13-13 035, 13-13 035

Veteran served on active duty Nov 1974–Nov 1994 and appealed VA RO decisions on skin rash (service-connected since 1994) and bilateral knee disabilities.
Procedural history: initial RO decision Jan 2011; Board remanded Nov 2015 and June 2016 for development; RO granted 10% for skin condition effective Dec 17, 2015; case returned to Board.
Medical evidence: VA exams in Mar 1995, Mar 2010, Dec 17, 2015; addendum opinion July 2016. Pre-2015 records show minimal body-area involvement and mostly topical treatment; Dec 2015 exam documented 5%–<20% body area involvement and systemic corticosteroid use <6 weeks in past 12 months.
Knee evidence: diagnoses of bilateral degenerative arthritis appear in 2009–2015 records; service records (enlistment, periodic, separation exams) are largely normal and lack in-service knee injury or chronic arthritis manifestations.
Veteran contends both knee conditions and worsening skin condition are related to service and seeks compensable ratings/service connection; VA medical opinions concluded no nexus for knees and that skin condition warrants noncompensable rating before 12/17/2015 and 10% thereafter.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to a compensable rating for skin rash prior to Dec 17, 2015	Skin worsened since service; used topical corticosteroids bi‑monthly and had constant symptoms	Medical records do not show systemic therapy or ≥5% body involvement pre‑12/17/2015; exams document ~1% coverage earlier	Denied — noncompensable rating prior to 12/17/2015
Entitlement to a rating >10% for skin rash since Dec 17, 2015	Condition covers more area and required intermittent systemic therapy	Dec 2015 exam documents 5%–<20% body area and systemic corticosteroid use <6 weeks -> 10% meets but not exceeds criteria	Denied — 10% is proper rating since 12/17/2015
Service connection for right knee disability	Knee pain began in service and progressed to degenerative arthritis	Service records lack in‑service injury or chronic manifestations; VA nexus opinion finds less likely than not related to service	Denied — preponderance against service connection
Service connection for left knee disability	Same as right knee	Same as right knee; imaging consistent with age‑related changes; no continuity of symptoms from service	Denied — preponderance against service connection

Stegall v. West, 11 Vet. App. 268 (Board remand compliance standard)
Scott v. McDonald, 789 F.3d 1375 (VA notice requirements)
Shedden v. Principi, 381 F.3d 1163 (elements for service connection)
Jandreau v. Nicholson, 492 F.3d 1372 (lay evidence competency limits)
Walker v. Shinseki, 708 F.3d 1331 (continuity of symptomatology for presumptive service connection)
Gilbert v. Derwinski, 1 Vet. App. 49 (benefit of the doubt rule)
Ortiz v. Principi, 274 F.3d 1361 (application of benefit of the doubt)
Butts v. Brown, 5 Vet. App. 532 (assignment of alternative diagnostic codes)
Bostain v. West, 11 Vet. App. 124 (weight to speculative medical opinions)
McLendon v. Nicholson, 20 Vet. App. 79 (probative value of medical opinions)