DBQs, Private Medical Opinions and Independent Medical Opinions
Disability Benefits Questionnaires, or DBQs, are VA's standard forms for recording the medical findings a disability claim needs. VA examiners use them at C&P exams, and for many conditions your own provider can fill one out too. This guide also covers the two kinds of outside medical opinion: a private opinion you get yourself, and an independent medical opinion VA requests from outside experts under 38 CFR 3.328.
The rules below come from 38 CFR 3.326, 3.328, 4.2 and 4.70 as published on eCFR (current through October 26, 2026), and from VA's public DBQ page, its private medical evidence page and its claim exam page, all read on October 28, 2026.
What a DBQ does
VA's DBQ page says DBQs "help collect necessary medical information to process your disability claims." Each one is built for a condition or body system, and the findings it collects follow the rating criteria. The knee criteria in 38 CFR 4.71a are written in degrees of flexion and extension, so a knee exam has to measure them. The mental health formula in 4.130 is written in levels of occupational and social impairment, so a mental health exam has to describe them. At a C&P exam, VA.gov says the provider may ask you questions from the DBQ for each condition you claim.
Reading the DBQ for your condition before the exam shows you what the examiner should cover. If a section is skipped or a required test is not done, you can point to it later.
DBQs your own provider can complete
VA publishes a list of public DBQs, grouped by body system, from cardiovascular and musculoskeletal to psychological and respiratory. VA's page asks your provider to "fill out and submit the appropriate forms for your claimed conditions." The same page sets these conditions:
| Point | What VA's DBQ page says |
|---|---|
| Cost | VA does not pay or reimburse costs of completing or submitting a DBQ |
| Completion | All clinician information blocks must be completed, and the clinician must sign and date the form |
| Verification | VA reserves the right to confirm the authenticity of all DBQs |
| Upload | After completing a form, print it to PDF before uploading it |
| VA exam still possible | VA may decide an additional exam is needed, and if one is scheduled, you must report |
Some DBQs are not released for public use. VA's page says they need specialized training or are limited by federal regulations. The list includes the Medical Opinion DBQ, the Initial PTSD DBQ, the Hearing Loss and Tinnitus DBQ, the initial and review TBI DBQs, the General Medical DBQs for compensation and pension, the Gulf War General Medical Examination, the Former POW Protocol, Cold Injury Residuals and Part B of the Separation Health Assessment. If you file before separation through Benefits Delivery at Discharge or the Integrated Disability Evaluation System, the page says you must complete Part A of the Separation Health Assessment DBQ.
How VA treats a private DBQ or opinion
A private report can stand in for a VA exam if it is good enough. Section 3.326(b) says an examination report "from any government or private institution may be accepted for rating a claim without further examination," and 3.326(c) says the same of "a statement from a private physician," in each case "provided that it is otherwise adequate for rating purposes."
That condition is the test. A private DBQ that leaves out findings the criteria need, or that reaches a conclusion its findings do not support, is not "otherwise adequate for rating purposes," and under 3.326(a) a VA examination will then be authorized. A complete, well-explained one gives the rater what the criteria ask for. VA's claim exam page says you can upload non-VA records through the claim status tool, send them through an accredited representative, or mail them, and VA Form 21-4142 lets you authorize VA to request them from your provider.
Where the medical opinion question comes from
When VA needs a medical opinion, VA staff write the request that goes to the examiner, including the question the examiner is asked to answer. The Medical Opinion DBQ the examiner completes is on VA's list of DBQs not released for public use.
If the opinion in your report answers a narrower or different question than the one your claim raises, such as a direct link when you claimed a secondary one, say so to VA in writing. Section 4.2 says a report without "sufficient detail" is to be returned "as inadequate for evaluation purposes," and 4.70 lets the rater ask the examiner for a supplementary report. See how to challenge an inadequate exam.
Independent medical opinions under 38 CFR 3.328
In VA's regulations, an independent medical opinion is a specific thing. Under 3.328(a), "when warranted by the medical complexity or controversy involved in a pending claim," VA may get an advisory opinion from medical experts "who are not employees of VA." The opinions come from medical schools, universities, clinics or institutions VA has arrangements with, and an official of that institution picks the expert.
| Step | What 3.328 says |
|---|---|
| Who can ask | The office with jurisdiction over the claim, you, or your representative (3.328(b)) |
| How | In writing, giving in detail the reasons the opinion is necessary, submitted through the Veterans Service Center Manager or Pension Management Center Manager (3.328(b)) |
| When it is approved | When the Service director or designee finds the medical issue complex or controversial enough, or when a Board of Veterans' Appeals remand requires it (3.328(c)(1)) |
| If it is refused | The refusal can be contested only as part of a Board appeal on the merits of the main decision (3.328(c)(2)) |
| Your copy | You are told when a request is approved and given a copy of the opinion, subject to the special procedures of 38 CFR 1.577 where disclosure could harm your health (3.328(d)) |
Getting your own outside opinion
Many veterans also use "IMO" for a private opinion they arrange themselves. That is a different route, and it needs no approval. You can submit a private opinion with your claim, or later as new evidence in a supplemental claim. Under 3.326(c), VA can accept it if it is otherwise adequate for rating purposes.
A private opinion tends to carry more weight when the doctor has expertise in the condition and has reviewed your records. It helps if the doctor answers the actual question in the claim and explains the reasoning from your own history. If it is meant to answer a VA opinion, it should take up that opinion's specific gaps. VA does not pay for private DBQs. For opinions that link a condition to service, see nexus letters.
Note: This article references sections of the VA's M21-1 Adjudication Procedures Manual. The VA periodically reorganizes the M21-1 and section numbers may have changed since this article was written. For the most current section references, visit the VA's public M21-1 Web Automated Reference Material System (WARMS).
Frequently Asked Questions
Can my own doctor fill out a DBQ?
Yes, for the DBQs VA lists as public. VA's DBQ page asks your provider to fill out and submit the forms for your claimed conditions, with every clinician information block completed and the form signed and dated. Some DBQs, including the Medical Opinion, Initial PTSD and Hearing Loss and Tinnitus forms, are not released for public use.
Does VA pay for a private DBQ?
No. VA's DBQ page says it does not pay or reimburse costs of completing or submitting DBQs, and its claim exam page says the same of your own provider completing one.
Will a private DBQ replace my VA exam?
It can. Under 38 CFR 3.326(b) and (c), a private exam report or a private physician's statement may be accepted for rating without a further exam if it is otherwise adequate for rating purposes. VA's DBQ page says VA may still decide an exam is needed, and if one is scheduled, you must report.
What is an independent medical opinion under 38 CFR 3.328?
An advisory opinion from medical experts who are not VA employees, obtained when a claim involves medical complexity or controversy. You or your representative can ask for one in writing, giving detailed reasons. It is approved when the Service director finds the issue complex or controversial enough, or when a Board remand requires it.
Can I challenge VA's refusal to get an independent medical opinion?
Only as part of a Board of Veterans' Appeals appeal on the merits of the main decision (38 CFR 3.328(c)(2)).