M21-1MR Citations

V.iii.4.A.1.e. Requirement for PFTs

PFT results are required for 38 CFR 4.97, DC 6600, 6603, 6604, 6825-6833, and 6840-6845 as specified at 38 CFR 4.96(d) except when:

the results of a maximum exercise capacity test are of record and are 20 milliliters/per kilogram of body weight per minute (ml/kg/min) or less
pulmonary hypertension has been diagnosed
cor pulmonale has been diagnosed
right ventricular hypertrophy has been diagnosed
there have been one or more episodes of acute respiratory failure, or
outpatient oxygen therapy is required.

The table below contains instructions for assigning disability evaluations based on the results of PFTs. This table applies to 38 CFR 4.97, DC 6600, 6603, 6604, 6825-6833, and 6840-6845 as specified at 38 CFR 4.96(d).

<aside> 📚 Notes:

If a maximum exercise capacity test is not of record, evaluate based on alternative criteria.
A diagnosis of pulmonary hypertension requires objective documentation by an echocardiogram or cardiac catheterization.
When the rating criteria for a disability not regulated by 38 CFR 4.96(d) include PFTs among the potential methods for assigning a disability evaluation, such as 38 CFR 4.97, DC 6602 for asthma, PFTs are not required to evaluate the disability. However, if PFTs were previously utilized to assign a disability evaluation and consideration is being given to a reduced evaluation, apply 38 CFR 3.344(a). When the prior evaluation was assigned based on PFTs, the current examination must also include PFTs if a reduced evaluation due to improvement is being considered.

Reference: For more information on when PFTs are required, see 38 CFR 4.96(d).

</aside>

If …	And …	Then ...
PFTs are not consistent with clinical findings	the examiner does not state why PFTs are not a valid indication of respiratory disability	evaluate based on PFTs.
PFTs are not consistent with clinical findings	the examiner states why PFTs are not a valid indication of respiratory disability	evaluate based on alternative criteria.
there is a disparity between PFT results (FEV-1, FVC, FEV-1/FVC, DLCO)	the evaluation would differ depending on the test result used	use the test result that the examiner states most accurately reflects the level of disability.
FEV-1 is greater than 100 percent	FVC is greater than 100 percent	do not assign a compensable evaluation based on a decreased FEV-1/FVC ratio.
DLCO is not of record	the examiner states why DLCO would not be useful or valid	evaluate based on alternative criteria.
DLCO is not of record	the examiner does not state why DLCO would not be useful or valid	return the examination as insufficient and request clarification.

V.iii.4.A.1.g. Post-Bronchodilator Studies, Requirements, and Evaluations

Post-bronchodilator studies are required when PFTs are done for disability evaluation purposes for disabilities rated under 38 CFR 4.97, DC 6600, 6603, 6604, 6825-6833, and 6840-6845 except when

the results of pre-bronchodilator PFTs are normal
the examiner determines that post-bronchodilator studies should not be done and states why, or
using the DLCO score values (Clinicians have stated that bronchodilator use has no effect on DLCO values.)

When evaluating based on PFTs, use post-bronchodilator results unless the post-bronchodilator results were poorer than the pre-bronchodilator results. In those cases, use the pre-bronchodilator values for rating purposes.

V.iii.4.A.1.h. DLCO Testing

When utilizing DLCO to evaluate a respiratory disability, only test results recognized as DLCO or DLCO by the single breath method (DLCO (SB)) will be utilized for rating purposes.

DLCO divided by alveolar volume (DLCO/VA) is a variant of DLCO (SB) in which the DLCO is divided by the alveolar volume of the lungs. There is no provision for considering DLCO/VA under 38 CFR 4.96 or 38 CFR 4.97. Consequently, DLCO/VA cannot be utilized for rating purposes.