Skin Cancer VA Rating: Melanoma, Basal Cell, and Squamous Cell Criteria

Complete skin cancer VA rating table (DC 7818, DC 7833, and residual codes)

The table below lists the rating criteria for DC 7818, DC 7833, and their residual scar and disfigurement codes in 38 CFR 4.118.

(Note: the regulation’s cross-references for DCs 7818 and 7833 still list DC 7803, but that code was removed effective October 23, 2008 (73 FR 54708), and unstable scars are now rated under DC 7804.)

The 100% treatment rule vs. treatment confined to the skin

Both DC 7818 and DC 7833 contain the same binding Note in 38 CFR 4.118:

“Note: If a skin malignancy requires therapy that is comparable to that used for systemic malignancies, i.e., systemic chemotherapy, X-ray therapy more extensive than to the skin, or surgery more extensive than wide local excision, a 100-percent evaluation will be assigned from the date of onset of treatment, and will continue, with a mandatory VA examination six months following the completion of such antineoplastic treatment, and any change in evaluation based upon that or any subsequent examination will be subject to the provisions of § 3.105(e) of this chapter. If there has been no local recurrence or metastasis, evaluation will then be made on residuals. If treatment is confined to the skin, the provisions for a 100-percent evaluation do not apply.”

• When the 100% rating DOES apply: Starting at the onset of treatment when the skin cancer requires (1) surgery more extensive than wide local excision (sentinel lymph node biopsy, regional lymph node dissection, amputation, parotidectomy, or deep resection into muscle, cartilage, or bone); (2) systemic chemotherapy or systemic immunotherapy/targeted therapy (pembrolizumab, nivolumab, ipilimumab, cemiplimab, BRAF/MEK inhibitors, or vismodegib); or (3) X-ray (radiation) therapy more extensive than to the skin (radiation to regional lymph nodes or deep tissues).
• When the 100% rating DOES NOT apply (“confined to the skin”): When treatment is limited to simple or wide local excision confined to the skin, Mohs surgery, curettage, cryosurgery, superficial skin radiation, or topical chemotherapy creams (5-FU or imiquimod). Here, the VA skips 100% and rates residuals.
• Six-month mandatory VA exam and 38 CFR 3.105(e): The 100% rating continues for six months after completion of antineoplastic treatment, when a mandatory C&P exam is scheduled. If that exam shows no recurrence or metastasis and residuals below 100%, the VA must issue a proposed reduction notice under 38 CFR 3.105(e), giving 60 days to submit evidence and 30 days to request a predetermination hearing under 38 CFR 3.105(i).

How the VA rates skin cancer residuals: disfigurement, scars, and function

Most skin cancer claims are rated under the scar and disfigurement criteria in 38 CFR 4.118; see our VA rating for scars guide for complete rules:

• Head, face, and neck disfigurement (DC 7800): Any surgical scar, Mohs reconstruction, flap, graft, or radiation change on the head, face, or neck is rated at 10% (1 characteristic), 30% (2–3 characteristics, or tissue loss with gross distortion/asymmetry of 1 feature/paired set: nose, chin, forehead, eyes/eyelids, ears/auricles, cheeks, lips), 50% (4–5 characteristics, or 2 features/paired sets), or 80% (6+ characteristics, or 3+ features/paired sets). Under Note (1), the eight characteristics are: (1) scar 5+ in. (13+ cm.) long; (2) scar ≥0.25 in. (0.6 cm.) wide; (3) surface contour elevated or depressed on palpation; (4) scar adherent to underlying tissue; (5) hypo- or hyper-pigmentation >6 sq. in. (39 sq. cm.); (6) abnormal texture (irregular, atrophic, shiny, scaly) >6 sq. in.; (7) missing soft tissue >6 sq. in.; and (8) indurated, inflexible skin >6 sq. in. Under Note (5), characteristics are cumulative across multiple head/face/neck scars, and under Note (2), auricle loss is rated under DC 6207 (38 CFR 4.87).
• Painful or unstable scars (DC 7804): Any excision scar warrants 10% (1–2 unstable or painful scars), 20% (3–4 scars), or 30% (5+ scars), plus 10% under Note (2) if at least one scar is both unstable (Note 1: frequent loss of skin covering) and painful. Under Note (3) to DC 7804 and Note (4) to DC 7800, a scar rated under DC 7800, 7801, 7802, or 7805 can also receive a separate rating under DC 7804.
• Trunk/extremity scars (DC 7801/7802), function (DC 7805), and actinic keratosis: Deep excisions outside the head, face, and neck with underlying soft tissue damage are rated under DC 7801 (10%–40% by area across the six body zones in 83 FR 32592), superficial scars ≥144 sq. in. receive 10% under DC 7802, and functional limitations are rated under DC 7805. Precancerous actinic keratoses rated under DC 7806 (see our eczema VA rating guide) require ≥5% body or exposed-area lesions or qualifying systemic/photochemotherapy duration for 10%+ because topical 5-FU and imiquimod creams are topical therapy under 38 CFR 4.118(a).

PACT Act melanoma and skin cancer presumptions (as stated on VA.gov)

Under the PACT Act, VA.gov treats melanoma and non-melanoma skin cancers differently:

1. Melanoma is presumptive regardless of body site: Listed on The PACT Act and Your VA Benefits and the VA Presumptive Cancers page, including melanomas of the skin (acral lentiginous, lentigo maligna, nodular, and superficial spreading), melanomas of the eye (choroidal, conjunctival, and iris), and mucosal melanoma.
2. Basal cell and squamous cell carcinoma are presumptive on specific sites: Non-melanoma skin cancers on the arms, legs, or trunk are not general burn pit presumptions on VA.gov. However, under “Head cancer of any type” (scalp, face, mouth, aural areas, lips, palate), “Neck cancer of any type”, and “Gastrointestinal cancer of any type”, VA.gov lists basal cell carcinoma of the skin, melanoma, and squamous cell carcinoma of the skin under mouth and neck cancers; melanoma and squamous cell carcinoma under nose cancers; dermatofibrosarcoma under head or neck sarcomas; and basal cell cancer, carcinoma in situ (“Bowen’s disease”), melanoma, and squamous cell cancer under anal cancer.
3. Qualifying PACT Act service locations and dates: Service on or after August 2, 1990, in Bahrain, Iraq, Kuwait, Oman, Qatar, Saudi Arabia, Somalia, the UAE, or airspace above; or on or after September 11, 2001, in Afghanistan, Djibouti, Egypt, Jordan, Lebanon, Syria, Uzbekistan, Yemen, or airspace above.

Direct UV exposure, radiation, secondary claims, DBQs, and help

Veterans outside PACT Act presumptions—including those with basal or squamous cell carcinoma on the forearms, hands, shoulders, trunk, or legs—can establish service connection via:

• In-service UV sun exposure (38 CFR 3.303): Current diagnosis, evidence of in-service solar UV exposure, and a medical nexus opinion (or within one year of discharge under 38 CFR 3.309(a) for “Tumors, malignant”).
• Ionizing radiation (38 CFR 3.311): “Skin cancer” (§ 3.311(b)(2)(vii)) for atmospheric nuclear test, Hiroshima/Nagasaki, and PACT Act radiation cleanup veterans (Enewetak Atoll, Palomares, Thule AFB) manifest 5+ years after exposure (§ 3.311(b)(5)(iv)). Skin cancer is not on the Agent Orange list in 38 CFR 3.309(e); Vietnam-era veterans claim direct UV sun exposure or secondary service connection inside a burn/shrapnel scar under 38 CFR 3.310(a).

Under 38 CFR 3.310(a), skin cancer or its treatment may support secondary claims with a medical nexus for lymphedema (DC 7121), facial/trigeminal nerve damage (DCs 8207/8305), eyelid ectropion/lagophthalmos (DCs 6021/6022), depression/anxiety (38 CFR 4.130), or immunotherapy endocrinopathies (DC 7903). At the C&P exam, the clinician completes Section VI and VII of the Skin Diseases DBQ and the Scars/Disfigurement DBQ. Separate ratings under DC 7800/7801/7802 and DC 7804 combine under 38 CFR 4.25 (with the 10% bilateral factor under 38 CFR 4.26 for paired extremities); use our VA combined rating calculator. For free help, contact a Veterans Service Organization (VSO) (DAV, VFW, American Legion) or verify accreditation via the VA Office of General Counsel Accreditation Search.