Comments Submitted on the Genitourinary Changes

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: 
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 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?
Item #2
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.


  • Have this proposed kidney rating been officially adopted by the VA yet? After reviewing my GFR data from both my VA & private insurance doctors, I may now qualify based on my blood test results. A 30% rating is given if the GFR is between 45 and 59 mL/min/1.73 m2 for a minimum of 3 consecutive months

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