Board decisionsVA Case Search

Board of Veterans' Appeals · AMA series

An earlier effective date of November 12, 2004, for a 10 percent rating for gastroesophageal reflux disease (GERD) is granted.

July 30, 2026Citation Nr. A26069973Docket 250605-551734va.gov source

  • Gastroesophageal reflux disease (GERD) - earlier effective date for a 10 percent ratingGranted

Board reasoning

The Board found that the Veteran had sufficient GERD symptoms since service connection was granted on November 12, 2004, to warrant a 10 percent rating. It applied the symptoms flexibly by rating by analogy to hiatal hernia (DC 7346) and concluded the earliest date achievable for the 10 percent rating is the grant date of November 12, 2004, relying on multiple medical records showing recurrent GERD symptoms and ongoing treatment across years; the examiner's 2012 report was deemed internally inconsistent but the diagnosis of GERD was established by later imaging, and the July 2023 examination documented symptoms supporting the 10 percent rating.

Issues

  • Gastroesophageal reflux disease (GERD) - earlier effective date for a 10 percent ratingGranted

Authorities

  • Webb v. McDonough, 71 F.4th 1377cited to support rating by analogy (symptom flexibility) with esophageal conditions

Extracted with gpt-5-nano-2025-08-07. Citations are kept only when they appear in the decision text.