Today, the VA released a proposal to add a new code for Constrictive Bronchiolitis (CB) to the VASRD for Respiratory System conditions.
Currently, the entire Respiratory System is pending the final publication of the proposed changes the VA issued on February 15th, 2022, so this new code for CB will be tacked on and finalized with all of those changes.
It’s impossible to predict exactly when these changes will all go into effect, as it has already been two and a half years since the first proposal was published, but it is likely that the delay was in large part due to the addition of this new code. Probably once the due process is completed for the proposed CB code, all of the respiratory changes will be finalized.
The addition of a new code for constrictive bronchiolitis comes in response to the PACT Act that was passed in August 2022. The PACT Act added 24 new conditions to the Burn Pit Presumptive List, including constrictive bronchiolitis. All of the other respiratory conditions added by the PACT Act already have their own VASRD codes, but constrictive bronchiolitis does not.
While CB has always been rated Analogously in the past, the VA is now proposing to add a code specifically for constrictive bronchiolitis to ensure that the VA is able to consistently rate the condition across the board and to “easily track claims and decision outcomes for this condition.”
Here is the code the VA is proposing to add for constrictive bronchiolitis:
-NEW Proposed- Code 6605: Constrictive bronchiolitis (a.k.a. “obliterative bronchiolitis” or “popcorn lung“) is a condition where inflammation blocks the smallest airways in the lungs. It is rated on the Respiratory Rating System.
According to the proposed changes from February 2022, the VA will be making significant changes to the Respiratory Rating System that will use only modern lung function test results to assign ratings. Today’s proposal for CB specifies that the condition will be rated under the proposed Respiratory Rating System once it is finalized and not the one currently in use.
Comments on the addition of code 6605 for constrictive bronchiolitis can be submitted to the VA until October 15, 2024. The proposal clearly emphasizes, however, that these comments can only be in regards to the addition of the new code and not to any of the other proposed respiratory changes since the comment period for those changes has already passed.
After the comment period, the VA will review the comments and make any necessary adjustments to the proposal. They will then publish the final changes with an effective date determining when the new code will start being used.
There is no way to predict exactly when this will happen until those final changes are published, but we will post about them as soon as they are in, so keep an eye on our blog for the most recent updates.