190805-24440, 190805-24440

Veteran underwent left total knee replacement (TKR) in April 2017; granted temporary 100% from 4/24/2017–6/1/2018, then assigned 30% thereafter.
VA examinations (Jan 2018, Aug 2019, Nov 2019) documented limited ROM (flexion 40–50°, extension 0°), pain on exam, localized tenderness, functional loss, cane use, and examiner findings of "chronic residuals consisting of severe painful motion or weakness."
Veteran reported post‑operative infection, ongoing wound drainage/scabbing, stiffness, swelling, flare‑ups, and substantial functional limitations (difficulty bending, walking, getting in/out of vehicles); testified at Board hearing June 2021 and submitted lay statements.
Procedural history: appeal of October 2019 RO decision continuing 30% rating; Board hearing June 2021; Board decision issued September 29, 2021.
Diagnostic Code (DC) 5055 governs knee replacement ratings; 60% is assigned for chronic residuals consisting of severe painful motion or weakness; 30% is the minimum rating.
The Board granted an increased rating to 60% for left knee s/p TKR based on the examiners’ specific conclusions that the residuals constituted severe painful motion or weakness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to rating in excess of 30% for left knee, status post TKR (DC 5055)	Veteran: post‑op infection, persistent limited ROM, pain, functional loss, and flare‑ups warrant >30% (seek 60%)	RO initially continued 30% because it found criteria for higher rating not met	Board granted 60% based on multiple VA examiners explicitly finding chronic residuals of severe painful motion or weakness

Peyton v. Derwinski, 1 Vet. App. 282 (1991) (Board must consider the veteran's medical history when evaluating disability severity)
Powell v. West, 13 Vet. App. 31 (1999) (past medical reports must be considered when determining whether a higher rating is warranted for the period on appeal)