Diabetic Retinopathy and VA Disability

DC 6040 is the rating schedule's code for diabetic retinopathy, added May 13, 2018. DC 6006 is the general code for retinopathy or maculopathy not otherwise specified, and it is the code retinopathy carried before that date. Both sit under the same General Rating Formula for Diseases of the Eye, so the code number by itself does not change the percentage. A page or decision that rates retinopathy under 38 C.F.R. § 4.84a is citing the eye schedule as it stood before December 10, 2008, the earlier of the two recent changes VA's manual lists (M21-1 Part V, Subpart iii, Chapter 2, Section A, Block 1.j); today's eye schedule is § 4.79, and the current eCFR has no § 4.84a. Under 38 C.F.R. § 4.27, a hyphenated code such as 6040-6066 or 6006-6066 is built with the disease first and, after the hyphen, the code that set the rating; 6066 is the central-visual-acuity code for vision of 10/200 or better in one eye. In a coding review we ran on Board decisions found by search, 20 are dated after May 13, 2018 and cite an eye code for diabetic retinopathy: 10 cite 6040 and 9 cite 6006, one of them both, and the other 2 cite neither. One of those 20 cites 6006-6066 for a 60 percent rating the Board set on treatment visits, so a decision's reasons, not its code line alone, show which route set the percentage. Board decisions are binding only with regard to the specific case decided (38 C.F.R. § 20.1303). VA's manual says service connection is not severed when the diagnostic code is corrected (M21-1 Part V, Subpart ii, Chapter 3, Section D, Block 1.e).

Under 38 C.F.R. § 4.75(b), the examination "must be conducted by a licensed optometrist or by a licensed ophthalmologist", the examiner "must identify the disease, injury, or other pathologic process responsible for any visual impairment found", and, unless medically contraindicated, the back of the eye is examined with the pupils dilated. Uncorrected and corrected vision, for distance and near, is measured for each eye (4.76(a)), and visual fields are tested only when there is a medical indication of disease or injury that may be associated with a visual field defect. The findings go on VA's Eye Conditions Disability Benefits Questionnaire, which has a check box for diabetic retinopathy and asks for the number of documented treatment visits for an eye condition in the past 12 months. Bring or point to your eye clinic's treatment records, and describe your vision and your treatment exactly as they are.

Not under a code of its own. The phrase "macular edema" does not appear anywhere in the rating schedule. Of the 20 Board decisions in our coding review (decisions found by search, dated after May 13, 2018, that cite an eye code for diabetic retinopathy), the six that named macular edema or maculopathy in the eye issue all rated it within the retinopathy, and none gave it a separate code. In A25002903 (2025), treatment visits for bilateral diabetic retinopathy with macula edema, including intravitreal injections every 4 to 6 weeks, supported 60 percent; in A26019674 (2026), mild nonproliferative retinopathy with macular edema, with no treatment visits and no impairment of visual acuity or visual field, was denied a separate compensable rating and stayed part of the diabetic process. Board decisions are binding only with regard to the specific case decided (38 C.F.R. § 20.1303). How VA regional offices code it is not public.

It can, at severe levels of vision loss. 38 C.F.R. § 4.75(f) tells raters to check 38 C.F.R. § 3.350, and footnotes in the eye table flag the levels to review. Special monthly compensation under 38 U.S.C. 1114(k) covers blindness of one eye with only light perception, which 3.350(a)(4) describes as "inability to recognize test letters at 1 foot" when "perception of objects, hand movements, or counting fingers cannot be accomplished at 3 feet." Under 1114(l), "5/200 visual acuity or less bilaterally" qualifies, though an evaluation of 5/200 "based on acuity in excess of that degree but less than 10/200" does not (3.350(b)(2)), and "Concentric contraction of the field of vision beyond 5 degrees in both eyes is the equivalent of 5/200 visual acuity." Higher rates cover blindness in both eyes having only light perception, and anatomical loss of both eyes or blindness without light perception in both eyes. 4.75(f) adds that other levels of visual impairment combined with disabilities of other body systems may also establish entitlement.

For the rules on this page, the type matters for one: the herbicide presumption. 38 C.F.R. § 3.309(e) names "Type 2 diabetes (also known as Type II diabetes mellitus or adult-onset diabetes)". The one-year chronic-disease list in 3.309(a) says only "Diabetes mellitus." with no type, and the diabetes rating code, DC 7913, rates diabetes mellitus without separating types. The eye rating does not depend on the type either: DC 6040 is rated on vision or treatment visits in both. A veteran with type 1 diabetes can reach service connection for the diabetes on another route, such as the one-year presumption or direct service connection, and a diagnosed retinopathy can be service connected as a complication of that diabetes, on medical evidence that it is one (M21-1 Part V, Subpart iii, Chapter 11, Block 2.b).

VA's final rule at 83 FR 15316, effective May 13, 2018, added DC 6040 for diabetic retinopathy and retitled DC 6006 as retinopathy or maculopathy not otherwise specified. It also replaced the old incapacitating-episode test, which required prescribed bed rest and measured episodes in weeks, with the current count of treatment visits in the past 12 months. VA explained that a visit for diagnostic, monitoring or screening purposes "would only require time away from work for the visit itself." If a page or decision you read requires bed rest for an incapacitating eye episode, or measures eye episodes in weeks, it is drawing on the rule before May 13, 2018, which can still matter for a rating period before that date. VA's manual says the 2018 changes "were not liberalizing changes" and that changes in rating criteria "should not be the basis for a reduction in disability rating unless medical evidence establishes that the disability has actually improved."

Ask VA for an increase. With the diabetes service connected, VA's manual also treats a new diabetic complication as a claim for increase rather than a claim for secondary service connection (M21-1 Part V, Subpart iii, Chapter 11, Block 2.c). The effective date follows 38 C.F.R. § 3.400(o)(2): the earliest date it is factually ascertainable that the increase occurred, if a complete claim or intent to file a claim is received within 1 year from that date; otherwise, the date VA receives the claim. The evidence is the same as for the first rating: dated treatment visits in the past 12 months, and current corrected acuity and fields. If the retinopathy was 0 percent and becomes compensable, Note (1) to DC 7913 has it evaluated separately from the diabetes unless it is part of the criteria used to support a 100 percent diabetes evaluation.

No rule we found answers this. The rating formula counts "treatment visits", VA's manual speaks of "a clinic visit to a provider specifically for treatment purposes", and the Eye Conditions DBQ asks for the number of documented medical visits for treatment. None of them says whether one visit with injections in both eyes counts once or twice, and none of the four Board decisions we read that discussed injections in both eyes decided it (Board decisions are binding only with regard to the specific case decided, 38 C.F.R. § 20.1303). We state no rule either way. In three of them the Board weighed treatment records together with the veteran's or a family member's statements; in the fourth it found no documented treatment visit, although the veteran reported laser treatments and injections, and denied a compensable rating. Records showing each visit date and what was done to each eye are the ones to keep.

It can count toward one. If service-connected disabilities leave you unable to secure or follow a substantially gainful occupation, 38 C.F.R. § 4.16(a) allows a total rating when one disability is rated at 60 percent or more, or when one is at 40 percent or more and the combined rating is 70 percent or more. For that test, 4.16(a) counts "disabilities resulting from common etiology or a single accident" as one disability, and VA's manual applies that rule to a primary service-connected disability and the disabilities service connected as secondary to it or aggravated by it under 3.310 (M21-1 Part VIII, Subpart iv, Chapter 3, Section C, Block 4.a). 4.16(b) allows referral for extra-schedular consideration below those levels. We found no eye-specific TDIU rule in VA's manual.