Thrombocytopenia and ITP (Immune Thrombocytopenia) — VA Disability Rating Criteria (DC 7705)

Diagnostic Code 7705 · 38 CFR §4.117

What Is It?

Thrombocytopenia means a low platelet count, which leaves the blood unable to clot properly. It shows as easy bruising, petechiae, bleeding gums, nosebleeds, heavy menstrual bleeding, prolonged bleeding from small cuts, and in severe cases dangerous internal or intracranial bleeding. Low platelets are a finding rather than a single disease, and the cause matters to the claim. The cause the schedule names is immune thrombocytopenia — long known as immune or idiopathic thrombocytopenic purpura, ITP — an autoimmune condition in which the immune system destroys platelets and blocks their production. ITP can follow a viral infection, a medication, or another autoimmune disease, and it can be secondary to conditions such as HIV or hepatitis C. In 38 CFR 4.117 it has its own entry, and the entry is named for it: DC 7705, "Immune thrombocytopenia." That title and the criteria under it come from the revision of the hemic schedule that took effect 9 December 2018 — the same revision that removed DC 7700, the general anemia code. DC 7701 is not part of that change: it does not appear in the full rewrite of 38 CFR 4.117 that took effect October 23, 1995, or in any version since. The criteria are built on two things that appear together in almost every row: the platelet count, and what treatment the disease requires. The count thresholds are 30,000 and 50,000, and the treatment ladder runs from no treatment through oral corticosteroids or intravenous immune globulin, to immunosuppressive therapy, to chemotherapy for chronic refractory disease. There is a 0 percent row for a count above 50,000 with no symptoms or for disease in remission, which is worth claiming because it establishes service connection. The schedule has no separate entry for low platelets from other causes, and no note under DC 7705 that addresses them. Where the low count is part of another service-connected condition whose criteria already account for it — aplastic anemia, whose rows count platelet transfusions, or cirrhosis, whose Note (2) lists thrombocytopenia among the findings of liver dysfunction, for example — it is often considered within that condition's rating, because 38 CFR 4.14 says the evaluation of the same manifestation under different diagnoses is "to be avoided." Leukemia under DC 7703 is rated 100 percent when there is active disease or during a treatment phase; otherwise, DC 7703 says to "rate residuals under the appropriate diagnostic code(s)." Where a low count stands on its own and is not immune-mediated, 38 CFR 4.20 permits rating an unlisted condition under "a closely related disease or injury," and DC 7705 can serve as that code. This page previously carried DC 7712. That code is live, but 38 CFR 4.117 lists it as "Multiple myeloma" — a plasma-cell malignancy with its own criteria. DC 7705 was already the thrombocytopenia code in the 1995 rewrite, which listed it as "Thrombocytopenia, primary, idiopathic or immune"; the 2018 revision gave the entry its current title.

Rating Criteria

Evidence Needed

Serial platelet counts are the claim. One number is a snapshot; the criteria are written around thresholds of 30,000 and 50,000 and around whether a count stays low despite treatment, so a run of complete blood counts across months is what a rater can work with. Add the treatment record in the schedule's own categories: whether you take oral corticosteroids, whether you have received intravenous immune globulin, whether you are on immunosuppressive therapy such as rituximab, azathioprine or mycophenolate, whether you take a thrombopoietin receptor agonist, and whether chemotherapy has been used for chronic refractory disease. Bring the bleeding history with dates — mucous membrane bleeding, any transfusion of platelets, and any hospitalization for severe bleeding, which the 70 percent row names specifically. Include the diagnostic workup that established why the platelets are low — the bone marrow biopsy if one was done, antibody and viral testing, the medication review — because the cause decides whether DC 7705 applies directly, by analogy, or not at all, and 38 CFR 4.20 says analogous ratings are to be avoided for conditions "not fully supported by clinical and laboratory findings." Where the low count is secondary, add the records for the underlying condition. If your spleen has been removed, bring the operative report: Note (1) directs that splenectomy be separately evaluated under DC 7706 and combined with the rating under this code.

C&P Exam Tips

Bring the laboratory history rather than describing it, and point out the lowest counts and when they occurred. Be precise about the diagnosis: if a hematologist has diagnosed immune thrombocytopenia, make sure that term appears in the examination report. If the low count is caused by another service-connected condition — liver disease, an autoimmune condition, a medication taken for a service-connected disease — say so, because 38 CFR 3.310 service connects a disability that is "proximately due to or the result of a service-connected disease or injury," and where the underlying condition's rating already accounts for the low count, it may be considered within that rating under 38 CFR 4.14. Name your treatments precisely, because the rows are separated by treatment class — oral corticosteroids and IVIG sit at 30 percent, immunosuppressive therapy at 70, chemotherapy for chronic refractory disease at 100. Describe bleeding in the terms the entry uses: mucous membrane bleeding for the 30 percent row, severe bleeding requiring hospitalization, intravenous immune globulin, high-dose parenteral corticosteroids and platelet transfusions for the 70 percent row. Mention any restrictions you live under — avoiding contact activity, stopping anticoagulants or anti-inflammatories, dental procedures deferred. If you have had a splenectomy, say so and ask that it be rated separately under DC 7706, which is a flat 20 percent, and that the two be combined as Note (1) requires. If you are in remission, that is the 0 percent row and not a reason to withdraw the claim.

How to File

File under DC 7705 on VA Form 21-526EZ with the serial platelet counts, the treatment record and the bleeding history. Name the diagnosis as precisely as the record allows: if it is immune thrombocytopenia, DC 7705 applies directly; if the low count is part of another service-connected disease whose rating already accounts for it, it is often considered within that condition's evaluation rather than as a second claim; and if it stands alone from another cause, 38 CFR 4.20 permits rating by analogy. Two provisions of the entry shape what happens afterwards. Note (1) authorizes a separate 20 percent evaluation for splenectomy under DC 7706, combined rather than absorbed. And Note (2) governs the top row: a 100 percent evaluation continues beyond the cessation of chemotherapy, and six months after that treatment is discontinued the appropriate rating is determined by a mandatory VA examination, with any reduction based on that or a later examination subject to 38 CFR 3.105(e) — which requires notice and a 60-day period to submit evidence — and 38 CFR 3.105(i) adds the opportunity for a predetermination hearing if VA receives the request within 30 days of the notice. One route to service connection is easy to miss. 38 CFR 3.309(a) lists "Purpura idiopathic, hemorrhagic" among the chronic diseases, and 38 CFR 3.307(a)(3) provides that a listed chronic disease manifest to a degree of 10 percent or more within one year of separation is presumptively service connected. A veteran whose platelet count fell in that first year after discharge should raise the presumption expressly rather than relying on a nexus opinion alone.

Common Mistakes

Filing under DC 7712, which is the schedule's multiple myeloma entry. Submitting a single platelet count instead of a series, when the criteria turn on thresholds and on whether counts stay low despite treatment. Claiming low platelets separately from a service-connected disease whose rating already accounts for them, when 38 CFR 4.14 says evaluating the same manifestation under different diagnoses is "to be avoided." Describing treatment loosely — "steroids" covers both the oral corticosteroids of the 30 percent row and the high-dose parenteral corticosteroids of the 70 percent row, and the distinction is a 40-point difference. Leaving a splenectomy inside the ITP claim rather than claiming it separately under DC 7706 as Note (1) directs. Assuming remission ends the claim, when the 0 percent row is written for exactly that and keeps service connection alive. And treating a proposed reduction after chemotherapy as automatic, when Note (2) requires a mandatory examination and 38 CFR 3.105(e) protections apply.

Frequently Asked Questions

What diagnostic code is ITP rated under?

DC 7705. 38 CFR 4.117 titles the entry "Immune thrombocytopenia," which is the current clinical name for what was long called immune or idiopathic thrombocytopenic purpura. The title and criteria date from the revision of the hemic schedule that took effect 9 December 2018.

My low platelets are not ITP. How are they rated?

DC 7705 is titled "Immune thrombocytopenia," so it applies directly to that diagnosis, and 38 CFR 4.117 has no separate code for low platelets from other causes. Where the low count comes from another service-connected condition, such as aplastic anemia or cirrhosis of the liver, it is often considered within that condition's rating, because 38 CFR 4.14 says evaluating the same manifestation under different diagnoses is "to be avoided." Where it stands alone, 38 CFR 4.20 permits rating by analogy under a closely related code, and DC 7705 can serve as that code.

What is DC 7712?

Multiple myeloma — a cancer of the plasma cells in the bone marrow, with its own criteria in 38 CFR 4.117. It is a live code, but it is not thrombocytopenia of any kind.

What platelet counts matter?

Two thresholds do the work: 30,000 and 50,000. A count of 30,000 or below despite treatment is 100 percent. A count above 30,000 but not above 50,000 sits at 10, 30 or 70 percent depending on what treatment it takes and what bleeding history goes with it. A count above 50,000 with no symptoms, or disease in remission, is 0 percent.

Can I get a separate rating if my spleen was removed?

Yes. Note (1) to DC 7705 directs that splenectomy be separately evaluated under DC 7706 and combined with the rating under this code. DC 7706 is a flat 20 percent, and it carries its own Note directing separate evaluation of complications such as systemic infections with encapsulated bacteria.

My ITP is in remission. Should I still claim it?

Yes. The 0 percent row covers a platelet count above 50,000 and asymptomatic, or immune thrombocytopenia in remission. It pays nothing now, but it establishes service connection, so a relapse becomes a claim for increase rather than a fight about whether the condition started in service.

What happens to a 100 percent rating after chemotherapy ends?

Note (2) keeps it in place beyond the cessation of chemotherapy. Six months after treatment is discontinued, a mandatory VA examination determines the appropriate rating, and any reduction based on that or a later examination is subject to 38 CFR 3.105(e) — notice and a 60-day window to submit evidence — with 38 CFR 3.105(i) adding the opportunity for a predetermination hearing if VA receives the request within 30 days of the notice.

Is there a presumptive route for ITP?

There is. 38 CFR 3.309(a) includes "Purpura idiopathic, hemorrhagic" in its list of chronic diseases, and 38 CFR 3.307(a)(3) presumes service connection where a listed chronic disease became manifest to a degree of 10 percent or more within one year of separation. If your platelet count fell during that first year out, say so in the claim — it is a different and often easier argument than proving a nexus.