Crohn's Disease and Undifferentiated Inflammatory Bowel Disease — VA Disability Rating Criteria (DC 7326)
Diagnostic Code 7326 · 38 CFR §4.114
What Is It?
38 CFR 4.114 gives DC 7326 the title "Crohn's disease or undifferentiated form of inflammatory bowel disease." The 2024 revision of the digestive schedule, effective 19 May 2024, put that name on the code and wrote a new set of criteria for it, and in doing so made DC 7326 the criteria home for inflammatory bowel disease generally: DC 7323 (ulcerative colitis) is rated as DC 7326, and DC 7325 (chronic enteritis) is rated as either irritable bowel syndrome under DC 7319 or as DC 7326, whichever reflects the predominant disability. "Chronic enterocolitis" — the phrase this page's web address still uses — is a clinical description rather than a schedule term, and the veteran who arrives with inflammation of both the small bowel and the colon is describing what Note (3) to this entry describes: inflammation may involve small bowel (ileitis), large bowel (colitis), or any component of the gastrointestinal tract from the mouth to the anus. What is worth understanding about the current criteria is the axis they are written on. They do not read on weight loss, anaemia or malnutrition as the pre-2024 criteria did. Each row pairs a treatment level with a symptom count: what class of drug is holding the disease, how many episodes of diarrhoea a day, and what signs of systemic toxicity are present. Immunosuppressants and biologics carry the 60 percent row; oral and topical agents carry 30 and 10; and the 100 percent row needs disease unresponsive to treatment, hospitalisation at least once a year, and either an inability to work or a specific combination of severe symptoms. There is no 0 percent row — 38 CFR 4.31 supplies one where no listed criterion is met.
Rating Criteria
| Rating | Criteria |
|---|---|
| 100% | Severe inflammatory bowel disease that is unresponsive to treatment; and requires hospitalization at least once per year; and results in either an inability to work or is characterized by recurrent abdominal pain associated with at least two of the following: (1) six or more episodes per day of diarrhea, (2) six or more episodes per day of rectal bleeding, (3) recurrent episodes of rectal incontinence, or (4) recurrent abdominal distension. |
| 60% | Moderate inflammatory bowel disease that is managed on an outpatient basis with immunosuppressants or other biologic agents; and is characterized by recurrent abdominal pain, four to five daily episodes of diarrhea; and intermittent signs of toxicity such as fever, tachycardia, or anemia. |
| 30% | Mild to moderate inflammatory bowel disease that is managed with oral and topical agents (other than immunosuppressants or other biologic agents); and is characterized by recurrent abdominal pain with three or less daily episodes of diarrhea and minimal signs of toxicity such as fever, tachycardia, or anemia. |
| 10% | Minimal to mild symptomatic inflammatory bowel disease that is managed with oral or topical agents (other than immunosuppressants or other biologic agents); and is characterized by recurrent abdominal pain with three or less daily episodes of diarrhea and no signs of systemic toxicity. This is the lowest listed row; 38 CFR 4.31 supplies a 0 percent evaluation where no listed criterion is met. |
Evidence Needed
Note (2) to DC 7326 requires that the diagnosis be confirmed by endoscopy or radiologic studies, so the colonoscopy or CT/MR enterography report with its pathology is the foundation of the claim — a clinical impression alone is the cleanest ground for a denial. After that the criteria read on two things, and both live in the treatment record. The drug class: whether the disease is held by oral and topical agents such as mesalamine or budesonide, or by immunosuppressants and biologics such as azathioprine, methotrexate, infliximab, adalimumab, vedolizumab or ustekinumab — that distinction is the line between the 30 and 60 percent rows. And the symptom count: daily episodes of diarrhoea, recurrent abdominal pain, and the signs of toxicity the entry names, meaning fever, tachycardia and anaemia. Bring the laboratory record showing anaemia or inflammatory markers, admission records for any hospitalisation, and, where the top row is in play, the evidence of inability to work. Where a colectomy or colostomy has been performed, add those operative records: Note (1) directs that persistent or recurrent symptoms afterwards be rated either under DC 7326 or under DC 7329 for large intestine resection, whichever gives the higher rating.
C&P Exam Tips
Count and report. The examiner needs a number of daily episodes of diarrhoea, not "frequent" — three or fewer, four to five, and six or more are three different rows. Name your medications and let the examiner record the class, because "managed with oral and topical agents" and "managed with immunosuppressants or other biologic agents" are the words the criteria use. Mention fever, racing heart and anaemia specifically if they occur, since those are the signs of toxicity the entry names, and bring the blood work that shows them. Rectal bleeding, rectal incontinence and abdominal distension all appear in the 100 percent row and are easy to leave unsaid — say them. If you have been hospitalised for a flare in the last year, bring the discharge summary. And if you have had bowel surgery, ask that the residuals be considered under DC 7329 as well as this code, because Note (1) requires whichever produces the higher rating.
How to File
File under DC 7326 on VA Form 21-526EZ with the confirmatory endoscopy or imaging, the medication record naming the drug class, and a symptom diary that counts daily episodes. The opening paragraph of 38 CFR 4.114 provides that ratings under DC 7301 through 7329, 7331, 7342, 7345 through 7350, 7352 and 7355 through 7357 will not be combined with each other — DC 7326, DC 7323, DC 7325 and DC 7329 are all inside that group, so a veteran with Crohn's disease and ulcerative colitis, or with inflammatory bowel disease and irritable bowel syndrome, receives one evaluation under the code that reflects the predominant disability picture, elevated to the next higher evaluation if the severity of the overall disability warrants it. That elevation clause is the argument worth making where two listed conditions each contribute. 38 CFR 4.113 explains the reasoning: coexisting abdominal conditions produce a common disability picture and do not lend themselves to separate evaluations without pyramiding.
Common Mistakes
Quoting the pre-2024 criteria, which read on malnutrition, anaemia and weight loss. Those words are gone; the current rows read on drug class and daily episode counts. Describing symptoms without counting them. Leaving the medication class out of the record, which is the single difference between 30 and 60 percent. Filing Crohn's disease under DC 7323, which is the ulcerative colitis entry and carries no criteria of its own. Expecting a 0 percent row in the entry — there is none, and 38 CFR 4.31 supplies the zero. Skipping the endoscopy or radiologic confirmation Note (2) requires. And accepting a single evaluation without arguing the elevation clause where more than one listed digestive condition is present.
Frequently Asked Questions
Did DC 7326 change?
Yes. The 2024 revision of the digestive schedule, effective 19 May 2024, retitled DC 7326 as "Crohn's disease or undifferentiated form of inflammatory bowel disease" and replaced the criteria. The current rows are 100, 60, 30 and 10 percent, keyed to the class of medication managing the disease and the number of daily episodes of diarrhoea.
How is ulcerative colitis rated?
On these criteria. DC 7323 is the code of record for ulcerative colitis, but its entry reads "Rate as Crohn’s disease or undifferentiated form of inflammatory bowel disease (DC 7326)," so the ladder on this page is the one that decides the percentage.
What separates 30 percent from 60 percent?
The drug class, primarily. The 30 percent row describes disease managed with oral and topical agents other than immunosuppressants or biologics, with three or fewer daily episodes of diarrhoea and minimal signs of toxicity. The 60 percent row describes disease managed on an outpatient basis with immunosuppressants or other biologic agents, with four to five daily episodes and intermittent signs of toxicity such as fever, tachycardia or anaemia.
What counts as a sign of toxicity?
The entry names three: fever, tachycardia and anaemia. They appear at three levels — none at 10 percent, minimal at 30 percent, intermittent at 60 percent — so the laboratory record and the vital signs in your clinic notes carry real weight.
I had a colectomy. Which code applies?
Both are considered. Note (1) directs that following colectomy or colostomy with persistent or recurrent symptoms, the rating be taken under either DC 7326 or DC 7329 (large intestine resection), whichever provides the higher rating. Ask for both to be evaluated.
What is "undifferentiated" inflammatory bowel disease?
It is the term for inflammatory bowel disease that has not been classified as either Crohn’s disease or ulcerative colitis — sometimes called indeterminate colitis. The 2024 revision wrote it into the code title so that veterans with an unclassified diagnosis are rated on the same criteria rather than by analogy.
Is chronic enterocolitis its own diagnostic code?
No. It is a clinical description of inflammation involving both the small bowel and the colon, and the schedule has no entry by that name. Note (3) to DC 7326 makes the point directly: inflammation may involve small bowel (ileitis), large bowel (colitis), or any component of the gastrointestinal tract from the mouth to the anus. DC 7325 covers chronic enteritis, and it is rated as either irritable bowel syndrome (DC 7319) or DC 7326 depending on the predominant disability.