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Board of Veterans' Appeals · AMA series

A rating greater than 70 percent for post-traumatic stress disorder (PTSD) is denied.

July 30, 2026Citation Nr. A26069960Docket 210923-188947va.gov source

  • Post-traumatic stress disorder (PTSD) disability ratingDenied
  • Total disability rating based on individual unemployability (TDIU) due to service-connected disabilityGranted
  • Dependents' Educational Assistance (DEA) benefitsGranted
  • Right knee arthritis, limitation of flexionDismissed

Board reasoning

The Board denied a rating greater than 70 percent for PTSD, but granted an earlier effective date of September 20, 2019 for TDIU due to PTSD and for DEA eligibility, citing the Veteran’s persistent but non-total occupational and social impairment and the record showing unemployability tied to PTSD among other factors. It also granted withdrawal of the right knee issue on the record after the April 2025 hearing, concluding no pending appellate review remains for that issue.

Authorities

  • Rice v. Shinseki, 22 Vet. App. 447 (2009)Reasoning about early TDIU effective date based on continuous pursuit
  • Gonzales v. West, 218 F.3d 1378 (Fed. Cir. 2000)Holistic analysis of mental disorder symptoms under the General Formula
  • Bankhead v. Shulkin, 29 Vet. App. 10Holistic analysis of unlisted symptoms for rating
  • Mauerhan v. Principi, 16 Vet. App. 436 (2002)Guidance on considering unlisted symptoms
  • Ray v. Wilkie, 31 Vet. App. 58Assessing economic and non-economic factors for TDIU
Citation Nr: A26069960 Decision Date: 07/30/26 Archive Date: 07/30/26 DOCKET NO. 210923-188947 DATE: July 30, 2026 ORDER A rating greater than 70 percent for post-traumatic stress disorder (PTSD) is denied. An effective date of September 20, 2019, for the award of total disability rating based on individual unemployability (TDIU) due to service-connected disability is granted. An effective date of September 20, 2019, for the grant of eligibility for Dependents' Educational Assistance (DEA) under 38 U.S.C. Chapter 35, is granted. Entitlement to a rating greater than 10 percent for right knee arthritis, limitation of flexion, is dismissed. FINDINGS OF FACT 1. The severity, frequency, and duration of the Veteran's PTSD symptoms more nearly approximate occupational and social impairment with deficiencies in most areas, without more severe symptoms that would cause total occupational and social impairment. 2. As of September 20, 2019, the date of receipt of an initial claim for compensation, the Veteran was unable to secure and follow a substantially gainful occupation as a result of her service-connected disability; and TDIU is warranted based solely on her service-connected PTSD. 3. As of September 20, 2019, the Veteran is permanently and totally disabled due to a service-connected disability and meets the criteria for DEA benefits. 4. On April 8, 2025, prior to the promulgation of a decision in the appeal for entitlement to a rating greater than 10 percent for right knee arthritis, limitation of flexion, the Veteran orally withdrew the appeal of that issue at a Board of Veterans' Appeals (Board) hearing. CONCLUSIONS OF LAW 1. The criteria for a rating greater than 70 percent for PTSD have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.1, 4.3, 4.7, 4.126, 4.130, Diagnostic Code (DC) 9411. 2. The criteria for an effective date of September 20, 2019, for the award of TDIU due to PTSD have been met. 38 U.S.C. § 5110; 38 C.F.R. §§ 3.340, 3.341, 3.400, 4.16(a), 3.2500; Rice v. Shinseki, 22 Vet. App. 447 (2009). 3. The criteria for an effective date of September 20, 2019, for the grant of eligibility for DEA have been met. 38 U.S.C. §§ 3510, 5110, 5113; 38 C.F.R. §§ 3.807, 21.3021. 4. The criteria for oral withdrawal of the appeal for entitlement to a rating greater than 10 percent for right knee arthritis, limitation of flexion, have been met. 38 U.S.C. § 7105; 38 C.F.R. § 20.205. REASONS AND BASES FOR FINDINGS AND CONCLUSIONS The Veteran served on active duty in the United States Army from September 1998 to July 2001. For her meritorious service, the Veteran was awarded (among other decorations) the Army Achievement Medal. Before turning to the merits of this case, a review of the procedural history is instructive. As pertinent to this appeal, the Veteran was initially granted service connection for PTSD with a 30 percent evaluation, effective November 20, 2009, in an October 2010 rating decision. Thereafter, the Veteran sought entitlement to a TDIU due to her service-connected disabilities, in addition to an increased rating for PTSD. See November 2010 VA Form 21-4138, Statement in Support of Claim; March 2011 Correspondence. The Veteran was granted a 70 percent rating for PTSD, effective November 23, 2010, the date of her TDIU claim, but denied entitlement to a TDIU, in June 2013 and December 2014 rating decisions, which became final in the legacy appeal system. On September 20, 2019, the Veteran submitted a VA Form 21-526EZ, seeking a rating greater than 70 percent for her service-connected PTSD. In a January 2020 rating decision, a Department of Veterans Affairs (VA) Regional Office (RO) continued the Veteran's 70 percent evaluation for PTSD. On October 19, 2020, the Veteran submitted a VA Form 20-0996, requesting higher-level review (HLR) of the January 2020 rating decision. In a corresponding letter, the Veteran's representative indicated she was seeking entitlement to a rating greater than 70 percent for PTSD. In addition, the representative noted the Veteran is unable to work as a result of her service-connected impairments and requests TDIU be considered part and parcel with the current appeal. In February 2021 correspondence, VA informed the Veteran the issue of TDIU was not eligible for HLR because it was last denied in a December 2014 rating decision. Then, in a February 2021 rating decision, the RO continued the Veteran's 70 percent evaluation for PTSD. On June 10, 2021, the Veteran submitted a VA Form 21-8940, Veterans Application for Increased Compensation Based on Unemployability (i.e., TDIU application), and reported being unable to work due to her right knee, right lower extremity weakness, PTSD, and depression. In a July 2021 rating decision, the RO continued the Veteran's 70 percent evaluation for PTSD once again, but granted a TDIU solely due to her service-connected PTSD and established eligibility for DEA under 38 U.S.C. Chapter 35, effective June 10, 2021. This matter is presently before the Board on appeal of the July 2021 rating decision. Given the dates of the rating decisions on appeal, the Veteran's appeal is governed by the modernized review system, known by the Board as the Appeals Modernization Act (AMA). 38 C.F.R. §§ 3.2400, 19.2. On September 23, 2021, the Veteran submitted two VA Form 10182, Decision Review Request: Board Appeals (Notice of Disagreement (NOD)), and elected the Hearing docket. The Veteran appeared at a hearing before the undersigned Veterans Law Judge on April 8, 2025. A transcript of the hearing is in the Veteran's file. Therefore, the Board may only consider the evidence of record at the time of the July 2021 rating decision (i.e., agency of original jurisdiction (AOJ) decision) on appeal, as well as any evidence submitted by the Veteran, or her representative, at the hearing or within 90 days following the hearing. 38 C.F.R. § 20.302(a). If evidence was submitted either (1) during the period after the AOJ issued the decision on appeal and prior to the Board hearing, or (2) more than 90 days following the hearing, the Board did not consider it in its decision. 38 C.F.R. §§ 20.300, 20.302(a), 20.801. If the Veteran would like VA to consider any evidence that was submitted that the Board could not consider, the Veteran may file a Supplemental Claim (VA Form 20-0995) and submit or identify this evidence. 38 C.F.R. § 3.2501. If the evidence is new and relevant, VA will issue another decision on the claims, considering the new evidence in addition to the evidence previously considered. Id. Specific instructions for filing a Supplemental Claim are included with this decision. Increased Ratings VA's percentage ratings are based on the average impairment of earning capacity as a result of service-connected disability. 38 U.S.C. § 1155; 38 C.F.R. § 4.1. If two disability evaluations are potentially applicable, 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. All reasonable doubt will be resolved in favor of the claimant. 38 C.F.R. § 4.3. This decision will focus on the evidence pertinent to the rating criteria and disability severity during the relevant period on appeal, but the Board has considered the entire record to have a full picture of the disability. See 38 C.F.R. §§ 4.1, 4.2, 4.41; Gonzales v. West, 218 F.3d 1378 (Fed. Cir. 2000). In making all determinations, the Board must fully consider the lay assertions of record. A layperson is competent to report on the onset and continuity of his or her current symptomatology. See Layno v. Brown, 6 Vet. App. 465, 470 (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. § 5107; 38 C.F.R. § 3.102. See Lynch v. McDonough, 21 F.4th 776 (Fed. Cir. 2021). 1. Entitlement to a rating greater than 70 percent for PTSD is denied. Legal Criteria Under the General Formula for Mental Disorders (General Formula), the Board must conduct a "holistic analysis" that considers all associated symptoms, regardless of whether they are listed as criteria. Bankhead v. Shulkin, 29 Vet. App. 10, 22 (2017); 38 C.F.R. § 4.130 (2018). The Board must determine whether unlisted symptoms are similar in severity, frequency, and duration to the listed symptoms associated with specific disability percentages. Then, the Board must determine whether the associated symptoms, both listed and unlisted, caused the level of impairment required for a higher disability rating. Vazquez-Claudio v. Shinseki, 713 F.3d 112, 114-118 (Fed. Cir. 2013). Under the General Formula, a 70 percent rating is warranted when there is 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); or inability to establish and maintain effective relationships. A 100 percent rating is warranted when there is 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; intermittent inability to perform activities of daily living (including maintenance of minimal personal hygiene); disorientation to time or place; or memory loss for names of close relatives, own occupation or own name. The symptoms listed in the General Formula are not intended to constitute an exhaustive list. Rather, the symptoms serve as examples of the type and degree of the symptoms, or their effects, that would justify a particular rating. See Mauerhan v. Principi, 16 Vet. App. 436 (2002). Thus, the Board will consider whether "the evidence demonstrates that a claimant suffers symptoms or effects that cause occupational or social impairment equivalent to what would be caused by the symptoms listed in the diagnostic code," and, if so, the "equivalent rating will be assigned." Id. Factual Background The Veteran is seeking a rating greater than 70 percent for her service-connected PTSD. See September 2021 VA Form 10182, NOD; September 2021 Appellant Brief; April 2025 Hearing Transcript. The appeal period begins on September 20, 2019, the date of the Veteran's claim for an increased rating. Per 38 C.F.R. § 3.400(o)(2) and Gaston v. Shinseki, 605 F.3d 979 (2010), there is a one-year lookback period for non-initial claims for an increased rating, such as in the instant case. Therefore, the Board must consider whether an increase in disability occurred at any time from September 20, 2018. Around the start of the appeal period, VA treatment records show the Veteran denied experiencing suicidal or homicidal ideation, but diagnoses of chronic PTSD and major depressive disorder with a history of suicidal ideation are reflected. The Veteran's mental health treatment consisted of taking an antidepressant prescribed by her primary care provider. See September 27, 2018, and September 27, 2019, VA Treatment Records. Primary care visits ROS (review of symptoms) indicated the Veteran denied issues with agitation, confusion, anxiety, and depression. On examination, she was awake, alert, and oriented to name, time, and place. Her mood and affect were calm and/or euthymic. Id. In October 2019, the Veteran was afforded a VA examination for PTSD. At the time, the Veteran reported being married to her husband for one year, and together for four years. She described the relationship as good, and indicated her husband is very supportive. She noted that they struggle at times, but they are able to talk it over. The Veteran indicated this was her fourth marriage. She reported having no children of her own, but she does have two stepchildren. The Veteran also indicated she has a strong relationship with her mother, but is no longer in contact with her younger sister and has not been in years. The Veteran reported having a few friends, and noted she has a couple of people she will talk with. However, the Veteran stated she does not go out with anyone, as one friend left for Texas and she has ongoing struggles with trust; but she did keep in contact with a few people through Facebook. The Veteran noted that she will go to the track barn, as she has a few horses training for the track. She indicated she will see people when they are there. She also indicated she enjoys spending time with those people and she sees them most every day. In terms of occupation, the Veteran was unemployed. She reported that she last worked for one season as a trainer at the train track a few years ago. The Veteran had not looked for work since that time. She reported being a good worker, but she struggles to connect with others on the job. She denied having any troubles with work performance, and she denied any changes to her education since she was last seen in 2013. As for treatment, the Veteran was last seen by mental health in February 2018, but she was prescribed medication (i.e., Sertraline HCl) that she took as prescribed. The October 2019 VA examiner observed that the Veteran arrived on time for her appointment. She was casually and appropriately dressed, and she sat upright in the chair with adequate eye contact. The Veteran's orientation was intact, and she was pleasant and cooperative. She was teary eyed throughout the evaluation, but her speech was normal in rate and tone. No psychomotor agitation or retardation was observed. The Veteran's thought production appeared logical and goal oriented, and she denied any current suicidal ideation. The October 2019 VA examiner determined the Veteran experienced occupational and social impairment with occasional decrease in work efficiency and intermittent periods of inability to perform occupational tasks, although generally functioning satisfactorily, with normal routine behavior, self-care and conversation. Her identified symptoms included depressed mood, anxiety, mild memory loss (such as forgetting names, directions or recent events), disturbances of motivation and mood, and difficulty in establishing and maintaining effective work and social relationships. On November 25, 2020, the Veteran underwent an initial mental health consult. During the consult, the Veteran reported being chronically depressed. She also reported a history of suffering from a lack of sleep, anxiety, overwhelm, rage, reactivity to crowds, noises, and smells, and PTSD symptoms. Notably, the Veteran endorsed suicidal ideation, "in the back of my head," but denied having a plan or intent. She was not demonstrating acute suicidal ideation, behavior, or risk. The Veteran endorsed a history of suicide attempt in 2008 as well. She denied having current or previous homicidal ideation, intent, or plan to harm others. In July 2021, the Veteran was afforded another VA examination for PTSD. The Veteran related that she, her husband, and her stepdaughter all relocated one year prior. As a product of her condition, the Veteran reported she has been unable to work since 2015. She explained that she left a position in law enforcement to work with horses, as she could not maintain her employment due to her inability to function with others and under stress. With regard to mental health treatment, the Veteran stated she was working with a Veteran's group online, attending weekly group therapy and group support sessions. She stated that she discontinued treatment with the VA system, following a series of failed attempts to find a therapist that she felt she could trust. The July 2021 VA examiner observed that the Veteran was casually dressed and presented as a hypervigilant, suspicious, and withdrawn individual. She was angry and frustrated regarding the travel conditions imposed for the appointment. She preferred sitting with her back to the wall, and she acknowledged her frustration. The Veteran was cooperative and direct, and expressed statements that were linear. Her attention and concentration were grossly intact, although she was perseverative regarding her expressed thoughts. The Veteran's cognition was grossly intact. She was forgetful of names, dates and numbers, but no other difficulties with cognition were noted. She had good insight and good judgment. She was oriented to all spheres. The July 2021 VA examiner determined the Veteran experienced occupational and social impairment with reduced reliability and productivity. Her identified symptoms included 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, impaired abstract thinking, disturbances of motivation and mood, difficulty 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, and suicidal ideation. In addition, the examiner remarked that the Veteran appears to be managing her symptoms predominantly by avoidance. She has few friends, lives in an isolated area with her husband, and does not socialize. The evidence of record includes lay statements from the Veteran's former coworker and employer, her husband, and her mother. See January 2021 Statement from M.P., the Veteran's Former Coworker and Employer; July 2022 Statement from the Veteran's Husband; July 2022 Statement from the Veteran's Mother. The Veteran's former coworker/employer, husband, and mother reported she has issues with anger, anxiety, socializing and isolating. Id. The Veteran's husband and mother indicated the Veteran lives on a little farm and only leaves to get necessities and go to doctor appointments. See July 2022 Statement from the Veteran's Husband; July 2022 Statement from the Veteran's Mother. Both the Veteran's husband and her mother indicated she is reclusive, anti-social, and avoids crowds. Id. According to her husband, when the Veteran's anxiety sets in, it is difficult for her to be around others. When things get stressful, she has "a moment" when she will get frustrated and lash out. Her husband also stated that sudden noises (e.g., an exhaust backfiring) will quickly change the Veteran's demeanor. See July 2022 Statement from the Veteran's Husband. The Veteran's mother similarly states that she has fits of anger for unknown reasons. Her mother indicated the Veteran no longer has any friends, as she says she cannot trust anyone. Her mother said she has been divorced several times due to her anger and anxiety issues. Additionally, the Veteran's mother reported being worried for the Veteran because she was very depressed, angry, and talking suicide. See July 2022 Statement from the Veteran's Mother. The Veteran's former coworker and employer, M.P., stated the Veteran worked for her as a groom and assistant racehorse trainer from 2013 to 2015. The Veteran was a very hard worker and very experienced, but struggled with getting along with people and being in social settings. M.P. explained that the job not only required the Veteran to be able to work with others, as she also needed the ability to conduct herself with owners, the general public, and crowds on race days. See January 2021 Statement from M.P., the Veteran's Former Coworker and Employer. M.P. said this is where the Veteran struggled. When things were not routine even in the slightest, the Veteran struggled to handle it and often lashed out at people for no good reason. She was jumpy and reacted to quick movements and loud noises. She would also become very defensive, and at times combative, with others. As the Veteran's symptoms worsened, she and M.P. had a heart-to-heart and she decided to leave. Id. M.P. noted that the things the Veteran could handle mentally, she could not handle physically due to her knees, back, and shoulders, and the things she could handle physically she could not handle mentally. Id. In April 2025, the Veteran appeared at a Board hearing. During the hearing, the Veteran endorsed symptoms of depression, anxiety, and frequent suicidal thoughts. See April 2025 Hearing Transcript, pp. 3-5. The Veteran stated that her hygiene is affected, because sometimes she has a hard time getting up and taking care of her personal needs. She indicated that she does not attend to her hygiene needs for a week or more sometimes. Id. at p. 4. She reported that she feels she needs assistance with activities of daily living, such as cooking, cleaning, paying the bills, and maintaining the household as well. Id. at 7. In addition, the Veteran reported that she avoids social situations, public places, and crowds (large and small), as they induce anxiety and panic attacks. Id. at p. 3. She stated crowds and loud noises put her on edge and cause panic attacks. Id. at p. 7. For instance, the Veteran stated she is more subject to having a panic attack if she is out going to the grocery store, or running an errand. As a result, she explained that she alienates herself to her farm. The Veteran reported she does not have a social life or relationship with her family, and her husband is the only person with whom she socializes. Id. at pp. 4, 8. The Veteran stated she is easily angered as well. She stated that she blows up at her husband, and avoids being around a lot of other people to prevent arguments. Id. at p. 5. Additionally, the Veteran indicated she has difficulty sleeping, poor attention, and memory issues. She explained that she has a hard time staying focused in, and remembering, conversations because her mind wanders easily. Id. at p. 6. Analysis The Board finds the Veteran's PTSD symptoms did not more nearly approximate the criteria for a 100 percent rating at any point during the appeal period. When evaluating a mental disorder, the Board considers the frequency, severity, and duration of psychiatric symptoms, the length of remission, and the veteran's capacity for adjustment during periods of remission. The evaluation is based on all the evidence of record that bears on occupational and social impairment rather than solely on an examiner's assessment of the level of disability at the moment of the evaluation. 38 C.F.R. § 4.126(a). The Veteran's service-connected PTSD is rated as 70 percent disabling. Notably, the symptoms associated with a 70 percent disability rating support an occupational and social impairment with deficiencies in most areas, such as work, school, family relations, judgment, thinking, or mood. Such symptoms need not rise to the level of activity preclusion, but rather negatively influence or impact most areas of life functioning. On the other hand, the hallmark of symptoms associated with a 100 percent disability rating is that they result in total occupational and social impairment. 38 C.F.R. § 4.130. In this case, the Veteran's PTSD manifests in occupational and social impairment with deficiencies in most areas, but her symptoms do not rise to the level of total occupational and social impairment. For instance, although the Veteran experiences suicidal ideation, the evidence of record does not indicate that the severity, frequency, and duration of her suicidal ideation have risen to the level of showing she is a persistent danger to herself or others, as contemplated by the 100 percent rating criteria. During the appeal period, the Veteran has either denied experiencing suicidal ideation or endorsed passive thoughts of suicide (i.e., "in the back of my head") without a plan or intent. See September 27, 2019, and November 25, 2020, VA Treatment Records; October 2019 and July 2021 VA Examinations for PTSD; July 2022 Statement from the Veteran's Mother. In addition, she has denied having any homicidal ideation, intent, or plan to harm others. See September 27, 2019, and November 25, 2020, VA Treatment Records. The Veteran reported having issues with her memory in general, and poor attention. She explained that she has a hard time staying focused in, and remembering, conversations because her mind wanders easily. See April 2025 Hearing Transcript, p. 6. Such evidence does not reflect memory issues that rise to the level of showing she forgets the names of close relatives, her own occupation, or her own name, as contemplated by the 100 percent rating criteria. The Veteran also reported that her hygiene is affected by her PTSD symptoms, because she sometimes has a hard time getting up and taking care of her personal needs. She admitted that she does not attend to her hygiene needs for a week or more sometimes. Id. at p. 4. Of note, the Veteran's hygiene issues are not documented in the medical or lay evidence of record. Nevertheless, this evidence potentially reflects neglect of appearance and hygiene, a symptom contemplated by the 70 percent rating criteria. However, the Veteran indicated that she feels she needs assistance with activities of daily living, such as cooking, cleaning, paying the bills, and maintaining the household as well. Id. at 7. While the Veteran's reported issues with her hygiene and need for assistance with activities of daily living could reflect an intermittent inability to perform activities of daily living (including maintenance of minimal personal hygiene), a symptom contemplated by the 100 percent rating criteria, the evidence does not show this one symptom is of the severity, frequency, and duration to support a total rating on its own. Furthermore, the Veteran does not assert, and the evidence does not show, she experiences persistent delusions or hallucinations, or that she demonstrates gross impairment in thought or communication, grossly inappropriate behavior, or disorientation to time or place. To the contrary, the evidence provides further support that the Veteran's disability picture more nearly approximates the criteria for a 70 percent rating, with symptoms such as difficulty adapting to stressful circumstances (including work or a work-like setting) and an inability to establish and maintain effective relationships, in addition to suicidal ideation, discussed above. For example, the Veteran reports being easily angered and "blowing up" at her husband. She also reports that she avoids being around a lot of other people to prevent arguments. See April 2025 Hearing Transcript, p. 5. Such evidence reflects difficulty adapting to stressful circumstances and an inability to establish and maintain effective relationships. The Veteran's reports are consistent with statements she made to a VA treatment provider and the July 2021 VA examiner, as well as the lay evidence of record. In November 2020, the Veteran told a VA treatment provider she had a history of suffering from overwhelm, rage, and reactivity to crowds, among other things. See November 25, 2020, VA Treatment Record. At the July 2021 VA examination, she reported an inability to function with others and under stress in her past employment. At the examination, the July 2021 VA examiner observed that she was angry and frustrated regarding the travel conditions for the appointment. The Veteran preferred sitting with her back to the wall, and she acknowledged her frustration. See July 2021 VA Examination for PTSD. Moreover, the Veteran's former coworker and employer, husband, and mother reported she has issues with anger, socializing and isolating. See January 2021 Statement from M.P., the Veteran's Former Coworker and Employer; July 2022 Statement from the Veteran's Husband; July 2022 Statement from the Veteran's Mother. Her former employer M.P. specifically mentioned that the Veteran struggled getting along with people at work and handling changes in routine at work. See January 2021 Statement from M.P., the Veteran's Former Coworker and Employer. While this evidence suggests the Veteran has deficiencies in her social abilities in most areas, it does not support a total social impairment. The Veteran has also been in a long-term relationship throughout the appeal period, which weighs against a finding of total social impairment. Even when viewing the evidence in a light most favorable to the Veteran, the evidence does not show her symptoms manifested in total occupational and total social impairment at any point during the appeal period. Based upon the foregoing, the persuasive weight of the evidence is against the claim for an increased rating for the Veteran's service-connected PTSD. There is no doubt to be resolved. A disability rating greater than 70 percent for PTSD is not warranted. The appeal is denied. Effective Date Unless specifically provided otherwise, the effective date of an award based on an initial claim, or a supplemental claim, of compensation, dependency and indemnity compensation, or pension, shall be fixed in accordance with the facts found, but shall not be earlier than the date of receipt of application therefor. 38 U.S.C. § 5110(a). For continuously pursued claims, except as otherwise provided, the effective date will be fixed in accordance with the date of receipt of the initial claim or date entitlement arose, whichever is later, if a claimant continuously pursues an issue by timely filing in succession any of the available review options as specified in 38 C.F.R. § 3.2500(c) within one year of the issuance of the decision, provided that any appeal to the Court of Appeals for Veterans Claims (Court) must be accepted as timely by that court. 38 C.F.R. § 3.2500(h)(1). The phrase "date entitlement arose" is not specifically defined in the current statute or regulation. The Court has interpreted it as the date when the claimant met the requirements for the benefits sought. This is determined on a "facts found" basis. See 38 U.S.C. § 5110(a); see also McGrath v. Gober, 14 Vet. App. 28, 35 (2000). This means the date the disability manifested, once it has been determined that it is service connected. 2. Entitlement to an effective date earlier than June 10, 2021, for the award of TDIU due to service-connected PTSD is granted. The Veteran is seeking an earlier effective date than June 10, 2021, for an award of TDIU. See September 2021 VA Form 10182, NOD; September 2021 Appellant Brief. The appeal period begins on September 20, 2019, the date of the Veteran's increased rating claim. At the outset, The Board notes that a request for a TDIU, whether expressly raised by the veteran or reasonably raised by the record, is not necessarily a separate claim for benefits, but rather is an attempt by a claimant to obtain an appropriate rating; it thus may be considered part and parcel of any increased rating claim for which it is argued that an appealed disability has contributed to unemployability. See Rice v. Shinseki, 22 Vet. App. 447, 453-54 (2009). In this case, the Veteran submitted a VA Form 21-526EZ on September 20, 2019, seeking a rating greater than 70 percent for her service-connected PTSD. In a January 2020 rating decision, the RO continued the Veteran's 70 percent evaluation for PTSD. On October 19, 2020, the Veteran submitted a VA Form 20-0996, requesting HLR of the January 2020 rating decision and consideration for a TDIU, as part and parcel of the appeal. In February 2021 correspondence, the VA informed the Veteran the issue of TDIU was not eligible for HLR because it was last denied in a December 2014 rating decision. Then, in a February 2021 rating decision, the RO continued the Veteran's 70 percent evaluation for PTSD once again. On June 10, 2021, the Veteran submitted a VA Form 21-8940, TDIU application. In a July 2021 rating decision, the RO continued the Veteran's 70 percent evaluation for PTSD, but granted a TDIU solely due to her service-connected PTSD and established eligibility for DEA under 38 U.S.C. § Chapter 35, effective June 10, 2021. On September 23, 2021, the Veteran submitted a timely 10182, NOD, and listed both the February 2021 and July 2021 rating decisions as decisions she wished to appeal. It is upon this history that the current appeal is before the Board. The Board observes that the Veteran's September 20, 2019, claim for an increased rating resulted in the January 2020 rating decision, an initial decision under AMA. Thereafter, the Board finds the Veteran continuously pursued her claim by timely filing proper administrative review options since the initial decision (i.e., HLR and Board appeal). See 38 C.F.R. § 3.2500(c). Additionally, the Board finds that pursuant to Rice, the Veteran's request for a TDIU was reasonably raised by the record, because an October 2019 VA examiner noted the Veteran was unemployed and struggled to connect with others on the job. The examiner also identified difficulty in establishing and maintaining effective work and social relationships as one of the Veteran's PTSD symptoms. See October 2019 VA Examination for PTSD. Therefore, the request for a TDIU is considered part and parcel with the Veteran's September 20, 2019, increased rating claim. Given the Veteran's continuous pursuit of her claim, the effective date will be fixed in accordance with the date of receipt of the initial claim or date entitlement arose, whichever is later. 38 C.F.R. § 3.2500(h)(1). The "date entitlement arose" is the date when the Veteran met the requirements for the benefits sought, and is determined on a "facts found" basis. See 38 U.S.C. § 5110(a); McGrath v. Gober, supra. Here, the benefit sought is a TDIU. A TDIU may be assigned, where the schedular rating is less than total, when the veteran is unable to secure or follow a substantially gainful occupation as a result of service-connected disabilities. 38 C.F.R. § 4.16(a). To qualify for schedular consideration of a TDIU, if there is only one such disability, this disability shall be ratable at 60 percent or more, and, if there are two or more disabilities, there shall be at least one disability ratable at 40 percent or more and sufficient additional disability to bring the combined rating to 70 percent or more. Id. There is no question the Veteran met the schedular criteria for a TDIU under 38 C.F.R. § 4.16(a). Her PTSD alone was ratable at 70 percent throughout the appeal period. Furthermore, the Veteran had multiple service-connected disabilities (i.e., PTSD and right knee disabilities) with a combined disability rating of 80 percent and at least one disability rated at 40 percent or higher. Thus, a TDIU is warranted with evidence that the Veteran's service-connected disability or disabilities preclude her ability to secure or follow a substantial gainful occupation. The phrase "unable to secure and follow a substantially gainful occupation" contains both economic and noneconomic components. See Ray v. Wilkie, 31 Vet. App. 58, 73 (2019). Regarding the economic factors contemplated in Ray, the Veteran reported she last worked in 2016. See June 2021 VA Form 21-8940; April 2025 Hearing Transcript, pp. 8-10. Accordingly, the Veteran has not engaged in employment earning more than marginal income during the period on appeal. With regard to non-economic factors, the Veteran has a high school education with some college. Id. Her past employment includes working with horses, and training racehorses. Id. In addition to working with horses, the Veteran's past work duties involved working with others, to include owners, the general public, and crowds on race days, and being in social settings. See January 2021 Statement from M.P., the Veteran's Former Coworker and Employer. The Board notes that the RO found the Veteran was entitled to a TDIU based solely on her service-connected PTSD. The Board similarly finds the evidence of record shows the Veteran's service-connected PTSD impacted her mental ability to perform activities required by her past occupation. Due to her PTSD symptoms, the Veteran reported that she had a difficult time getting along with other people, and she was not easy to work with. She also had issues when things fell out of a routine, and problems with her attention, concentration, and memory (i.e., hard time staying focused, mind wandering). See April 2025 Hearing Transcript, pp. 10-11. The Veteran's former employer from 2013 to 2015, M.P., reported the Veteran struggled to get along with people and with being in social settings. When things were not routine even in the slightest, the Veteran struggled to handle it and often lashed out at people for no good reason. She was jumpy and reacted to quick movements and loud noises. She would also become very defensive, and at times combative, with others. See January 2021 Statement from M.P., the Veteran's Former Coworker and Employer. As the Veteran's symptoms worsened, she and M.P. had a heart-to-heart and the Veteran decided to leave her last job. M.P. noted that the things the Veteran could handle mentally, she could not handle physically due to her knees, back, and shoulders, and the things she could handle physically she could not handle mentally. Id. As previously mentioned, the October 2019 VA examiner identified difficulty in establishing and maintaining effective work and social relationships as one of the Veteran's PTSD symptoms. In a subsequent VA examination for PTSD, a July 2021 VA examiner also identified symptoms such as difficulty in adapting to stressful circumstances (including work or a work-like setting), and an inability to establish and maintain effective relationships. See Tatum v. Shinseki, 24 Vet. App. 139 (2010) (It is the information in a medical opinion, and not the date of the medical opinion, that is relevant when determining effective date.). When viewing the evidence in a light most favorable to the Veteran, the Board resolves all doubt in her favor and finds her service-connected PTSD, alone, is sufficient to support a grant of entitlement to a TDIU on a "facts found" basis at the time of her September 2019 claim for increased rating. In sum, the Board finds the Veteran is entitled to an effective date earlier than June 10, 2021, for an award of TDIU. Resolving any doubt in her favor, the Board finds an effective date of September 20, 2019, for the award of TDIU is warranted based solely on her service-connected PTSD. Therefore, her appeal is granted. Additional Considerations In offering this conclusion, the Board has considered whether entitlement to special monthly compensation (SMC) is warranted in this case as well. The Court has held that the VA has a duty to maximize a claimant's benefits, which includes the duty to assess all of the claimant's disabilities to determine whether any combination of disabilities establishes entitlement to SMC under 38 U.S.C. § 1114. See Buie v. Shinseki, 24 Vet. App. 242, 250 (2011). Under 38 U.S.C. § 1114(s) and 38 C.F.R. § 3.350(i), SMC at the housebound rate is payable where a veteran has a single service-connected disability rated as 100 percent and, (1) has additional service-connected disability or disabilities independently ratable at 60 percent or more, separate and distinct from the 100 percent service-connected disability and involving different anatomical segments or bodily systems, or (2) is permanently housebound by reason of service-connected disability or disabilities. The requirement of "permanently housebound" is met when the veteran is substantially confined as a direct result of service-connected disabilities to his or her dwelling and the immediate premises or, if institutionalized, to the ward or clinical areas, and it is reasonably certain that the disability or disabilities and resultant confinement will continue throughout his or her lifetime. A TDIU may satisfy the statutory requirement that a disability be rated as total. See Buie, 24 Vet. App. at 248. The Veteran is in receipt of a TDIU based solely on her service-connected PTSD. However, entitlement to SMC is not warranted. The Veteran does not have additional service-connected disability or disabilities, involving different anatomical segments or bodily systems, that are independently ratable at 60 percent or more. Moreover, the Veteran does not assert, and the evidence of record does not show, that she is permanently housebound by reason of her service-connected disability. Although she may experience anxiety and panic attacks at times, the Veteran is able to leave her farm to get necessities, run errands, and attend medical appointments. See, e.g., See July 2022 Statement from the Veteran's Husband; July 2022 Statement from the Veteran's Mother; April 2025 Hearing Transcript, p. 8. 3. Entitlement to an effective date earlier than June 10, 2021, for the grant of eligibility for DEA is granted. The Veteran is seeking an effective date earlier than June 10, 2021, for the grant of eligibility for DEA as well. See September 2021 VA Form 10182, NOD; September 2021 Appellant Brief. For purposes of eligibility for DEA benefits under Chapter 35, the child or surviving spouse of a veteran will have basic eligibility if the following conditions are met: (1) the veteran was discharged from service under conditions other than dishonorable, or died in service; and (2) the veteran has a permanent total service-connected disability; or (3) a permanent total service-connected disability was in existence at the date of the veteran's death; or (4) the veteran died as a result of a service-connected disability. 38 U.S.C. § 3510; 38 C.F.R. § 3.807(a). DEA benefits may not be awarded prior to the effective date of a permanent and total service-connected disability rating. As relevant here, the effective date for DEA benefits is directly predicated on the effective date from which VA considered that the Veteran's permanent and total disability commenced for purposes of VA benefits. See 38 C.F.R. § 21.3021(a)(iii), (p), (r). As granted herein, the Board finds September 20, 2019, is the earliest effective date for the Veteran's award of TDIU. Given the Board's decision to grant entitlement to a TDIU from September 20, 2019, entitlement to eligibility for DEA also arose on September 20, 2019. Accordingly, an effective date earlier than June 10, 2021, for the grant of eligibility for DEA is warranted. There is no doubt to resolve. The appeal is granted. 4. Entitlement to a rating greater than 10 percent for right knee arthritis, limitation of flexion, has been withdrawn. The Board may dismiss any appeal which fails to allege specific error of fact or law in the determination being appealed. 38 U.S.C. § 7105. An appeal may be withdrawn as to any or all issues involved in the appeal at any time before the Board promulgates a decision. 38 C.F.R. § 20.205. Withdrawal may be made by the appellant or an authorized representative. 38 C.F.R. § 20.205. In the present case, at the April 2025 Board hearing, the Veteran orally withdrew her appeal seeking entitlement to a rating greater than 10 percent for right knee arthritis, limitation of flexion. See April 2025 Hearing Transcript, p. 2. Of note, the Veteran affirmed that she understood that by withdrawing her claim on the record she would not receive a decision on the merits of this issue, and the issue would be dismissed without the Board reviewing the evidence to determine whether an increased rating is warranted. Id. The Board finds that the Veteran's withdrawal met the requisite criteria for an oral withdrawal, as it was (1) explicit, (2) unambiguous, and (3) done with full understanding of the consequences of such an action. See DeLisio v. Shinseki, 25 Vet. App. 45, 57 (2011); see also Acree v. O'Rourke, 891 F.3d 1009, 1014 (Fed. Cir. 2018) (the Board must address all three prongs of the DeLisio standard when it applies). As the Veteran has withdrawn the appeal seeking entitlement to a rating greater than 10 percent for right knee arthritis, limitation of flexion, there remains no allegation of errors of fact or law for appellate consideration with regard to the issue. Accordingly, the Board does not have jurisdiction to review the appeal and it is dismissed. M. C. WILSON Veterans Law Judge Board of Veterans' Appeals Attorney for the Board C. Neal, Associate 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.