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Monday, March 2, 2015

Proposed Changes to the Ratings for the Female Reproductive System Are Now Open to Comments

Last Friday, the 27th, Congress published their proposed changes to the Military Disability Ratings for the Female Reproductive System. The entire VASRD is currently being updated and rewritten, one section at a time, in order to update the criteria to current medical standards and to provide better, more accurate and fair compensation. The rewrites are scheduled to be completed sometime in 2016. The Female Reproductive System is the second section posted so far. The Mental Disorders section was updated in August 2014.

Comments are currently being accepted regarding the proposed changes to the Female Reproductive System. The deadline for submitting comments is April 28, 2015. We will be compiling and submitting comments on your behalf, so if you would like for your voice to be heard, please comment on this blog or Contact Us directly through our site before April 15, 2015. This is a great opportunity for us to make positive changes for the future, so please share your thoughts with us, especially you female veterans who deserve proper compensation for your conditions.

After April 28th, the rule makers will review all of the comments and determine if any additional changes should be made based on the arguments received. They will then post the final version of the new ratings for the Female Reproductive System, along with an official date for the new ratings to take affect. Once the changes are official, we’ll get that info to you as soon as possible. 

Below are the proposed changes. Not every condition/code has been changed, so if it is not listed below, then it will remain the same and can be found on our current Female Reproductive System page. I’ve started by listing the current code as it is right now. The proposed changes to each code are discussed directly after.

Code 7610: Diseases or injuries of the vulva (the part of the female genitals that are on the outside of the body).

The proposed change to code 7610 is super simple: to specify that this code includes the clitoris. The clitoris is already a part of the vulva, and all clitoris conditions should already be rated here, but I guess some people have been getting all confused. Thus the word “clitoris” is being specifically added in addition to “vulva” to get rid of any confusion. The ratings stay the same.

Code 7615: Diseases, injuries or adhesions of the ovaries.

The only change to this code will be a note specifying that dysmenorrhea (severe pain during menstruation) or secondary amenorrhea (the normal menstrual cycle is interrupted and menstruation stops completely for at least 6 months) caused by any of these problems with the ovaries will be rated under this code. The ratings stay the same.

Code 7619: the removal of one or both ovaries is rated 100% for the first 3 months after surgery. After that period, the complete removal of both ovaries is rated 30%. Anything less than the complete removal of both ovaries is rated 0%.

The change to this code is pretty awesome and too long in coming, if I say so myself. The change was made in order to make the female ratings for loss of the ovaries equal with the male ratings for loss of the testicles. It was acknowledged that the risk of future health problems due to the loss of the ovaries is just as severe as the risk of future health problems for men, so the ratings should be comparable. The new code with the changes will read as follows:

Code 7619: the removal of one or both ovaries is rated 100% for the first 3 months after surgery. After that period, the complete removal of both ovaries is rated 30%. A 30% rating is also given if a single service-connected ovary is removed and the other ovary has also been removed or doesn’t function at all, even if the problems with the second ovary are not related to service. Anything less than the complete removal or loss of use of both ovaries is rated 0%.

Code 7621: If the uterus slips down completely through the vagina, then it is rated 50%. If it slips down only partially through the vagina, then it is rated 30%.
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Code 7622: If the uterus does not slip down, but is significantly out of place, then it is rated under this code. If the displacement causes constant or frequent problems with menstrual periods, then it is rated 30%. If the displacement causes adhesions (scar tissue that causes the organs to stick together), and the menstrual periods are irregular, then it is rated 10%.
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Code 7623: If pregnancy causes the wall between the vagina and the rectum to tear, resulting in a rectocele (the rectum bulges into the vagina), or if it causes the wall between the bladder and the vagina to tear, resulting in a cystocele (the bladder bulges into the vagina), it is rated 50%. If the pregnancy causes the vagina to be loose or gaping, then it is rated 10%.

All three of these codes deal with the same basic thing: at least one of the pelvic organs (uterus, bladder, or rectum) is out of place and bulging into the vagina. Because of this, they are combining all three codes into a single code. Code 7622 and 7623 will not longer exist, and code 7621 will be changed as follows:

Code 7621: If any of the pelvic organs (the uterus, bladder, or rectum) are prolapsed (out of place) because of a disease, injury, or complications of pregnancy, it is rated under this code. This includes tears and bulges into the uterus or vagina, cystocele (the bladder bulges into the vagina), urethrocele (the urethra bulges into the vagina), rectocele (the rectum bulges into the vagina), enterocele (the small intestines and peritoneum bulge into the vagina), a perineal deficiency (the perineal muscles bulge into the vagina), or any combination. The ratings are based on how far the prolapsed organ protrudes into the vagina.

The severity of the prolapse is determined during examination by the Pelvic Organ Prolapse (POP) classification system as severe, moderate, or mild.

A 50% rating is given for a severe POP score where the prolapsed organ protrudes to within 2 cm of the vaginal opening.

A 30% rating is given for a moderate POP score where the prolapsed organ protrudes more than 1 cm past the hymen, but is more than 2 cm from the vaginal opening.

A 10% rating is given for a mild POP score where the prolapsed organ is within 1 cm below the hymen to 1 cm past the hymen.

Code 7627: Cancer of the female organs and breasts that is active is rated 100%. This 100% will continue for the first 6 months after the last treatment. The condition will then be reevaluated. If it is no longer active, then it will be rated on any lasting symptoms just like any benign condition.
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Code 7628: Benign tumors of the female organs and breasts are rated based on how they affect the systems around them….

Both of these codes consider breast cancer to be a female-only condition, but men can also get breast cancer. To fix this, codes 7627 and 7628 will only be for cancer and tumors of the female organs (not including the breasts).

Two new codes, 7630 and 7631, will be added for all breast cancer, male or female:

Code 7630: Cancer of the breasts that is active is rated 100%. This 100% will continue for the first 6 months after the last treatment. The condition will then be reevaluated. If it is no longer active, then it will be rated on any lasting symptoms just like any benign condition.

Code 7631: Tumors and other injuries of the breast are rated based on any remaining symptoms or on how they affect the systems around them. This includes scars, disfigurement, muscle loss, nerve damage, and any other complications.

I want to draw your attention to the fact that code 7631 not only includes benign tumors, but also any and all other injuries of the breast, like blast-trauma, or any complications to other parts of the body due to breast surgery. These codes will NOT replace code 7626 for removal of the breast.

Another new code is also being proposed to get female ratings more in line with the male ratings:

Code 7632: Female sexual arousal disorder (FSAD) is the inability get and stay aroused during sex. It is rated 0% unless there is physical damage to the genitals, in which case, it is rated under the codes for damaged parts. FSAD may be entitled to additional compensation under Special Monthly Compensation K.

These are all of the proposed changes to the Female Reproductive System. Again, let us know your thoughts, and we’ll send in a report with suggested changes to the committee. We’ll also let you know when all the changes are finalized and in effect.

12 comments:

  1. Now that FSAD may be recognized, what effect will it have as supporting evidence of MST, if any? As far as SMC(k), FASD should be considered the same way ED in men is. Yes, both vets may still be fertile, but the inability to perform is just as real in women as men. Additionally, the issue of repeated miscarriage from unknown etiology while on Active Duty should be considered as potentially ratable, and award SMC (k).

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    1. Thanks for your comment. You make some very valid points. With these new codes/ratings, FSAD will definitely be treated the same sexual dysfunction in men, which is far too long in coming. We'll add repeated miscarriages to our list of comments to submit. It's true that it is not currently being addressed at all, but could be a potentially significant issue. It'll be interesting to see how they respond to it if they do.

      As for FSAD being used as supportive evidence of MST, this is another great issue that they have not yet addressed. We'll make sure to ask this question, and will let you know if/when we get a response.

      Thank you so much for your excellent questions and issues to raise. We highly value the response of our veterans, and hope by encouraging this type of interaction, we might be able to affect change.

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    2. This is not true. Women will never be treated the same for sexual dysfunction. I was diagnosed with FSAD by my Dr., yet I had to get "approval" from a male psychiatrist in order to get my VA claim approved. This quack had NO idea what FSAD was - he spent 25 minutes of MY appt time looking up what FSAD was on his phone and then wrote in his summary that although I was diagnosed by someone else, he felt that I just had an emotional instability. OMG. And they wonder why no one wants to go get help.

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    3. I'm sorry to hear about your negative experience. While this is clearly still an issue, the VA is making changes to hopefully correct circumstances like yours. There is definitely still a ways to go, but changing the laws to ensure that the conditions are rated the same is a significant step. Hopefully through our encouragement, even bigger steps will be taken to ensure that each veteran is given the proper care.

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  2. I am trying to find information on uterine fibroids. Can anyone help me out?

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    1. Fibroids are considered "injuries" of the uterus for rating purposes and so are rated under code 7613.

      http://www.militarydisabilitymadeeasy.com/femalereproductive.html#diseases

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  3. Trying to find information about ectopic pregnancy.

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    1. Ectopic pregnancies are rated on whatever remaining symptoms that they cause. So if the fallopian tube is damaged or removed, it is rated under code 7614.

      http://www.militarydisabilitymadeeasy.com/femalereproductive.html#f

      Any other symptoms can be rated under the code that best covers the symptom.

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  4. I was diagnosed with cancer in the right breast and currently receiving 100% until I finish treatment. I wan to know what it will reduce to after treatment? The right breast had axillary sentienl node dissection only one node with a simple mastectomy. The left breast had a simple mastectomy.

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    1. A simple ("total") mastectomy is rated 50% for both breasts. It's rated under code 7626:

      http://www.militarydisabilitymadeeasy.com/femalereproductive.html#removal

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  5. Thank you Dr. Johnson,
    The reason I asked the question is I had axillary sentinel node removed in the right breast during my mastectomy does that change the rating to modified mastectomy rating?

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    1. Usually not. The removal of the sentinel lymph node is still considered a simple mastectomy. It usually only qualifies a modified radical mastectomy if all or most of the axillary lymph nodes are removed.

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