How the VA rates diabetes
Diabetes is rated on how much it takes to manage, not on how high the numbers are. The tiers are short and the first two are easy. The third has a phrase in it that the VA reads narrowly, and the real value of a diabetes rating is usually in the conditions it causes rather than the diabetes itself.
Diabetes mellitus is rated under diagnostic code 7913 in 38 CFR § 4.119, the endocrine section. Type 1 and type 2 use the same code.
The tiers
| Rating | What the schedule requires |
|---|---|
| 10% | Manageable by restricted diet only. |
| 20% | Requiring one or more daily injection of insulin and restricted diet; or oral hypoglycemic agent and restricted diet. |
| 40% | Requiring one or more daily injection of insulin, restricted diet, and regulation of activities. |
| 60% | Requiring insulin, restricted diet, and regulation of activities, with episodes of ketoacidosis or hypoglycemic reactions requiring one or two hospitalizations per year or twice-monthly visits to a diabetic care provider, plus complications that would not be compensable if separately evaluated. |
| 100% | Requiring more than one daily injection of insulin, restricted diet, and regulation of activities, with episodes requiring at least three hospitalizations per year or weekly visits to a diabetic care provider, plus either progressive loss of weight and strength or complications that would be compensable if separately evaluated. |
Most veterans with service-connected type 2 diabetes are rated 20%: they take metformin or insulin and watch their diet. Getting to 40% requires all three of insulin, diet, and regulation of activities, and that last phrase is where claims stall.
The schedule defines it in the 100% tier as "avoidance of strenuous occupational and recreational activities." The Veterans Court in Camacho v. Nicholson (2007) held that this means a medical necessity to avoid strenuous activity in order to control the diabetes, and that it must be established by medical evidence: a doctor has told you, in the record, to restrict activity because exertion destabilizes your blood sugar. A veteran who has chosen to be less active, or whose activity is limited by a different condition (the knees, the back), does not meet it. If your provider has in fact advised you to avoid strenuous activity because of hypoglycemic episodes, ask them to write that down in those words. Without it, the 40% tier is unreachable regardless of how much insulin you take.
Service connection: the Agent Orange presumption
Type 2 diabetes has been on the herbicide presumptive list since 2001. Veterans with qualifying exposure, Vietnam service between January 9, 1962 and May 7, 1975 (including the inland waterways and, since the Blue Water Navy Act of 2019, offshore within 12 nautical miles), the Korean DMZ from September 1967 to August 1971, Thailand air bases under the PACT Act's expanded rules, and the other locations in § 3.309(e) and § 3.307, are presumed service connected for type 2 diabetes with no nexus. A diagnosis plus qualifying service is the claim. The presumptive conditions guide explains the mechanics and how to reopen an old denial.
Outside the presumption, diabetes is claimed directly through in-service diagnosis or elevated glucose in the service treatment records, through the one-year chronic-disease presumption in § 3.309(a) if it reached a compensable degree within a year of separation, or as secondary to another service-connected condition: medications (some antipsychotics and long-term corticosteroids), pancreatic conditions, or, with a supporting opinion, conditions that drove weight gain. Note (2) to the code says that once diabetes is conclusively diagnosed, the VA will not order a glucose tolerance test just for rating purposes; the diagnosis in your record is enough.
The complications: where the rating actually lives
Note (1) to DC 7913 says to evaluate compensable complications of diabetes separately unless they are being used to support the 100% tier. Non-compensable complications are considered part of the diabetic process. The practical effect is that every condition diabetes causes gets its own rating, and these commonly add up to more than the diabetes rating:
- Peripheral neuropathy in each extremity, rated under the peripheral nerve codes as mild, moderate, or severe incomplete paralysis. Bilateral lower-extremity neuropathy at 10% or 20% each, with the bilateral factor, is nearly universal in long-standing diabetes. See how the VA rates nerve damage.
- Erectile dysfunction, rated 0% but carrying SMC-K, a flat monthly award.
- Diabetic nephropathy (kidney disease), rated under the renal codes in § 4.115a, with ratings from 0% to 100% depending on kidney function and whether dialysis is needed.
- Diabetic retinopathy and cataracts, under the eye codes in § 4.79.
- Hypertension and coronary artery disease, under § 4.104; heart disease is rated on the METs workload that brings on symptoms and can reach 60% or 100%. See how the VA rates hypertension.
- Stroke residuals, peripheral vascular disease, skin conditions, gastroparesis, and amputations, each under its own code.
Each complication needs its own diagnosis and a medical finding that it is attributable to the diabetes. For neuropathy, retinopathy, and nephropathy the attribution is usually made by the treating specialist as a matter of course; for the cardiovascular conditions it takes an opinion. List each complication as its own claimed condition: "peripheral neuropathy, left lower extremity, secondary to diabetes mellitus."
The exam
The diabetes DBQ asks about your treatment regimen (diet, oral agents, insulin and how many injections), whether regulation of activities is required, episodes of ketoacidosis or hypoglycemia and the hospitalizations or provider visits they caused, and a checklist of complications. Bring your medication list, your A1C history, your endocrinology or primary care notes, and a list of every complication with the specialist who diagnosed it. If the examiner marks "no" on regulation of activities and your provider has in fact restricted you, a letter from that provider is the evidence to submit with the claim or on appeal. Read Preparing for a C&P exam for the general approach.
The checklist
- A diagnosis of diabetes with the date and the current treatment regimen.
- For presumptive claims: proof of qualifying service location and dates.
- Pharmacy records showing insulin or oral agents.
- For the 40% tier and above: a provider's written statement that strenuous activity must be avoided to control the diabetes, and records of any hypoglycemic or ketoacidosis episodes with the hospitalizations or visits they required.
- Each complication listed as a separate claimed condition, with its diagnosis and the specialist's attribution to diabetes.
READY214's rating calculator applies the bilateral factor and VA rounding, so a 20% diabetes rating plus two neuropathies and a heart condition shows as the number the VA will actually pay. Free, no account needed.