VA Rating by Analogy (Built-Up Diagnostic Codes)

Why analogous ratings exist

The rating schedule cannot list every possible medical condition. When a veteran is service-connected for something that has no code of its own, VA does not deny the rating — it rates the condition by analogy under 38 CFR § 4.20, using the criteria of a listed condition that closely resembles it.

The regulation directs that the analogous condition be selected based on the affected anatomical localization and the functions affected — not simply on a similar-sounding name.

How built-up codes are constructed

1. The first four digits identify the body-system range and end in '99' to signal the condition is unlisted — for example 5299 for an unlisted musculoskeletal condition, 8799 for an unlisted peripheral nerve condition.
2. A hyphen follows.
3. The last four digits are the listed diagnostic code whose criteria VA is actually applying.
4. Read together, 5299-5237 means: an unlisted musculoskeletal condition, rated using the criteria for lumbosacral or cervical strain.

When an analogy is a poor fit

• The analogous code measures a function your condition does not primarily impair.
• A specific listed code for your exact diagnosis exists and was overlooked.
• The analogous code's ceiling is well below the level of impairment your records document.
• The analogy is based on a superficially similar name rather than the same anatomical location and impaired function.
• The condition has since been added to the schedule as a listed code — the schedule is amended periodically.

How to challenge the analogy

Identify a better-fitting code, then show two things: that the alternative matches the anatomical location and impaired functions more closely, and that your medical records contain the findings that code requires. Without the second piece, a code substitution rarely changes the percentage.

Whether the issue belongs in a Higher-Level Review or a Supplemental Claim depends on whether new evidence is needed. Errors visible on the face of the decision generally fit HLR; missing medical findings generally require new evidence.

Common pitfalls with analogous ratings

• ×Assuming a hyphenated code is itself an error. Built-up codes are expressly authorized by regulation.
• ×Proposing an alternative code without checking whether the record contains the findings it requires.
• ×Overlooking that the condition may now be separately listed after a recent amendment to the schedule.
• ×Focusing on the diagnosis name rather than the anatomical location and impaired function, which is the standard the regulation actually uses.

Frequently Asked Questions

References & sources

1. 38 CFR § 4.20 — Analogous ratings — eCFR
2. 38 CFR § 4.27 — Use of diagnostic code numbers — eCFR