Veteranclaims’s Blog

September 9, 2020

Single Judge; In Miller, the Court held that “[w]hen the Board has made its decision without finding that the veteran is not competent to report symptoms and nothing suggests that the Board failed to review the evidence at issue, we may reasonably conclude that it implicitly found the veteran credible.” Miller v. Wilkie, 32 Vet. App. at 261, 249 (2020). Miller further held that when a VA medical examiner fails to address the veteran’s statements about medical history, and the Board does not address the credibility of those statements but does not find the veteran not credible or not competent to offer that lay evidence, “the proper remedy is to order a new examination.” Id. at 262;

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Designated for electronic publication only
UNITED STATES COURT OF APPEALS FOR VETERANS CLAIMS
No. 18-2496
IKE D. COMPTON, APPELLANT,
V.
ROBERT L. WILKIE,
SECRETARY OF VETERANS AFFAIRS, APPELLEE.
Before PIETSCH, Judge.
MEMORANDUM DECISION
Note: Pursuant to U.S. Vet. App. R. 30(a), this action may not be cited as precedent.
PIETSCH, Judge: The appellant, Ike D. Compton, through counsel, appeals a
February 22, 2018, Board of Veteran’s Appeals (Board) decision denying service connection for
right ear hearing loss. Record of Proceedings (R.) at 2-14. The appellant argued in his initial brief that (1) the May 2016 and August 2017 medical opinions are inadequate and the Board failed to fulfill its duty to assist the appellant when it relied on these reports; and (2) the Board erred in failing to provide an adequate statement of reasons or bases explaining why it rejected the appellant’s competent and credible statements about continuity of symptomatology for his right ear hearing loss. The Secretary disputed the appellant’s arguments. On January 23, 2020, the Court
issued a single-judge memorandum decision remanding the Board decision for readjudication.
On February 11, 2020, the appellant filed a motion for partial reconsideration, requesting
that the Court reconsider its remedy in light of Miller v. Wilkie, 32 Vet.App. 249 (2020), which
was issued a week before the memorandum decision. The motion for partial reconsideration is
hereby granted, and the January 23, 2020, memorandum decision is hereby withdrawn, and this
decision is issued in its stead. Single-judge disposition is appropriate. See Frankel v. Derwinski,
1 Vet.App. 23, 25-26 (1990).
2
I. BACKGROUND
The appellant served on active duty in the U.S. Army from February 1971 to November
1973, and from January 1974 to October 1978. R. at 2949-50. Service treatment records reflect
that at a June 1970 enlistment examination, his right ear puretone thresholds, in decibels, at 500,
1000, 2000, and 4000 Hertz were shown to be 0, 0, 20, and 0, respectively. R. at 3011. At an
October 1973 separation examination, the appellant’s right ear puretone thresholds in decibels were
shown to be 20 at 500 Hertz, 10 at 1000 Hertz, 20 at 2000 Hertz, and 20 at 4000 Hertz. R. at 3007.
During his second period of service, at the January 1976 periodic examination, the
appellant’s right ear puretone thresholds in decibels at 500, 1000, 2000, 3000, and 4000 Hertz,
were shown to be 30, 25, 25, 20, and 20 respectively. R. at 3005. On an authorized July1978
audiological evaluation, puretone thresholds, in decibels, were shown to be 0 at 500 Hertz, 0 at
1000 Hertz, 15 at 2000 Hertz, 15 at 3000 Hertz, and 15 at 4000 Hertz. R. at 2923. At the August
1978 audiological evaluation conducted at the appellant’s separation examination, the right ear
hearing puretone thresholds, in decibels, were shown to be 25 at 500 Hertz, 15 at 1000 Hertz, 10
at 2000 Hertz, and 25 at 4000 Hertz. R. at 3001. Audiological testing conducted 8 days later
revealed puretone thresholds in decibels at 500, 1000, 2000 and 4000 Hertz to be 10, 5, 15 and 15.
R. at 3052.
In July 2008, the appellant filed an informal claim for service connection for hearing loss.
R. at 2809.
During a VA audiological examination in November 2008, he reported having experienced
bilateral hearing loss since his military service, as well as difficulty hearing others at a distance.
R. at 2793-94. The appellant also reported that while he served in Vietnam he experienced
significant noise exposure from gunfire and helicopters. R. at 2793. The VA audiologist observed
that for 30 years while the appellant did electrical work around motors, power plants, and
construction sites, his exposure to noise was significant. Id. The appellant denied any significant
recreational noise exposure. Id. After undergoing audiometric testing, the appellant was
diagnosed with normal hearing from 250 to 1000 Hertz, and “sloping to a mild to moderate severe
[sensorineural hearing loss]” of the right ear. R. at 2794. According to the examiner, there was
no change in the appellant’s hearing from the time of his entrance into the military in 1970 and his
separation from service in 1978. Id. Thus, “it is not likely that military noise exposure contributed
to or cause[d] his bilateral hearing loss. Id.
3
In a September 2009 rating decision, the regional office (RO) denied service connection
for the appellant’s hearing loss. R. 2763-64. The appellant filed a Notice of Disagreement (NOD)
with this decision in October 2009, R. at 2743-46, and perfected his appeal in August 2011. R.
at 2496.
The appellant continued to report a history of hearing loss and in-service noise exposure.
At a January 2015 private treatment visit, the appellant reported a history of in-service noise
exposure, as well as a long history of progressive hearing loss. R. at 630-35. After interviewing
the appellant, and conducting an audiological evaluation, the treatment provider diagnosed
moderate bilateral sensorineural hearing loss. R. at 632. During a video conference hearing at the
Board in September 2015, the appellant testified that his hearing loss began in service, while he
was serving in Vietnam, as a result of his exposure to loud noises from small arms gunfire, mortar
rounds, and aviation equipment. R. at 1210, 1207-24. According to the appellant, he experienced
some type of hearing problem throughout his entire military career. R. at 1212. He also testified
that for several years after returning from service in Vietnam, before the nature of his hearing loss
was determined, he had difficulty hearing. Id. The appellant also testified that his hearing loss
could be linked to several ear infections that he experienced in service. R. at 1215.
In April 2016, the Board remanded the claim for additional development, and specifically,
to schedule the appellant for an audiological examination to determine the nature and etiology of
his hearing loss, otitis media, and tinnitus. R. at 1186-1206. The Board instructed VA to schedule
the appellant for an examination to determine the nature and etiology of his hearing loss, and
particularly, the likelihood that his hearing loss had its onset in service or was otherwise caused
by or related to his service, including his exposure to gunfire and loud noise from aircraft. R. at
1199-1200.
Pursuant to this remand, the appellant was afforded a new VA audiological examination in
May 2016. R. at 960-65. The VA audiologist diagnosed the appellant with sensorineural hearing
loss in the right ear, and determined that this disorder was not caused by, or a result of, an event
that occurred during his military service. R. at 962-63. In the remarks section of the examination
report, the audiologist determined that the appellant’s “current sensor-ineural hearing loss is not
. . . related to noise exposure in the form of gun fire and loud aircrafts or any other form of military
noise as he did not exhibit such hearing loss at separation.” R. at 964. Similar to the November
2008 examiner, the May 2016 examiner found “no evidence of sensorineural hearing loss for this
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[appellant] at separation in 1978,” and “[i]t is less likely as not that the [appellant’s] hearing loss
had its onset during service, or was otherwise caused by any incident that occurred during service.”
Id. The examiner also noted that the appellant had worked “around motors and power plants in
construction” for 30 years after service, which more likely worsened his hearing after service. Id.
In May 2017, the Board remanded the appellant’s claim once again for additional
development. R. at 844-60. Specifically, the Board instructed VA to obtain from the May 2016
VA examiner an addendum opinion, or if the May 2016 VA examiner was unavailable, to obtain
from another medical professional an opinion addressing the likelihood that the appellant’s
bilateral hearing loss is related to his military noise exposure, “to include the threshold shifts seen
among the June 1970 enlistment audiogram, October 1973 separation audiogram, January 1976
audiogram, July 1978 audiogram, August 17, 1978 audiogram, and August 25, 1978 separation
audiogram.” R. at 858. The Board also instructed the VA examiner to (1) note the appellant’s
periods of active duty; (2) explain the significance and severity of any threshold shift as it pertains
to hearing damage caused by noise exposure, or the significance of the absence of any threshold
shift; and (3) explain the significance of normal hearing in regard to the likelihood that military
noise exposure caused permanent hearing damage, including addressing theories of delayed or
latent onset of hearing loss. Id.
In the August 2017 addendum opinion, a VA audiologist who was not the author of the
May 2016 opinion determined that the appellant’s right ear hearing loss was less likely as not
caused by or a result of an event in service, noting the appellant’s in-service records and the
audiometric findings reflected in these reports. R. at 342, 331-38. The VA audiologist explained
that the appellant’s “hearing fluctuated while in the service” and that comparing his enlistment
examination results to those of his final separation examination revealed “no significant permanent
positive threshold shifts in the right ear.” Id. The VA audiologist further found the fluctuations in
the appellant’s hearing uncharacteristic of permanent damage caused by exposure to military noise
because “fluctuations are typically due to a medical condition or a temporary shift right after
significant noise exposure.” Id. The VA audiologist also referenced medical literature, an article
by Kujawa and Liberman about the effect of noise exposure in rodents, suggesting the possibility
of “neural changes related to noise exposure even when threshold shifts have resolved.” Id.
According to the VA audiologist, “the gold standard for determination of auditory damage is
permanent, positive threshold shifts.” R. at 434. The VA audiologist determined that “[a]s a result
5
of the questionable generalizability of rodent studies to humans . . . there is no conclusive data
supporting the universal occurrence of ‘delayed onset’ in human beings exposed to noise who
otherwise have normal auditory acuity with no significant permanent, positive threshold shifts
following acoustic incidents.” Id. According to the VA audiologist, “[i]f we start basing our
opinions on delayed onset theory then every [v]eteran should be awarded service connection for
hearing loss.” Id. The VA audiologist concluded that “[t]here has not been any objective evidence
of a conductive hearing loss in the right ear in the service or outside of the service.” Id.
In a November 2017 rating decision, the RO granted service connection for left ear hearing
loss and evaluated it as 0% disabling. R. at 283-87. In a November 2017 Supplemental Statement
of the Case, the RO continued to deny service connection for right ear hearing loss. R. at 288-302.
In its February 2018 decision, the Board denied service connection for right ear hearing loss, on
the basis that the appellant did not exhibit right ear hearing loss in service or within 1 year after
his discharge from service, and that right ear hearing loss was not otherwise shown to be associated
with his active service. R. at 2-14.
II. ANALYSIS
A. Inadequate Medical Examinations
The appellant contends that the May 2016 and August 2017 medical opinions are
inadequate and the Board failed to fulfill its duty to assist the appellant when it relied on these opinions. Appellant’s Brief (Br.) at 12. Specifically, the appellant maintains that although the May 2016 audiologist related the appellant’s hearing loss primarily to his postservice occupational noise exposure, and the August 2017 audiologist found no “objective evidence” of hearing loss in or out of service, “neither opinion addressed [a]ppellant’s competent reports of continuous postservice right ear hearing loss symptoms or explained why those competent reports were not persuasive or sufficient to support a finding of service connection.” Id. at 13. The appellant also contends that “neither opinion meaningfully addressed [a]ppellant’s report of several years having elapsed before identifying the nature of his hearing loss, nor of his having been told that both ears
were affected by moisture getting in or behind the eardrum or that ‘it just looked like marbles in both my eyes.'” Id. at 14. In addition, the appellant contends that the August 2017 VA audiologist failed “to support her rejection of the validity of a delayed onset theory of hearing loss with a reasoned medical explanation other than her bare disagreement.” Id. According to the appellant,
6
“[t]his sweeping, generalized rejection of the idea of the onset of hearing loss being delayed is
wholly unsupported by the facts of [a]ppellant’s case and suggests a conclusory antagonism toward a delayed onset theory.” Id. at 15. The appellant further asserts that “as neither the May 2016 nor the August 2017 VA opinion[] fully address[es] [a]ppellant’s competent lay reports of having experience[ed] hearing loss symptoms from the time of his separation from service, the Board clearly erred by relying on them, and without obtaining an opinion which discussed those reports it failed to satisfy its duty to assist.” Id.
The Secretary maintains that these arguments are unpersuasive because no reasons or bases
requirement applies to a medical examiner. Secretary’s Brief. At 7. According to the Secretary,
although the May 2016 VA examiner did not mention the appellant’s lay statements, she did review
the claims file, “which included [a]ppellant’s lay statements,” and she personally examined the
appellant. Id. The Secretary further states that after reviewing the claims file, to include the
appellant’s in-service audiometric findings, the examiner determined that the appellant’s current
hearing loss began after his separation from service and was not related to his in-service noise
exposure. Id. at 7-8. According to the Secretary, this finding reflects no hearing loss at the time
of the appellant’s separation from service, and thus, “no bases for consideration of continuity of
symptoms.” Id. at 8. The Secretary further contends that the August 2017 examination report
considered the appellant’s lay statements and noted that “the entire appointment time was spent
listening to [a]ppellant’s concerns regarding his hearing loss.” Id. Thus, based on the Secretary’s
assertions, the examiner was aware of the appellant’s lay statements, and “[w]hen read as a whole,
it is clear . . . that the examiner considered [a]ppellant’s lay assertions.” Id. at 8-9. With respect
to the appellant’s allegations that the 2017 opinion is “a sweeping, generalized rejection of the idea
of the onset of hearing loss being delayed,” the Secretary finds this assertion without merit and
points to other sections of the August 2017 opinion in which the examiner asserted that “the gold
standard for determining auditory damage is permanent, positive threshold shifts” and that “the
fluctuations in [a]ppellant’s right ear are not characteristic of permanent damage caused by
exposure to military noise.” Id. at 10.
When the Secretary undertakes to provide a veteran with a VA medical examination or
opinion, he must ensure that that examination or opinion is adequate. Barr v. Nicholson,
21 Vet.App. 303, 311 (2007). A VA medical examination or opinion is adequate “where it is based
upon consideration of the veteran’s prior medical history and examinations,” Stefl v. Nicholson,
7
21 Vet.App. 120, 123 (2007), “describes the disability … in sufficient detail so that the Board’s
‘evaluation of the claimed disability will be a fully informed one,'” id. (internal quotation marks
omitted) (quoting Ardison v. Brown, 6 Vet.App. 405, 407 (1994)), and “sufficiently inform[s] the
Board of a medical expert’s judgment on a medical question and the essential rationale for that
opinion,” Monzingo v. Shinseki, 26 Vet.App. 97, 105 (2012) (per curiam); see also Acevedo v.
Shinseki, 25 Vet.App. 286, 293 (2012) (“[A]n adequate medical report must rest on correct facts
and reasoned medical judgment so as [to] inform the Board on a medical question and facilitate
the Board’s consideration and weighing of the report against any contrary reports.”);
Nieves-Rodriguez v. Peake, 22 Vet.App. 295, 301 (2008) (“[A] medical examination report must
contain not only clear conclusions with supporting data, but also a reasoned medical explanation
connecting the two.”).
The Court reviews the Board’s determination regarding the adequacy of a medical
examination or opinion under the “clearly erroneous” standard of review set forth in 38 U.S.C.
§ 7261(a)(4). See D’Aries v. Peake, 22 Vet.App. 97, 104 (2008). “A factual finding ‘is “clearly
erroneous” when although there is evidence to support it, the reviewing court on the entire evidence
is left with the definite and firm conviction that a mistake has been committed.'” Hersey v.
Derwinski, 2 Vet.App. 91, 94 (1992) (quoting United States v. U.S. Gypsum Co., 333 U.S. 364,
395 (1948)).
In concluding that it is less likely as not that the appellant’s hearing loss had its onset during
service or was otherwise caused by an in-service incident, R. at 8-9, 963, the May 2016 VA
audiologist primarily relied on the service treatment records, noting the June 1970 examination,
which revealed the appellant’s hearing at enlistment to be within normal limits. Id. According to
the May 2016 examiner, although the August 17, 1978, separation examination appeared to reveal
a shift at 500 Hertz in the right ear, results obtained 8 days later, on August 25, 1978, “indicated
no significant shift of the right ear from enlistment to separation,” id.
And in concluding that the appellant’s right ear hearing loss is not related to his military
noise exposure, R. at 9, 342, the August 2017 VA audiologist considered the appellant’s service
treatment records, as well as the fact that he had served in combat aviation flight control from 1970
to 1978, id. The VA audiologist determined that, although the appellant’s right ear hearing loss
had fluctuated in service, “when comparing [his] enlistment hearing acuity to that documented in
the final separation examination report, there were no significant permanent threshold shifts in the
8
right ear.” Id. The VA audiologist also summarized the study by Kujawa and Liberman, which
focused on the effect of noise exposure in rodents and addressed the possibility of “neural changes
related to noise exposure even when threshold shifts have resolved.” Id.
In the February 2018 decision, the Board noted that the August 2017 VA audiologist had
reviewed these medical studies and found that they “suggest that noise-induced damage to the ear
has progressive consequences that are considerably more widespread than are revealed by
conventional threshold testing.” Id. at 10-11, 343. But the Board noted that the VA audiologist had
discounted the significance of these studies because of “the questionable generalizability of rodent
studies to humans” and ultimately found “no conclusive data supporting the universal occurrence
of ‘delayed onset’ hearing loss in human beings exposed to noise who otherwise have normal
auditory acuity with no significant permanent, positive threshold shifts following acoustic
incidents.” Id. at 11.
The Court agrees with the appellant that the May 2016 and August 2017 VA medical
opinions are inadequate and that the Board erred in relying on these opinions. In this case, both
examiners failed to consider the appellant’s lay statements and hearing testimony of ongoing
postservice hearing problems.1 Though the Secretary argues that both VA audiologists considered
the appellant’s lay statements, either through reviewing the claims file or interviewing the
appellant, Secretary’s Br. at 7-8, there is a difference between acknowledging lay statements within
the record and considering them when issuing an opinion. In this case, there is no indication that
either VA audiologist considered the import of the appellant’s hearing testimony about the ongoing
symptomatology he experienced after he separated from service.
A medical opinion is adequate when it is based on consideration of the veteran’s medical
history and examinations and it describes the disability in sufficient detail so that the Board’s
“‘evaluation of the claimed disability will be a fully informed one.'” Ardison, 6 Vet.App. at 407
(1994) (quoting Green v. Derwinski, 1 Vet.App. 121, 124 (1991)). In addition, service-connection
claims are to be decided based on “all pertinent medical and lay evidence.” 38 U.S.C. § 1154(a).
Here, the VA examiners’ failure to consider the appellant’s testimony of continual symptomatology
1 At the September 2015 hearing, the appellant testified that he first noticed his hearing loss when he
developed an ear infection while serving in Vietnam. R. at 1210-11. He also testified that he experienced some type
of hearing loss, or hearing problem, throughout his military career. R. at 1212. In addition, the appellant testified that
when he returned from Vietnam, it seemed as though he had difficulty hearing for several years before medical experts
identified his condition. Id.
9
postservice renders these opinions inadequate. See Barr v. Nicholson, 21 Vet.App. 303, 310-11
(2007) (finding that a medical examination that ignores lay assertions regarding continued
symptomatology is inadequate because it fails to take into account the veteran’s medical history);
Dalton v. Nicholson, 21 Vet.App. 23, 39 (2007) (finding a medical examination inadequate where
the examiner “impermissibly ignored the appellant’s lay assertions that he sustained a back injury
during service”). Because the VA examiners did not consider relevant evidence in formulating
their opinions, the Court holds that the Board erred in relying on their May 2016 and August 2017
opinions when denying the appellant’s claim for right ear hearing loss.
B. Credibility Determination
The appellant contends that the Board erred in failing to provide an adequate statement of
reasons or bases for rejecting his competent and credible statements attesting to continuity of
symptomatology for his right ear hearing loss. Appellant’s Br. at 18. According to the appellant,
the Board did not provide adequate reasons or bases when it determined that “‘[t]here is no medical
or credible persuasive lay evidence’ indicating [a]ppellant’s right ear hearing loss had manifested
during or within a year of his discharge from service” and when it “found that the evidence
preponderated against a finding of service connection either on a presumptive basis or on the basis
of continuity of symptomatology.” Id. at 19-20. The appellant maintains that “[w]ithout
articulating an adequate finding on the subject of [a]ppellant’s competent and credible reports of
right ear hearing loss symptoms continuing since his separation from service” the Board’s
determination “that no credible persuasive lay evidence indicates that hearing loss was present
following his service is entirely conclusory and frustrates judicial review.” Id. at 20. In response,
the Secretary acknowledges that though it is undisputed that the appellant had noise exposure and
suffered hearing fluctuations in service, the evidence showed only a temporary shift, and therefore
no continuity of symptoms or indication of permanent hearing loss appeared until years after his
military service. Secretary’s Br. at 14-15.
In his motion for partial reconsideration, the appellant asserts that “in conditioning the
receipt of a new VA medical opinion on a favorable Board credibility determination,” the Court,
in the January 23, 2020, memorandum decision, failed to consider Miller v. Wilkie, 32 Vet.App.
249 (2020). See Appellant’s Motion for Partial Reconsideration at 2 (Appellant’s Motion). In Miller, the Court held that “[w]hen the Board has made its decision without finding that the veteran is not competent to report symptoms and nothing suggests that the Board failed to review the
10
evidence at issue, we may reasonably conclude that it implicitly found the veteran credible.” Miller v. Wilkie, 32 Vet. App. at 261, 249 (2020). Miller further held that when a VA medical examiner fails to address the veteran’s statements about medical history, and the Board does not address the credibility of those statements but does not find the veteran not credible or not competent to offer that lay evidence, “the proper remedy is to order a new examination.” Id. at 262.

In the February 2018 decision, the Board acknowledged the appellant’s contention that his
right ear hearing loss is related to his service-related acoustic trauma, finding it “within the realm
of common medical knowledge that exposure to loud noises may cause hearing loss.” R. at 13.
The Board also found that the appellant’s lay opinion “could possibly be sufficient to serve as the
required nexus for his claim” but that the evidence reflects “a gap in time between the [appellant’s]
exposure to loud noises in service and the initial manifestation of his . . . hearing loss . . . and there
is extensive post-service noise exposure.” Id. According to the Board, in these circumstances
“other potential causes of his sensorineural hearing loss must be considered.” Id. The Court finds
that as in Miller, the Board discussed certain statements from the appellant in a way that would
not make sense if it had considered those statements incredible. Thus, Miller is pertinent to this
case and in applying Miller, the Court finds that the Board clearly erred in determining that the
duty to assist was met. The Court will properly remedy this error by ordering VA to obtain a new
examination, and the Board need not address the appellant’s credibility.
Remand thus is warranted for the Board to order a new examination or explain why a new
examination is not needed. See Tucker v. West, 11 Vet.App. 369, 374 (1998) (remand is appropriate
“where the Board has incorrectly applied the law, failed to provide an adequate statement of
reasons or bases for its determinations, or where the record is otherwise inadequate”). The Board
must also provide an adequate statement of reasons or bases that explains its reasons for
discounting favorable evidence, Thompson v. Gober, 14 Vet.App. 187, 188 (2000); discuss all
issues raised by the claimant or the evidence of record, Robinson v. Peake, 21 Vet.App. 545, 552
(2008), aff’d sub nom. Robinson v. Shinseki, 557 F.3d 1335 (Fed. Cir. 2009); and discuss all
provisions of law and regulation where they are made “potentially applicable through the
assertions and issues raised in the record,” Schafrath v. Derwinski, 1 Vet.App. 589, 592 (1991).
Given this disposition, the Court need not, at this time, address the other arguments and
issues raised by the appellant. See Best v. Principi, 15 Vet.App. 18, 20 (2001) (per curiam order)
(holding that “[a] narrow decision preserves for the appellant an opportunity to argue those claimed
11
errors before the Board at the readjudication, and, of course, before this Court in an appeal, should
the Board rule against him[or her]”). The appellant is free on remand to submit additional evidence
and argument, including the arguments raised in his briefs to this Court, in accordance with
Kutscherousky v. West, 12 Vet.App. 369, 372-73 (1999) (per curiam order), and the Board must
consider any such evidence or argument submitted. See Kay v. Principi, 16 Vet.App. 529, 534
(2002). The Court reminds the Board that “[a] remand is meant to entail a critical examination of
the justification for [the Board’s] decision,” Fletcher v. Derwinski, 1 Vet.App. 394, 397 (1991),
and must be performed in an expeditious manner in accordance with 38 U.S.C. § 7112.
III. CONCLUSION
After consideration of the appellant’s and the Secretary’s briefs and a review of the record,
the Board’s February 22, 2018, decision is VACATED and the matter is REMANDED for further
proceedings consistent with this decision.
DATED: September 8, 2020
Copies to:
Glenn R. Bergmann, Esq.
VA General Counsel (027)

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