The Board remands the issues of entitlement to a disability rating in excess of 20 percent for right shoulder instability, limitation of motion associated with right shoulder glenohumeral arthrosis, and TDIU prior to July 11, 2013, due to insufficient evidence regarding range of motion measurements and other factors.
The deciding factor: The remand is necessary because the VA examination did not comply with the Board's directives in Correia v. McDonald, specifically regarding joint testing for pain on both active and passive motion, in weight-bearing and non-weight-bearing conditions.
- Claimed conditions
- right shoulder instability, limitation of motion associated with right shoulder glenohumeral arthrosis, headaches
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- May 29, 2025
- Citation
- 25007298
What this means for you
A remand is not a loss. The Board sent the case back for more development — often a new exam or missing records — before making a final decision. Many remands later end in a grant, and the decision spells out exactly what the Board wanted to see.
What you can do next
Related decisions
Other Board decisions on a similar condition or argued the same way.
- Partly granted
The Board granted service connection for headaches and increased ratings for left shoulder rotator cuff tear, right shoulder rotator cuff tear, hypertension, and left and right leg restless leg syndrome. The Board denied a compensable rating for bilateral hearing loss and an initial rating in excess of 70 percent for posttraumatic stress disorder.
- Remanded (sent back)
The Board remands the claim for an increased initial disability evaluation of headaches due to an inadequate VA examination.
- Granted
The Board granted service connection for multiple disabilities, including cervical spine and thoracolumbar spine disabilities, radiculopathies, a bladder disability, headaches, a left knee disability, an acquired psychiatric disorder, and bilateral conjunctivitis. The Board also granted entitlement to a total disability rating based on individual unemployability due to service-connected disability.
- Dismissed
The appeals for restoration of ratings and for a higher disability rating were dismissed as the April 2025 rating decision did not make final decisions on these issues.
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