The Bulletin

T HE U.S. C OURT OF V ETERANS A PPEALS FOR V ETERANS C LAIMS ISSUES A DECISION REGARDING THE CONSIDERATION OF PAIN MEDICATION AND DISABILITY EVALUATIONS

On March 12, 2025, the United States Court of Appeals for Veterans Claims (USCAVC) issued a decision regarding the consideration of the effects of pain medication and VA disability evaluations for musculoskeletal disabilities. The case was No. 23-1798, Carlton H. Ingram, Appellant, v. Douglas A. Collins, Secretary of Veterans Affairs, Appellee. Ingram argued that the Board of Veterans Appeals erred in denying higher evaluations for his musculoskeletal disabilities because it failed to account for the beneficial effects of medication when evaluating both disabilities under appeal. The USCAVC found that the Board of Veterans Appeals did not consider the impact of medication on

Ingram's disabilities and remanded the case for further development and re-adjudication. Because of this decision, the VA must now assess the effects of medication on pain, functional impact, and range of motion when evaluating musculoskeletal disabilities. As a recommendation, when attending compensation and pension examinations to support claims for service connection or increased evaluations of musculoskeletal disabilities, veterans should inform the examiner if they are taking pain medications. Patients should also be prepared to discuss the functional impact of their disability with and without the medication. This may directly affect the outcome of the evaluation.

P UBLIC L AW 119-70 D ISABLED V ETERANS H OUSING S UPPORT A CT

On January 20, 2026, H.R. 224 was signed into law as Public Law 119-70 during the 119th Congress. This law amends section 102 (a)(20) of the Housing and Community Development Act of 1974. The amendment requires that VA service-connected disability compensation be excluded when determining whether a person is a person of low and moderate income, a person of low income, or a person of moderate income, and for other purposes.

shall exclude any service-connected disability compensation received by such person from the Department of Veterans Affairs. ” The law is intended to: • Enhance Housing Accessibility: Veterans with disabilities can more easily qualify for housing programs. • Promote Equity: Aligns the treatment of veteran benefits across the CDBG program.

“ When determining whether a person is a person of low or moderate income, a person of low income, or a person of moderate income under this paragraph, a State, unit of general local government, or Indian tribe • Provide Accountability: Requires a report to Congress on how service-connected disability compensation is treated across HUD programs to improve access for our veteran populations. P UBLIC L AW 119 - 72, “ F OCUSED A SSISTANCE AND S KILLS T RAINING FOR V ETERANS ’ E MPLOYMENT AND T RANSITION S UCCESS A CT ” OR THE FAST VETS A CT

On January 20, 2026, H.R. 4446 was signed into law under Public Law 119-72 during the 119th Congress. This law amends title 38, United States Code, to modify the conditions under which the Secretary of Veterans Affairs must redevelop the individualized vocational rehabilitation plan for a veteran, and for other purposes. After the PACT Act was enacted, more veterans qualified for the VR&E program, leading to a significant increase in enrollment. This surge has led to longer wait times for veterans seeking access. The FAST VETS Act, proposed by Dexter, introduces important

improvements to streamline the process, helping veterans graduate and find employment more quickly and allowing counselors to assist more veterans. The FAST VETS Act strengthens the VA ’ s VR&E program by prioritizing outcome-focused planning to support veteran success. This legislation establishes clearer standards for redeveloping a veteran ’ s vocational rehabilitation plan in instances when a veteran ’ s employment barrier has changed and when a different plan would more effectively support their rehabilitation goals.

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