EDUCATIONAL TOOL ONLY. Not legal or medical advice. Not affiliated with the VA.
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Cholangitis
✓ VERIFIED AGAINST 38 C.F.R.§ 4.114 (Digestive system) · reviewed 2026-05-17 · ClaimRecon Editorial Team
Cholangitis is rated by the U.S. Department of Veterans Affairs under DC 7314 of 38 CFR § 4.114, DC 7314 across 3 severity tiers (0% / 10% / 30%). Service connection requires (1) a current diagnosis, (2) an in-service event, injury, or exposure, and (3) a medical nexus opinion linking the two under 38 C.F.R. § 3.303.
OVERVIEW
Inflammation or infection of the bile duct system, often from obstruction by gallstones
RATING CRITERIA (3 LEVELS)
0%
Asymptomatic, without history of a clinically documented attack of right upper quadrant pain with nausea and vomiting in the past 12 months.
10%
With one or two clinically documented attacks of right upper quadrant pain with nausea and vomiting in the past 12 months.
30%
With three or more clinically documented attacks of right upper quadrant pain with nausea and vomiting during the past 12 months; or requiring dilatation of biliary tract strictures at least once during the past 12 months.
KEY EVIDENCE TO GATHER
-Service treatment records showing injury or complaints
-Imaging (X-ray, MRI, CT)
-Range of motion measurements
-Flare-up documentation per Sharp v. Shulkin
-Buddy statements describing limitations
-Prescription history
-Physical therapy records
-Employment impact documentation
C&P EXAM TIPS (6)
1.Do NOT stretch, warm up, or take pain medication before your exam. The VA needs your baseline limitation.
2.Report your WORST day. DeLuca v. Brown requires documentation of functional loss during flare-ups.
3.Tell the examiner about flare-ups: frequency, duration, estimated ROM loss. Sharp v. Shulkin (2017) requires estimates.
4.Request active, passive, weight-bearing, and non-weight-bearing ROM testing per Correia v. McDonald (2016).
5.If you use assistive devices (brace, cane), bring them.
6.Describe daily activity impact: work, sleep, household tasks.
SOURCES & EDITORIAL
Rating criteria text quoted verbatim from 38 C.F.R. § 4.114 (Digestive system). Source verified 2026-05-17 by ClaimRecon Editorial Team during a regulation-text comparison against the Cornell Law CFR mirror; eCFR.gov is the authoritative government source.
EDUCATIONAL TOOL ONLY. NOT LEGAL OR MEDICAL ADVICE.
NOT AFFILIATED WITH THE U.S. DEPARTMENT OF VETERANS AFFAIRS.
CLAIM RECON 2026