Cardiovascular System Changes Comments

The following are the comments we submitted on your behalf to the VA in regards to the proposed changes to the ratings of the Cardiovascular 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 Cardiovascular 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 Cardiovascular System: 
We at would like to submit the following comments on behalf of our staff and veterans in response to the proposed changes to the ratings for the Cardiovascular System. 
Item #1
For Code 7019, please clarify the one-year time periods required for the rating and the mandatory evaluation. It doesn’t make sense to have two different one-year time periods for this code. The 100% rating starts on the date of admission to the hospital while the mandatory examination is 1-year from the date of discharge. If the 100% rating can only be for a year, then immediately upon its end, a re-evaluation must take place in order to provide a new rating. If this is to account for the amount of time the person is hospitalized, it might be better to have the 100% start upon admission saying nothing about the 1-year limit. Then specify that the 100% rating will only continue for 1-year following discharge whereupon there must be a mandatory evaluation in order to award the new rating. 
Item #2
For Code 7110, there is a bit of confusion regarding that “ands” and “ors” in this code. The first part separates the size of the aneurysm from the need for symptoms or surgery, suggesting that the size itself rates 100%. If it is smaller, but causes symptoms and requires surgery, then it is also rated 100%. The 0% code, however, also includes an “or” that would make rating confusing. The wording suggests that any aneurysm less than 5 cm is rated here regardless of the severity of symptoms. Does that mean that a small aneurysm requiring surgery is only rated 0%? Clearly not, so an adjustment in the language would help clarify how these ratings should be applied to ensure proper rating. Potentially, “If less than 5 cm and surgical correction not recommended.”
Thanks for considering these comments.


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