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VA just published a proposed change to how it evaluates “painful scars” under Diagnostic Code 7804 (DC 7804). If you have scars that hurt—and you’re filing a new claim, going for an increase, or heading into a review exam—this could affect how your scar pain is documented and rated.
Most veterans don’t have a problem enduring pain.
We have a problem admitting it.
That “push through it” mindset kept you effective in uniform. But in the VA disability system, it can quietly cost you—because if your scar pain isn’t clearly documented during an exam (or even a routine medical appointment), VA can treat it like it doesn’t exist.
You already know the rule from active duty: if it’s not written down, it didn’t happen. The same principle applies to VA disability benefits.
And this proposed rule change puts that reality front and center.
Let’s break it down.
Table of Contents
Summary of Key Points
- VA proposed a rule change for painful scars (DC 7804): Painful scars may require “objective evidence” of pain during evaluation to be rated as painful.
- Documentation is everything: If scar pain isn’t clearly recorded in exams or medical appointments, VA can treat it like it doesn’t exist—“if it’s not written down, it didn’t happen.”
- Ratings themselves are not changing: DC 7804 percentages stay the same and are still based mainly on the number of painful or unstable scars, with a possible bonus when a scar is both.
- How you communicate at your C&P exam can make a big difference: Be specific about which scars are painful (especially with touch or movement), what triggers the pain, how severe it is, and how it limits your daily function—so the examiner documents it clearly and completely.
Proposed Changes to VA Ratings for Painful Scars (DC 7804)
On September 29, 2025, VA published a proposed rule titled Objective Evidence of Pain for Painful Scars Under DC 7804. The proposal targets 38 CFR § 4.118, Diagnostic Code 7804 (“Scar(s), unstable or painful”).
VA proposes adding a clarifying note under DC 7804:
“Pain must be confirmed by objective evidence upon evaluation or demonstration.”
Comments on the proposed rule were due November 28, 2025.
The simple takeaway
If this becomes final as written, VA is signaling that a veteran’s statement like “My scar hurts” may not be enough by itself to rate a scar as painful under DC 7804—unless the file shows objective confirmation during evaluation or demonstration.
What “Objective Evidence” Means in Real Life
VA isn’t saying you need a special test.
They’re saying they want pain to be confirmed in an observable way during evaluation (usually at your VA C&P exam).
A plain, easy example:
- Tenderness when the scar is touched during the exam
Put simply: VA examiners would be looking for physical indicators that support pain—not relying only on self-reports.
Why VA Says It’s Making This Change
VA’s stated goal is clarity and consistency.
In everyday terms, they want a standardized approach so scar pain is evaluated the same way across different examiners and different VA raters. VA also frames this as aligning with how painful scars have historically been evaluated, even when the wording of DC 7804 changed over time.
What’s NOT Changing (And This Matters)
This proposal is not a rewrite of current VA disability ratings for scars.
VA says the change is intended to clarify a longstanding requirement—not change the underlying rating criteria or reduce compensation.
So, the rating percentages under DC 7804 stay the same.
DC 7804 Rating Criteria Refresher (Unstable or Painful Scars)
Under 38 CFR, Part 4, the VASRD, DC 7804, ratings depend mainly on how many scars are painful or unstable:
- 10% — 1 or 2 scars that are unstable or painful
- 20% — 3 or 4 scars that are unstable or painful
- 30% — 5 or more scars that are unstable or painful
There’s also an important bonus rule:
- If one or more scars are both unstable AND painful, VA adds an additional 10%.
Who This Could Impact Most
This proposal matters most if you’re a veteran who is:
- Filing a new claim for painful scars
- Requesting an increase for scar ratings
- Going through a C&P review / reevaluation exam
- Attending appointments where scar pain should be documented (because those notes often end up influencing the claim file)
Examples: How Veterans Can Lose (or Protect) a DC 7804 Rating
Example #1: The “I deal with it” exam → weak documentation → underrated
You have a surgical scar that burns daily and hurts when clothing rubs it.
At the C&P exam, you say: “Yeah it hurts sometimes, but I deal with it.”
If the examiner doesn’t document objective confirmation, the file may not support a “painful scar” finding strongly enough—so VA may underrate it.
Example #2: Clear pain description + documented tenderness → clean 10%
Same scar, but this time you explain:
- what it feels like (burning, stabbing, throbbing, pulling)
- how often (daily vs intermittent)
- triggers (touch, clothing friction, temperature, stretching)
- real impact (sleep, mobility, work tasks)
The examiner palpates the scar and documents tenderness/pain response.
That kind of record is exactly what DC 7804 is meant to capture.
Example #3: Multiple painful scars, but only one is documented → lower rating than deserved
You have four scars that hurt, but the exam only documents one as painful/tender.
VA can only rate what’s supported in the record. If the painful scar count isn’t captured correctly, the rating can come out lower than what the facts justify.
Pro Tips: How to Protect Your Painful Scar Rating (DC 7804)
1) Don’t downplay pain—at exams OR appointments
Veterans are trained to push through pain. But if pain isn’t discussed or demonstrated, it may not be documented—and your rating can suffer.
2) Describe pain in a way that’s easy to document
Use specifics to describe your severity of symptoms:
- burning, throbbing, stabbing, pulling
- frequency: constant vs intermittent
- triggers: touch, friction, stretching, heat/cold
- functional impact: sleep, concentration, work tasks, mobility
3) Make objective confirmation easy for the examiner
If the scar is painful to touch, say so—clearly.
If certain movements or friction trigger it, describe that.
If you have flare-ups, explain what makes them worse and what they prevent you from doing.
4) Remember: this isn’t complaining—it’s documentation
You’re not asking for sympathy.
You’re documenting a condition accurately so the record reflects reality.
Conclusion & Wrap-Up
VA’s proposed change is narrow, but meaningful:
- It does not change current VA ratings for scars.
- It does increase the importance of documented, objective confirmation of pain when rating scars under DC 7804.
If you have painful scars and you’re headed into an exam or review, your mission is simple:
Be honest, accurate, detailed, and don’t hold anything back. If you have pain upon touch or movement, make sure to tell your doctor or C&P examiner. Do not minimize or downplay your symptoms. Make sure your medical records are properly documented with the pain you live with.
Frequently Asked Questions (FAQs)
Is this rule final?
No. This is still a proposed VA rule change—not a finalized regulation. It was published as a proposed rule on September 29, 2025, and the public comment period closed on November 28, 2025. A proposal doesn’t automatically change your current rating today, but it’s a clear signal of what VA wants reinforced: painful-scar ratings under DC 7804 should be supported by objective confirmation in the exam record.
What exactly is VA proposing to change for scars?
VA is proposing to add a clarifying note under Diagnostic Code 7804 (scar(s), unstable or painful) stating that pain must be confirmed by objective evidence upon evaluation or demonstration. The focus is narrow: it’s about what VA requires to label a scar “painful” for DC 7804 purposes—not about rewriting all scar diagnostic codes.
Does this change the DC 7804 percentage levels?
No. The percentage structure under DC 7804 remains the same. Ratings are still based primarily on how many scars are painful or unstable:
- 10% for 1–2 painful or unstable scars
- 20% for 3–4 painful or unstable scars
- 30% for 5+ painful or unstable scars
There’s also a key rule that can increase the outcome when a scar is both painful and unstable.
What does VA mean by “objective evidence” of pain?
In plain terms, VA is saying scar pain needs to be confirmed during evaluation, not just reported. “Objective evidence” usually means the examiner documents an observable finding consistent with pain—most commonly tenderness when the scar is touched (palpation) or an observable pain response (guarding, flinching, pulling away). The big point: you don’t need a special test—you need the exam and medical record to reflect pain in a way VA considers confirmable and clearly documented.
What counts as an “unstable” scar?
An unstable scar is one where there is frequent loss of covering of skin over the scar—for example, it repeatedly breaks open, scabs, reopens, or has recurring skin breakdown. If you have that, it’s not just “annoying”—it can directly affect how the scar is rated.
If my scar is both painful and unstable, does that matter?
Yes. Under DC 7804 rules, when one or more scars are both painful and unstable, VA can apply an additional increase on top of the evaluation based on the number of painful/unstable scars. This is a commonly missed rating opportunity because “painful” and “unstable” are often not both documented clearly.
Does this proposal affect all scar ratings or only DC 7804?
This proposal is specifically about DC 7804—the code for unstable or painful scars. Other VA scar ratings (like scars of the head/face/neck, large scars by area, or scars that cause functional limitations) may still be rated under other diagnostic codes, depending on your facts.
What should I say at my C&P exam so scar pain is documented correctly?
Be honest, accurate, and don’t hold back. Don’t just say “it hurts.” Explain “how” it hurts:
- What it feels like: burning, stabbing, throbbing, pulling
- How often: daily, intermittent, constant
- What triggers it: touch, friction from clothing, stretching, pressure, temperature changes
- What it prevents: sleep disruption, walking/kneeling limits, lifting limits, work task interference
Then make sure the examiner understands which scars you’re talking about (scar #1, #2, location) so the count is documented correctly.
What if my scar pain is real but the examiner didn’t document it?
That’s one of the most common reasons veterans get underrated. If the exam write-up doesn’t reflect the truth, your next step is to strengthen documentation—medical notes describing scar pain/tenderness, photos if relevant, and a detailed statement describing pain triggers and functional impact. If the decision is already issued, the right review lane depends on whether you need to add new evidence or correct an error in how VA evaluated the evidence already in the file.
What’s the #1 way veterans get underrated for painful scars?
Minimizing pain and leaving the exam record vague. Two patterns cause most underrates:
- Veterans downplay pain (“I deal with it”)
- The C&P exam fails to document (a) which scars are painful, (b) how many are painful/unstable, and (c) objective confirmation of pain during evaluation
VA can only rate what’s supported in the record. If you have 3–4 painful scars but only one is documented properly, you can end up at 10% instead of 20%.
Does this proposed change mean VA won’t believe veterans anymore?
Not exactly. It’s not “VA doesn’t believe you.” It’s “VA wants the record to show confirmation.” The practical impact is that self-report alone may carry less weight for DC 7804 unless supported by exam findings and consistent medical documentation.
What’s the bottom-line action step for veterans?
If you have painful scars and you’re headed into an exam or review, your mission is simple: be honest, be specific, and make sure the record documents the painful scar count and objective confirmation of pain. That’s how you protect your rating under DC 7804—especially if VA finalizes this proposal.
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Brian Reese
Brian Reese is a world-renowned VA disability benefits expert and the #1 bestselling author of VA Claim Secrets and You Deserve It. Motivated by his own frustration with the VA claim process, Brian founded VA Claims Insider to help disabled veterans secure their VA disability compensation faster, regardless of their past struggles with the VA. Since 2013, he has positively impacted the lives of over 10 million military, veterans, and their families.
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