The Board denied the veteran's claim for SMC under 38 U.S.C.A. § 1114(s) for the period from March 17, 1997 to April 30, 1998 due to lack of additional service-connected disabilities independently ratable at 60 percent and because he was not substantially confined as a result of his service-connected disabilities.
The deciding factor: The veteran did not have additional service-connected disabilities independently rated at 60 percent during the period in question, thus failing to meet the criteria for SMC under § 1114(s).
- Claimed conditions
- rheumatoid arthritis of the cervical spine, total left hip arthroplasty, right hip total arthroplasty, postoperative right wrist condition, rheumatoid arthritis of the left shoulder, rheumatoid arthritis of the right shoulder, rheumatoid arthritis of the left hand, rheumatoid arthritis of the right hand, rheumatoid arthritis of the left wrist
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating
- Not verified here — check the original decision
- Decision date
- October 8, 2004
- Citation
- 0428021
This is a plain-language summary generated by AI from a public Board of Veterans’ Appeals decision. It can contain errors — always verify against the original. Search VA.gov for the original decision (opens in a new tab) using citation 0428021.
What this means for you
A final Board denial may be appealed to the U.S. Court of Appeals for Veterans Claims, generally within 120 days of the Board mailing date. A Supplemental Claim with new and relevant evidence is a separate option. Another Higher-Level Review of the Board decision is not available. Check your own notice: this historical decision does not set your deadline.
What you can do next
Use your own notice and decision stage. A remanded issue is not a final court-appealable denial. VA review guidance and CAVC filing instructions (U.S. federal; reviewed October 7, 2026).
Related decisions
Other Board decisions on a similar condition or argued the same way.
- Whole decision: Remanded (sent back)
The Board remands the claims for service connection for rheumatoid arthritis of various body parts due to in-service exposure to hazardous materials, as an addendum opinion is needed.
- Whole decision: Partly granted
The Veteran's rheumatoid arthritis of the cervical spine was granted a 20 percent rating from December 8, 2021, to October 12, 2022, while other claims for increased ratings were denied.
- Whole decision: Denied
The Board denied the veteran's request to revise the February 2012 rating decision that granted a 30 percent rating for left and right hip total arthroplasty, on the basis of clear and unmistakable error (CUE).
- Whole decision: Dismissed
The Board dismissed the Veteran's appeals for service connection of rheumatoid arthritis of the left shoulder, right shoulder, left hip, and left knee due to his withdrawal of the appeal.
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