Benign Gynecological Tumors — VA Disability Rating (DC 7628)
Diagnostic Code 7628 · 38 CFR §4.116
What Is It?
DC 7628 covers benign, meaning non-cancerous, growths of the gynecological system: uterine fibroids, ovarian cysts and benign ovarian tumors, endometrial and cervical polyps, and similar lesions. They are common, they are not dangerous in the way cancer is, and they can still be genuinely disabling — heavy bleeding that causes iron deficiency, pelvic pain and pressure, urinary frequency from a mass pressing on the bladder, painful intercourse, and infertility. Under 38 CFR §4.116, DC 7628 carries no percentage tiers of its own. The entry directs that chronic residuals, to include scars, lymphedema, disfigurement, and other impairment of function, be rated under the appropriate diagnostic code or codes within the appropriate body system. That instruction is easy to misread as a denial and it is nothing of the kind. It means the evaluation is assembled from what the growth and its treatment actually do, each piece rated where it lives: bleeding and pelvic symptoms under the General Rating Formula for Disease, Injury, or Adhesions of Female Reproductive Organs, which runs 0, 10, and 30 percent; surgical scars under the scar codes; organ removal under the codes for removal of the uterus or ovaries; urinary symptoms under the genitourinary criteria; and resulting anemia under the hemic codes. A note worth carrying: uterine fibroids have their own code at DC 7613, so a fibroid claim is usually filed there rather than here.
Rating Criteria
| Rating | Criteria |
|---|---|
| See pathways | DC 7628 assigns no percentage. Under 38 CFR §4.116 it directs that chronic residuals — to include scars, lymphedema, disfigurement, and other impairment of function — be rated under the appropriate diagnostic code(s) within the appropriate body system. In practice the routes are: (1) pelvic pain and abnormal bleeding under the General Rating Formula for Disease, Injury, or Adhesions of Female Reproductive Organs (DC 7610-7615) — 30 percent for symptoms not controlled by continuous treatment, 10 percent for symptoms that require continuous treatment, 0 percent for symptoms that do not require continuous treatment; (2) surgical scars under DC 7801-7805; (3) removal of the uterus or ovaries under DC 7617, 7618, or 7619; (4) urinary frequency or obstruction from mass effect under the voiding dysfunction criteria of 38 CFR §4.115a; (5) iron deficiency anemia from chronic bleeding under 38 CFR §4.117 — and note that DC 7720 excludes anemia due to blood loss, directing that it be rated under the criteria for the condition causing the loss, which here is the gynecological condition itself. Separate evaluations are combined under 38 CFR §4.25. |
Evidence Needed
Because the evaluation is assembled from residuals, the file has to document each one separately. Start with what proves the growth is benign and where it is: the pelvic ultrasound or MRI with measurements, and the pathology report from any biopsy or removal. Then document the functional consequences one at a time. For bleeding, a menstrual calendar recording days of bleeding, pad or tampon changes per day, and any episodes of flooding, plus hemoglobin and ferritin results showing iron loss. For pain, the treatment record: what you take, how often, whether it controls the symptoms, and whether continuous treatment is required — that phrase is the literal difference between 0, 10, and 30 percent on the general formula. For pressure symptoms, a voiding diary and any imaging describing the mass against the bladder. For surgery, the operative report, the pathology, and photographs of the scars with measurements.
C&P Exam Tips
The single most important thing to make clear is whether your symptoms require continuous treatment and whether that treatment controls them, because the general rating formula for female reproductive organs is built on exactly those two questions. Say it in those words: my symptoms require continuous treatment, or my symptoms are not controlled by continuous treatment. Bring the menstrual calendar and give numbers for bleeding rather than describing it as heavy. Report the pressure symptoms — urinary frequency, constipation, pelvic heaviness — since those are rated in other body systems and will not be captured by a gynecological questionnaire alone. If you have had surgery, ask that the scars be measured and examined, and if you were left anemic, say so and ask that the blood work be reviewed. Name each residual you are claiming while you are in the room.
How to File
File on VA Form 21-526EZ naming the specific growth — an ovarian cyst, an endometrial polyp, a benign ovarian tumor — under DC 7628, and then list each residual as its own issue in the same claim rather than assuming they follow: pelvic pain, abnormal bleeding, anemia, urinary symptoms, surgical scars, and any psychiatric condition. Attach the imaging, the pathology, the menstrual calendar, the treatment record showing whether continuous treatment is required, and the operative report if you have had surgery. If the condition is a uterine fibroid, file under DC 7613, which is the code written for it. If the growth arose from or was worsened by a service-connected condition or treatment, cite 38 CFR §3.310 and name the primary condition.
Common Mistakes
The first mistake is reading a decision that grants service connection under DC 7628 with no percentage as a denial. It is a grant, and the percentage comes from the residuals — which have to be claimed. The second is filing one line for the tumor and never naming the bleeding, the pain, the anemia, the urinary symptoms, or the scars, which leaves the rater nothing to evaluate. The third is describing bleeding and pain in adjectives when the general formula turns on whether continuous treatment is required and whether it controls the symptoms; those exact phrases should appear in your evidence. The fourth is letting anemia from heavy bleeding go unclaimed, or claiming it under the iron deficiency code, when the note under DC 7720 directs that anemia due to blood loss be evaluated under the criteria for the condition causing the loss. The fifth is filing a fibroid here instead of under DC 7613, where it belongs.
Frequently Asked Questions
Why does DC 7628 have no percentage?
Because a benign growth is not itself a measure of impairment. Under 38 CFR §4.116 the entry directs that chronic residuals — scars, lymphedema, disfigurement, and other impairment of function — be rated under the appropriate diagnostic codes within the appropriate body system. The percentage exists; it just lives in the codes the instruction points to. A rating decision naming DC 7628 with no evaluation is telling you which residuals were never documented, not that the condition was rejected.
Where does the bleeding and pelvic pain get rated?
Under the General Rating Formula for Disease, Injury, or Adhesions of Female Reproductive Organs, which covers DC 7610 through 7615 and has three tiers: 30 percent for symptoms not controlled by continuous treatment, 10 percent for symptoms that require continuous treatment, and 0 percent for symptoms that do not require continuous treatment. The entire formula turns on the phrase continuous treatment, so your records need to show what treatment you are on, that it is continuous, and whether it actually controls the symptoms.
Is a uterine fibroid rated under this code?
Usually not. Uterine fibroids have their own diagnostic code at DC 7613, and a claim for fibroids is normally filed and evaluated there. DC 7628 is for benign gynecological growths that do not have a code of their own — ovarian cysts and benign ovarian tumors, endometrial and cervical polyps, and similar lesions. If your claim was filed under the wrong one, it is a labeling question rather than a lost claim, and it is worth correcting so the criteria applied are the ones written for your condition.
Can I get a separate rating for anemia from the bleeding?
Yes, but pay attention to which code it goes under. The note attached to DC 7720 provides that iron deficiency anemia due to blood loss is not evaluated under that code, and directs instead that it be evaluated under the criteria for the condition causing the blood loss. In practice that means heavy gynecological bleeding and the anemia it causes are considered together under the gynecological criteria rather than rated twice. Document the hemoglobin and ferritin results anyway, because they are strong evidence of how severe the bleeding actually is.
What about scars and surgery residuals?
Those are separately evaluated and are among the most commonly forgotten pieces. Surgical scars are rated under DC 7801 through 7805 depending on location, size, and whether they are painful or unstable. Removal of the uterus is rated under DC 7618, removal of an ovary under DC 7619, and removal of the uterus with both ovaries under DC 7617. Photograph the scars with something for scale, measure them, and claim each surgical consequence by name — separate evaluations are combined under 38 CFR §4.25 rather than added.