Most veterans searching for a diabetes rating want one answer: what does the record have to show to reach the next percentage. The answer sits in Diagnostic Code 7913 of 38 CFR 4.119, and unlike most codes, it is written almost entirely around how the disease is managed.
The code does not rate your last A1C. It rates what treatment keeps the disease under control, whether your activities are restricted, and how often severe episodes and complications occur.
The management ladder
The criteria climb with the intensity of management. Restricted diet alone supports 10 percent. Restricted diet with regulation of activity reaches 20 percent. Insulin plus restricted diet reaches 30 percent, and insulin with restricted diet and regulation of activities - injections timed around meals and activity - is where the mid-range criteria begin.
The practical point is that the prescriptions and the restrictions, not the diagnosis alone, set the floor. A file that says only diabetes, well controlled leaves the rater nowhere to go.
Episodes and complications
The higher percentages come from episodes and complications. Episodes of ketoacidosis or hypoglycemic reactions - the severe swings that require intervention - are counted by frequency, with more frequent episodes driving the rating toward 60 percent and beyond. Complications that are themselves compensable, or effects such as loss of weight and strength, push toward the top of the scale.
The counting matters: episodes recorded in emergency room and hospital records are the evidence, and a veteran who treats these episodes at home and never goes in has episodes the file does not show.
The complications are rated separately
The most valuable part of a diabetes claim is often not the diabetes itself. Diabetic peripheral neuropathy, kidney disease, retinopathy, and other distinct complications are rated under their own diagnostic codes, and their combined values frequently exceed the diabetes evaluation. 38 CFR 4.14 prohibits rating the same manifestation twice, but distinct complications are separately ratable.
Our complications guide walks through the main ones, including the neurological codes in 38 CFR 4.124a and the renal criteria.
What gets recorded matters
The rating is built from what the C&P exam and the treatment records document, which follows the structure of VA Form 21-0960C-3, the diabetes mellitus disability benefits questionnaire: treatment method, diet and activity restrictions, episode frequency, and complications.
Gaps are common - insulin doses recorded without the activity restrictions, complications mentioned without a current evaluation. Our C&P exam guide explains what gets measured, and a medical records review identifies where the file falls short before the rating does.
Where veterans start
Every case is different, and there is no obligation at any step. When veterans want to understand what their records actually support, these are the two most common starting points:
- Medical records review
A licensed physician reviews your records for a $250 flat fee and identifies which conditions the available evidence may support. The fee is refunded in full if nothing supportable is identified.
- Nexus letter
When the records support one, a licensed provider writes the medical opinion that addresses the link between your condition and your service or an already service-connected disability.
Increased ratings over time
Diabetes is progressive. Management that required diet alone a decade ago often requires insulin now, and complications accumulate. A rating set years ago can be stale, and the criteria in 38 CFR 4.1 direct the VA to evaluate the disability as it exists today, not as it was rated.
When the rating no longer matches reality, the evidence guide covers what an increased rating claim needs, and our guide on why VA claims get denied helps identify what a prior decision actually found missing.
Regulation of activities as its own criterion
One of the most overlooked pieces of Diagnostic Code 7913 is regulation of activities - a medically prescribed limitation on strenuous occupational and recreational activity because of the diabetes itself. This is not the same as being tired or deconditioned. It is a specific restriction a physician or nurse practitioner documents in the treatment record, and it is a required element for the 40 percent evaluation and above.
Veterans who have been told informally to take it easy but whose chart never records a specific activity restriction often have the clinical reality without the paperwork that supports the higher percentage. Asking the treating physician or nurse practitioner to document the restriction explicitly, in writing, at a routine visit closes that gap before the next C&P exam or file review.
The restriction also has to be tied to the diabetes, not to an unrelated orthopedic or cardiac limitation, because the rater is looking for the specific connection the diagnostic code requires.
Insulin dependence versus insulin use
The 7913 criteria do not simply ask whether a veteran takes insulin. They ask what combination of diet, medication, and activity regulation the treatment plan requires, and insulin is one part of a larger picture. A veteran on a fixed insulin regimen with no activity restriction and no episodes sits in a different place on the scale than a veteran on multiple daily injections with frequent hypoglycemic episodes and a documented activity restriction.
This is why two veterans who both say I am on insulin can receive very different percentages. The file has to spell out the full regimen - injection frequency, dosage adjustments, continuous glucose monitoring if it is used, and how often the plan is revised - because the rater works from what is written down, not from the general fact of insulin use.
Hospitalizations and the record trail
Ketoacidosis and severe hypoglycemic reactions requiring hospitalization or emergency treatment are counted, and the counting is stricter than most veterans expect: the VA generally looks for medical documentation of the episode, not a veteran's recollection alone. An emergency department note, an ambulance run report, or a hospital discharge summary is far stronger evidence than a statement written months later.
Veterans who manage severe lows or highs at home with glucose tablets or emergency glucagon, without ever calling for help, should still document those events as they happen - a note in a symptom log, a message to the treating provider, or a mention at the next appointment - so the pattern exists somewhere in the record before a rating decision is made.
Frequently asked questions
What percentage does the VA rate diabetes at?
Diagnostic Code 7913 in 38 CFR 4.119 rates diabetes from 10 to 100 percent based on how the disease is managed - restricted diet alone supports 10 percent, insulin with restricted diet and regulation of activities reaches the mid-range, and episodes of ketoacidosis or hypoglycemic reactions plus complications support the higher percentages. The exact evaluation depends on what the treatment records and the C&P exam document.
Does the VA rate diabetes based on A1C or blood sugar numbers?
No. Diagnostic Code 7913 does not use a blood sugar or A1C threshold at all. The rating turns on the treatment regimen - diet, oral medication, insulin - and on regulation of activities, episodes, and complications. A veteran with a well-controlled A1C who still requires insulin and activity restriction can rate higher than the numbers alone would suggest.
Are diabetes complications included in the 7913 rating?
Some complications factor into the top of the 7913 scale, but distinct complications such as diabetic peripheral neuropathy, kidney disease, and retinopathy are typically rated separately under their own diagnostic codes rather than folded into the diabetes percentage. Our [complications guide](/articles/diabetes-complications-va-ratings) explains how those separate ratings work.
Can a diabetes rating go up over time?
Yes. Diabetes is progressive, and 38 CFR 4.1 directs the VA to evaluate the disability as it currently exists, not as it was rated years earlier. When management has intensified - moving from diet alone to oral medication to insulin, or new complications have developed - the current treatment records support a request for an increased rating.
Sources
- 38 CFR 4.119 - Schedule of ratings, endocrine system (eCFR)
- 38 CFR 4.14 - Avoidance of pyramiding (eCFR)
- 38 CFR 4.124a - Schedule of ratings, neurological conditions and convulsive disorders (eCFR)
- VA Form 21-0960C-3, Diabetes Mellitus Disability Benefits Questionnaire
- VA: Eligibility for VA disability benefits


