The Court held that the veteran submitted new and material evidence to reopen a claim for secondary service connection, and it vacated and remanded because the Board failed to properly consider the reopened claim, including aggravation and benefit-of-the-doubt analysis.

The veteran sought to reopen a previously denied claim for service connection for left knee arthritis as secondary to a service-connected left foot deformity. The record contained multiple medical statements suggesting a relationship between the foot disorder and the knee arthritis, including opinions that the knee condition was due to abnormal gait or had been accelerated by the foot disability. The Board denied reopening, reasoning that the evidence did not establish a new factual basis for service connection and suggesting the arthritis was due to aging.

The Court held that the post-1986 submissions were new and material under 38 C.F.R. § 3.156 and Colvin because they were not cumulative and raised a reasonable possibility of changing the outcome. The Court further held that the Board failed to reopen and fully review the claim as required by Manio, and it did not provide adequate reasons or bases for rejecting favorable medical evidence. The Court emphasized that the Board may not rely on its own medical judgment, must consider whether secondary service connection is warranted under 38 C.F.R. § 3.310(a), including possible aggravation, and must address the benefit-of-the-doubt doctrine and sworn testimony when material. The Board decision was vacated and the case remanded for readjudication.

The Court held that the Board erred by failing to ensure that VA obtained a medical examination addressing whether the veteran’s additional disability may have resulted from VA medical treatment under 38 U.S.C. § 1151. The decision clarified that the low threshold requiring a VA medical examination under McLendon also applies in § 1151 claims when the record reasonably indicates a potential relationship between VA treatment and additional disability.

The case held that VA must consider all applicable theories under special statutes such as 38 U.S.C. § 1151 when the record reasonably raises them and must develop the claim accordingly. In Trafter v. Shinseki, the Court addressed VA’s duty to provide medical examinations and opinions in claims brought under 38 U.S.C. § 1151 involving alleged negligent VA medical treatment.

The veteran sought compensation under § 1151 based on allegations that:

• VA failed to timely diagnose and treat recurrent breast cancer,
• and VA improperly diagnosed him with bipolar disorder,

resulting in additional psychiatric disability.

The Board denied the claim without obtaining a VA medical opinion, reasoning that:

• the record lacked competent medical evidence showing negligence or fault by VA,
• and the veteran’s lay statements alone were insufficient to warrant an examination.

The Court rejected that analysis and held that the Board misinterpreted the duty-to-assist standard under 38 U.S.C. § 5103A(d).

The Court emphasized that:

• the threshold for obtaining a medical opinion is intentionally low,
• VA cannot require proof of negligence before providing an examination,
• and evidence need only indicate that a disability “may be associated” with VA treatment.

The Court further explained that:

• the Board improperly treated the absence of evidence as substantive negative evidence,
• improperly engaged in its own medical analysis,
• and failed to recognize that causation questions required medical expertise.

The Court also found that VA failed to adequately assist the veteran in obtaining potentially relevant private medical records related to cancer treatment.

The Board decision was vacated and remanded for further development and readjudication.

The Court reversed a Board denial of service connection for multiple sclerosis, holding the record compelled a finding that the disease manifested to a compensable degree within the seven-year presumptive period. The case is significant for rejecting unsupported Board medical conclusions, limiting use of extra-record medical treatises, and showing when reversal—not remand—is appropriate.

Edgar Traut appealed a Board decision denying service connection for multiple sclerosis. The Court reviewed a record showing in-service hospitalization for weakness, dizziness, visual difficulty, and pain; post-service medical observations dating back to 1957 and 1961; and later medical opinions from Drs. Neils and Larson that the disease was present during the seven-year presumptive period for multiple sclerosis. The Board had concluded that there was no evidence of multiple sclerosis until at least 1966 and relied in part on medical treatises and its own medical judgment to reject favorable evidence. The Court held that the Board’s factual conclusion lacked a plausible basis in the record, that the Board improperly substituted its own medical judgment for competent medical evidence, and that any reliance on extra-record treatises without notice would also be error under Thurber. Because the only plausible conclusion from the competent evidence was that multiple sclerosis manifested within the presumptive period to a compensable degree, the Court reversed rather than remanded and ordered assignment of an appropriate rating.

The Court vacated and remanded because the Board gave inadequate reasons or bases for rejecting new and material evidence, failed to assess the credibility and probative value of lay evidence, and failed to address direct service connection and related presumptive theories reasonably raised by the record.

The veteran sought service connection for schizophrenia after a prior final Board denial. The Court first held that the veteran had submitted new and material evidence sufficient to reopen the claim, but found that the Board failed to explain why the evidence did not alter the basis of the 1975 denial. The Court emphasized that the Board must provide adequate reasons or bases and must evaluate the credibility and probative value of the veteran’s statements that psychiatric treatment began in service.

The Court also held that the Board failed to address direct service connection, even though the record raised that theory, and noted that service connection could be established either presumptively or through direct evidence under 38 C.F.R. § 3.303(d). The opinion further directed the Board to consider the applicability of 38 U.S.C. § 1154(b) and the benefit-of-the-doubt rule on remand. The practical effect is a remand requiring a fuller analysis of evidence and all reasonably raised service-connection theories.

The Court reversed the reduction from 50% to 30% because VA relied on an inadequate examination and substituted its own medical judgment for independent medical evidence. The case underscores that rating reductions must be based on adequate examinations and proper medical evidence, especially when the record is incomplete.

Harold Tucker appealed a Board decision that upheld a reduction in his service-connected bipolar disorder rating. The Court explained that it lacked jurisdiction over two earlier reductions because the notices of disagreement predated November 18, 1988, but it did have jurisdiction over the later reduction from 50% to 30%. For that reduction, the Court found that the rating board relied on an April 1989 psychiatric examination that apparently had not been conducted with review of the claims file. Rather than return the report for correction or seek an adequate examination, VA substituted its own judgment for that of a medical professional. The Court held that this was improper under the requirement that disabilities be viewed in relation to their history and that inadequate reports be returned for evaluation purposes. Citing Colvin, the Court also reiterated that VA adjudicators may not rely on their own medical judgment in place of independent medical evidence. Because the Board’s finding that the bipolar disorder produced no more than definite impairment was not plausible on the record, the Court reversed the 30% reduction and remanded with directions to restore the 50% rating effective October 1, 1989.

The Court vacated a Board decision denying an earlier effective date for Special Monthly Compensation (SMC) based on loss of use of the lower extremities because the Board applied the wrong legal standard, failed to adequately analyze functional loss and pain, and provided inadequate reasons or bases. The Court clarified that the proper inquiry is whether effective function remains beyond that which would be equally well served by amputation with suitable prosthetics—not whether amputation is medically warranted.

Tucker v. West involved a combat veteran who suffered catastrophic lower-extremity injuries after stepping on an explosive device in Vietnam. The veteran later sought an earlier effective date for Special Monthly Compensation (SMC) based on loss of use of both feet. Although VA ultimately granted SMC effective October 24, 1990, the veteran argued that the evidence demonstrated entitlement years earlier.

The record contained substantial evidence of severe lower-extremity impairment long before 1990. A 1980 VA examination documented that the veteran required crutches for ambulation, could not balance without them, experienced significant pain in both feet, and bore most of his weight through his upper extremities and shoulders because of pain and limited function in the feet and ankles. The examination also documented sensory deficits, limited motion, weakness, and inability to effectively bear weight.

Despite this evidence, the Board denied an earlier effective date, reasoning in part that the veteran’s condition did “not warrant amputation.” The Court held that the Board applied the wrong legal standard. Under 38 C.F.R. §§ 3.350(a)(2) and 4.63, the proper inquiry is not whether amputation is medically necessary, but whether the veteran retains effective function beyond that which would be equally well served by an amputation stump with suitable prosthetic appliance.

The Court further held that the Board failed to adequately consider functional loss and pain under 38 C.F.R. § 4.40. The Board focused heavily on the veteran’s limited ability to ambulate while failing to explain how pain, weakness, balance impairment, and inability to bear weight affected the loss-of-use analysis. The Court emphasized that pain and functional impairment are central considerations in musculoskeletal evaluations and must be meaningfully analyzed.

Additionally, the Court found that the Board provided inadequate reasons or bases and improperly relied on its own medical speculation in violation of Colvin v. Derwinski. The Board asserted that the veteran’s balance and propulsion had improved without citing independent supporting medical evidence. The Court held that the Board cannot substitute its own medical judgment for competent medical evidence.

The Court vacated and remanded the matter for readjudication under the correct legal standards and with adequate reasons or bases. Tucker became an important SMC and functional-loss precedent clarifying the legal standard governing loss of use and reinforcing the importance of pain and actual functional impairment in VA adjudications.

The Court affirmed the Board’s denial of DIC because the Board had a plausible factual basis for finding that the veteran’s service-connected polio residuals did not cause or materially contribute to death, and because the Board provided adequate reasons or bases without relying on its own medical judgment.

The veteran’s widow sought DIC based on service connection for the cause of his death. The veteran had been service connected for residuals of poliomyelitis and later died after treatment for recurrent laryngeal cancer with metastatic lung cancer, COPD, and hypertension. A private physician wrote that the veteran’s disability made recovery from surgery more difficult and was probably a contributing factor in death. The Board denied the claim, relying in part on a medical treatise and 38 C.F.R. § 3.312(c)(2) to conclude that the service-connected polio residuals were quiescent or static and did not materially contribute to death.

The Court affirmed. It held that the Board did not commit clear factual error or legal error, and that the Board’s decision satisfied the reasons-or-bases requirement. The Court distinguished cases prohibiting the Board from substituting its own medical judgment, explaining that the Board had not done so here because it relied on record evidence, including the physician’s letter, the death certificate, and the regulatory standard for contributory cause of death. The Court also rejected the widow’s lay medical causation arguments and declined to consider extra-record evidence. The case is a useful illustration of how the Court reviews cause-of-death determinations and when a Board can rely on independent medical evidence to deny DIC.

The Court held that an April 2019 medical report submitted to the Court during a prior appeal and served on VA counsel was constructively before the Board when it later decided the same DIC claim, so the Board erred by failing to consider it. The decision clarifies that constructive possession can reach evidence served on VA during appellate litigation, not just evidence physically filed with VBA or the Board.

Christine Varad, the adult child of a deceased veteran, sought DIC benefits on the theory that she became permanently incapable of self-support before age 18. After an earlier Board denial was vacated and remanded in Varad I, the Board issued a new December 2020 decision denying the claim again. The issue on the second appeal was whether an April 2019 private medical report and narrative summary, submitted by Varad to the Court during the first appeal and served on VA counsel, were constructively before the Board when it readjudicated the claim.

The Court held that the April 2019 evidence satisfied the constructive-possession doctrine. It pre-dated the Board decision, was within the Secretary’s control because it was served on VA counsel during the prior Court appeal, and was relevant and reasonably connected to the DIC issue. The Court rejected the Secretary’s argument that materials submitted to the Court could not be part of the administrative record, and it also rejected the argument that VAOGC’s lack of adjudicatory authority defeated constructive possession. Because the Board failed to consider this favorable evidence, the Court set aside the decision and remanded for readjudication on the entire record.

The Court vacated and remanded because the Board denied increased ratings without analyzing functional loss due to pain under 38 C.F.R. §§ 4.40 and 4.45. Voyles reinforces that musculoskeletal ratings must account for pain-related impairment, not just measured motion.

The appellant sought increased ratings for residuals of a left femur fracture and a lumbar spine disability. The record included VA and private examinations noting pain, limp, muscle spasm, and some limitation of motion, as well as sworn testimony describing constant low back pain and radiating symptoms. The Board denied higher ratings based primarily on measured range of motion and did not meaningfully address the effect of pain on functional loss.

The Court held that the Board was required to consider 38 C.F.R. §§ 4.40 and 4.45(f), even though the veteran had not expressly raised those provisions, because the record repeatedly referenced pain. The Court explained that examinations on which ratings are based must adequately portray functional loss due to pain and discuss whether pain is supported by adequate pathology and visible behavior. Because the Board failed to analyze pain-related functional loss and relied on examinations that did not fully address that issue, the Court vacated and remanded for readjudication. The Court also directed that if the record lacked adequate pathology, the Board should obtain an examination before deciding entitlement to increased ratings.

The Court held that the veteran’s PTSD effective date could not reach back to the original 1985 claim because that denial became final, but it vacated and remanded the PTSD rating and pension issues because VA failed to obtain an adequate psychiatric examination and relevant SSA records.

The veteran sought an earlier effective date for service connection for PTSD, a higher PTSD rating, and consideration of pension benefits. The Court held that the 1986 RO denial became final because the veteran did not perfect an appeal after the SOC, so the later grant of service connection arose from a reopened claim and could not receive an effective date earlier than the reopened claim under the governing statutes and regulations. The Court also concluded that the Board had not fulfilled the duty to assist on the increased-rating issue because the record did not contain a thorough examination separating the functional impairment due to PTSD from other psychiatric disorders. In addition, the Court held that the Board failed to adjudicate the reasonably raised pension claim and failed to obtain relevant Social Security Administration records that bore on employability. The decision is practically important because it reinforces finality and reopened-claim effective-date rules while also requiring robust development when psychiatric disability and pension entitlement turn on functional impairment and work capacity.

The Federal Circuit held that continuity of symptomatology under 38 C.F.R. § 3.303(b) applies only to chronic diseases specifically listed in 38 C.F.R. § 3.309(a). The decision significantly limited the use of continuity-of-symptomatology evidence as an independent route to establish service connection for conditions not recognized as chronic diseases under VA regulations.

The case held that continuity of symptomatology under 38 C.F.R. § 3.303(b) applies only to the chronic diseases listed in 38 C.F.R. § 3.309(a). In Walker v. Shinseki, the Federal Circuit addressed the scope of continuity-of-symptomatology claims under 38 C.F.R. § 3.303(b) and clarified that the regulation applies only to chronic diseases specifically listed in 38 C.F.R. § 3.309(a).

The veteran sought service connection for bilateral hearing loss and submitted lay statements from family members asserting that:

• hearing problems began during service,
• and continued throughout his life after discharge.

Because many service records had been destroyed in a records fire, the claim relied heavily on:

• lay evidence,
• continuity of symptoms,
• and post-service medical evidence.

The Board denied service connection after relying on a VA examiner who attributed the hearing loss primarily to:

• aging,
• and recreational noise exposure.

On appeal, the veteran argued that continuity of symptomatology under § 3.303(b) independently supported service connection based on long-standing hearing problems since service.

The Federal Circuit rejected an expansive interpretation of § 3.303(b) and held that:

• continuity of symptomatology applies only to the chronic diseases specifically listed in § 3.309(a),
• not to every condition that might be medically considered “chronic.”

The Court explained that:

• § 3.303(b) creates a limited alternative path to service connection,
• and continuity of symptomatology cannot replace the nexus requirement for non-listed conditions.

The Federal Circuit also clarified that:

• continuity of symptomatology functions as an evidentiary substitute for nexus only within the confines of § 3.309(a) chronic diseases.

The Court ultimately affirmed the denial of the claim.

The Court established the core elements required to prove secondary service connection: (1) evidence of a current disability, (2) evidence of an existing service-connected disability, and (3) competent medical evidence establishing a nexus between the service-connected disability and the current condition. The decision became a foundational framework for analyzing secondary service connection claims.

In Wallin v. West, the Court addressed whether medical treatise evidence could satisfy the nexus requirement necessary to well ground a secondary service connection claim. The veteran sought service connection for ankylosing spondylitis as secondary to service-connected bacillary dysentery acquired during military service.

The veteran submitted medical literature discussing the relationship between Shigella infections, HLA-B27 genetic predisposition, and the later development of ankylosing spondylitis and reactive arthritis conditions. Although several VA physicians disputed the ultimate causal relationship, the Court held that the medical treatise evidence established at least a plausible causal connection sufficient to well ground the claim.

The Court distinguished prior cases involving overly generic medical literature and explained that treatise evidence may be sufficient when it discusses relationships with enough certainty and specificity to establish plausible causality under the facts of the individual case. The Board’s decision was reversed and remanded for adjudication on the merits.

The Court affirmed the Board’s refusal to reopen a psychiatric-disorder claim because the additional evidence was cumulative, not probative of service incurrence or presumptive psychosis, and did not create a reasonable possibility of changing the outcome.

The appellant sought to reopen a previously denied claim for service connection for a psychiatric disorder. The Board found that the evidence submitted after the final denial was not new and material, and the Court affirmed. The record showed an in-service diagnosis of antisocial personality and later postservice psychiatric diagnoses, but the governing issue on reopening was whether the new submissions were relevant and probative of service incurrence or manifestation of a psychosis within one year after separation. The Court held that a duplicate service medical record was cumulative, private childhood records and a religious book were not probative of the dispositive service-connection question, and the veteran’s own statements could not establish the required medical diagnosis or nexus. The Court also held that the veteran’s account of a doctor’s comment that the condition “could have been” caused by psychosis was too speculative to be material. The decision reinforces that reopening requires evidence that meaningfully addresses the basis of the prior denial, not merely additional background material or conjecture.

The Court vacated a Board decision that awarded only a 30 percent rating and denied unemployability because the Board misused psychiatric rating terminology, contradicted itself about the nature of the disability, and failed to provide adequate reasons or bases for finding the veteran employable.

The veteran served in the Navy and was service connected for a psychophysiological musculoskeletal disorder manifested by headaches, later increased to 30 percent, along with a scar. He sought a higher rating and individual unemployability, relying in part on VA treatment records, psychiatric examination findings describing minimal social adjustment and industrial adjustment from moderate to nil, and a Social Security Administration decision finding him unemployable. The Board granted 30 percent but denied unemployability, reasoning that his disabilities did not preclude a relatively low-stress job.

The Court held that the Board failed to apply the psychiatric rating criteria properly. The Board used terminology associated with higher evaluations, such as difficulty obtaining or retaining employment and isolation, while assigning only a 30 percent rating for definite impairment. The Court also held that the Board did not adequately explain how it reconciled the VA psychiatrist’s findings with the rating schedule and contradicted itself about whether back pain was part of the service-connected psychophysiological disorder. Because the record did not contain adequate medical support for the Board’s characterization of the disability, the Board effectively made an unsupported medical judgment.

On unemployability, the Court found the Board’s statement that the veteran could do low-stress work was unsupported and conflicted with the treating physician’s statement that any stress would trigger symptoms. The Court also faulted the Board for giving only a summary dismissal of the SSA disability determination without explaining what weight it assigned to that evidence. The decision was vacated and remanded for proper application of the rating schedule and a reasoned explanation supported by the record.

The Federal Circuit held that a conclusory generalized lay statement asserting that a current condition is related to service is not, by itself, sufficient to require VA to provide a medical examination under 38 U.S.C. § 5103A(d). The decision clarified limits on the low-threshold examination standard established in McLendon v. Nicholson.

The veteran sought service connection for hypertension, diabetes, glaucoma, and a psychiatric disorder, asserting that the conditions were secondary to schizophrenia. VA denied the claims without obtaining medical examinations or nexus opinions.

The veteran argued that his lay statements alone were sufficient to trigger VA’s duty to obtain examinations under the low-threshold standard described in McLendon v. Nicholson.

The Federal Circuit disagreed. While acknowledging that McLendon established a relatively low threshold, the court explained that Congress did not intend for conclusory generalized lay assertions automatically to require medical examinations in every service-connection claim. The court held that some evidentiary basis suggesting an association between the disability and service must exist beyond a bare conclusory statement.

The court emphasized that requiring examinations whenever a veteran merely alleges causation would effectively mandate examinations in virtually every claim, contrary to the statutory framework.

Waters became an important limiting case on McLendon and is frequently cited when evaluating whether evidence sufficiently triggers VA’s duty to obtain a medical opinion.

The Court vacated and remanded because, after finding new and material evidence, the Board failed to properly readjudicate the claim on all the evidence and gave inadequate reasons or bases for rejecting favorable lay and medical evidence.

The veteran sought to reopen a previously denied claim for service connection for Buerger’s disease and related vascular problems. The Board found that some of the evidence submitted after the prior final denial was new and material, but concluded that it did not alter the basis of the earlier decision. The Court held that once the claim was reopened, the Board was required under Manio to evaluate the merits in light of all the evidence, both old and new.

The Court concluded that the Board’s discussion was too conclusory to permit effective judicial review under 38 U.S.C. § 7104(d)(1). It emphasized that the Board did not adequately address the probative value of lay statements, including evidence describing cold sensitivity shortly after service, and did not properly explain its rejection of medical opinions linking the disability to service. The Court also noted that service connection can be supported by competent lay evidence in the context of presumptive chronic disease analysis. The decision was vacated and remanded for readjudication with adequate reasons or bases and proper consideration of the entire record.

An SOC that contains a DRO review decision may be a final decision subject to CUE, but the appellant must still prove CUE; mere disagreement with how the evidence was weighed is not enough.

The Court considered whether a February 2006 document labeled as an SOC, but issued after de novo Decision Review Officer (DRO) review, could be treated as a final decision subject to collateral attack for clear and unmistakable error (CUE). The appellant had argued that the Board erred in finding no CUE in that document, and later asserted that VA improperly combined the DRO and SOC functions into a single document in violation of the legacy DRO regulations.

The Court held that an SOC containing a DRO review decision may qualify as a Secretary decision for purposes of CUE under 38 U.S.C. § 5109A, because the DRO process produces a new merits decision and Mayfield and Prickett recognize that readjudicatory decisions may be announced in an SOC. The Court also concluded that the appellant waived his procedural objection to the document format through a prior joint motion for remand. On the merits, however, the Court affirmed the Board because the appellant’s arguments amounted to disagreement with how the DRO weighed conflicting medical evidence, which is not CUE.

The Court reversed and remanded because the Board gave no adequate reasons or bases for denying a higher PTSD rating and failed to explain how it separated service-connected from nonservice-connected psychiatric impairment. The decision reinforces that psychiatric ratings must be supported by a transparent analysis of the evidence and the rating criteria.

Richard H. Webster sought an increased rating for service-connected PTSD after previously receiving a 30 percent evaluation. The record contained substantial evidence of serious psychiatric impairment, including private and VA psychiatric evaluations, sworn testimony from the veteran and a coworker, and a Social Security disability decision finding him unable to engage in gainful activity because of mental impairment. The Board nevertheless denied a rating higher than 30 percent in a brief conclusion that the disability caused only definite social and industrial inadaptability.

The Court held that the Board failed to comply with the statutory reasons-or-bases requirement because it did not explain why it rejected or discounted the favorable evidence suggesting greater industrial impairment. The Court also noted that the Board was silent on whether part of the veteran’s psychiatric impairment should be attributed to a nonservice-connected bipolar disorder. If the Board chooses to make such a separation on remand, the Court instructed that it must do so based on medical evidence. The Court further reminded the Board to meaningfully address the benefit-of-the-doubt doctrine rather than reciting it mechanically. The case was reversed and remanded for further proceedings.

The Court held that the Board had to address both the DRO’s CUE finding and the veteran’s entitlement to a higher PTSD/TBI rating, and vacated and remanded because the Board had not fully analyzed both intertwined issues in one decision.

Army veteran Edward T. Westervelt had a 70% rating for TBI when VA later awarded a separate 30% rating for PTSD. A DRO concluded that the separate PTSD award was clear and unmistakable error because the evidence showed the PTSD and TBI symptoms could not be differentiated, and revised the decision to combine the conditions at 70% under the anti-pyramiding rule. The veteran appealed, arguing that the Board had to address the propriety of the CUE finding as well as the merits of his PTSD evaluation.

The Court agreed that the CUE issue was properly before the Board, explaining that the DRO review process under 38 C.F.R. § 3.2600 did not create a new operative NOD and did not eliminate the veteran’s original appeal. The Court also held that the Board still had to address the underlying rating question on direct appeal. Because the Board had not fully resolved both intertwined issues in a single decision, the Court vacated in part and remanded for readjudication. The Court also rejected additional arguments that the DRO could not revise a nonfinal decision and that reduction procedures under 38 C.F.R. § 3.105(e) applied.

Practically, the decision reinforces that when VA revises a decision for CUE during legacy DRO review, the Board must still address the appealed rating issue on the merits. It also confirms that CUE-based revisions under § 3.2600 can apply to nonfinal decisions and are not treated as ordinary compensation reductions.

The Court held that the Board’s conclusion that the veteran’s rating period began in April 2016 was a final denial of benefits because it foreclosed compensation before that date. The Court also reversed the Board’s finding that the 2014 rating decision became final, holding that evidence of suicidal ideation received within one year was new and material under 38 C.F.R. § 3.156(b).

James P. Willen appealed a Board decision that remanded his increased-rating and TDIU claims for a psychiatric disability but also concluded that the period on appeal did not extend back to his January 2014 claim. The Board reasoned that a September 2014 rating decision was final and that the relevant period began in April 2016, one year before his April 2017 increased-rating claim. The Secretary argued the Court lacked jurisdiction because the Board had only issued a remand. The Court rejected that view, explaining that the Board’s limitation of the appeal period effectively denied benefits for the period before April 2016 and therefore constituted a final decision reviewable under 38 U.S.C. § 7252.