The Court clarified that extraschedular consideration under 38 C.F.R. § 3.321(b)(1) requires analysis of whether the veteran’s symptoms and level of disability are adequately contemplated by the schedular rating criteria. The Court also explained that the Board is required to address the collective impact of multiple service-connected disabilities for extraschedular purposes only when that issue is expressly raised by the claimant or reasonably raised by the record.

The veteran appealed a Board decision denying higher ratings and extraschedular referral for several orthopedic disabilities. One of the principal issues involved the proper scope of extraschedular analysis under 38 C.F.R. § 3.321(b)(1), particularly following the Federal Circuit’s decision in Johnson v. McDonald regarding the combined effects of disabilities.

The Court clarified that extraschedular analysis begins by determining whether the rating criteria reasonably contemplate the veteran’s symptoms and level of disability. If the schedular criteria adequately address the disability picture, extraschedular referral is unnecessary.

The Court further explained that the Board is not automatically required to discuss the collective impact of all service-connected disabilities in every case. Instead, combined-effects extraschedular analysis becomes necessary only when expressly argued by the claimant or reasonably raised by the evidence of record.

The Court also emphasized the Board’s obligation to provide adequate reasons and bases explaining why the schedular criteria adequately contemplate the veteran’s symptoms and functional limitations.

The Federal Circuit held that DC 5201 allows only one rating per affected arm for limitation of shoulder motion, regardless of whether the limitation appears in both flexion and abduction.

Stephen Yonek sought separate disability ratings for his service-connected shoulder impairment under Diagnostic Code 5201, arguing that limitation of motion in flexion and abduction were separately compensable. The Board denied a rating above 20 percent, and the Veterans Court agreed that DC 5201 authorizes only a single rating for limitation of motion of the arm at the shoulder joint. The Federal Circuit affirmed, holding that the text of DC 5201 is unambiguous and refers generally to limitation of motion of the arm, not separate plane-specific limitations. The court reasoned that other portions of the rating schedule expressly use separate diagnostic codes for flexion and extension or for different planes of motion, and the absence of similar separation in DC 5201 indicates that VA did not intend multiple ratings under that code. The court also rejected reliance on Plate I, 38 C.F.R. § 4.25, 38 C.F.R. § 4.45, and the cited General Counsel opinion, explaining that those authorities did not authorize multiple ratings under a single diagnostic code. The decision matters because it confirms that the shoulder rating code itself governs the number of ratings available, and that claimants cannot multiply ratings by parsing the same shoulder limitation into different motion planes.