Diabetes VA Rating and Diagnostic Code 7913 Criteria

Cumulative criteria and breakdown of each rating tier

A key legal rule governing Diagnostic Code 7913 is that the rating tiers from 10% through 100% are successive and cumulative. Federal appellate decisions interpreting 38 CFR 4.119 (including Camacho v. Nicholson and Middleton v. Shinseki) confirmed that because criteria in the 40%, 60%, and 100% tiers are joined by “and” rather than “or,” a veteran must satisfy every element of a lower tier before advancing to the next higher percentage.

10 percent rating: Restricted diet only

The minimum compensable rating under Diagnostic Code 7913 is 10%, assigned when diagnosed diabetes mellitus is manageable by a restricted diet only. Medical records must show a confirmed diagnosis of diabetes mellitus and indicate that a provider instructed the veteran to follow a diabetic or carbohydrate-restricted diet without oral medication or insulin. Prediabetes or impaired fasting glucose alone does not meet the clinical definition of diabetes mellitus and is not compensable.

20 percent rating: Oral hypoglycemic agents or insulin with restricted diet

A 20% evaluation is the most common initial rating for Type 2 diabetes and applies under either of two pathways:

1. Oral hypoglycemic agent and restricted diet: The veteran follows a prescribed diabetic diet and takes one or more oral blood-glucose-lowering medications, such as metformin, sulfonylureas (glipizide, glimepiride), DPP-4 inhibitors (sitagliptin, linagliptin), SGLT2 inhibitors (empagliflozin, dapagliflozin), or thiazolidinediones (pioglitazone).
2. One or more daily injections of insulin and restricted diet: The veteran requires daily insulin therapy (or an insulin pump) and a restricted diet, without a medical requirement to regulate strenuous occupational and recreational activities.

Because the 40% tier explicitly requires daily insulin injections, a veteran who takes oral medications (or non-insulin injectable GLP-1 receptor agonists without insulin) alongside a restricted diet and activity limitations remains at 20% under Diagnostic Code 7913, though compensable complications are rated separately.

40 percent rating: Insulin, restricted diet, and regulation of activities

To qualify for a 40% rating under Diagnostic Code 7913, a veteran must satisfy all three cumulative requirements:

1. One or more daily injection of insulin (including basal or bolus injections or an insulin pump).
2. Restricted diet medically prescribed for diabetes care.
3. Regulation of activities, explained in the regulation’s 100% criteria as (avoidance of strenuous occupational and recreational activities).

The “regulation of activities” element distinguishes a 40% rating from 20% for insulin-dependent veterans. Routine advice encouraging exercise for weight control does not satisfy this criterion. Instead, medical records or the C&P examiner must confirm that a clinician requires the veteran to avoid strenuous work and recreational exertion specifically because strenuous activity triggers dangerous blood sugar swings or hypoglycemia. Activity limitations caused solely by an unrelated back or knee injury do not satisfy this requirement.

60 percent and 100 percent ratings: Unstable control and hospitalizations

• 60% rating: Requires all three elements of the 40% rating, plus episodes of ketoacidosis or hypoglycemic reactions requiring one or two hospitalizations per year or twice-a-month visits to a diabetic care provider, plus complications that would not be compensable if separately evaluated (such as a diabetic complication that would receive a 0% rating on its own).
• 100% rating: Requires more than one daily injection of insulin, a restricted diet, and regulation of activities, plus episodes of ketoacidosis or hypoglycemic reactions 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.

Note (1) and separate ratings for diabetic complications

For many veterans with Type 2 diabetes, the overall combined rating is driven more by Note (1) to Diagnostic Code 7913 than by the base 10%, 20%, or 40% endocrine rating. Note (1) instructs the VA to evaluate compensable complications of diabetes separately under 38 CFR 3.310(a) unless those complications are used to support a 100% evaluation under DC 7913:

• Diabetic Peripheral Neuropathy (38 CFR 4.124a): Nerve damage causing numbness, tingling, burning pain, decreased reflexes, or weakness is rated separately for each affected extremity (commonly Sciatic DC 8520 or Common Peroneal DC 8521 for legs, and Median or Ulnar DCs 8515–8516 for arms) based on mild, moderate, moderately severe, or severe incomplete paralysis. Paired extremity ratings qualify for the bilateral factor under 38 CFR 4.26.
• Diabetic Nephropathy (38 CFR 4.115a, DC 7541): Renal dysfunction is evaluated at 0%, 30%, 60%, 80%, or 100% based on estimated Glomerular Filtration Rate (eGFR), persistent albuminuria, edema, or regular dialysis.
• Diabetic Retinopathy and Eye Conditions (38 CFR 4.79, DC 6006): Evaluated on impaired central visual acuity, visual field loss, diplopia, or secondary cataracts and glaucoma.
• Cardiovascular and Peripheral Vascular Disease (38 CFR 4.104): Includes coronary artery disease (DC 7005), hypertension with diabetic renal disease (DC 7101), and peripheral arterial disease (DC 7114), rated 20% to 100% per limb by claudication, ankle-brachial index (ABI), or ischemic ulcers.
• Erectile Dysfunction (DC 7522) and SMC-K (38 CFR 3.350(a)): Rated 0% without deformity (a noncompensable complication under Note 1), and qualifies for Special Monthly Compensation (SMC-K) for loss of use of a creative organ.

Agent Orange and herbicide presumptive service connection (38 CFR 3.309(e))

Under 38 CFR 3.309(e) and 38 CFR 3.307(a)(6), Type 2 diabetes (also known as Type II diabetes mellitus or adult-onset diabetes) is a presumptive disease associated with tactical herbicide (Agent Orange) exposure. If Type 2 diabetes manifests to 10% or more at any time after service, the VA presumes service connection without requiring in-service medical records or a nexus opinion. This presumption applies only to Type 2 diabetes, not Type 1 diabetes.

Qualifying service locations (the Vietnam, Korean DMZ, and C-123 provisions appear in 38 CFR 3.307(a)(6); Thailand, Laos, Cambodia, Guam, American Samoa, and Johnston Atoll are listed in 38 U.S.C. § 1116(d)) listed on the VA Agent Orange eligibility page include:

• Republic of Vietnam (land, inland waterways, and Blue Water Navy vessels within 12 nautical miles) from January 9, 1962, to May 7, 1975.
• Thailand at any U.S. or Royal Thai military base from January 9, 1962, to June 30, 1976.
• Laos (December 1, 1965 – September 30, 1969) and Cambodia at Mimot or Krek, Kampong Cham Province (April 16 – April 30, 1969).
• Guam or American Samoa (January 9, 1962 – July 31, 1980) and Johnston Atoll (January 1, 1972 – September 30, 1977).
• Korean Demilitarized Zone (DMZ) from September 1, 1967, to August 31, 1971 (the date range on the VA Agent Orange eligibility page and in 38 CFR 3.814(c)(2); note that 38 CFR 3.307(a)(6)(iv) still states April 1, 1968, for conceded herbicide exposure, and 38 U.S.C. 1116 does not list the Korean DMZ), or regular service on herbicide-contaminated C-123 aircraft.

Direct, one-year chronic, and secondary service connection pathways

Veterans without herbicide exposure can establish service connection through three pathways:

1. Direct service connection (38 CFR 3.303): Established when diabetes was diagnosed on active duty, or when service treatment records show persistent hyperglycemia, glycosuria, or elevated HbA1c linked by a nexus opinion to a post-service diagnosis.
2. One-year chronic disease presumption (38 CFR 3.309(a) and 38 CFR 3.307(a)(3)): Diabetes mellitus is a statutory chronic disease presumed service connected if it manifests to 10% or more within one year of discharge from 90 days or more of active service.
3. Secondary service connection (38 CFR 3.310(a)): With a medical nexus opinion showing causation or permanent aggravation, Type 2 diabetes may be claimed secondary to systemic corticosteroids (such as oral steroids for asthma), psychotropic medications or chronic stress in PTSD or depression, sleep apnea, or obesity as an intermediate step (VAOPGCPREC 1-2017) when service-connected back pain, knee pain, or mental health conditions prevent exercise and cause weight gain leading to Type 2 diabetes.

How the C&P exam and Diabetes Mellitus DBQ measure your condition

During a C&P exam, the clinician completes the Diabetes Mellitus Disability Benefits Questionnaire (DBQ), verified on the VA Public DBQs page:

1. Diagnosis (Section 1): Records Diabetes Mellitus Type I or Type II, ICD code, and diagnosis date, or impaired fasting glucose.
2. Treatment & Activity Regulation (Section 2): Records restricted diet, oral hypoglycemic agents, daily insulin injection frequency (1 vs. more than 1), and whether you require regulation of activities (“avoidance of strenuous occupational and recreational activities” with the intention of avoiding hypoglycemic episodes), requiring examples if “Yes.” Also records ketoacidosis or hypoglycemia hospitalizations and diabetic care visits over the past 12 months, plus progressive weight and strength loss.
3. Complications & Labs (Sections 3–5): Identifies peripheral neuropathy, nephropathy, retinopathy, erectile dysfunction, cardiovascular or peripheral vascular disease, stroke, and skin conditions (triggering specialist DBQs), and records diagnostic labs (FPG ≥ 126 mg/dL or HbA1c ≥ 6.5% on two or more occasions, or 2-hour OGTT ≥ 200 mg/dL). Under Note (2) to DC 7913, once diabetes is conclusively diagnosed, a glucose tolerance test is not ordered solely for rating purposes.

Combining ratings and getting accredited help

Separate ratings for diabetes and its complications combine under the whole-person table in 38 CFR 4.25, and paired-extremity neuropathy or vascular ratings receive the 10% bilateral factor under 38 CFR 4.26. Model your overall rating with our VA combined rating calculator and estimate retroactive pay with our VA back pay calculator.

For help with a claim or appeal, Veterans Service Organizations (VSOs) such as the DAV, VFW, and American Legion provide representation free of charge, while VA-accredited claims agents and attorneys handle appeals. No representative can guarantee an outcome; verify credentials via the VA Office of General Counsel Accreditation Search.