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Through our blog, we jump deep into Military Disability topics, concerns, upcoming changes, etc. For a complete overview of the veteran's disability systems, ratings, and benefits, check out our website, www.MilitaryDisabilityMadeEasy.com. It has an immense amount of information, and should be able to address the majority of your questions very well.

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Monday, April 11, 2022

Comments Submitted to the VA on the Changes to the Ratings for the Respiratory System and the Ears, Nose, and Throat


The following are the comments we submitted on your behalf to the VA in regards to the proposed changes to the ratings of the Respiratory System and the Ears, Nose, and Throat

After the VA publishes their proposed changes, they always allow a period for comments. Thank you for submitting your comments to us so that we could submit them in a unified front to the VA. Hopefully, we will be able to effect change and make the rating system fairer for all veterans. 

Here are the comments we submitted for the Respiratory System and the Ears, Nose, and Throat:

 

We at www.MilitaryDisabilityMadeEasy.com would like to submit the following comments on behalf of our staff and veterans in response to the proposed changes to the ratings of the Respiratory System and Ears, Nose, and Throat.

 

Comment #1. 

 

The addition of the 100% rating for peripheral vestibular disorders, code 6204, will be a huge benefit to veterans with very severe conditions. However, this leaves a large hole between the 30% and 100% rating. With the acknowledgement of a wide-range of symptoms and severities, it seems like these rating options will under-rate many conditions that interfere with work/self-care more significantly than the 30% rating requires but not completely, like the 100% requires. 

 

Additional rating levels would greatly benefit veterans who may require occasional assistance with tasks, but who can accomplish tasks themselves with modifications/accommodations other times. Perhaps a more tiered rating system that allows for task-interference a percentage of the time (ex. requires modification and/or accommodation 50% of the time, requires assistance of others 25% of the time, etc.), like the recently proposed changes to the mental disorder ratings, would allow for ratings that more accurately reflect the impact of the condition on work and daily life.

 

Comment #2. 

 

For the proposed General Rating Formula for Respiratory Conditions, the 100% ratings for acute respiratory failure and outpatient oxygen therapy are not included. However, in §4.96 paragraph C, the notes regarding not requiring PFTs when there is acute respiratory failure or outpatient oxygen therapy remain. These notes imply that these conditions can be rated without the need for PFTs, but the ratings for them have been removed. Without these tests performed, what is the intention for rating acute respiratory failure and the need for oxygen therapy? If the intent is for them to not be independently rated, then removing them from §4.96 (c) would ensure the PFTs needed to rate the conditions are performed. Otherwise, there is no system in place to correctly rate them.

 

Comment #3. 

 

The removal of an independent rating for tinnitus based on the assertion that tinnitus is a symptom only and not an independent condition is not fully supported by medical research. There are a number of studies that acknowledge the presence of tinnitus in the absence of hearing loss or other identifiable underlying conditions, and a 2017 publication summarized that “the majority of tinnitus patients are affected by chronic idiopathic tinnitus.” 

 

In order to ensure that veterans are properly compensated for tinnitus in cases without a ratable underlying cause, we ask the VA to consider retaining an independent tinnitus code, but possibly adding instruction that limits the application of the code when an underlying condition (like Meniere’s or hearing loss) is identified and rated. 

 

https://pubmed.ncbi.nlm.nih.gov/27995315/

 

https://pubmed.ncbi.nlm.nih.gov/31644709/

 

Friday, March 11, 2022

Comments Submitted to the VA on the Changes to the Ratings for the Digestive System


The following are the comments we submitted on your behalf to the VA in regards to thproposed changes to the ratings of the Digestive System. After the VA publishes their proposed changes, they always allow a period for comments. Thank you for submitting your comments to us so that we could submit them in a unified front to the VA. Hopefully, we will be able to effect change and make the rating system more fair for all veterans. 


Here are the comments we submitted for the Digestive System:

 

We at www.MilitaryDisabilityMadeEasy.com would like to submit the following comments on behalf of our staff and veterans in response to the proposed changes to the ratings of the Digestive System.

 

Comment #1. 

 

For code 7203, Esophagus, stricture of, the definition of “refractory” requires at least 5 dilation treatments at 2-week intervals. With the rating requirements, the minimum rating this would qualify for would be 50%, since that requires 3 or more dilation treatments/year. Yet, refractory strictures are included on the 30% rating, though by definition they cannot qualify. Please adjust the requirements to clarify exactly how many dilation treatments are required for the various rating levels and for the condition to be considered refractory.

 

Comment #2.

 

The rationale for rating both GERD (code 7206) and Hiatal Hernia (code 7346) under code 7203 states that “these criteria consider symptoms of esophageal obstruction and irritation.” This is not the case, however. The wording of code 7203 only includes dysphagia as a ratable symptom. The 0% and 10% ratings both require no other symptoms and the 30% rating requires dilation. Under the current rating requirements these conditions could both easily qualify for a 30% based on heartburn, reflux, pain, etc., but there is no clear way to rate these symptoms on the proposed requirements for 7203. Both of these conditions, therefore, will have no way to be properly rated on the symptoms they cause. Please consider adjusting the rating options so that these symptoms can continue to contribute to the ratings for these conditions.

 

Comment #3.

 

For code 7329, the proposed ratings for 60% and 100% are inconsistent. The 60% rating simply states a “total colectomy without high-output syndrome.” A logical 100% rating would then simply be a total colectomy with high-output syndrome. Instead, additional requirements are included in order to achieve the 100% rating (ileostomy, 3 or more episodes of dehydration, etc.). 

 

Because of the significant jump between rating requirements, inconsistent ratings are likely to be applied in cases that fall between these two requirements. For instant, a total colectomy with high-output syndrome, but no ileostomy. 

 

We request that the VA clarify the rating requirements to ensure appropriate ratings between the 60% and 100% levels, with the potential to add an intermediary 80% rating to cover the cases that fall between. 

 

Comment #4.

 

Under the 60%, 30%, and 10% ratings for code 7332, the incontinence requires “wearing” a pad a specific number of times each week or month. 

 

The “wearing” requirement for the pads is a bit difficult to distinguish unless the incontinence episodes are 100% predictable. If there are two episodes/week, the patient would likely wear pads every day since they wouldn’t be able to predict when the episodes would occur. 

 

The 100% rating uses “changing” as the pad requirement instead of just “wearing.” A similar wording of the 60% and 30% would then allow pads to be worn regularly, just in case, but only the need to change them after an episodewould qualify for the rating. 

 

Comment #5. 

 

Dietary modification is used as rating criteria under a number of codes, but the phrasing is inconsistent. “Prescribed dietary modification,” “dietary intervention,” “dietary restriction,” etc. In order to clarify and ensure consistent application, we request that the terms are either standardized throughout if all mean the same thing, or clearly defined if there are differences. 

 

Similarly, though numerous important terms are clearly defined in 4.112, these terms are not consistently used throughout the proposed ratings. For example, under code 7355, “weight loss resulting in wasting and nutritional deficiencies” does not clearly specify weight loss as defined in 4.112. Similarly, the term “malabsorption syndrome” is used in this code, but not defined in the rating schedule. It ultimately results in undernutrition, so “undernutrition” could be used in place of it since the defining symptoms support the accompanying ratings. Again, consistency in terminology throughout will greatly help reduce confusion and aid consistent application. 

 

Comment #6.

 

For code 7347, a 60% rating requires hospitalization for complications of pain or enteral feeding. Enteral feeding is not included in any of the other rating options for this code. Under other proposed codes, enteral feeding is rated 80% with no caveats for number of hospitalizations or complications. Further clarification is needed on how to rate this condition if it requires enteral feeding, regardless of whether or not that feeding causes complications. Please also consider applying the 80% rating for enteral feeding in order for it to align with the rest of the proposed ratings.

 

Comment #7.

 

Under code 7356, the wording for the 50% rating is unclear. 

 

“With recurrent emergency treatment for episodes of intestinal obstruction or regurgitation due to poor gastric emptying, abdominal pain, recurrent nausea, or recurrent vomiting.” 

 

Is the emergency treatment only for the intestinal obstruction or also for the regurgitation? Is the obstruction also “due to poor gastric emptying, abdominal pain, recurrent nausea, or recurrent vomiting” or is that only for the regurgitation? Adjusted wording for further clarification would be appreciated. 

 

Similarly, the 30% rating requires symptoms of CIPO and intestinal motility disorder, but CIPO is an intestinal motility disorder, so this is repetitive and misleading, implying that these conditions are separate and distinct with different symptoms. Please clarify for clarity and correct application.

 

Thanks for considering our comments on the proposed changes to the ratings of the Digestive System. 

Wednesday, March 9, 2022

-NEW- Proposed Changes to the Ratings of the Respiratory System

On February 15th, 2022, the VA published proposed changes to the ratings of the Respiratory System.

These were published along with changes to the Ears, Nose, and Throat which we discuss here


 

The current VASRD does not include an Ears, Nose, and Throat section. Instead, the Ears have their own section, and the Nose and Throat are included in the Respiratory section. The VA proposes to move the Nose and Throat conditions out of the Respiratory System and combine them with the Ears since they are associated together in modern medicine.  

 

With these changes, the VA only has one more section left, the Nervous System, until they complete the full rewrite of the VASRD that began in 2014. In addition to the Ear, Nose, and Throat and Respiratory System, the VA has not yet published the final changes to the Digestive System and Mental Disorders

 

With each set of proposed changes, the VA allows a period in which comments can be submitted. The VA then takes each comment into consideration and makes any additional changes that are warranted before publishing the final ruling. 

 

We encourage you to submit any comments you might have on these proposed changes to the Respiratory System to us either by commenting on this post or by contacting us through our website. All comments must be received by April 1st, 2022. 

 

We will then compile all of your comments into a single report and submit it on your behalf to the VA, just as we’ve done for the other sections (see the Skin Comments). This is a great opportunity to really make a difference, so please let us know your thoughts. 

 

The following are the VA’s new proposed changes to the ratings for the Respiratory System. The changes are fairly extensive, so we’ll walk through each, one at a time.

 

For each condition, the small, indented parts are the codes as they are right now. Click on the links to be taken to the discussion of that code on our site. After the current code, we’ll discuss the proposed changes and the VA’s justification.

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Nose and Throat Conditions

 

The VA currently includes conditions of the nose and throat in the Respiratory System section of the VASRD. 

 

They are proposing to move the codes for nose and throat conditions from the Respiratory System section to the Ear section of the VASRD, creating an Ear, Nose, and Throat section. 

 

The ear, nose, and throat (ENT) are commonly treated together in the medical community, and this change would align the VASRD with that standard.

 

You can find all the proposed changes to the Nose and Throat conditions in our post discussing the Ear, Nose, and Throat section.

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Respiratory Rating System

 

The Respiratory Rating System is fairly extensive, so we aren’t going to reproduce the entire thing here. You can find the current system on our site via the link above.

 

-Proposed- Respiratory Rating System

 

The Respiratory Rating System is used to rate all respiratory conditions unless otherwise noted. 

 

Only a single respiratory condition can be rated. If multiple conditions are present, the one that causes the main disability is rated. If, however, the overall respiratory picture is more severe than is covered by this rating, the rating can be increased to the next highest rating. 

 

The only condition that can be rated in addition to other respiratory conditions is Sleep Apnea. 

 

Ratings for respiratory conditions are based on how well the lungs take in air, absorb oxygen into the blood, and then exhale the left-over gases. Pulmonary function tests (PFTs) are performed to record the proper functioning of the lungs and their effects on the entire body.

 

Every PFT is not required when the VO2 Max has been tested and is 20 ml/kg/min or less, there has been one or more episodes of respiratory failure, or when regular oxygen therapy is needed outside of a medical facility.

 

When deciding which test result to use to rate the condition, the one that the examining physician feels most closely reflects the nature of the condition must be used. If they all accurately reflect the condition, then the one that gives the highest rating can be used. If any of the test results are not consistent with the other tests or overall condition, then the examining physician must explain why that test result should not be used to rate the condition.

 

If there is a heart condition in addition to the respiratory condition, only one can be rated using METs. The other condition must be rated on other rating criteria. 

 

The ratings:

 

Test/Requirement

Result/Condition

Rating

FVC

Less than 50%

100%

FVC

50-64%

60%

FVC

65-74%

30%

FVC

75-80%

10%

FEV-1

Less than 45%

100%

FEV-1

45-55%

60%

FEV-1

56-70%

30%

FEV-1

71-80%

10%

DLCO (SB)

Less than 40%

100%

DLCO (SB)

40-55%

60%

DLCO (SB)

56-65%

30%

DLCO (SB)

66-80%

10%

FEV-1/FVC

Less than 40%

100%

FEV-1/FVC

40-55%

60%

FEV-1/FVC

56-70%

30%

FEV-1/FVC

71-80%

10%

VO2 Max

Less than 10.5 ml/kg/min

100%

VO2 Max

10.5-17.5

60%

VO2 Max

17.6-24.5

30%

METs

3 or less

100%

METs

3.1-5.0

60%

METs

5.1-7.0

30%

 

The VA is proposing significant changes to the Respiratory Rating System in order to update the tests, ratings, and practices to modern medical understandings. 

 

The ratings themselves will not change very much, but the VA is removing the heart condition ratings, so those can be rated separately, and the rating for oxygen use since this no longer accurately reflects the level of disability. They are also adding rating options for additional PFTs, as well as METs, which are already used to rate heart conditions related to respiratory conditions. This will align the respiratory and heart ratings to create more consistency.

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Code 6600chronic bronchitis, continues to be rated on the Respiratory Rating System. 

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-Current- Code 6601Bronchiectasis is a condition where part of the bronchial tree becomes enlarged and causes obstruction of the airflow. This is a permanent condition that cannot be reversed.

 

It is either rated on the Respiratory Rating System or on incapacitating episodes below, whichever provides the highest rating. The definition of an “incapacitating episode” for rating this condition is a period where there is an active infection in the lungs, and it requires bed rest and treatment by a physician.

 

If there are a total of at least 6 weeks of incapacitating episodes each year, it is rated 100%.

 

If there are a total of 4 to 6 weeks of incapacitating episodes each year, or if there is constant coughing of mucous mixed with puss or blood that requires near-constant antibiotic treatment with anorexia and weight loss, it is rated 60%.

 

If there are a total of 2 to 4 weeks of incapacitating episodes each year, or if there is daily coughing occasionally of muscous mixed with puss or blood that requires between 4 to 6 weeks of antibiotic treatment 3 or more times a year, it is rated 30%.

 

If there is occasional coughing with infections requiring antibiotics 2 or more times a year, it is rated 10%.

 

-Proposed- Code 6601Bronchiectasis is a condition where part of the bronchial tree becomes enlarged and causes obstruction of the airflow. This is a permanent condition that cannot be reversed. It is rated on the Respiratory Rating System.

 

The VA proposes to remove rating requirements based on vague incapacitating episodes and simply rate this condition on the new Respiratory Rating System. 

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Codes 6603pulmonary emphysema, and 6604chronic obstructive pulmonary disease, continue to be rated on the Respiratory Rating System. 

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The VA is proposing very few changes for code 6602asthma, so we won’t reproduce the entire thing here. The only significant change is to update the FEV-1 requirements for the 100% rating to less than 45% and the 60% rating to 45-55%. Everything less remains the same. 

 

Test/Requirement

Result/Condition

Rating

FEV-1

Less than 45%

100%

FEV-1

45-55%

60%

FEV-1

56-70%

30%

FEV-1

71-80%

10%

FEV-1/FVC

Less than 40%

100%

FEV-1/FVC

40-55%

60%

FEV-1/FVC

56-70%

30%

FEV-1/FVC

71-80%

10%

Medical Care

2 or more attacks per week with respiratory failure that requires immediate medical care

100%

Medical Care

Requires monthly doctor visits

60%

Medication

Requires daily HIGH doses of corticosteroids or immunosuppressive medications taken by mouth or by injection

100%

Medication

Requires the use of corticosteroid medications taken by mouth or by injection 3 of more times a year

60%

Medication

Requires occasional use of inhaled anti-inflammatory medication

30%

Medication

Requires daily bronchodilator therapy taken by mouth or inhaled

30%

Medication

Requires occasional bronchodilator therapy taken by mouth or inhaled

10%

 

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Code 6730 for active pulmonary tuberculosis remains the same. 

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-Current- Code 6731: Inactive pulmonary tuberculosis is rated on the lasting symptoms or complications. If it causes restrictive heart disease or interstitial lung disease, then it will be rated on those conditions. Obstructive lung disease is rated as chronic bronchitis under code 6600, and a Thoracoplasty is rated under code 5297.

 

-Proposed- Code 6731: Inactive pulmonary tuberculosis is rated on the Respiratory Rating System. If a thoracoplasty was performed, it is rated under code 5297.

 

The VA proposes to rate inactive tuberculosis on the new Respiratory Rating System as they feel this system accurately covers the residuals of pulmonary tuberculosis. 

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Code 6732 for tuberculous pleurisy remains the same. 

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-Current- Code 6817: All pulmonary vascular diseases are rated under this code. These conditions affect the blood vessels leading to and from the lungs.

 

If the condition causes Pulmonary hypertension, Chronic Pulmonary Thrombo-embolism with pulmonary hypertension, Right Ventricular Hypertrophy, right heart failure, or pulmonary hypertension with right heart failure or right ventricular hypertrophy caused by the blockage of arteries or veins in the lungs, it is rated 100%.

 

If the condition causes pulmonary thrombo-embolism that requires anticoagulant therapy, it is rated 60%. A 60% rating is also given if surgery has been done on the Inferior Vena Cava and there is no evidence of pulmonary hypertension or any other problems with the right ventricle.

 

If there has been a pulmonary embolism and it has been treated and cleared, but the conditions still causes symptoms, it is either rated 30% under this code or it can be rated under the code of the symptom (like 6600 for bronchitis or 6844 for pleural effusion or fibrosis), whichever provides the highest rating. Only one code can be used, however, even if there are multiple symptoms. If there are no symptoms, it is rated 0%.

 

-Proposed- Code 6817: Pulmonary thromboembolic disease occurs when blood clots travel to the blood vessels leading to and from the lungs.

 

A 100% rating is given if the arteries or veins are consistently blocked and there is either pulmonary hypertension or right ventricular hypertrophy.

 

A 60% rating is given if the condition requires anticoagulant therapy or if surgery has been done on the Inferior Vena Cava and there is no evidence of pulmonary hypertension or any other problems with the right ventricle.

A 30% rating is given if the clot has been cleared, but the condition still causes symptoms. If it provides a higher rating, the condition can instead be rated under the code of the main symptom (like 6600 for bronchitis or 6844 for pleural effusion or fibrosis). Only one code can be used, however, even if there are multiple symptoms. 

 

A 0% rating is given if the clot has been cleared and there are no symptoms.

 

This condition cannot be rated in addition to a heart condition, so when both are present, a single rating is given for the main disability. The only respiratory condition that can be rated in addition to this code is sleep apnea.

 

The VA proposes to change the name of this condition to “pulmonary thromboembolic disease” stating that this is the more commonly used name in modern medicine. The ratings are not significantly changing, but the 100% rating for primary pulmonary hypertension is being removed as this condition will now be rated under its own code (see below), and the overall criteria simplified to focus on the main disabilities caused by this condition.

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-Proposed NEW Code- Code 6849: Chronic pulmonary hypertension is high blood pressure between the lungs and the heart. The condition can cause the right ventricle of the heart to swell, resulting in poor lung and heart function. 

 

It is rated on the size of the right ventricle and pulmonary/cardiovascular test results: VO2 Max, METs, and BNPs. VO2 Max and METs are discussed in the Respiratory Rating System. Brain natriuretic peptides (BNP) are a type of protein made by the heart when it is failing. The higher the number, the worse the heart failure.

 

A 100% rating is given if the right ventricle is more than 4 cm and either the VO2 Max is less than 15 or there are 3 METs or less.

 

A 60% rating is given if the right ventricle is more than 4 cm and either the VO2 Max is 15-20, there are 3.1-5.0 METs, or the BNP is greater than 500.

 

A 30% rating is given if the right ventricle is 3-4 cm and either there are 5.1-7.0 METs or the BNP is 100-500.

 

A 0% rating is given if either the VO2 Max is greater than 20 or the BNP is less than 100.

 

This condition cannot be rated in addition to a heart condition, so when both are present, a single rating is given for the main disability. The only respiratory condition that can be rated in addition to this code is sleep apnea.

 

The VA proposes to add a new code for pulmonary hypertension as it is currently rated analogously, but none of the current codes fully cover the unique symptoms it can cause. The new rating system considers how the condition affects both the lungs and the heart. 

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-Current- Code 6819: Any malignant cancer of the respiratory system (not including skin growths) is rated 100% while it is active. This 100% rating continues for 6 months following the last treatment. The condition is then re-evaluated and any left-over symptoms or complications are rated separately.

 

-Current- Code 6820: Any tumor of the respiratory system is rated on any systems or functions that it affects. For example, if the tumor pushes on the Larynx and makes it hard to speak, then it would be rated as aphonia, code 6519.

 

-Proposed- Code 6819: Any malignant cancer of the respiratory system (not including skin growths) is rated 100% while it is active. This 100% rating continues for 6 months following the last treatment. The condition is then re-evaluated and rated on the Respiratory Rating System.

 

-Proposed- Code 6820: Any tumor of the respiratory system is rated on the Respiratory Rating System.

 

The only proposed change to these codes is for any residuals to be rated on the Respiratory Rating System.

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For all Interstitial Lung Diseases, the VA proposes removing the current rating system, and instead rating all of these conditions (codes 6825-6833 and 6846) on the Respiratory Rating System. The current system is already similar, but with fewer rating options, so this will broaden the rating requirements. 

 

The proposed ratings also add an additional 10% to any rating for these conditions if they are being treated either with more than 20mg of oral prednisone daily or with daily non-steroidal immunosuppressive medications. 

 

Non-steroidal immunosuppressives include, but are not limited to, azathioprine, cyclophosphamide, colchicine, penicillamine, and etanercept.

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Codes 6834-6839 for Mycotic Lung Diseases remain the same. 

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For all Restrictive Lung Diseases, the VA proposes removing the current rating system, and instead rating all of these conditions (codes 6840-6845) on the Respiratory Rating System. The current system is already similar, but with fewer rating options, so this will broaden the rating requirements. 

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-Current- Code 6847: Any sleep apnea syndrome is rated under this code. Sleep apnea is a disorder that occurs while asleep. There is either a pause when breathing that can last up to a few minutes or there is very shallow, low breathing. Central sleep apnea is caused by a decrease in the “action” of breathing—the body doesn’t try as hard to breathe properly. Obstructive sleep apnea is caused by a block in the airways, like a narrowing of the airway passages or an excess of mucus. This causes severe snoring. Mixed sleep apnea is a combination of both central and obstructive.

 

Sleep apnea can cause a significant impairment of the heart and respiratory system by limiting the amount of air that is taken in during the hours of sleep.

 

If the condition continues over a long period of time and causes respiratory failure with right heart ventricle failure or with too much carbon dioxide in the blood stream, or if it requires a Tracheotomy, it is rated 100%.

 

If it requires the use of breathing machines like a continuous positive airway pressure (CPAP) machine during sleep, it is rated 50%.

 

If it causes serious sleepiness during the daytime or not feeling rested after sleeping, it is rated 30%.

 

If it is diagnosed by a sleep test, but it doesn’t cause any significant symptoms, it is rated 0%.

 

-Proposed- Code 6847: Any sleep apnea syndrome is rated under this code. Sleep apnea is a disorder that occurs while asleep. There is either a pause when breathing that can last up to a few minutes or there is very shallow, low breathing. 

 

Central sleep apnea is caused by a decrease in the “action” of breathing—the body doesn’t try as hard to breathe properly. Obstructive sleep apnea is caused by a block in the airways, like a narrowing of the airway passages or an excess of mucus. This causes severe snoring. Mixed sleep apnea is a combination of both central and obstructive.

 

Sleep apnea can cause a significant impairment of the heart and respiratory system by limiting the amount of air that is taken in during the hours of sleep.

 

A 100% rating is given if there is end-organ damage (damage of the heart, kidneys, brain, or eyes) and the condition does not respond to treatment or cannot be treated.

 

A 50% rating is given if the condition does not respond to treatment or cannot be treated.

 

A 10% rating is given if the symptoms are only partially resolved with treatment.

 

A 0% rating is given if the symptoms are fully resolved with or without treatment.

 

The VA is proposing huge changes for sleep apnea. Currently, it is rated on the treatments required for management. However, the purpose of the ratings is to compensate veterans for loss of earning capacity. The VA therefore proposes instead to rate sleep apnea on any symptoms that remain after treatment. This does put these ratings more in line with the ratings for other conditions, but will make it harder to receive a higher rating under this code. 

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-Proposed NEW Code- Code 6848:  Lung transplants are rated under this code. The condition is rated 100% for 1 year following discharge from the hospital after the surgery. It is then rated on the Respiratory Rating System based on any remaining symptoms with a minimum 30% rating. 

 

The VA proposes adding a code for lung transplants in order to ensure consistent and correct ratings.

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