The following are the comments we
submitted on your behalf to the VA in regards to the new proposed changes to the ratings of the Genitourinary System.
Every time the VA publishes their proposed changes for a section
of the VASRD, they include a comment period in which veterans and
organizations can provide feedback on the coming changes. Thank you for
submitting your comments to us regarding the Genitourinary System 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 Genitourinary System:
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like to submit the following comments on behalf of our staff and veterans in
response to the proposed changes to the ratings for the Genitourinary
System.
Item #1
In the proposed changes released in July 2017, a note was proposed
to clarify that Peyronie’s disease is not ratable. That note is not in the
recent proposal. What, then, is the intention of the VA regarding the rating of
Peyronie’s disease?
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One veteran submits his situation regarding
code 7543 for varicoceles and hydroceles. In his case, they cause acute pain
that inhibits walking and keeps him from working for more than 4 hours. Driving
also aggravates his condition. Offering a single rating option of only 0%
eliminates the ability for veterans like him whose conditions definitely interfere
with their earning capacity to be properly compensated. He suggests adding a
10% (max) rating for severe cases like this.
Item #3
In the withdrawal of the original proposed
changes, it was mentioned that the error needing correction was in the ACR
values. However, in the new proposed changes, the GFR values have been
significantly altered as well. A comment from one veteran notes how these GFR
changes will affect their ratings:
“I believe the July 2017 renal disease
recommendations for ratings are more in line with the Kidney Foundation than
those that are being considered in the October 2019 version. I have a
consistent GFR in the 40's. I do not have albumin in the urine. I am tired all
the time. I definitely have less energy. By 2pm I am exhausted beyond belief.
My appetite stinks, I sleep like crap, and I have to go to the bathroom often. It
is tiring and hard to stay focused when working. I highly recommend that the VA
stays with their July 2017 proposed changes for renal disease. July 2017
recommendations more accurately reflect disease progression when considering
disability.”
Thanks for considering these comments.
