Correia v. McDonald — Joint examinations must include active, passive, weight-bearing, and non-weight-bearing range-of-motion testing whenever possible

The case held that joint examinations should, where possible, include testing for pain on active and passive motion and in weight-bearing and non-weight-bearing positions. In Correia v. McDonald, the Court clarified the examination requirements imposed by the final sentence of 38 C.F.R. § 4.59 in musculoskeletal disability claims involving joints. The veteran sought increased ratings for bilateral knee disabilities, arguing that the VA examinations relied upon by the Board were inadequate because they failed to include all required range-of-motion testing necessary to properly evaluate painful motion and functional impairment.

The Court examined the final sentence of § 4.59, which states that joints should be tested for pain on both active and passive motion, in weight-bearing and nonweight-bearing situations, and, if possible, with comparison to the opposite undamaged joint. The Court held that this testing is required whenever possible in cases involving joint disabilities because the regulation is intended to ensure that adjudicators have sufficient information to properly evaluate painful motion and functional loss.

The Court rejected the Secretary’s argument that the testing language in § 4.59 was merely optional or suggestive. Instead, the Court concluded that adequate VA joint examinations generally must include:

• active range-of-motion testing,
• passive range-of-motion testing,
• weight-bearing testing,
• nonweight-bearing testing,
• and explanation if such testing cannot be performed.

Because the examinations relied upon by the Board failed to include the required testing and did not explain why such testing could not be performed, the Court held that the Board clearly erred in finding the examinations adequate. The Board decision was vacated and remanded for a new examination and readjudication.

Correia became one of the foundational musculoskeletal examination cases in veterans law and remains central to disputes involving painful motion, range-of-motion testing, flare-ups, and functional loss under §§ 4.40, 4.45, and 4.59.

To be adequate, a VA examination involving joint disabilities must, whenever possible, include range-of-motion testing for active motion, passive motion, weight-bearing, and nonweight-bearing conditions as required by the final sentence of 38 C.F.R. § 4.59.

VA musculoskeletal examinations are generally inadequate when they fail to include or explain the absence of active/passive and weight-bearing/nonweight-bearing range-of-motion testing required by § 4.59.

Held that joint examinations should, where possible, include testing for pain on active and passive motion and in weight-bearing and non-weight-bearing positions.

Correia v. McDonald is one of the most important modern VA examination cases involving orthopedic and musculoskeletal disabilities. Prior to Correia, many VA examinations recorded only basic range-of-motion measurements without fully evaluating painful motion and functional impairment under real-world conditions.

The Court clarified that § 4.59 imposes specific testing requirements designed to ensure that adjudicators receive sufficient medical information to properly evaluate painful joints and functional loss. The decision reinforced that musculoskeletal ratings cannot be based solely on incomplete or mechanically recorded range-of-motion numbers.

Correia is especially important in claims involving knees, shoulders, hips, ankles, wrists, elbows, spine conditions, postoperative joint disabilities, degenerative joint disease, instability, and chronic pain syndromes where painful motion and functional limitations fluctuate under different conditions.

The case also strongly reinforces VA’s duty to assist by requiring adequate examinations that meaningfully evaluate functional impairment rather than relying on incomplete or conclusory findings.

The VA often relies on musculoskeletal examinations that provide only basic range-of-motion measurements while failing to perform or document active-motion testing, passive-motion testing, weight-bearing testing, nonweight-bearing testing, or flare-up analysis. Examiners frequently fail to explain why required testing could not be performed, and adjudicators often overlook these deficiencies when denying increased ratings.

A veteran seeks an increased rating for a service-connected knee condition. During the VA examination, the examiner records only a single set of flexion and extension measurements and briefly notes painful motion. The examination report does not indicate whether testing was conducted during active motion versus passive motion or during weight-bearing versus nonweight-bearing conditions.

The VA denies a higher rating based on the examination findings.

Under Correia v. McDonald, the examination may be inadequate because § 4.59 generally requires testing for active motion, passive motion, weight-bearing, and nonweight-bearing conditions whenever possible. Without that information, or an adequate explanation why testing could not be performed, the Board may lack sufficient evidence to properly evaluate functional loss and painful motion.

Correia is one of the most powerful procedural examination cases in orthopedic rating litigation because it creates a clear framework for identifying inadequate joint examinations.

Strategically, the case is highly useful whenever a VA examination:

• records only a single set of range-of-motion measurements,
• fails to specify active versus passive motion,
• omits weight-bearing or nonweight-bearing testing,
• inadequately addresses painful motion,
• fails to discuss flare-ups,
• or lacks explanation for missing testing.

Correia is especially effective in increased-rating claims where VA relies heavily on range-of-motion findings to deny higher evaluations. The case allows veterans, VSOs, and advocates to directly challenge the adequacy of the underlying examination and force VA to obtain a more complete orthopedic evaluation.

Commonly tied to 38 U.S.C. § 1155 and 38 C.F.R. Part 4, including the diagnostic code and functional-loss provisions relevant to the disability.