Analogous Ratings (§ 4.20)

What Are Analogous Ratings?

The VA rating schedule (38 CFR Part 4) lists about 800 diagnostic codes — but there are thousands of medical conditions. When your condition isn't specifically listed, the VA doesn't deny it. Instead, under 38 CFR § 4.20, they rate it by analogy to a listed condition that:

• Affects the same body functions
• Is located in the same anatomical area
• Has similar symptoms

When rated analogously, your condition gets assigned an existing DC number followed by a hyphen and the analogous code. For example, if your unlisted wrist condition is rated analogous to DC 5215 (wrist limitation of motion), your code sheet might show "5299-5215."

How the VA Picks an Analogous Code

The VA considers three factors when selecting an analogous code, in this order of priority:

1. Functions affected: What body functions does the condition impair? A condition that limits breathing should be rated under a respiratory code, even if it's caused by something else.
2. Anatomical location: Where in the body is the condition? A condition in the knee area should be rated under knee codes, even if the specific diagnosis isn't listed.
3. Symptomatology: What symptoms does it cause? Pain, limitation of motion, nerve damage, fatigue — the symptoms guide the code selection.

Common Analogous Rating Examples

Arguing for a More Favorable Analogous Code

The choice of analogous code directly affects your rating percentage. Different codes have different criteria and maximum ratings. You have the right to argue for the code that best represents your disability picture.

When to Challenge the VA's Code Selection

• The selected code has a lower maximum rating than another applicable code. Some codes max out at 30% while others for similar symptoms go to 100%.
• The criteria don't match your symptoms. If you're rated under a code that evaluates range of motion but your primary symptom is pain/fatigue, a different code may be more appropriate.
• Your condition affects multiple body systems. The VA should rate the predominant disability, but sometimes a different system's code better captures your overall impairment.

How to Argue

1. Identify the alternative code that you believe better matches your condition. Search our condition lookup to compare codes and criteria.
2. Get a medical opinion explaining why your condition more closely resembles the alternative code's listed condition — in terms of functions affected, symptoms, and anatomical location.
3. Cite § 4.20 specifically in your appeal or statement. The regulation requires the VA to select the code that represents the "closely related" function, anatomical localization, and symptomatology.
4. Explain the functional impact using the criteria language of your preferred code. Show the VA rater how your symptoms map to specific rating levels under that code.

C&P Exam Tips for Analogous Conditions

• Know which DBQ will likely be used. If you expect an analogous rating, the examiner will use the DBQ for the analogous condition. Review that DBQ before your exam so you know what they'll measure.
• Describe ALL symptoms, not just the primary one. The more symptoms you document, the more codes become potentially applicable — and the VA must pick the one most favorable to you.
• Ask the examiner which code they're evaluating under. You have a right to know, and if you believe a different code is more appropriate, note that in your claim file.
• Bring a list of how your unlisted condition compares to listed conditions. A side-by-side comparison showing symptom overlap helps the examiner and rater understand your position.
• Report functional limitations in the language of the rating criteria. If you want to be rated under a code that evaluates "incapacitating episodes," describe your episodes. If under a code that evaluates ROM, emphasize your movement limitations.

Key Tips

• Check if your condition has been added since your last claim. The VA periodically updates the rating schedule. Conditions that were once analogous (like fibromyalgia) may now have their own code with different criteria.
• Look at your code sheet. If you see a "99" code (e.g., 5299-5215), that confirms you're being rated analogously. The second number tells you which code's criteria are being applied.
• Don't accept "not listed" as a denial. The VA cannot deny service connection solely because a condition isn't in the rating schedule. § 4.20 explicitly requires them to rate it by analogy.
• Multiple analogous ratings are allowed. If your unlisted condition causes symptoms in multiple body systems, you may be entitled to separate analogous ratings for each — as long as they don't constitute pyramiding.
• Consider asking for a 0% rating. Even if your symptoms are mild, a 0% service-connected rating preserves your connection to service and opens the door for increases later.