Comments Submitted to the VA on the Changes to the Ratings for Dental and Oral Conditions

The following are the comments we submitted on your behalf to the VA in regards to the proposed changes to the ratings of Dental and Oral Conditions. After the VA publishes their proposed changes, they always allow a period for comments. Thank you for submitting your comments to us 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 more fair for all veterans.
We are currently accepting comments on the proposed changes to the ratings of the Hemic and Lymphatic System. This is your next opportunity to participate in providing feedback to the VA, but more opportunities will be coming. Check our blog regularly for new opportunities.
Here are the comments we submitted for Dental and Oral Conditions:
We at www.MilitaryDisabilityMadeEasy.comwould like to submit the following comments on behalf of our staff and veterans in response to the proposed changes to the ratings for Dental and Oral Conditions.
Item #1
Codes 9001, 9908, 9909, 9913, 9914, and 9915 are all entirely missing from the discussion of the proposed changes and the list of codes in the schedule of ratings. Other proposed changes, like for the ratings of the Eyes, did not just omit codes altogether. Even if no change was being proposed for a certain code, the code would still be listed as it is in the schedule of ratings.
Are these codes being removed? We assume that they are simply remaining the same, but confirmation that they are not being removed would be appreciated.
Item #2
The proposed ratings under code 9904 for malunion of the mandible and code 9916 for malunion of the maxilla do not provide comparatively fair ratings. Regardless of whether the mandible or the maxilla is affected, the main disability rated is the presence of an anterior or posterior open bite. The presence of an open bite should be rated  exactly the same no matter the cause since the same disability is present in each case.
This comparatively fair rating is found when looking at the ratings for nonunion of the maxilla or mandible. Regardless of which bone is affected, any false motion is 30% and no false motion is 10%. Equal ratings should then also be extended to malunions, regardless of which bone is affected.
Under code 9904, a severe open bite is rated 20%, a moderate open bite is 10%, and no open bite is 0%. Under code 9916, however, a severe open bite is rated 30%, a moderate open bite is rated 10%, and a mild open bite is rated 0%.
Not only are the rating themselves conflicting, but the requirement for a 0% rating differs in each case with one requiring a mild open bite and the other requiring no open bite whatsoever. Changes should be made to allow for consistent ratings for the severity of a disability in regards to malunions.

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