VA Disability Rating for Liver Transplant (DC 7351)
Diagnostic Code 7351 · 38 CFR §4.114
What Is It?
DC 7351 is the diagnostic code for liver transplantation, and it is unusual in the rating schedule because it compensates a treatment pathway rather than a set of symptoms. It has three levels and they correspond to three stages: 60 percent as a minimum once you are eligible and awaiting transplant surgery, 100 percent for an indefinite period beginning on the date of hospital admission for the transplant, and 30 percent as a minimum afterwards. The 60 percent waiting-list level is the part veterans most often do not know exists. Being listed for a liver means end-stage disease that is being actively managed, and the schedule recognises it with a minimum evaluation before the operation ever happens. Veterans arrive at transplant from several service-connected routes: cirrhosis from hepatitis C acquired in service, hepatitis B, alcohol-related liver disease that is secondary to a service-connected mental-health condition, non-alcoholic fatty liver disease alongside service-connected metabolic conditions, and liver injury from toxic exposure. After transplant the liver disease is replaced by a different chronic condition — lifelong immunosuppression, its side effects, and permanent surveillance — which is why the schedule sets a floor rather than returning the evaluation to zero when the graft is working.
Rating Criteria
| Rating | Criteria |
|---|---|
| 100% | For an indefinite period from the date of hospital admission for transplant surgery. The Note to DC 7351 directs that the 100 percent evaluation is assigned as of the date of hospital admission; that one year following discharge the appropriate evaluation is determined by mandatory VA examination; and that 38 CFR 3.105(e) applies to any change in evaluation based on that or any later examination. |
| 60% | Eligible and awaiting transplant surgery — minimum rating. This level applies while you are medically eligible and listed, before admission for the operation. |
| 30% | Following transplant surgery — minimum rating. This is a floor, not a ceiling: the Note directs that residuals of any recurrent underlying liver disease are rated under the appropriate diagnostic code and, where appropriate, combined with other post-transplant residuals under the appropriate body systems, subject to 38 CFR 4.14 and to the no-combining provisions of 38 CFR 4.114. |
Evidence Needed
The documents follow the three stages. For the 60 percent waiting-list level, what proves the claim is the transplant center's listing confirmation and your position on the United Network for Organ Sharing register, together with the MELD score history and the hepatology notes establishing that you are medically eligible and awaiting surgery. Veterans routinely have all of this in hand and never send it, because they are waiting for the operation before filing. For the 100 percent level, the pivotal document is the hospital admission record, because the evaluation runs from the date of admission rather than the date of the operation, and the discharge summary, because the mandatory re-examination is timed one year from discharge. For the period after that, the file needs the immunosuppression regimen and its monitoring — tacrolimus or cyclosporine levels, renal function trends, the infection history, any rejection episodes and their treatment, biopsy results, and the surveillance schedule — plus documentation of anything the medication has caused: chronic kidney disease, hypertension, diabetes, osteoporosis, skin cancers, or post-transplant lymphoproliferative disease. Underneath all three stages, the evidence establishing service connection for the underlying liver disease is what makes the code available at all, so the hepatitis serology, the in-service risk exposure or diagnosis, and any nexus opinion linking cirrhosis to a service-connected condition belong at the front of the file.
C&P Exam Tips
Bring the two dates the regulation actually uses and make sure they are recorded correctly: the date of hospital admission for the transplant, which is when the 100 percent evaluation begins, and the date of discharge, which starts the clock on the mandatory examination one year later. Those are frequently transcribed as the date of surgery, which is not what the Note says and can cost weeks or months of the 100 percent evaluation. If you are being examined while still on the waiting list, say so plainly and bring the listing documentation, because the 60 percent minimum applies to that stage and an examiner focused on current symptoms may not raise it. If you are being examined at the one-year point after discharge, prepare for it as a substantive examination rather than a formality: describe the immunosuppression regimen and its side effects, the frequency of laboratory monitoring and clinic visits, every infection that has required treatment, any rejection episode, and the effect of all of it on work and daily activity. The 30 percent floor is the minimum, not the expected outcome, and the Note directs that residuals be rated under their own codes and combined where appropriate — so any kidney impairment, diabetes, hypertension or skin malignancy that followed the transplant should be described and claimed rather than folded into a single number.
How to File
File on VA Form 21-526EZ under DC 7351, and file as soon as you are listed rather than waiting for the surgery — the 60 percent minimum applies to the period when you are eligible and awaiting transplant, and a claim filed then carries an earlier effective date for everything that follows. Establish service connection for the underlying liver disease first or alongside: the hepatitis C or B evidence, the in-service exposure, or the nexus opinion linking cirrhosis to a service-connected condition such as alcohol use disorder secondary to PTSD. Send the listing confirmation, the hospital admission record, the discharge summary, the immunosuppression regimen and the monitoring schedule. Before the one-year post-discharge examination, make sure the VA has current evidence of every residual and every medication effect, because that examination sets the evaluation that follows the 100 percent period. If the VA proposes to reduce the 100 percent evaluation, the reduction is governed by 38 CFR 3.105(e): you are entitled to notice of the proposal, 60 days to submit evidence, 30 days to request a predetermination hearing, and a separate decision before it takes effect. Claim post-transplant residuals under their own diagnostic codes rather than assuming the 30 percent minimum covers them.
Common Mistakes
The most consequential mistake is not knowing the 60 percent level exists. A veteran who is listed for a liver and waiting is entitled to a minimum 60 percent evaluation under DC 7351, and many wait until after the operation to file, losing months of an evaluation the schedule already provided for. The second is misreading when the 100 percent period begins and ends. It begins on the date of hospital admission for the transplant, not the date of surgery, and it runs for an indefinite period — it does not expire on its own at the twelve-month mark. What happens at one year following discharge is a mandatory VA examination; the evaluation only changes if the VA acts on that examination through the 38 CFR 3.105(e) reduction procedure, which requires notice, a period to respond, and a separate decision. The third is treating the 30 percent minimum as the answer rather than the floor. The Note to the code directs that residuals of recurrent underlying liver disease are rated under the appropriate code and combined with other post-transplant residuals under the appropriate body systems where appropriate, so kidney impairment, diabetes, recurrent infection and medication-related malignancy each belong in the claim. The fourth is never establishing service connection for the disease that destroyed the liver, which is what makes the whole code available; a transplant is not service connected because it happened, but because the condition that required it was.
Frequently Asked Questions
Can I get a rating while I am still waiting for a transplant?
Yes, and this is the part of DC 7351 that is most often missed. The code provides a 60 percent minimum rating for a veteran who is "eligible and awaiting transplant surgery." If your service-connected liver disease has put you on the transplant list, that minimum applies to the waiting period, before any operation. File when you are listed rather than after the surgery — the listing confirmation and hepatology records are the evidence, and filing early sets an earlier effective date for everything that follows.
When exactly does the 100 percent rating start?
On the date of hospital admission for the transplant surgery, not the date of the operation itself. The Note to DC 7351 states it plainly: assign a 100 percent rating as of the date of hospital admission for transplant surgery. Where a veteran is admitted several days before the operation, that difference is real money and it depends entirely on which date reaches the file, so send the admission record rather than the operative report alone.
Does the 100 percent rating automatically drop to 30 percent after a year?
No. The criteria assign 100 percent "for an indefinite period" from admission. What the Note schedules for one year following discharge is a mandatory VA examination, and any change in evaluation based on that examination has to go through 38 CFR 3.105(e) — notice of a proposed reduction, 60 days to submit evidence, 30 days to request a predetermination hearing, and a separate decision before the reduction takes effect. Note also that the clock runs from discharge, not from surgery. If your evaluation drops without that process, it is worth challenging.
Is 30 percent the most I can get after a successful transplant?
No — 30 percent is a minimum, not a maximum. The Note directs that residuals of any recurrent underlying liver disease are rated under the appropriate diagnostic code and, where appropriate, combined with other post-transplant residuals under the appropriate body systems, subject to 38 CFR 4.14 and to the no-combining provisions of 38 CFR 4.114. Chronic kidney disease from calcineurin inhibitors, post-transplant diabetes, recurrent infection, and immunosuppression-related malignancy are each rated under their own codes. The 30 percent floor exists because lifelong immunosuppression is itself a disability, even when the graft is working perfectly.
My liver disease came from drinking. Can it still be service connected?
It can, through the secondary route. Compensation is barred for disability that is the result of a veteran's own willful misconduct, and primary alcohol abuse falls within that bar. But where alcohol use disorder is itself secondary to a service-connected condition — most commonly PTSD or another mental-health disability — the liver disease that follows can be service connected as secondary to that condition. This is well-established and turns on a competent medical opinion tracing the chain from the service-connected disability to the alcohol use disorder to the liver damage.
Will the VA pay for the transplant itself?
VA operates transplant programs at designated centers and also authorizes care in the community where distance or clinical need requires it. Eligibility for the surgery is a health-care question, decided under the VA health-care rules, and it is separate from the compensation question this page addresses — a veteran can be entitled to VA transplant care without the underlying disease being service connected, and can be entitled to a DC 7351 evaluation for a transplant performed outside VA. Post-transplant immunosuppressive medication and monitoring are part of the ongoing care.