38 C.F.R. § 4.46
Accurate measurement
Accurate measurement of the length of stumps, excursion of joints, dimensions and location of scars with respect to landmarks, should be insisted on. The use of a goniometer in the measurement of limitation of motion is indispensable in examinations conducted within the Department of Veterans Affairs. Muscle atrophy must also be accurately measured and reported.
Notes of Decisions
Cited in 3
cases (1 in the last 5 years), 1993–2024 · leading case: Robertson v. Brown, 5 Vet. App. 70 (Vet. App. 1993).
Robertson v. Brown, 5 Vet. App. 70 (Vet. App. 1993). “38 C.F.R. § 4.46 (b) (1992) (emphasis added).”
Crockwell v. Austin (D.D.C. 2024). “” AR 5, 568-69; 38 C.F.R. § 4.46 (establishing that goniometers should be used by the VA in measuring range of motion).”
09-43 328 (Board of Vet. App. 2013). “Although the regulations do not require the use of a goniometer, 38 C.F.R. § 4.46 explains that the use of a goniometer in measuring limitation of motion is indispensable.”
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