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DC 7716 · 38 CFR 4.117

Aplastic Anemia C&P Exam Prep

To accurately document the current severity of your aplastic anemia for VA disability rating purposes under 38 CFR - 4.117, DC 7716. The examiner will assess treatment intensity, frequency of transfusions, frequency of infections, and whether stem cell or bone marrow transplant has been required, all of which directly determine your rating percentage.

Format:
Interview + Physical
Typical duration:
30-45 minutes
DBQ form:
Hematologic_and_Lymphatic_Conditions_Including_Leukemia (Hematologic_and_Lymphatic_Conditions_Including_Leukemia)
Examiner:
Hematologist or Oncologist

What the examiner evaluates

  • History of aplastic anemia diagnosis including date of initial diagnosis and cause if known
  • Current and past treatment regimens including immunosuppressive therapy, biologic agents, and platelet-stimulating factors
  • Frequency of red cell and/or platelet transfusions over the past 12-month period
  • Frequency and severity of infections, including those requiring hospitalization
  • Whether peripheral blood or bone marrow stem cell transplant has been required
  • Current complete blood count (CBC) values: hemoglobin, hematocrit, RBC count, WBC count with differential, and platelet count
  • Functional impact on employment and activities of daily living
  • Presence of any secondary or residual conditions related to aplastic anemia or its treatment
  • Review of current medications required to control the condition

The exam will typically take place at a VA medical center, VA community care provider, or contracted exam facility such as LHI, QTC, or VES. The examiner will review your claims file and treatment records prior to or during the exam. You may be asked to bring copies of recent CBC lab results and records of any hospitalizations or transfusions. In most states, you have the right to record this examination - confirm your state's law before the appointment.

Measurements and tests

Complete Blood Count (CBC) - Hemoglobin

What it measures: Oxygen-carrying capacity of the blood; low levels indicate anemia severity and functional impairment

What to expect: The examiner will review your most recent lab values. Normal hemoglobin is approximately 13.5-17.5 g/dL for men and 12.0-15.5 g/dL for women. In aplastic anemia, this value is characteristically suppressed.

Critical thresholds

  • Below 8 g/dL Indicative of severe anemia likely requiring transfusion support, relevant to 30%, 60%, or 100% ratings depending on transfusion frequency
  • 8-10 g/dL Moderate anemia; transfusion frequency over 12 months determines exact rating tier
  • Above 10 g/dL on treatment May reflect controlled disease, but treatment intensity (e.g., continuous immunosuppressive therapy) still drives rating

Tips

  • Bring printed copies of your most recent CBC results dated within 3-6 months
  • If you have trending CBC data showing fluctuation, bring those records as well
  • Note the date of the blood draw on each result - the examiner will record this on the DBQ

Pain considerations: Severe anemia causes profound fatigue, weakness, and shortness of breath that can be debilitating even at rest. Communicate exactly how these symptoms affect your daily functioning.

Platelet Count

What it measures: Clotting ability and bleeding risk; critically suppressed in aplastic anemia due to bone marrow failure

What to expect: Normal platelet count is 150,000-400,000/mm-. In aplastic anemia, counts are frequently below 50,000 or even below 20,000, requiring platelet transfusions. The examiner will record your most recent platelet count and the date of testing.

Critical thresholds

  • 30,000 or below despite treatment Directly referenced in DBQ criteria for severe thrombocytopenia; relevant to high-tier rating evaluation
  • 30,001-50,000 Moderate thrombocytopenia; treatment type and symptom burden determine rating level
  • Above 50,000 asymptomatic Lower severity bracket; however, if achieved only through continuous platelet-stimulating factors, 60% rating may still apply

Tips

  • If your platelet count fluctuates significantly, bring the range of values from the past 12 months
  • Note whether current count reflects treatment effect (i.e., you are on eltrombopag or romiplostim)
  • Document any spontaneous bleeding episodes - bruising, petechiae, nosebleeds, gum bleeding - that have occurred even when platelets were 'controlled'

Pain considerations: Thrombocytopenia does not typically cause pain directly, but bleeding episodes and the anxiety around injury risk significantly impact quality of life and functional activities.

White Blood Cell (WBC) Count and Differential

What it measures: Immune system capacity; low WBC (leukopenia) and especially low absolute neutrophil count (ANC) indicate susceptibility to life-threatening infections

What to expect: The examiner will review total WBC and differential, particularly absolute neutrophil count (ANC). Severe neutropenia (ANC below 500/mm-) places the veteran at extreme infection risk. Infections are one of the primary rating criteria under DC 7716.

Critical thresholds

  • ANC below 500/mm- Severe neutropenia; infections at this level commonly recur with high frequency, potentially supporting 100% or 60% rating depending on documented frequency
  • ANC 500-1,000/mm- Moderate neutropenia; infection frequency over 12 months is key to rating determination
  • Infections once per 12-month period Minimum threshold for 30% rating under DC 7716

Tips

  • Prepare a written chronological list of every infection episode over the past 12 months with dates, type of infection, treatment required, and whether hospitalization was needed
  • Distinguish between minor infections treated outpatient and serious infections requiring IV antibiotics or hospitalization
  • Include documentation from your hematologist, urgent care, or ER for each infection episode

Pain considerations: Recurrent infections cause significant pain, fatigue, and functional limitation. Describe the total burden of infection episodes - recovery time, time missed from work, and impact on daily activities.

Hematocrit

What it measures: Percentage of red blood cells in total blood volume; correlates with anemia severity and functional tolerance

What to expect: The examiner will record hematocrit from your most recent CBC. Normal range is approximately 38-50% in adults. Severely suppressed hematocrit supports the need for red cell transfusions.

Critical thresholds

  • Below 25% Severe anemia typically requiring red cell transfusion support; transfusion frequency governs rating tier
  • 25-30% Moderate-to-severe anemia; transfusion threshold varies by patient but often applies

Tips

  • Bring most recent dated CBC showing hematocrit
  • If you have received red cell transfusions, document exact dates and locations of each transfusion over the past 12 months

Pain considerations: Severely low hematocrit causes extreme fatigue, weakness, and dyspnea on exertion - symptoms that can preclude even light manual labor. Describe functional limits accurately.

Rating criteria by percentage

100%

Requiring peripheral blood or bone marrow stem cell transplant; OR requiring transfusion of platelets or red cells, on average, at least once every six weeks per 12-month period (approximately 8 or more transfusions per year); OR infections recurring, on average, at least once every six weeks per 12-month period (approximately 8 or more infections per year). Note: A 100% evaluation for stem cell transplant is assigned as of the date of hospital admission and continues with a mandatory VA exam six months after hospital discharge.

Key symptoms

  • Underwent peripheral blood or bone marrow stem cell transplant
  • Requires platelet or red cell transfusion approximately every 6 weeks or more frequently
  • Experiences serious infection requiring treatment approximately every 6 weeks or more frequently
  • Profound pancytopenia despite treatment
  • Inability to perform any meaningful physical activity without medical intervention

From 38 CFR: 38 CFR - 4.117, DC 7716: 'Requiring peripheral blood or bone marrow stem cell transplant; or requiring transfusion of platelets or red cells, on average, at least once every six weeks per 12-month period; or infections recurring, on average, at least once every six weeks per 12-month period.'

60%

Requiring transfusion of platelets or red cells, on average, at least once every three months per 12-month period (approximately 4 or more transfusions per year); OR infections recurring, on average, at least once every three months per 12-month period (approximately 4 or more per year); OR using continuous therapy with an immunosuppressive agent or newer platelet-stimulating factors (e.g., eltrombopag/Promacta, romiplostim/Nplate, avatrombopag, or other FDA-approved agents).

Key symptoms

  • Requires platelet or red cell transfusion approximately every 3 months
  • Experiences infections requiring medical treatment approximately every 3 months
  • On continuous cyclosporine, tacrolimus, anti-thymocyte globulin (ATG), or similar immunosuppressive agent
  • On continuous therapy with FDA-approved platelet-stimulating factors (eltrombopag, romiplostim, avatrombopag)
  • Persistent fatigue, weakness, and increased bleeding/infection risk despite treatment

From 38 CFR: 38 CFR - 4.117, DC 7716: 'Requiring transfusion of platelets or red cells, on average, at least once every three months per 12-month period; or infections recurring, on average, at least once every three months per 12-month period; or using continuous therapy with immunosuppressive agent or newer platelet stimulating factors.'

30%

Requiring transfusion of platelets or red cells, on average, at least once per 12-month period (but less than once every three months); OR infections recurring, on average, at least once per 12-month period (but less than once every three months).

Key symptoms

  • Has required at least one platelet or red cell transfusion in the past 12 months
  • Has experienced at least one documented infection requiring medical treatment in the past 12 months
  • Not on continuous immunosuppressive therapy or platelet-stimulating factors at current time
  • May be in partial remission or on watchful waiting but still symptomatic

From 38 CFR: 38 CFR - 4.117, DC 7716: 'Requiring transfusion of platelets or red cells, on average, at least once per 12-month period; or infections recurring, on average, at least once per 12-month period.'

Describing your symptoms accurately

Fatigue and Functional Limitation

How to describe it: Describe fatigue as a constant, pervasive exhaustion that is not relieved by rest. Explain how it limits your ability to perform work-related tasks, household activities, and self-care. Quantify: how many hours per day can you be active before fatigue becomes disabling? Can you climb stairs, carry groceries, or stand for extended periods without needing to rest?

Example: On my worst days, I am so fatigued I cannot get out of bed without assistance. I cannot walk from my bedroom to the kitchen without feeling short of breath and needing to sit down. I have missed work repeatedly because I lack the energy to function. Even showering exhausts me to the point where I need to rest afterward.

Examiner listens for: Quantifiable functional limitation - how many minutes/hours of activity before fatigue sets in, whether fatigue prevents employment, whether the veteran requires assistance with activities of daily living.

Avoid: Do not say 'I get tired sometimes' or 'I manage okay most days.' Accurately describe the full spectrum of fatigue burden, including worst days and the cumulative impact over the past year.

Infection History and Frequency

How to describe it: Provide a specific, chronological account of every infection you have experienced in the past 12 months. Include the type of infection (e.g., pneumonia, sepsis, skin infection, UTI), the date it occurred, how it was treated (outpatient antibiotics vs. ER visit vs. hospitalization), and how long recovery took. If you are on prophylactic antibiotics to prevent infections, explain this clearly.

Example: In the past 12 months, I was hospitalized twice for serious infections - once for pneumonia that required IV antibiotics for 5 days, and once for a bloodstream infection that landed me in the ICU. Between those, I had three additional infections treated with oral antibiotics at urgent care. Each infection set me back weeks in terms of energy and functioning.

Examiner listens for: Precise frequency of infections per 12-month period - whether they average once every six weeks (100%), once every three months (60%), or at least once per year (30%). Whether infections required hospitalization. Whether prophylactic antibiotics are being used.

Avoid: Do not minimize infections as 'just a cold' or fail to mention infections that resolved quickly. Every documented infection matters. Do not omit infections that occurred before the formal exam period if they establish a pattern.

Transfusion Dependency

How to describe it: Provide exact dates of every platelet and red cell transfusion in the past 12 months. State whether transfusions were scheduled or emergent. Describe the symptoms that prompted each transfusion - dangerous bleeding, extreme anemia symptoms, or dangerously low platelet counts. If you have been told you are transfusion-dependent, state that explicitly.

Example: I have required red cell transfusions every six to eight weeks over the past year because my hemoglobin drops below 7 g/dL without them. Without these transfusions, I cannot function - I become too weak to walk, I feel dizzy constantly, and I cannot breathe normally with any exertion.

Examiner listens for: Precise frequency of transfusions - whether they average at least once every six weeks (100%), at least once every three months (60%), or at least once per year (30%). Whether transfusions are for red cells, platelets, or both.

Avoid: Do not round down frequency. If you received 9 transfusions in 12 months, that averages approximately once every 6 weeks - do not describe this as 'about once every few months.'

Treatment Burden and Medication Side Effects

How to describe it: Describe the full burden of your treatment regimen. If you are on continuous immunosuppressive therapy (cyclosporine, tacrolimus, mycophenolate, etc.) or platelet-stimulating factors (eltrombopag/Promacta, romiplostim/Nplate), state the medication names, doses, and how long you have been on them continuously. Describe side effects that further impair your functioning - kidney toxicity from cyclosporine, nausea, immunosuppression side effects, increased cancer risk.

Example: I have been on eltrombopag continuously for 18 months. Without it, my platelets drop to critically low levels. The medication causes significant nausea and my kidney function is monitored constantly due to cyclosporine toxicity. I require lab work every 2-4 weeks to monitor my blood counts.

Examiner listens for: Whether treatment is continuous vs. intermittent - continuous immunosuppressive therapy alone qualifies for 60% rating. The examiner will record specific medication names for the DBQ medications field.

Avoid: Do not fail to mention medications simply because they are 'working.' If you require continuous medication to maintain any level of function, that treatment burden itself is a rating criterion.

Stem Cell or Bone Marrow Transplant History

How to describe it: If you underwent a peripheral blood stem cell transplant or bone marrow transplant, provide the exact date of hospital admission, the facility where the transplant occurred, the date of hospital discharge, and any ongoing complications or follow-up treatment. A transplant automatically triggers a 100% rating as of the date of hospital admission.

Example: I was admitted to [facility name] on [date] for an allogeneic bone marrow transplant. I was discharged on [date] after [number] days. I continue to experience graft-versus-host disease affecting my skin and gastrointestinal tract, and I remain on immunosuppressive therapy as a result.

Examiner listens for: Confirmed dates of hospital admission and discharge for the transplant. Ongoing complications of the transplant such as graft-versus-host disease (GvHD). Whether the veteran has had the mandatory 6-month post-discharge VA examination.

Avoid: Do not fail to report the transplant date precisely - the 100% rating is assigned from the date of hospital admission, so accuracy on this date is critical to your retroactive rating.

Bleeding Episodes and Spontaneous Hemorrhage

How to describe it: Describe any spontaneous bleeding episodes not triggered by injury - petechiae (pinpoint skin hemorrhages), purpura, gum bleeding, nosebleeds, blood in urine or stool, or intracranial bleeding. Note how frequently these occur and whether they required medical treatment.

Example: I regularly develop extensive bruising and petechiae without any trauma. I have had nosebleeds lasting over 30 minutes. Last month I had visible blood in my urine. These episodes are frightening and limit my activities because any minor bump could cause serious bleeding.

Examiner listens for: Evidence of clinically significant bleeding as a consequence of thrombocytopenia, which supports transfusion necessity and overall severity of disease burden.

Avoid: Do not dismiss bruising or minor bleeding as unimportant. These are clinical manifestations of aplastic anemia that document the real-world impact of your disease.

Common mistakes to avoid

Failing to document exact transfusion frequency over the prior 12 months

Why: The entire rating scale for DC 7716 is built around whether transfusions occurred once every 6 weeks, once every 3 months, or at least once per year. Without precise documentation, the examiner cannot accurately check the correct DBQ boxes.

Do this instead: Create a written log of every transfusion with the exact date, type (red cells vs. platelets), facility, and reason. Bring copies of transfusion records or infusion center visit summaries.

Impact: Differentiates between 30%, 60%, and 100%

Not mentioning continuous immunosuppressive therapy or platelet-stimulating agents

Why: Continuous therapy with immunosuppressive agents or newer platelet-stimulating factors (e.g., eltrombopag, romiplostim) is a standalone criterion for a 60% rating - even if transfusions and infections are infrequent. Veterans who do not mention these medications may be underrated.

Do this instead: Explicitly state every medication you take continuously for aplastic anemia, including the drug name, dose, and how long you have been on it without interruption. Bring a current medication list.

Impact: Can mean the difference between 30% and 60%

Understating the frequency or severity of infections

Why: Infection frequency is a primary rating criterion alongside transfusions. Veterans who describe infections vaguely or omit minor-seeming infections may not meet documented thresholds.

Do this instead: Prepare a written, dated list of every infection episode in the past 12 months regardless of severity. Include urgent care visits, ER visits, hospitalizations, and outpatient antibiotic courses.

Impact: Differentiates between 30%, 60%, and 100%

Failing to bring dated lab results to the exam

Why: The DBQ requires the examiner to record specific CBC values (hemoglobin, hematocrit, RBC, WBC with differential, and platelet count) with dates. If the examiner cannot access recent labs, the DBQ may be incomplete or based on outdated data.

Do this instead: Bring printed copies of your most recent CBC (within 3-6 months if possible) with dates clearly visible. If labs fluctuate significantly, bring trending data from the past 6-12 months.

Impact: All rating levels - supports accurate documentation

Saying 'I'm doing okay' or minimizing symptoms out of habit

Why: Veterans often adapt to their condition and normalize severe limitations. The examiner documents current severity, not average days - describing your best days will result in underrating.

Do this instead: Per M21-1 guidance, describe your worst days and your typical bad days. Accurately communicate how your condition affects you at its worst within a representative period.

Impact: All rating levels

Not disclosing the stem cell or bone marrow transplant date precisely

Why: A 100% rating for aplastic anemia with transplant is assigned as of the date of hospital admission - not the transplant procedure date alone. An incorrect or missing admission date may result in a delayed effective date, costing the veteran significant back pay.

Do this instead: Provide the exact date of hospital admission for the transplant, the facility name, and the date of hospital discharge. Bring discharge summaries if available.

Impact: 100% - affects effective date and potential back pay

Forgetting to address functional impact on employment and daily activities

Why: The DBQ includes a section on functional impairment. Failure to describe how aplastic anemia affects your ability to work, perform household tasks, or maintain employment leaves this section blank, weakening the overall record.

Do this instead: Prepare specific examples of how your condition has limited your work capacity, led to missed work days, required workplace accommodations, or prevented you from performing your occupational duties.

Impact: All rating levels - supports overall claims adjudication

Prep checklist

  • critical

    Compile a complete transfusion log for the past 12-24 months

    List every red cell and platelet transfusion with exact dates, types, facility names, and the clinical reason for each transfusion. Count the total number per 12-month period and calculate average frequency. This is the single most critical document for your rating determination.

    before exam

  • critical

    Compile a complete infection log for the past 12-24 months

    List every infection episode with date, type of infection (e.g., pneumonia, bacteremia, UTI), how it was treated (outpatient antibiotics vs. ER vs. hospitalization), and recovery time. Calculate frequency per 12-month period.

    before exam

  • critical

    Gather current and recent CBC lab results

    Print copies of your most recent complete blood count including hemoglobin, hematocrit, RBC count, WBC count with differential, and platelet count. Include the date of the blood draw. If possible, include 12 months of trending CBC data.

    before exam

  • critical

    Prepare a complete medication list

    List all current medications with drug name, dose, frequency, and duration of use. Specifically highlight continuous immunosuppressive agents (cyclosporine, tacrolimus, mycophenolate, ATG) and platelet-stimulating factors (eltrombopag/Promacta, romiplostim/Nplate, avatrombopag). Include start dates to demonstrate continuous use.

    before exam

  • critical

    Document stem cell or bone marrow transplant history

    If you underwent a peripheral blood stem cell or bone marrow transplant, locate your hospital admission date, discharge date, facility name, and any post-transplant complications (e.g., graft-versus-host disease). Bring the discharge summary if available.

    before exam

  • recommended

    Review your VA claims file and treatment records

    Request your VA claims file (C-file) through eBenefits or your VSO and review treatment records to ensure all hospitalizations, transfusions, and specialist visits are documented. Identify any gaps in documentation that you need to address.

    before exam

  • recommended

    Prepare a written functional impact statement

    Write 2-3 paragraphs describing how aplastic anemia affects your ability to work, perform daily activities, care for yourself, and maintain social/family relationships. Include specific examples of activities you can no longer do or have had to modify.

    before exam

  • recommended

    Obtain buddy statements or lay statements if applicable

    Ask a spouse, family member, coworker, or caregiver to write a statement describing what they have personally witnessed regarding your fatigue, bleeding episodes, infections, transfusion visits, and functional limitations. Submit these to VA prior to the exam.

    before exam

  • recommended

    Verify state law on recording C&P examinations

    Most states permit veterans to record their C&P exam with prior notice. Verify your state's law, and if permitted, bring a recording device or use your smartphone. Notify the examiner at the start of the appointment.

    before exam

  • critical

    Arrive describing your worst representative day

    Per M21-1, the examiner is required to evaluate your condition at its worst. Do not put on your 'best face.' Dress and present yourself in a manner that honestly reflects how you feel on a typical bad day with aplastic anemia. Do not cancel or reschedule unless truly unable to attend.

    day of

  • critical

    Bring all printed documentation

    Bring your transfusion log, infection log, current CBC results, medication list, transplant records if applicable, and any private hematologist letters or treatment summaries. Offer these to the examiner at the start of the appointment.

    day of

  • optional

    Do not take pre-exam medications that mask symptoms unless medically necessary

    If you take medications that reduce fatigue or other symptoms, discuss with your treating physician whether it is appropriate to time doses to allow accurate presentation of your natural symptom burden. Never skip medically necessary medications.

    day of

  • critical

    Provide exact numbers, not vague descriptions

    When asked about transfusion or infection frequency, give the examiner exact counts and dates. Say '9 red cell transfusions between January and December of last year' rather than 'I get transfusions pretty often.' The DBQ requires specific frequency checkboxes.

    during exam

  • critical

    Describe the full impact of each infection episode

    For each infection, explain severity (did it require ER, hospitalization, or IV antibiotics?), duration (how many days were you sick?), and downstream impact (how long did it take to return to baseline?). This contextualizes frequency data.

    during exam

  • recommended

    Confirm the examiner has reviewed your claims file and submitted records

    Ask at the start: 'Have you had a chance to review my claims file and the records I brought today?' If the examiner has not reviewed your documentation, politely ensure they are aware of the key records you have brought.

    during exam

  • recommended

    Describe functional impact in specific, concrete terms

    When asked about how the condition affects your daily life, give concrete examples: 'I can no longer work more than 2-3 hours before I need to rest,' 'I have missed X days of work in the past year due to hospitalizations and recovery,' 'I can no longer exercise or perform physical labor because of bleeding risk and fatigue.'

    during exam

  • recommended

    Request a copy of the completed DBQ

    You have the right to request a copy of the completed DBQ. Submit a FOIA request to VA or ask your VSO to obtain it once your claim is processed. Review the DBQ for accuracy - if it misrepresents your symptoms or frequency data, you can submit a written statement to correct the record.

    after exam

  • recommended

    Document your recollection of the exam immediately after

    Write down everything discussed during the exam as soon as possible - what questions were asked, your answers, anything the examiner noted or seemed to skip. This record will be valuable if you need to appeal.

    after exam

  • critical

    Follow up on mandatory 6-month post-transplant examination if applicable

    Per DC 7716 Note (1), if you received a stem cell or bone marrow transplant and were rated 100%, VA is required to schedule a mandatory examination six months after hospital discharge. Ensure this exam is scheduled and attend it.

    after exam

Your rights during a C&P exam

  • You have the right to a thorough and accurate C&P examination; if the examiner does not ask about all relevant symptoms, you may volunteer that information.
  • You have the right to record your C&P examination in most states - verify your state's law before the appointment and notify the examiner at the start.
  • You have the right to request a copy of the completed DBQ once your claim is adjudicated, typically via FOIA request or through your VSO.
  • You have the right to submit a written statement to correct the record if the DBQ inaccurately reflects your reported symptoms or history - do this promptly after receiving the DBQ.
  • You have the right to request a new C&P examination if the original was inadequate - this may apply if the examiner failed to address key rating criteria, did not review your claims file, or if significant time has passed and your condition has worsened.
  • You have the right to submit a private medical opinion (Independent Medical Opinion/IMO or Nexus letter) from your treating hematologist or oncologist if you disagree with the VA examiner's findings.
  • You have the right to appeal a rating decision through the Supplemental Claim, Higher-Level Review, or Board of Veterans' Appeals lanes under the Appeals Modernization Act (AMA).
  • Under 38 CFR - 3.105(e), any change in your aplastic anemia evaluation based on a new examination is subject to due process protections - VA must propose reductions in writing and provide you an opportunity to respond before implementing a rating decrease.
  • You have the right to submit buddy statements (lay statements) from family members, caregivers, or coworkers who can describe the observable impact of your condition on your daily functioning.
  • If your aplastic anemia required a stem cell or bone marrow transplant, you are entitled to a 100% evaluation as of the date of hospital admission under DC 7716 Note (1), with a mandatory follow-up examination six months after discharge.

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This guide covers what to expect for any veteran with this condition. If you have already uploaded your medical records, sign in to generate a packet that maps your specific symptoms to the DBQ fields your examiner will fill out.

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This C&P exam preparation guide is for educational purposes only and does not constitute legal, medical, or claims advice. Always consult with a qualified Veterans Service Organization (VSO) representative or VA-accredited attorney for guidance specific to your claim. Never exaggerate, minimize, or fabricate symptoms during a C&P examination.