X.ii.5.B.2.c. Preparing the Final Rating Decision Narrative in Cases Involving Severance of SC | | A long-form rating decision Narrative is required in final severance decisions. As noted in M21-1, Part X, Subpart ii, 3.D.1.b, if the facts contained in the proposed rating decision were sufficiently discussed and no additional evidence was received, they do not need to be repeated in the final rating decision Narrative.While regulations require that the claimant be notified of the effective dates of entitlement and payment adjustments in running awards, there is no requirement that the rating decision Narrative identify or discuss the effective date for final severance of an SC disability.This guidance differs from the requirements for- proposed rating decisions, and
- final decision notices.
Example: A rating decision proposed to sever SC for migraines based on CUE. The Veteran did not submit any additional evidence, and the due process period expired. In the final rating decision Narrative, the DECISION field reads: Service connection for migraines is severed. Neither the date of the erroneous grant nor the date of the future reduction in payment should be- reflected in the decisional issue, or
- cited/discussed as the effective date of the final severance.
Notes: - If VBMS-R prompts for entry of an effective date when completing a final severance decision, manually delete the effective date from the DECISION field in the ISSUE MANAGEMENT tab.
- When completing a rating decision addressing final severance of SC, the Narrative must address any findings that were favorable to the claimant as detailed in M21-1, Part V, Subpart iv, 1.A.5.f.
- Ensure that the final rating decision discontinues any and all previously established ancillary benefits derived from the Veteran’s entitlement to SC for the erroneously granted disability (provided the Veteran was properly notified in the proposed rating decision). If the proposed rating decision failed to propose the discontinuance, follow the procedures in M21-1, Part X, Subpart ii, 3.D.
References: For more information on- long-form rating narratives, see M21-1, Part V, Subpart iv, 1.A.7
- requirements for proposed rating decisions related to severance, see
- how to handle evidence received within the adverse action proposal period, see
- required elements of a final decision notice, see
- preparing and sending a final rating decision, see M21-1, Part X, Subpart ii, 3.D.1.h, and
- instructions for generating a final severance rating, see the VBMS Rating User Guide.
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