Pulmonary Fibrosis

Pulmonary fibrosis involves two separate VA questions. The percentage comes from the General Rating Formula for Interstitial Lung Disease in 38 CFR § 4.97. Service connection may be presumed under 38 U.S.C. § 1120 when pulmonary fibrosis becomes manifest in a covered veteran as defined by § 1119(c).

The presumption can establish the connection to service. It does not set the percentage. VA still needs current pulmonary-function or severe cardiopulmonary evidence to assign 10, 30, 60, or 100 percent.

TL;DR

• DC 6825 covers diffuse interstitial fibrosis, and DCs 6825 through 6833 use the General Rating Formula for Interstitial Lung Disease.
• The formula provides 10, 30, 60, and 100 percent levels.
• The main measurements are FVC and DLCO (SB), with exercise capacity and certain severe findings also controlling at the higher levels.
• Section 4.96 explains when PFTs are required, which bronchodilator results to use, and what happens when test values point to different ratings.
• Pulmonary fibrosis is listed directly in 38 U.S.C. § 1120(b)(10). It is not a 38 CFR § 3.320 condition.
• The statutory presumption applies only when the veteran meets the covered-service definition in 38 U.S.C. § 1119(c).
• Coexisting listed respiratory ratings generally do not stack. VA assigns one predominant respiratory evaluation under § 4.96.

The 10, 30, 60, and 100 Percent Criteria

The interstitial-lung-disease formula applies to DCs 6825 through 6833. The clinician's diagnosis controls the exact code. DC 6825 is diffuse interstitial fibrosis, while other interstitial diagnoses have their own codes within the same formula.

10 percent

FVC of 75 to 80 percent predicted, or DLCO (SB) of 66 to 80 percent predicted.

30 percent

FVC of 65 to 74 percent predicted, or DLCO (SB) of 56 to 65 percent predicted.

60 percent

FVC of 50 to 64 percent predicted, DLCO (SB) of 40 to 55 percent predicted, or maximum exercise capacity of 15 to 20 ml/kg/min oxygen consumption with cardiorespiratory limitation.

100 percent

Any one of the following can support the top level:

• FVC below 50 percent predicted;
• DLCO (SB) below 40 percent predicted;
• maximum exercise capacity below 15 ml/kg/min oxygen consumption with cardiorespiratory limitation;
• cor pulmonale;
• pulmonary hypertension; or
• required outpatient oxygen therapy.

Use the predicted percentage, not the raw test value. Keep the complete report because the interpretation, bronchodilator status, test validity, and examiner explanation can control which number VA uses.

The Special PFT Rules in 38 CFR § 4.96

Section 4.96 applies special rules to DCs 6825 through 6833:

• PFTs are generally required unless a listed severe alternative is already documented, such as qualifying exercise capacity, pulmonary hypertension, cor pulmonale, right-ventricular hypertrophy, acute respiratory failure, or outpatient oxygen therapy.
• If DLCO (SB) is absent, the examiner must explain why that test would not be useful or valid before VA relies on alternatives.
• Post-bronchodilator studies are normally required for a disability evaluation unless pre-bronchodilator results are normal or the examiner explains why post-testing should not be performed.
• VA normally uses post-bronchodilator values. If those values are poorer than the pre-bronchodilator values, it uses the pre-bronchodilator results.
• When different PFT values would produce different percentages, VA uses the result the examiner says most accurately reflects the disability.

These rules prevent a claimant or rater from simply selecting the lowest number on the page without reading the medical interpretation.

The PACT Act Statutory Presumption

Section 1120(b)(10) lists pulmonary fibrosis as a specified disease. Under § 1120(a), the disease is presumed incurred in or aggravated by service when it becomes manifest in a covered veteran, subject to the statute's rebuttal rules. Section 1120(c) adopts the covered-veteran definition from 38 U.S.C. § 1119(c), which identifies qualifying locations, airspace, and periods.

This is a statutory PACT Act route. It should not be cited as 38 CFR § 3.320, which covers a different set of respiratory diseases and cancers. It also should not be reduced to “burn-pit exposure equals a grant.” The record still needs a current pulmonary-fibrosis diagnosis and proof that the veteran meets the statutory service definition.

For the presumptive route, preserve:

• the diagnosis and medical subtype;
• service records establishing a qualifying location and period; and
• current severity evidence for the percentage.

The presumption addresses nexus. It does not choose DC 6825 automatically or replace current PFT evidence.

Direct Service Connection Outside the Presumption

A veteran who does not meet § 1119(c) can still pursue direct service connection under 38 CFR § 3.303. That route needs a current diagnosis, an in-service disease, event, or exposure, and competent medical evidence linking the two.

Document the actual exposure history, including duty location, duration, protective equipment, and available service records. Do not assume that asbestos, silica, chemicals, or particulate matter caused the individual veteran's disease without a medical opinion addressing timing, dose, diagnosis, and competing causes.

Coexisting Respiratory Conditions

Section 4.96(a) generally prohibits combining ratings under DCs 6600 through 6817 and 6822 through 6847. VA assigns one evaluation under the code reflecting the predominant disability and may elevate to the next level when overall severity warrants it.

This matters when the record also lists COPD, chronic bronchitis, constrictive bronchiolitis, or another interstitial disease. The diagnoses still matter, but their overlapping respiratory impairment is not normally paid as stacked schedular percentages.

A records checklist for your pulmonary-fibrosis claim

Keep the service-connection and rating evidence in separate rows so one does not get mistaken for the other.

Fictional example: a report contains an FVC result and a different DLCO result that would point to different levels in the table. Keep the full report and the examiner's explanation of which result best reflects the disability. Do not copy the lower number alone into a statement and call it the assigned rating.

For the service question, Claim Raven's presumptive-conditions tool can help organize a possible match. Verify the diagnosis, dates, and location against VA's current PACT Act guidance. The presumption does not replace the medical evidence used to evaluate severity.

Common Failure Modes

• Treating the PACT Act presumption as the rating percentage.
• Citing § 3.320 instead of the § 1120 statutory pulmonary-fibrosis presumption.
• Calling every pulmonary-fibrosis subtype DC 6825 without checking the diagnosis.
• Using a raw PFT number rather than percent predicted.
• Choosing the worse PFT value without the examiner analysis required by § 4.96.
• Omitting DLCO without an explanation.
• Adding overlapping respiratory percentages despite § 4.96(a).

Bottom Line

The pulmonary-fibrosis percentage comes from the interstitial-lung-disease formula and the application rules in § 4.96. The PACT Act presumption is a separate statutory route under §§ 1119 and 1120. A complete record proves the exact diagnosis, qualifying service when claimed, and the current FVC, DLCO, exercise-capacity, oxygen, or cardiopulmonary findings that set the evaluation.

Related Conditions and Tools

Compare chronic bronchitis, COPD, constrictive bronchiolitis, and sarcoidosis. Review DC 6825 and organize exposure and functional evidence with the Statement Builder.

Legal sources: 38 CFR § 4.96, § 4.97, 38 U.S.C. § 1119, § 1120, and 38 CFR § 3.303, checked August 17, 2026.

Practical checklist and VA PACT Act guidance reviewed September 8, 2026. The example is fictional.