40, 43 (1993), the Court further held that CUE is one of fact or law, that when called to the attention of later reviewers compels the conclusion, to which reasonable minds could not differ, that the result would have been manifestly different but for the error. "Clear and unmistakable error is an administrative failure to apply the correct statutory and regulatory provisions to the correct and relevant facts; it is not mere misinterpretation of facts." Oppenheimer v. Derwinski, 1 Vet. App. 370, 372 (1991). In a CUE claim, "[t]he claimant, in short, must assert more than a disagreement as to how the facts were weighed or evaluated." Crippen v. Brown, 9 Vet. App. 412, 418 (1996). Law and regulations in effect at the time of the January 1973 rating decision (1) Disability ratings - in general The 1945 schedule for Rating Disabilities will be used for evaluating the degree of disabilities in claims for disability compensation, disability and death pension, and in eligibility determinations. The provisions contained in the rating schedule will represent as far as can practically be determined, the average impairment in earning capacity in civil occupations resulting from disability. 38 C.F.R. §§ 3.321(a) (1973). Where there is a question as to which of two evaluations shall be applied, the higher evaluation will be assigned if the disability picture more nearly approximates the criteria required for that rating. Otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7 (1973). It is essential, both in the examination and in the evaluation of disability, that each disability be viewed in relation to its whole history. 38 C.F.R. § 4.1 (1973). It is the responsibility of the rating specialist to interpret the reports of examination in the light of the whole recorded history, reconciling the various reports into a consistent picture, so that the current rating may accurately reflect the elements of permanent and temporary disability present. 38 C.F.R. § 4.2 (1973). (2) Assignment of diagnostic code The Veteran's schizophrenia with depression disability was rated 10 percent disabling under 38 C.F.R. § 4.130, Diagnostic Code 9205 [Schizophrenic reaction]. The Board observes, as is explained in greater detail below, that Diagnostic Code 9204 [schizophrenic reaction, chronic undifferentiated type] is deemed by the Board to be the most appropriate primarily because it pertains specifically to the primary diagnosed disability in the Veteran's case (chronic undifferentiated schizophrenia). Specifically, the diagnoses of record in at the time of the January 1973 rating decision were a 21 May 1971 diagnosis of depression, chronic; a 23 June 1971 diagnosis of "emotional unstable personality, chronic, moderate; manifested by past drug abuse and addiction to heroin, impulsivity, mood swings, depression, anxiety, passive-aggressive traits within his personality structure and lack of firm goals despite reasonably good intellectual functioning; precipitating stress, moderate, broken family situation; degree of impairment for further military duty, none at this time;" an August 1972 diagnosis of "schizophrenia, latent type (borderline state);" and an August 1972 diagnosis of "chronic undifferentiated schizophrenia [pseudo-psychopathic schizophrenia]" and "passive-aggressive personality disorder." After review of the evidence, the Board can identify nothing to suggest that another diagnostic code would be more appropriate and neither the Veteran nor his attorney has contended that a different diagnostic code should have been used. The Board observes in addition that the rating criteria for Diagnostic Codes 9204 and 9205 are identical. Accordingly, the Board concludes that the Veteran's service-connected disability is most appropriately rated under Diagnostic Code 9204 in January 1973. (3) Specific schedular criteria Under 38 C.F.R. § 4.130, Diagnostic Code 9204 (1973), a 10 percent rating is assigned when emotional tension or other evidence of anxiety are productive of moderate social and industrial impairment. A 30 percent rating is assigned for definite impairment in the ability to establish or maintain effective and wholesome relationships with people. The psychoneurotic symptoms result in such reduction in initiative, flexibility, efficiency and reliability levels as to produce considerable industrial impairment. A 50 percent rating is assigned when ability to establish or maintain effective or favorable relationships with people is substantially impaired. By reason of psychoneurotic symptoms the reliability, flexibility and efficiency levels are so reduced as to result in severe industrial impairment. A 70 percent rating is assigned when ability to establish and maintain effective or favorable relationships with people is seriously impaired. The psychoneurotic symptoms are of such severity and persistence that there is pronounced impairment in the ability to obtain or retain employment. A 100 percent rating is assigned when the attitudes of all contacts except the most intimate are so adversely affected as to result in virtual isolation in the community. Totally incapacitating psychoneurotic symptoms bordering on gross repudiation of reality with disturbed thought or behavioral processes associated with almost all daily activities such as phantasy, confusion, panic and explosions of aggressive energy resulting in profound retreat from mature behavior. Demonstrably unable to obtain or retain employment. "Moderate" is defined as "limited in scope or effect." See Merriam-Webster's Collegiate Dictionary, 11th Edition (2003), p. 798. "Severe" is defined as "of a great degree." Id at p. 1140. Note (1) to the Psychoneurotic Disorders Diagnostic Codes, 38 C.F.R. § 4.132 (1973) provides that the decision maker cannot focus exclusively on those words within the rest of the criteria: Social impairment per se will not be used as the sole basis for any specific percentage evaluation, but is of value only in substantiating the degree of disability based on all of the findings. Factual background A short factual statement will help clarify the CUE issue before the Board. As set out in the law and regulations section above, only evidence which was of record at the time of the January 1973 rating decision may be considered. In January 1973, the record included the Veteran's service treatment records, a discharged summary from an August 1972 hospitalization and an August 1972 statement from Dr. M.R., Ph.D., a clinical psychologist who had been treating the Veteran. The service treatment records include a "witness statement" dated 26 July 1971 that states that "on or about 12 May 1971," the Veteran was admitted to the psychiatric ward of Fort Leonardwood Army Hospital under the influence of Dexedrine, that he was treated until 20 May 1971 when he was transferred to Fitzsimmons Army Hospital in Denver, Colorado, where he received further psychiatric treatment until he was transferred to Hunter Army Airfield, Georgia on about 26 June 1971. A 21 May 1971 narrative summary states that the Veteran had been at Ft. Leonardwood since November 1970. The Veteran is reported to have stated that he began using "hard drugs" in Vietnam, including heroin, amphetamines and "acid," and admitted to using other narcotic substances while he was at Ft. Leonard Wood. The summary states that the Veteran had been "prone to hysterical outbursts with temper manifested, not (sic) by destructiveness, head- banging, crying, etc." The Veteran's mood was described as being predominately "frustration and depression." The diagnosis was "depression, chronic" with a history of drug abuse, and the recommendation was that the Veteran be transferred to an Army medical facility with a drug rehabilitation program. A discharge summary dated 23 June 1971 states that upon admission to Fitzsimmons General Hospital, the Veteran was oriented to person, place and time, and there was no evidence of psychosis, but there was evidence of "mild anxiety and moderate depression." The Veteran's insight and judgment were considered to be good. The Medical Officer's assessment was that the Veteran had "characterological difficulties" manifested by "lack of motivation, difficulty setting himself goals and general attitudes of passivity," but that the Veteran appeared to have benefited from therapy and was described to have "symptomatically improved." The Veteran apparently sought return to duty. The final diagnosis was of "emotional unstable personality, chronic, moderate; manifested by past drug abuse and addiction to heroin, impulsivity, mood swings, depression, anxiety, passive-aggressive traits within his personality structure and lack of firm goals despite reasonably good intellectual functioning; precipitating stress, moderate, broken family situation; degree of impairment for further military duty, none at this time." The record also establishes that the Veteran was hospitalized between 24 August 1972 and 1 September 1972. A discharge summary was in the record and considered by the RO in the January 1973 rating decision; it is essentially quoted in the rating decision. Dr. J.R., M.D., a VA physician stated that the Veteran had a long history of overt psychiatric problems and psychiatric treatment that dated to pre-service. The Veteran's physical description was provided and he was described as "cooperative, articulate, spontaneous and his vocabulary was punctuated with much psychological jargon." The Veteran was stated to have complained that he had difficulties in interpersonal relationships. The examiner noted that the Veteran "was seen by a clinical psychologist who indicated the protocol pointed towards (sic) a chronic borderline schizophrenia." The examiner noted that "despite his alleged difficulty in relating to people the [Veteran] seemed to get along very well with patients on the ward." The examiner further noted that he and the Veteran "had discussed his anxiety about becoming involved in any kind of long term relationship, . . ." and after having the conversation, the Veteran left treatment on a weekend pass and "returned impulsively to sign out against medical advice." The impression provided in the narrative summary was "schizophrenia, latent type (Borderline State)." The record also includes an 11 August 1972 letter on the letterhead of Dr. M.R., Ph.D., a clinical psychologist, who indicated in the cover letter that he had completed an enclosed form regarding the Veteran, his "patient." The reverse side of the cover letter bears a date stamp indicating that the cover letter had been received by the St. Petersburg RO on 14 August 1972. The handwritten form referred to in the cover letter immediately precedes the cover letter in the Veteran's VA claims folder and is written on the back of a letter from G.N., an Adjudication Officer from the RO, to Dr. M.R. asking for information concerning the treatment provided to the Veteran. The "certificate of attending psychologist" states that the Veteran has been a patient of Dr. M.R. since December 1971. The clinical findings are: Depersonalization, depression, anxiety, paranoid ideation, regression. Inability: 1) to work, 2) interact with others, 3) relate to peers 4) enter into a heterosexual relationship. Behavior disorder represents a major disability for this [Veteran]. He is frequently incapacitated due to the psychotic proportions of the disorder, however hospitalization probably would be ineffective. Institutionalization would be a likely result. The diagnoses were: "1) chronic undifferentiated schizophrenia [pseudo-psychopathic schizophrenia] presently in partial remission. 2) Passive-aggressive personality disorder." The narrative portion of the form goes on to state that the Veteran had been seen in "individual and family (x3) psychotherapy on a weekly basis from December 1971 to May 16, 1972," and in group psychotherapy "on a sporatic (sic) basis totaling 6 group therapy sessions, until present." Dr. M.R. states that the sessions ended when the Veteran could no longer afford to pay for them. Dr. M.R. stated that during treatment there had been "gradual and positive" progress, but that there was "a marked decline following termination of individual therapy and some, but not all of his behavior pathology has returned." Dr. M.R. further stated that he had referred the Veteran to a psychiatrist for medication which "aided somewhat in therapy." Dr. M.R. indicated that "more potent phenothiocines were avoided since the patient had severe side reactions to them when they were tried with him in the past." Analysis As indicated above, this matter must be resolved by reviewing the evidence and applying the law that was before the RO in January 1973 and has to be more than a disagreement as to how the facts were weighed or evaluated. The Board once again notes the very high standard (i.e. "undebatable") which is applied with respect to CUE claims. As alluded to above, the January 1973 rating decision reviews the service treatment record examination and hospital reports from May and June 1971, and essentially quotes from the August- September 1972 VA hospital narrative summary. There is nothing in the January 1973 rating decision that indicates the rating board considered the report of Dr. M.R. even though the record is clear that the information was received by the RO some 4 months prior to the decision, and the records are located in order within the VA claims folder prior to the January 1973 rating decision. In Bouton v. Peake, 23 Vet. App. 70 (2008), the Court held that an RO's denial of the existence of evidence in the claims file was sufficient to satisfy the first and second CUE requirements (i.e., either the facts known at the time were not before the adjudicator or the law then in effect was incorrectly applied, and an error occurred based on the record). See also Russell, 3 Vet. App. at 313-14. The facts in Bouton demonstrated that at the time of the RO decision, the claims file contained five medical records evidencing depression secondary to the veteran's service-connected back disorder. Yet, in denying the veteran's claim for service connection for an acquired psychiatric disorder, the RO stated that "[t]here is no record of psychiatric disability to include post-traumatic stress disorder showing a chronic disability subject to service connection." The RO's failure to address the five medical records was deemed by the Court as a "clear" denial of the existence of such evidence in the claims file. The facts in this case are similar to those found in Bouton. Here, like in Bouton, the RO did not acknowledge the existence of evidence in the record. Although the Bouton Court found error had been committed, it made clear that such error cannot constitute CUE unless it is the type of error that would have manifestly changed the outcome of the RO's decision. This may be shown where all evidence at the time of the decision "militated in support of the claim." Bouton at 73 citing Crippen v. Brown, 9 Vet. App. 412, 422 (1996). Thus, the third question is whether the evidence is so clear that it is undebateable that it paints a disability picture that more nearly approximates the criteria of a disability rating in excess of 10 percent. The Court has held that "even where the premise of error is accepted, if it is not absolutely clear that a different result would have ensued, the error complained of cannot be, ipso facto, clear and unmistakable." Fugo, 6 Vet. App. at 43-44. The 30 percent disability rating criteria, the next level of disability available under the schedular rating criteria, include a requirement of evidence showing "definite impairment in the ability to establish or maintain effective and wholesome relationships with people," and "psychoneurotic symptoms result in such reduction in initiative, flexibility, efficiency and reliability levels as to produce considerable industrial impairment." In this case, Dr. M.R.'s assessment was that the Veteran had an "inability: 1) to work, 2) interact with others, 3) relate to peers 4) enter into a heterosexual relationship." There was evidence of a definite impairment to establish or maintain effective and wholesome relationships with people. In addition, Dr. M.R. found that the Veteran's "behavior disorder represents a major disability" and that he was "frequently incapacitated due to the psychotic proportions of the disorder." The Board further observes that Dr. M.R. treated the Veteran over a period of about 6 months on a very frequent basis. On the other hand, there was evidence, the August 1973 VA narrative summary, that "despite his alleged difficulty in relating to people the [Veteran] seemed to get along very well with patients on the ward." The RO relied upon the VA narrative summary in making their decision. The Board recognizes the Veteran's contention and his characterization of it; that is, he is not in disagreement with the weight the 1973 RO gave the evidence, but rather is contending that they simply did not consider relevant evidence. While carefully crafted argument may work for the first two criteria described in Bouton; that either the facts known at the time were not before the adjudicator or that the law then in effect was incorrectly applied, and an error occurred based on the record, the crux of this claim is the third criterion: is it undebateable that Dr. M.R.'s August 1973 report would result in a conclusion that the evidence "militated in support of the claim" for a disability rating in excess of a 10 percent disability rating. The Board finds that the evidence is not undebatable. The probative value of the August 1973 VA narrative summary is not discounted by Dr. M.R.'s report to the degree where the Board can find that "all evidence at the time of the decision 'militated in support of the claim.'" The RO could have found the narrative summary persuasive in that the Veteran was able to have relationships, however superficial, with others that discounted Dr. M.R.'s opinion. The Board cannot find that "but for" Dr. M.R.'s opinion, it is absolutely clear that a different result would have ensued. Therefore, the error complained of cannot be, ipso facto, clear and unmistakable. The Board observes that to the degree that the Veteran and his attorney are contending that the RO's decision in 1973 is, in essence, fundamentally unfair, the argument is an equitable one that, although sympathetic, is one the Board cannot entertain. The Board is bound by the law and is without authority to grant benefits on an equitable basis. See 38 U.S.C.A. §§ 503, 7104 (West 2002); see also Harvey v. Brown, 6 Vet. App. 416, 425 (1994). The Board further observes that "no equities, no matter how compelling, can create a right to payment of the United States Treasury which has not been provided for by Congress." See Smith v. Derwinski, 2 Vet. App. 429, 432-33 (1992), citing Office of Personnel Management v. Richmond, 496 U.S. 414, 426 (1990). Finally, to the extent that the Veteran relies on the contention that the RO's failure to provide the Veteran with a medical examination to substantiate his claim and the failure to provide the Veteran with notice of his appellate rights are CUE, the Court has held that VA's breach of a duty to assist cannot form the basis for a claim of CUE. See Baldwin v. West, 13 Vet. App. 1, 5 (1999); Caffrey v. Brown, 6 Vet. App. 377 (1994). Furthermore, any assertion by the Veteran that the RO's failure to obtain a medical opinion regarding this issue constituted CUE cannot survive. See Cook v. Principi, 318 F.3d 1334 (Fed. Cir. 2002) (any breach of VA's duty to assist the veteran in the development of his claim cannot constitute a basis for CUE). For the reasons and bases presented above, the Board finds that the record does not support a finding that the August 1973 rating decision contained CUE. Last, the Board has considered whether the more proper remedy in this case is denial or dismissal. In this regard, the Board has considered the Court's holding in Simmons v. Principi, 17 Vet. App. 104 (2003), to the effect that if the claimant is only asserting disagreement with how VA evaluated the facts before it, the claim should be dismissed without prejudice because of the absence of legal merit or lack of entitlement under the law. The Board believes, given the circumstances of this case, denial is more appropriate. As was stated above, the primary focus of the Veteran's argument was that the RO failed to consider relevant evidence and that, therefore, the facts known at the time were not before the adjudicator. The Veteran's contention constitutes a valid CUE claim, and thus denial is warranted. Entitlement to an effective date earlier than August 30, 2001, for individual unemployability (TDIU). Relevant law and regulations Increased ratings - effective dates In general, the effective date for an increased rating will be the date of receipt of claim, or date entitlement arose, whichever is later. 38 C.F.R. § 3.400(o)(1) (2009). For an increase in disability compensation, the effective date will be the earliest date as of which it is factually ascertainable that an increase in disability had occurred if claim is received within 1 year from such date otherwise, date of receipt of claim. 38 U.S.C.A. § 5110; 38 C.F.R. § 3.400(o)(2); see also Hazan v. Gober, 10 Vet. App. 511 (1997); Servello v. Derwinski, 3 Vet. App. 196 (1992). In VAOPGCPREC 12-98 (Sept. 23, 1998), General Counsel noted that 38 C.F.R. § 3.400(o)(2) was added to permit payment of increased disability compensation retroactively to the date the evidence establishes the increase in the degree of disability had occurred; that this section was intended to be applied in those instances where the date of increased disablement can be factually ascertained with a degree of certainty. It was noted that this section was not intended to cover situations where disability worsened gradually and imperceptibly over an extended period of time. A claim for a TDIU is a claim for an increased rating. See Hurd v. West, 13 Vet. App. 449 (2000) [holding that a claim for TDIU is a claim for increased compensation, and the effective date rules for increased compensation apply to a TDIU claim]; see also Norris v. West, 12 Vet. App. 413 (1999). A TDIU claim is part of an increased rating claim when such claim is raised by the record. See Rice v. Shinseki, 22 Vet. App. 447 (2009). Analysis The Veteran contends that he is entitled to an effective date for receipt of TDIU benefits earlier than August 30, 2001. As noted above, in a November 2002 rating decision, the RO granted TDIU benefits effective January 24, 2002. In a statement received by the RO December 2002, the Veteran disagreed with the effective date and contended that the effective date should be "8/30/01 since that is the last day I was able to work according to SSA [Social Security Administration]." In a rating decision dated January 2004, the RO assigned an effective date for TDIU of August 30, 2001. Preliminarily, as noted above, the Veteran also contends that he is entitled to TDIU effective in 1973. Because the Board has just found that the August 1973 rating decision did not contain CUE, the rating decision remains final and no basis remains for provision of an effective date relating back to August 1973. A review of the claims file reveals that the Veteran first submitted a claim for an increased disability rating for his psychiatric disability on December 12, 1994. That claim was denied in a June 1995 rating decision and the Veteran appealed. The issue was addressed and decided by the Board in a September 1997 decision that was not appealed by the Veteran. In a statement received by the RO on September 10, 1998, the Veteran sought to "reopen" his claim and indicated that he had a "serious employment handicap." The Veteran's claim was decided in an August 1999 rating decision and the Veteran perfected an appeal. In a March 2001 decision, the Board remanded the Veteran's claim for compliance with the Veteran's Claims Assistance Act of 2000 (VCAA), and its requirements regarding VA's duties to inform and assist the Veteran in developing his claim. As noted above, the Veteran was granted TDIU benefits in a November 2002 rating decision. An effective date for receipt of TDIU benefits was later determined to be August 30, 1001. After review of the record, it appears that the last claim submitted by the Veteran that can be used to provide a date for potential receipt of TDIU benefits is the claim received on September 10, 1998. Thus, under the provisions of 38 C.F.R. § 3.400(o)(2), the earliest effective date possible for the Veteran would be September 10, 1997, so long as the evidence of record supported a finding that the Veteran was entitled to TDIU benefits. Under 38 C.F.R. § 3.340 (2009), "[T]otal disability will be considered to exist when there is present any impairment of mind or body which is sufficient to render it impossible for the average person to follow a substantially gainful occupation." A claim for TDIU benefits may be granted if the Veteran's unemployability is the result of a single service-connected disability ratable at 60 percent or more, or as a result of two or more disabilities, provided at least one disability is ratable at 40 percent or more, and there is sufficient additional service-connected disability to bring the combined rating to 70 percent or more. 38 U.S.C.A. § 1155; 38 C.F.R. §§ 3.340, 3.341, 4.16(a) (2009). A review of the record evidence shows that the Veteran was employed until August 30, 2001, the current effective date of TDIU benefits. The evidence reveals, however, that the Veteran was having difficulty in maintaining his employment prior to that time. The record includes several letters and reports of Dr. M.R. who indicates to the Veteran's employer, the U.S. Postal Service, that he was unable to work for specific periods. For example, Dr. M.R. sent a letter to the Veteran's employer in July 1997 indicating that the Veteran was unable to work between June 27 and July 2, 1997. Earlier letters indicate the Veteran had difficulty working in the environment his job provided. In a January 2002 letter from Dr. M.R. states that even with modifications given by the Veteran's employer, the work conditions "continued to aggravate his physical conditions." Dr. M.R. stated that "over the last year, [the Veteran] has been becoming increasingly depressed because of what he felt was, not only lack of proper accommodations at work, but the fact that the work was increasingly stressing and worsening his physical condition." Dr. M.R. stated that the worsening conditions "contributed to increasing depression." Dr. M.R. also stated that the Veteran "had an incident at work in which he became inappropriately hostile and aggressive to an individual in management on August 30, 2001," which behavior "was entirely against his usually passive demeanor." Dr. M.R. concluded that the Veteran "remains totally disabled for work from a psychiatric standpoint, with moderate to severe depression and poor response to medications," and "has been totally disabled for any work since early September of 2001." The SSA found that the date the Veteran's disability began was August 30, 2001. A January 2002 letter from Dr. G.A., M.D., also indicates that the Veteran has been "totally disabled for any work since early September of 2001 due to difficulty with concentration, attention span, ability to attend work regularly, ability to interact with fellow employees, management and the general public." After review of the entire record, the Board finds that the Veteran was employed until August 30, 2001, and was able to follow and substantially follow gainful employment until that date. The evidence does not support a finding that the Veteran met the criteria for TDIU benefits prior to August 30, 2001. For those reasons, the Board finds that the Veteran is not entitled to an effective date earlier than August 30, 2001, for TDIU benefits. ORDER The motion that a January 1973 rating decision contained CUE in denying a disability rating in excess of 10 percent disabling for service-connected schizophrenia is denied. Entitlement to an effective date earlier than August 30, 2001, for TDIU is denied. ____________________________________________ FRANK J. FLOWERS Veterans Law Judge, Board of Veterans' Appeals Department of Veterans Affairs