12-32 696, 12-32 696

Veteran served 1952–1974 and is service‑connected for chronic venous insufficiency (left lower extremity) rated 40% under DC 7121; filed for increased rating in June 2010 and for service connection for right lower extremity lymphedema.
Initial RO denials led to Board appeals, multiple remands, additional development, VA exams (2010, 2016, 2017), private treatment records, and wound care notes documenting edema, hyperpigmentation, and intermittent/healing skin openings.
Key medical findings: persistent edema documented throughout the record; stasis pigmentation and persistent ulceration became clinically apparent by November 19, 2015 (wound clinic notes and later exams/records). No evidence of massive, board‑like edema.
Board found VCAA notice and VA development adequate and that remand development was substantially complied with, but ordered further remand for the separate right‑leg lymphedema service‑connection claim because the April 2017 opinion did not comply with prior remand instructions.
Outcome for increase claim: denied for any rating above 40% before November 19, 2015; granted 60% from November 19, 2015 onward (no schedular 100% or extra‑schedular relief).

Issue	Veteran's Argument	VA/Secretary's Argument	Held
Whether left‑leg chronic venous insufficiency warrants >40% rating before Nov 19, 2015	Left‑leg symptoms (edema, pigmentation, ulcers) warrant higher rating earlier	Medical records do not show stasis pigmentation and persistent ulceration before Nov 19, 2015	Denied: pre‑Nov 19, 2015 rating remains 40% (evidence preponderates against >40%)
Whether left‑leg disease warrants 60% (or higher) from Nov 19, 2015	Worsening lymphedema, documented skin openings/pigmentation support 60% from Nov 2015	VA conceded increased manifestations after Nov 2015 but not massive edema or extra‑schedular criteria	Granted: 60% from Nov 19, 2015; 100% and extra‑schedular relief denied

Stegall v. West, 11 Vet. App. 268 (1998) (remand requires compliance with Board directives)
Mittleider v. West, 11 Vet. App. 181 (1998) (attribution of symptoms to service‑connected condition when not clearly distinguishable)
Gilbert v. Derwinski, 1 Vet. App. 49 (1990) (reasonable doubt rule and benefit of the doubt)
Francisco v. Brown, 7 Vet. App. 55 (1994) (present level of disability is primary concern for increased‑rating claims)
Dingess/Hartman v. Nicholson, 19 Vet. App. 473 (2006) (VCAA notice on rating criteria/effective dates)
Melson v. Derwinski, 1 Vet. App. 334 (1991) (conjunctive criteria must all be met for higher rating)
Middleton v. Shinseki, 727 F.3d 1172 (Fed. Cir. 2013) (conjunctive interpretation of rating criteria)
Thun v. Peake, 22 Vet. App. 111 (2008) (extra‑schedular referral framework)
Johnson v. McDonald, 762 F.3d 1362 (Fed. Cir. 2014) (extra‑schedular consideration for combined effects of multiple conditions)