CAVC Decision July 5, 2016

Correia

Correia v. McDonald, 28 Vet. App. 158 (2016)

Range of Motion Testing Requirements

Summary

The Court held that adequate joint examinations must include range of motion testing in active motion, passive motion, weight-bearing, and non-weight-bearing positions (where applicable). The examination must also test the opposite joint for comparison. Failure to conduct these tests renders an examination inadequate for rating purposes.

Key Points

  • Must test active and passive range of motion
  • Must test weight-bearing and non-weight-bearing (where applicable)
  • Must test the opposite joint for comparison
  • Failure to do so makes exam inadequate
  • Applies to all joint examinations
  • Can be basis for remand if exam is non-compliant

When This Applies

If your joint examination didn't include all required testing (active/passive, weight-bearing/non-weight-bearing, and the opposite joint), the exam may be inadequate. Check your exam report for these measurements. If they're missing, you may have grounds to request a new examination.

Related Conditions

Knee conditions Ankle conditions All joint conditions