Citation Nr: 21065574 Decision Date: 10/26/21 Archive Date: 10/26/21 DOCKET NO. 19-29 966 DATE: October 26, 2021 ORDER The petition to reopen the claim of compensation for a kidney condition, to include retroperitoneal fibrosis, to include under 38 U.S.C. § 1151, and directly related to claimed exposure to asbestos during service, is granted. The petition to reopen the claim of service connection for headaches, to include as secondary to sarcoidosis, is granted. Entitlement to an initial rating in excess of 70 percent for major depressive disorder, prior to August 8, 2020, is denied. Entitlement to a 100 percent rating, as of August 8, 2020, for major depressive disorder, is granted. Entitlement to an effective date earlier than May 15, 2018, for the grant of service connection for major depressive disorder, is denied. Entitlement to a rating in excess of 10 percent for tinnitus is denied. REMANDED Entitlement to compensation for a kidney condition, to include retroperitoneal fibrosis, to include under 38 U.S.C. § 1151 and directly related to claimed exposure to asbestos during service, is remanded. Entitlement to service connection for headaches, to include as secondary to sarcoidosis, is remanded. Entitlement to service connection for stomach pain, to include gastritis, to include as secondary to sarcoidosis, is remanded. Entitlement to service connection for erectile dysfunction, to include as secondary to sarcoidosis, is remanded. Entitlement to service connection for posttraumatic stress disorder is remanded. Entitlement to a compensable rating for sarcoidosis is remanded. Entitlement to a total disability rating due to individual unemployability (TDIU), prior to June 25, 2020, is remanded. FINDINGS OF FACT 1. A December 2011 rating decision declined to reopen a claim of compensation for a kidney condition. VA received no appeal or new and material evidence prior to expiration of the appeal period; this decision became final. 2. Evidence received since the December 2011 rating decision relates to unestablished facts necessary to substantiate the claim of compensation for a kidney condition. 3. An April 2001 rating decision declined to reopen a claim of service connection for headaches. VA received no appeal or new and material evidence prior to expiration of the appeal period; this decision became final. 4. For the period prior to August 8, 2020, the Veteran's major depressive disorder was manifested by occupational and social impairment with deficiencies in most areas, such as work, school, family relations, judgment, thinking, or mood. Total occupational and social impairment was not shown. 5. For the period since August 8, 2020, the Veteran's major depressive disorder is manifested by total occupational and social impairment. 6. The Veteran's VA Form 21-0966, Intent to File a Claim for Compensation and/or Pension, or Survivor's Pension and/or DIC, was received by VA on May 15, 2018. The May 15, 2018 effective date is the earliest possible effective date assignable. 7. The Veteran's tinnitus is rated at the maximum schedular evaluation. CONCLUSIONS OF LAW 1. The December 2011 rating decision declining to reopen the claim of compensation for a kidney condition is final; and new and material evidence has been received to reopen the claim. 38 U.S.C. §§ 5103, 5103A, 5108, 7105(c); 38 C.F.R. §§ 3.102, 3.156(a), 20.1103. 2. The April 2001 rating decision declining to reopen the claim of service connection for headaches is final; and new and material evidence has been received to reopen the claim. 38 U.S.C. §§ 5103, 5103A, 5108, 7105(c); 38 C.F.R. §§ 3.102, 3.156(a), 20.1103. 3. For the period prior to August 18, 2020, the criteria for a rating in excess of 70 percent disabling for major depressive disorder (MDD) have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.102, 3.159, 4.1, 4.3, 4.21, 4.126, 4.130, DC 9434. 4. For the period since August 18, 2020, the criteria for a rating of 100 percent disabling for major depressive disorder (MDD) are met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 3.102, 3.159, 4.1, 4.3, 4.21, 4.126, 4.130, DC 9434. 5. The criteria for the assignment of an effective date earlier than May 15, 2018, for the award of service connection for major depressive disorder have not been met. 38 U.S.C. §§ 5101, 5107, 5110; 38 C.F.R. § § 3.155, 3.400(b)(2). 6. The criteria for a rating in excess of 10 percent for tinnitus have not been met. 38 U.S.C. § 1155; 38 C.F.R. §§ 3.21, 4.87, Diagnostic Code 6260. REASONS AND BASES FOR FINDINGS AND CONCLUSIONS The Veteran served in the Air Force from September 1970 to April 1974. 1. Whether new and material evidence has been submitted to reopen a claim of compensation for a kidney condition, to include retroperitoneal fibrosis, to include under 38 U.S.C. § 1151 and directly related to claimed exposure to asbestos during service 2. Whether new and material evidence has been submitted to reopen a claim of service connection for headaches, to include as secondary to sarcoidosis A claim that has been denied in an unappealed Regional Office (RO) decision may not thereafter be reopened and allowed. 38 U.S.C. § 7105(c). The exception to this rule is 38 U.S.C. § 5108, which provides that if new and material evidence is presented or secured with respect to a claim which has been disallowed, the Secretary shall reopen the claim and review the former disposition of the claim. New evidence is defined as existing evidence not previously submitted to agency decision makers. Material evidence means evidence that, by itself or when considered with previous evidence of record, relates to an unestablished fact necessary to substantiate the claim. New and material evidence can be neither cumulative nor redundant of the evidence previously of record, and must raise a reasonable possibility of substantiating the claim. 38 C.F.R. § 3.156(a). The regulation is designed to be consistent with 38 C.F.R. § 3.159(c)(4), which "does not require new and material evidence as to each previously unproven element of a claim." Shade v. Shinseki, 24 Vet. App. 110 (2010). The Veteran's claim of compensation for a kidney condition was initially denied by a June 2003 rating decision. A December 2011 rating decision declined to reopen the claim. VA received no appeal or new and material evidence prior to expiration of the appeal period. Therefore, this decision became final. The Veteran's claim of service connection for headaches was initially denied by a March 1975 rating decision. Rating decisions in April 1994 and April 2001 declined to reopen this claim. VA received no appeal or new and material evidence prior to expiration of the appeal period. Therefore, this decision became final. The Board finds that the low threshold for reopening the claims have been met. Shade v. Shinseki, 24 Vet. App. 110 (2010). Therefore, new and material evidence has been received to reopen the claims. Accordingly, the petition to reopen the previously denied claims for compensation for a kidney condition, and service connection for headaches is granted. 3. Entitlement to an increased initial rating major depressive disorder, rated as 70 percent disabling A September 2018 rating decision awarded the Veteran service connection for major depressive disorder (MDD), rated as 70 percent disabling with an effective date of May 15, 2018. Veteran asserts that the symptoms of his MDD are such that they warrant a rating in excess of 70 percent. Legal Criteria Disability ratings are determined by applying the criteria set forth in VA's Schedule for Rating Disabilities. The percentage ratings are based on the average impairment of earning capacity and individual disabilities are assigned separate diagnostic codes. 38 U.S.C. § 1155; 38 C.F.R. § 4.1. The Veteran's entire history is to be considered when making disability evaluations. See generally 38 C.F.R. § 4.1; Schafrath v. Derwinski, 1 Vet. App. 589 (1995). Staged ratings are appropriate for any rating claim when the factual findings show distinct time periods during the appeal period where the service-connected disability exhibits symptoms that would warrant different ratings. Hart v. Mansfield, 21 Vet. App. 505 (2007). Staged ratings are appropriate for any initial rating claim when the factual findings show distinct time periods during the appeal period where the service-connected disability exhibits symptoms that would warrant different ratings. Fenderson v. West, 12 Vet. App. 119, 126 (1999). 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 for that rating. Otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7. Any reasonable doubt regarding a degree of disability will be resolved in favor of the veteran. 38 C.F.R. § 4.3. The Veteran's MDD has been rated under Diagnostic Code (DC) 9434. 38 C.F.R. § 4.130, DC 9411, 9434. DC 9434 is governed by a General Rating Formula for Mental Disorders (General Rating Formula). Under the General Rating Formula, a 70 percent rating is warranted for occupational and social impairment with deficiencies in most areas, such as work, school, family relations, judgment, thinking, or mood, due to such symptoms as: suicidal ideation; obsessional rituals which interfere with routine activities; speech intermittently illogical, obscure, or irrelevant; near-continuous panic or depression affecting the ability to function independently, appropriately, and effectively; impaired impulse control (such as unprovoked irritability with periods of violence); spatial disorientation; neglect of personal appearance and hygiene; difficulty in adapting to stressful circumstances (including work or a work-like setting); and/or inability to establish and maintain effective relationships. A 100 percent rating is warranted for total occupational and social impairment, due to such symptoms as: gross impairment in thought processes or communication; persistent delusions or hallucinations; grossly inappropriate behavior; persistent danger of hurting self or others; inability to perform activities of daily living (including maintenance of minimal personal hygiene); disorientation to time or place; and/or memory loss for names of close relatives, own occupation, or own name). When determining the appropriate disability evaluation to assign, the Board's primary consideration is a veteran's symptoms, but it must also make findings as to how those symptoms impact a veteran's occupational and social impairment. Vazquez-Claudio v. Shinseki, 713 F.3d 112 (Fed. Cir. 2013); Mauerhan v. Principi, 16 Vet. App. 436 (2002). Because the use of the term "such as" in the rating criteria demonstrates that the symptoms after that phrase are not intended to constitute an exhaustive list, the Board need not find the presence of all, most, or even some, of the enumerated symptoms to award a specific rating. Id. at 442. Nevertheless, all ratings in the General Rating Formula are also associated with objectively observable symptomatology and the plain language of the regulation makes it clear that the Veteran's impairment must be "due to" those symptoms, a Veteran may only qualify for a given disability rating by demonstrating the particular symptoms associated with that percentage, or others of similar severity, frequency, and duration. Vazquez-Claudio, 713 F.3d at 118. Prior to August 8, 2020 In August 2018, a VA mental health examiner reviewed the Veteran's psychiatric history contained in his VA e-folder and conducted an in-person examination of the Veteran. The examiner noted a diagnosis of major depressive disorder, moderate, recurrent. No other mental disorder was diagnosed. During the clinical interview, the Veteran reported that he was twice divorced and not currently dating, but had good relations with his two children. He had one close friend come with him to the appointment. The Veteran engaged in limited recreational activities. The Veteran denied any history of hospitalization for mental health conditions, and any history of suicide attempts. The examiner found the Veteran's symptoms to include anxiety, chronic sleep impairment, flattened affect, disturbances of motivation or mood, difficulty in establishing and maintaining effective work and social relationships, difficulty in adapting to stressful circumstances, including work or a worklike setting, neglect of personal appearance and hygiene, and intermittent inability to perform activities of daily living, including maintenance of minimal personal hygiene. The examiner concluded that the Veteran's mental health diagnosis would cause occupational and social impairment with reduced reliability and productivity. After consideration of the evidence of record, the Board finds that, for the period prior to August 8, 2020, the assignment of a 70 percent rating is appropriate. The evidence of record indicates that the Veteran experienced symptoms of near-continuous depression affecting the ability to function independently, appropriately, and effectively; neglect of personal appearance and hygiene; difficulty in adapting to stressful circumstances, and an inability to establish and maintain effective relationships. Therefore, the Veteran's symptoms more closely approximate a 70 percent disabling rating for the period prior to August 8, 2020. The evidence of record does not show that the Veteran's symptoms produce total occupational and social impairment as to warrant a 100 percent rating. The Veteran has been able to maintain relationships with his children and at least one close friend, which is inconsistent with a finding of total social impairment. The record does not establish that the Veteran is in persistent danger of hurting himself or others. There has also been no evidence of delusions, gross impairment in thought processes or communication, grossly inappropriate behavior, or disorientation to time or place during this period. The Veteran's medical records do not show evidence of auditory or visual hallucinations. Furthermore, the record does not show memory loss so severe that the Veteran forgets the names of close relatives, his own occupation, or his name. Therefore, a 100 percent rating is not warranted for the period prior to August 8, 2020. Since August 8, 2020 On August 8, 2020, the Veteran was provided with a VA mental disorder examination. The VA examiner reviewed the Veteran's psychiatric history contained in his e-folder, and conducted an in-person examination of the Veteran. The examiner noted a diagnosis of major depressive disorder, recurrent, severe. No other mental disorder was diagnosed. The examiner found the Veteran's symptoms to include depressed mood, anxiety, suspiciousness, panic attacks more than once a week, near-continuous panic or depression affecting the ability to function independently, appropriately and effectively, chronic sleep impairment, mild memory loss, such as forgetting names, directions or recent events, flattened affect, disturbances of motivation and mood, difficulty in establishing and maintaining effective work and social relationships, difficulty in adapting to stressful circumstances, including work or a work like setting, inability to establish and maintain effective relationships, suicidal ideation, impaired impulse control, such as unprovoked irritability with periods of violence, spatial disorientation, and neglect of personal appearance and hygiene. The examiner concluded that the Veteran's mental health diagnosis would cause total social and occupational impairment. Based on the foregoing, the Board finds that the Veteran's depression, with resulting symptoms including, but not limited to, gross inability to perform activities of daily living including maintenance of minimal personal hygiene, disorientation to time or place; and memory loss inability to establish and maintain effective relationships, panic attacks more than once per week, near-continuous panic or depression affecting the ability to function independently, appropriately and effectively, result in total occupational and social impairment. Therefore, the Board resolves all doubt in favor of the Veteran and finds that such disability results in total occupational and social impairment for period since August 8, 2020, thereby warranting a 100 percent rating. 4. Entitlement to effective date earlier than May 15, 2018 for the grant of service connection for major depressive disorder As discussed above, a September 2018 rating decision awarded the Veteran service connection for major depressive disorder (MDD), rated as 70 percent disabling with an effective date of May 15, 2018. The Veteran contends that he should be entitled to an earlier effective date. Legal Criteria 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. A specific claim in the form prescribed by VA must be filed in order for benefits to be paid or furnished to any individual under the laws administered by VA. 38 U.S.C. § 5101(a); 38 C.F.R. § 3.151(a). Claim or application means a formal or informal communication in writing requesting a determination of entitlement or evidencing a belief in entitlement to a benefit. 38 C.F.R. § 3.1(p). Any communication or action indicating an intent to apply for one or more benefits under the laws administered by VA, from a Veteran or representative or Member of Congress or a person who is not sui juris, may be considered an informal claim. An informal claim must identify the benefit sought. Upon receipt of an informal claim, if a formal claim has not been filed, an application form will be forwarded to the claimant for execution. If received within one year from the date it was sent to the Veteran, it will be considered filed as of the date of receipt of the informal claim. 38 C.F.R. § 3.155. Analysis In the present case, the Veteran's VA Form 21-0966, Intent to File a Claim for Compensation and/or Pension, or Survivor's Pension and/or DIC, was received by VA on May 15, 2018. The Veteran's VA Form 21-526EZ, Application for Disability Compensation and Related Compensation Benefits, was received by VA on June 22, 2018. Among other disabilities listed, the June 2018 application included a claim for "New Depression secondary to sarcoidosis." Therefore, receipt of the claim occurred more than one year following separation from service. As indicated above, generally, the effective date for service connection is not based on the date a disability began, but rather on the date of receipt of the claim. See Lalonde v. West, 12 Vet. App. 377, 382 (1999). After careful consideration, the Board finds that entitlement to an earlier effective date for the grant of service connection for MDD is not warranted. No communication, formal or informal, was received from the Veteran or his representative indicating an intent to claim service connection for this disability prior to May 15, 2018. The pertinent legal authority governing effective dates is clear and specific, and the Board is bound by that authority. Therefore, the appeal for an earlier effective date for a grant of service connection for this issue must be denied. See 38 U.S.C. § 5110(a); 38 C.F.R. § 3.400. There is no reasonable doubt to be resolved as to this issue. See 38 U.S.C. § 5107(b); 38 C.F.R. § 3.102; Gilbert v. Derwinski, 1 Vet. App. 49 (1990). 5. Entitlement to an increased rating for tinnitus, rated as 10 percent disabling The Veteran contends that the severity of his tinnitus warrants a rating in excess of 10 percent. The pertinent rating criteria provides a maximum rating of 10 percent for recurrent tinnitus. 38 C.F.R. § 4.87, DC 6260. In Smith v. Nicholson, 451 F.3d 1344 (Fed. Cir. 2006), the United States Court of Appeals for the Federal Circuit found that 38 C.F.R. § 4.25(b) and 38 C.F.R. § 4.87, DC 6260, limits a Veteran to a single rating for tinnitus, regardless of whether the tinnitus is unilateral or bilateral. The Veteran's service-connected tinnitus has been assigned the maximum schedular rating available for tinnitus, 10 percent, during the entire appeal. 38 C.F.R. § 4.87, DC 6260. As there is no legal basis upon which to award separate schedular evaluations for tinnitus in each ear, or any rating in excess of 10 percent for tinnitus, the Veteran's appeal must be denied. Sabonis v. Brown, 6 Vet. App. 426 (1994). REASONS FOR REMAND 1. Entitlement to compensation for a kidney condition, to include retroperitoneal fibrosis, to include under 38 U.S.C. § 1151 and directly related to claimed exposure to asbestos during service, is remanded. VA has previously denied the Veteran's entitlement to compensation for a kidney disorder under 38 U.S.C. § 1151. In June 2020, through his attorney, the Veteran raised a new theory of entitlement for service connection for a kidney condition, to include retroperitoneal fibrosis. The Veteran contends that he was exposed to asbestos while serving at Vandenberg Air Force Base in California, which caused his kidney condition. Remand is warranted to allow the Agency of Original Jurisdiction (AOJ) an opportunity to develop the record regarding possible exposure to asbestos and obtain a VA medical opinion as to whether the Veteran's kidney condition is directly related to service. 2. Entitlement to service connection for headaches, to include as secondary to sarcoidosis, is remanded. 3. Entitlement to service connection for stomach pain, to include gastritis, to include as secondary to sarcoidosis, is remanded. 4. Entitlement to service connection for erectile dysfunction, to include as secondary to sarcoidosis, is remanded. The Veteran contends that he is entitled to service connection for headaches, stomach pain, and erectile dysfunction (ED), all claimed as secondary to his service-connected sarcoidosis. Service connection may be established on a secondary basis for a disability that is proximately due to, or the result of a service-connected disease or injury. 38 C.F.R. § 3.310 (a). Establishing service connection on a secondary basis requires evidence sufficient to show that a current disability exists and that the current disability was either caused by or aggravated by a service-connected disability. 38 C.F.R. § 3.310(a); Allen v. Brown, 7 Vet. App. 439 (1995). Causation and aggravation are independent concepts and should have separate findings and rationales. Atencio v. O'Rourke, 30 Vet. App. 74 (2018). An opinion to the effect that one disability "is not caused by or a result of" another disability does not answer the question of aggravation. El-Amin v. Shinseki, 26 Vet. App. 136, 140-41 (2013). In August 2018, a VA examiner concluded that establishing a connection between the Veteran's headaches, stomach pain, and ED cannot be established without mere speculation. The examiner provided no opinion regarding aggravation. The Board notes that if an examiner is unable to offer a requested opinion, it is essential that the examiner offer a rationale for the conclusion that an opinion cannot be provided without resort to speculation, together with a statement as to whether there is additional evidence that might enable an opinion to be provided, or whether the inability to provide the opinion is based on the limits of medical knowledge. See Jones v. Shinseki, 23 Vet. App. 382 (2010). The Board finds that new VA medical opinions are necessary to determine whether the Veteran's headaches, stomach pain, and ED were caused by or aggravated by his service-connected sarcoidosis, to include rationale to support this opinion, or rationale for the conclusion that an opinion cannot be provided without resort to speculation. 5. Entitlement to a compensable rating for sarcoidosis is remanded. The Veteran's service-connected sarcoidosis is rated as non-compensable (zero percent disabling) under Diagnostic Code 6846. The Veteran contends that the severity of his sarcoidosis warrants a compensable rating. Sarcoidosis may also be rated pursuant to Diagnostic Code 6600 under the rating criteria for chronic bronchitis. 38 C.F.R. § 4.97, Diagnostic Code 6846 ("or rate active disease or residuals as chronic bronchitis (Diagnostic Code 6600) and extra-pulmonary involvement under specific body system involved"). Diagnostic Code 6600 provides ratings for chronic bronchitis based on the results of pulmonary function tests (PFTs). At the August 2020 VA respiratory condition examination, no PFTs were performed because the Veteran was a no-show to the diagnostic appointment. Resolving reasonable doubt in favor of the Veteran, the Board finds that the Veteran should be afford another opportunity to undergo PFTs to determine the severity of his service-connected sarcoidosis. 6. Entitlement to service connection for posttraumatic stress disorder is remanded. The Veteran contends that he is entitled to service connection for posttraumatic stress disorder (PTSD). Service connection for PTSD generally requires medical evidence establishing a diagnosis of the disorder, credible supporting evidence that the claimed in-service stressor(s) actually occurred, and a link, established by medical evidence, between current symptomatology and the claimed in-service stressor. 38 C.F.R. § 3.304(f). The PTSD diagnosis must be made in accordance with the criteria of Diagnostic and Statistical Manual of Mental Disorders (DSM-5). Id.; 38 C.F.R. § 4.125 (a). The Veteran has undergone multiple VA mental health examinations, but has not been diagnosed with posttraumatic stress disorder. However, these VA examinations did not provide any rationale to explain why the Veteran did not meet the criteria for PTSD under the DSM-5. Upon remand, the Veteran should be provided with a VA PTSD examination to determine whether he has a diagnosis of PTSD, and whether this diagnosis is related to an in-service stressor. 7. Entitlement to a total disability rating due to individual unemployability (TDIU) prior to June 25, 2020 An October 2020 rating decision awarded the Veteran TDIU with an effective date of June 25, 2020. In a June 2020 letter, the Veteran, via his attorney, contends that he is entitled to TDIU from an earlier date of May 15, 2018. Because a decision on the remanded issues of service connection for headaches, stomach pain, ED, PTSD, compensation for a kidney disorder, and an increased rating for sarcoidosis could significantly impact a decision on the issue of entitlement to TDIU prior to June 25, 2020, the issues are inextricably intertwined. A remand of the claim for TDIU prior to June 25, 2020 is required. The matters are REMANDED for the following action: 1. Conduct all necessary development to determine if the Veteran was exposed to asbestos while serving at Vandenberg Air Force Base in California. If necessary, obtain a VA medical opinion as to whether the Veteran's kidney condition is related to asbestos exposure. 2. Obtain addendum opinions from appropriate clinician(s) regarding whether the Veteran's headaches, stomach pain, and ED are at least as likely as not related to his service-connected sarcoidosis, proximately due to his service-connected sarcoidosis, or aggravated beyond its natural progression by his service-connected sarcoidosis. (a.) The VA examiner must provide separate findings and rationales relating to causation and aggravation. (b.) If the examiner is unable to offer a requested opinion, it is essential that the examiner offer a rationale for the conclusion that an opinion cannot be provided without resort to speculation, together with a statement as to whether there is additional evidence that might enable an opinion to be provided, or whether the inability to provide the opinion is based on the limits of medical knowledge. 3. Provide the Veteran with an opportunity to undergo VA pulmonary function testing (PFT) to determine the severity of his service-connected sarcoidosis. 4. Develop the record to verify the Veteran's claimed PTSD stressors. 5. Schedule the Veteran for a psychiatric examination to determine the nature and etiology of any posttraumatic stress disorder (PTSD). If the Veteran is diagnosed with PTSD, the examiner must explain how the diagnostic criteria are met and opine whether it is at least as likely as not related to a verified in-service stressor. If the Veteran is not diagnosed with PTSD, the examiner must explain how the diagnostic criteria are not met. 6. After the above development, and any additionally indicated development, has been completed, readjudicate the issues on appeal, including the inextricably intertwined issue of entitlement to TDIU prior to June 25, 2020. Any decision on this issue should address the June 2020 private vocational rehabilitation counselor opinion that the Veteran's service-connected disabilities have precluded him from substantial gainful employment since May 2018. If the benefit sought is not granted to the Veteran's satisfaction, send the Veteran and his representative a Supplemental Statement of the Case and provide an opportunity to respond. If necessary, return the case to the Board for further appellate review. JENNIFER HWA Veterans Law Judge Board of Veterans' Appeals Attorney for the Board C. Casey, Counsel The Board's decision in this case is binding only with respect to the instant matter decided. This decision is not precedential and does not establish VA policies or interpretations of general applicability. 38 C.F.R. § 20.1303.