Johnson: "SYSTEMIC THERAPY" INCLUDES TOPICAL CORTICOSTEROIDS
/Johnson v. McDonald, 27 Vet.App. 497 (Mar. 1, 2016), overruled, Johnson v. Shulkin, 862 F.3d 1351 (Fed. Cir. 2017)
HELD: “[T]he plain wording of Diagnostic Code 7806 is that systemic therapy includes the use of corticosteroids without any limitation to such use being oral or parenteral as opposed to topical.”
SUMMARY: 38 C.F.R. § 4.118, DC 7806, VA’s diagnostic code for rating dermatitis or eczema, provides for compensable ratings based on the use of “systemic therapy such as corticosteroids.” The regulation does not distinguish between topical and oral corticosteroids. Therefore, the Court held that the plain language of DC 7806 includes both oral and topical corticosteroids.
