WRIST IMPAIRMENT OF

R. BISIGNANI · 2026 · Case ID: A26038432

DENIED

Summary

The veteran served from November 2010 to December 2011 and again from May 2013 to April 2014. The veteran appealed the denial of an increased disability rating for bilateral wrist sprains and tenosynovitis, which were previously granted service connection at 10 percent disabling. The Board reviewed the evidence, including VA treatment records and a January 2025 VA examination. The examination noted pain with all ranges of motion and some joint instability, but found active range of motion within normal limits. The veteran reported pain with repetitive motions and inability to drive or grip objects for prolonged periods. However, the Board found no evidence of ankylosis or the functional equivalent of ankylosis, which would warrant a higher rating under DC 5214. The Board also considered the impact of pain and medication, referencing Jones v. Shinseki and Ingram v. Collins, but declined to remand for further development on medication's ameliorative effects due to the likelihood of speculative opinions. Ultimately, the Board denied entitlement to a rating in excess of the current 10 percent for the bilateral wrist disabilities, as the maximum schedular rating under DC 5215 for limitation of motion had been assigned and the criteria for ankylosis were not met.

Rationale

Criteria for rating in excess of 10% not met.; No evidence of ankylosis or functional equivalent.; Current limitation of motion does not warrant higher rating under DC 5215.

Special Benefit

NO SPECIAL BENEFIT

Diagnostic Code

5215

Docket No.

251016-602831

Full Decision Text

Citation Nr: A26038432
Decision Date: 04/24/26 Archive Date: 04/24/26

DOCKET NO. 251016-602831
DATE: April 24, 2026

ORDER

Entitlement to a rating in excess of 10 percent for right wrist sprain is denied.

Entitlement to a rating in excess of 10 percent for left wrist sprain and tenosynovitis is denied.

FINDINGS OF FACT

1. The Veteran's right wrist has not been manifested by limitation of motion less than 15 degrees in dorsiflexion, palmar flexion limited in line with forearm, or ankylosis or the functional equivalent.

2. The Veteran's left wrist has not been manifested by limitation of motion less than 15 degrees in dorsiflexion, palmar flexion limited in line with forearm, or ankylosis or the functional equivalent.

CONCLUSIONS OF LAW

1. The criteria for a rating in excess of 10 percent for right wrist sprain have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.71, 4.71a, Diagnostic Code (DC) 5215.

2. The criteria for a rating in excess of 10 percent for left wrist sprain and tenosynovitis have not been met. 38 U.S.C. §§ 1155, 5107; 38 C.F.R. §§ 4.71, 4.71a, DC 5024-5215.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty from November 2010 to December 2011 and from May 2013 to April 2014.

These matters come before the Board of Veterans' Appeals (Board) from an April 2025 decision by the agency of original jurisdiction (AOJ).

In the October 2025 VA Form 10182, Decision Review Request: Board Appeal (Notice of Disagreement), the Veteran elected the Evidence Submission docket for Board review of an April 18, 2024, adjudication of the evaluation for the right and left wrists. Initially, the Board notes that there is not an April 2024 rating decision pertaining to the right and left wrists. Instead, the date noted by the Veteran is the date of the Veteran's intent to file a claim for service connection for the right and left wrists, which was subsequently granted by way of an April 2025 rating decision.

The Board may construe argument liberally to determine whether such raises issues on appeal and finds the request to review the evaluation for the right and left wrists can be construed as a dispute on the April 2025 rating decision, which is a valid request to review this claim. As the Veteran has elected the Evidence Review Docket, the Board may only consider the evidence of record at the time of the April 2025 AOJ decision on appeal, as well as any evidence submitted by the Veteran or his representative with, or within 90 days from receipt of, the VA Form 10182. 38 C.F.R. § 20.303. If evidence was submitted either (1) during the period after the AOJ issued the decision on appeal and prior to the date the Board received the VA Form 10182, or (2) more than 90 days following the date the Board received the VA Form 10182, the Board did not consider it in its decision. 38 C.F.R. §§ 20.300, 20.303, 20.801.

If the Veteran would like VA to consider any evidence that was submitted that the Board could not consider, the Veteran may file a Supplemental Claim (VA Form 20-0995) and submit or identify this evidence. 38 C.F.R. § 3.2501. If the evidence is new and relevant, VA will issue another decision on the claims, considering the new evidence in addition to the evidence previously considered. Id. Specific instructions for filing a Supplemental Claim are included with this decision.

Increased Ratings

Disability evaluations are determined by the application of the facts presented to VA's Schedule for Rating Disabilities (Rating Schedule) at 38 C.F.R. Part 4. The percentage ratings contained in the Rating Schedule represent, as far as can be practicably determined, the average impairment in earning capacity resulting from diseases and injuries incurred or aggravated during military service and the residual conditions in civilian occupations. 38 U.S.C. § 1155; 38 C.F.R. § 4.1.

If two evaluations are potentially applicable, the higher evaluation will be assigned if the disability picture more nearly approximates the criteria required for
Id. Specific instructions for filing a Supplemental Claim are included with this decision.

Increased Ratings

If two evaluations are potentially applicable, the higher evaluation will be assigned if the disability picture more nearly approximates the criteria required for that rating; otherwise, the lower rating will be assigned. 38 C.F.R. § 4.7. When reasonable doubt arises as to the degree of disability, such doubt will be resolved in the Veteran's favor. 38 C.F.R. § 4.3.

The Veteran's entire history is reviewed when making a disability determination. 38 C.F.R. § 4.1. Where service connection has already been established, and an increase in the disability rating is at issue, it is the present level of the disability that is of primary concern. See Francisco v. Brown, 7 Vet. App. 55 (1994). However, in such cases, when the factual findings show distinct time periods during which a claimant exhibits symptoms of the disability at issue and such symptoms warrant different evaluations, staged evaluations may also be assigned. See Hart v. Mansfield, 21 Vet. App. 505 (2007).

The evaluation of the same disability under various diagnoses, known as pyramiding, is generally to be avoided. 38 C.F.R. § 4.14. The critical element in permitting the assignment of several ratings under various diagnostic codes is that none of the symptomatology for any one of the disabilities is duplicative or overlapping with the symptomatology of the other disability. See Esteban v. Brown, 6 Vet. App. 259, 261- 62 (1994).

The Board must assess the credibility and weight of all evidence, including the medical evidence, to determine its probative value, accounting for evidence which it finds to be persuasive or unpersuasive, and providing reasons for rejecting any evidence favorable to the claimant. Equal weight is not accorded to each piece of evidence contained in the record; every item of evidence does not have the same probative value.

Entitlement to a rating in excess of 10 percent for right wrist sprain is denied.

Entitlement to a rating in excess of 10 percent for left wrist sprain and tenosynovitis is denied.

An April 2025 rating decision granted service connection for right wrist sprain and left wrist sprain and tenosynovitis, rated 10 percent disabling, effective April 18, 2024.

The Veteran's left wrist disability is evaluated under DC 5024-5215. 38 C.F.R. § 4.71a. Hyphenated DCs are used when a rating under one DC requires use of an additional DC to identify the basis for the evaluation assigned; the additional code is shown after the hyphen. 38 C.F.R. §§ 4.20, 4.27. According to a Note in the Ratings Schedule, DCs 5013 through 5024 are to be evaluated as degenerative arthritis based upon limitation of motion of the affected parts. Here, DC 5024-5215 indicates that the Veteran's left wrist sprain and tenosynovitis (5024) is evaluated under limitation of motion of the wrist (5215).

The Veteran's right wrist disability is evaluated under DC 5215.

Under Diagnostic Code 5215, a 10 percent rating is warranted where palmar flexion is limited in line with the forearm, or where dorsiflexion is less than 15 degrees. 38 C.F.R. § 4.71a, Diagnostic Code 5215. This is the maximum schedular rating based on limitation of motion of the wrist under this diagnostic code.

Diagnostic Code 5214 applies to ankylosis of the wrist. Diagnostic Code 5214 provides the following ratings for a major extremity: 30 percent for favorable ankylosis in 20 degrees to 30 degrees dorsiflexion; 40 percent for ankylosis in any other position except favorable; and 50 percent for unfavorable ankylosis in any degree of palmar flexion or with ulnar or radial deviation. Diagnostic Code 5214 notes that extremely unfavorable ankylosis will be rated as loss of use of
§ 4.71a, Diagnostic Code 5215. This is the maximum schedular rating based on limitation of motion of the wrist under this diagnostic code.

Diagnostic Code 5214 applies to ankylosis of the wrist. Diagnostic Code 5214 provides the following ratings for a major extremity: 30 percent for favorable ankylosis in 20 degrees to 30 degrees dorsiflexion; 40 percent for ankylosis in any other position except favorable; and 50 percent for unfavorable ankylosis in any degree of palmar flexion or with ulnar or radial deviation. Diagnostic Code 5214 notes that extremely unfavorable ankylosis will be rated as loss of use of hands under Diagnostic Code 5125. 38 C.F.R. § 4.71a.

Normal range of motion for the wrist is 80 degrees palmar flexion and 70 degrees dorsiflexion. 38 C.F.R. § 4.71, Plate I. When evaluating musculoskeletal disabilities based upon limitation of motion, 38 C.F.R. § 4.40 requires consideration of functional loss caused by pain or other factors listed in that section that could occur during flare-ups or after repeated use and therefore, not be reflected on ROM testing. 38 C.F.R. § 4.45 requires consideration also be given to less movement than normal, more movement than normal, weakened movement, excess fatigability, incoordination, and pain on movement. See DeLuca v. Brown, 8 Vet. App. 202 (1995); Mitchell v. Shinseki, 25 Vet. App. 32, 44 (2011). Nonetheless, even when the background factors listed in §§ 4.40 or 4.45 are relevant when evaluating a disability, the rating is assigned based upon the extent to which motion is limited pursuant to 38 C.F.R. § 4.71a, and a separate or higher rating under § 4.40 or 4.45 itself is not appropriate. See Thompson v. McDonald, 815 F.3d 781, 785 (Fed. Cir. 2016) ("it is clear that the guidance of § 4.40 is intended to be used in understanding the nature of the Veteran's disability, after which a rating is determined based on the § 4.71a criteria").

Additionally, the intent of the Ratings Schedule is to recognize painful motion with joint or periarticular pathology as productive of disability. 38 C.F.R. § 4.59. Actually painful, unstable, or malaligned joints due to healed injury is recognized as entitled to at least the minimum compensable rating for the joint. Id. The joints involved should be tested for pain on both active and passive motion, in weight-bearing and non-weight-bearing and, if possible, with the ROM of the opposite undamaged joint. Id.

A December 2024 VA treatment record reflects the Veteran was seen for bilateral wrist pain. The pain had been present for a while and had worsened. There was no weakness or numbness.

Another December 2024 VA treatment record shows the Veteran presented for OT evaluation with complaints of right wrist pain. He stated that symptoms occurred a few months ago with no recollection of an inciting event. Active range of motion of the wrist and fingers were within normal limits. The Veteran endorsed general aching pain and increased pain with end range wrist movement. He was still able to complete his ADLs and IADLs and modified activities as needed to avoid pain. Testing suggested some joint instability and possible ligament strain/ TFCC damage. The examiner discussed the benefits and limitations of therapy. The Veteran was open to conservative treatment due to distance away from clinic. He was instructed in the possibility that he injured his wrist by straining the ligaments of his ulnar sided carpal bones. The Veteran was provided education on joint stabilization. He was issued a wrist cock up brace to use. The examiner planned to order wrist widget to provide support during functional activities. It was recommended that the Veteran return in one to two months.

The Veteran underwent a VA examination in January 2025. He was diagnosed with bilateral chronic wrist sprain and left wrist tenosynovitis and tendinitis. The Veteran reported shaking of his left wrist, pain with random shocking pains down the wrist into the third middle finger, bilateral aching, pressure, tension, wrist pain, and bilateral seizing up of the wrists. The Veteran reported that his bilateral wrists hurt in cold weather. Current treatment included a wrist brace, physical therapy, and Ibuprofen. The Veteran did not report flare-ups of the right wrist. Flare-ups of the left wrist were described as random shocking pains down into the left wrist, into the third finger, a few times a day every day, lasting a few seconds. Precipitating factors included use of wrist or fingers. Flare-ups were alleviated by rest and the severity was described as moderate. Flare-ups caused functional impairment such that the Veteran was unable to perform repetitive motions without exacerbation of symptoms and was unable to drive or grip objects for prolonged periods of time. The Veteran reported having functional loss or functional impairment in that bilateral wrists such that he was unable to perform repetitive motions without exacerbation of symptoms and was unable to drive or grip objects for prolonged periods of time.

Examination reveals that the Veteran had palmar flexion to 40 degrees, dorsiflexion to 20 degrees, ulnar deviation to 10 degrees, and radial deviation to 10 degrees, bilaterally. He had pain with all ranges of motion. Passive range of motion was the same as active range of motion. There was evidence of pain on weight-bearing, active motion, and passive motion that caused functional loss. The Veteran was unable to perform repetitive motions without exacerbation of symptoms and was unable to drive or grip objects for prolonged periods of time. There was no objective evidence of crepitus, bilaterally. There was objective evidence of localized tenderness or mild pain on palpation of the right wrist located on the lateral ulnar aspect. There was also objective evidence of localized tenderness or mild pain on palpation of the left wrist located on the medial and mid wrist. The Veteran able to perform repetitive-use testing with at least three repetitions, bilaterally. There was no additional loss of function or range of motion after three repetitions. The Veteran was not being examined immediately after repeated use over time. Procured evidence (statements from the Veteran) suggested pain and lack of endurance significantly limited functional ability with repeated use over time of the right wrist. Procured evidence (statements from the Veteran) suggested pain, weakness, and lack of endurance significantly limited functional ability with repeated use over time of the left wrist. With repeated use over time, the Veteran would have palmar flexion to 40 degrees, dorsiflexion to 20 degrees, ulnar deviation to 10 degrees, and radial deviation to 10 degrees, bilaterally. The examination was not being conducted during a flare-up. Estimated range of motion during flare-ups of the left wrist was the same as active range of motion. The Veteran did not have any additional factors contributing to disability. The Veteran did not have muscle atrophy or ankylosis. He reported the occasional use of a brace for the bilateral wrists. There was no functional impairment of either wrist such that no effective function remained other than that which would be equally well served by an amputation with prosthesis. The examiner noted that the Veteran's bilateral wrist disabilities impacted his ability to work based on his reports that repetitive movements like holding a wrench or ratchet and performing twisting movements aggravated his conditions, requiring him to rest.

Based on the evidence, the Board does not find that the Veteran is entitled to an evaluation in excess of the current 10 percent disability ratings for his bilateral wrist disability.

With respect to the applicable rating criteria, the Veteran is currently assigned initial 10 percent disability ratings under Diagnostic Code 5215. A 10 percent disability rating is the highest schedular rating available. As such, the Board is unable to grant higher schedular ratings under these criteria.

The Board notes that Diagnostic Code 5214 (wrist, ankylosis of), which is the only other diagnostic code which specifically references the wrist, is not appropriate for application in this case because, as there is no evidence of ankylosis in the record. Ankylosis is "immobility and consolidation of a joint due to disease, injury, surgical procedure." See Lewis v. Derwinski, 3 Vet. App. 259 (1992) (citing Saunders Encyclopedia and Dictionary of Medicine,
Diagnostic Code 5215. A 10 percent disability rating is the highest schedular rating available. As such, the Board is unable to grant higher schedular ratings under these criteria.

In this respect, the Board has also considered whether the Veteran's symptoms approximate ankylosis. See Chavis v. McDonough, 34 Vet. App. 1 (2021) (holding that the criteria for a rating based on ankylosis may be met by evidence demonstrating the functional equivalent of ankylosis). However, the evidence in this case does not show the functional equivalent of ankylosis, even when contemplating functional loss due to symptoms such as pain, fatigue, and lack of endurance; or due to repetitive use over time and/or flare-ups. The Veteran did not report ankylosis-like symptoms, none of the medical evidence suggests that the severity of the Veteran's bilateral wrist disability is the functional equivalent of ankylosis, nor has any examiner noted a pathology that causes ankylosis.

As noted above, in evaluating any disability on the basis of limitation of motion, VA must consider the actual degree of functional impairment imposed by pain, incoordination, weakness, fatigue, and lack of endurance with repetitive motion. 38 C.F.R. §§ 4.40, 4.45, 4.59; DeLuca v. Brown, 8 Vet. App. 202 (1995).

A review of the record therefore demonstrates that the Veteran experiences functional loss and limitation of motion due to his bilateral wrist disability as documented by the January 2025 VA examination. However, ankylosis of the left wrist is not shown.

As a result, while higher disabilities ratings are contemplated for ankylosis of the wrist under Diagnostic Code 5214, the evidence does not show that the Veteran's bilateral wrists have been manifested by symptoms consistent with ankylosis at any time during the course of the appeal, even upon consideration of the actual degree of functional impairment due to factors such as pain, weakness, fatigability, incoordination, and lack of endurance. 38 C.F.R. § 4.45; DeLuca v. Brown, 8 Vet. App. 202 (1995).

In making the above findings, the Board is cognizant of the fact that the Veteran has used medication, including Ibuprofen, to treat his bilateral wrist pain. The Court has held that in assigning a disability rating, VA may not consider the ameliorative effects of medication where such effects are not explicitly contemplated by the rating criteria. Jones v. Shinseki, 26 Vet. App. 56 (2012). More recently, the Court stated that the "the Board [is] obligated to discount the beneficial effects of the medication taken for each disability and evaluate the baseline severity of those disabilities." Ingram v. Collins, 38 Vet. App. 130 (2025).

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The Board notes, however, that neither Jones nor Ingram address how the Board is to discount the beneficial effects of medication without resorting to speculation. Remanding this appeal to order an addendum medical opinion based on Jones and Ingram would almost certainly require an examiner to engage in medical speculation and would result in a medical opinion that lacks the degree of certainty to ascertain, even under the benefit-of-the-doubt standard, the impact of the ameliorative effects of medication on the severity of a veteran's service-connected condition. See, e.g., Hood v. Shinseki, 23 Vet. App. 295, 298-99 (2005) (medical opinions that are speculative have "little probative value"). Because it is highly unlikely that remand to obtain a medical opinion as to the ameliorative effects of medication on the severity of the Veteran's bilateral wrist disabilities would result in a probative, non-speculative opinion as to such, the Board does not wish to further delay adjudication of the Veteran's appeal to engage in likely unfruitful further development pursuant to Jones and Ingram.

As a result, the Board finds that a rating in excess of 10 percent is not warranted
of a veteran's service-connected condition. See, e.g., Hood v. Shinseki, 23 Vet. App. 295, 298-99 (2005) (medical opinions that are speculative have "little probative value"). Because it is highly unlikely that remand to obtain a medical opinion as to the ameliorative effects of medication on the severity of the Veteran's bilateral wrist disabilities would result in a probative, non-speculative opinion as to such, the Board does not wish to further delay adjudication of the Veteran's appeal to engage in likely unfruitful further development pursuant to Jones and Ingram.

As a result, the Board finds that a rating in excess of 10 percent is not warranted for the Veteran's bilateral wrist disabilities.

R. Bisignani

Veterans Law Judge

Board of Veterans' Appeals

Attorney for the Board Griffith, S.

The Board's decision in this case is binding only with respect to the instant matter decided. This decision is not precedential and does not establish VA policies or interpretations of general applicability. 38 C.F.R. § 20.1303.

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