The VA is still wrong
The May 27, 2026 VA insomnia “clarification” continues to be wrong and continues to misrepresent what the DSM-5 actually says
The VA added a key changes/revision “clarification” for insomnia 5/27/2026. They did this to “reorganize” the guidance and
• To clarify that when insomnia is shown to be secondary to, or a symptom of, another underlying service-connected (SC) disability
the insomnia symptoms are to be included in the evaluation assigned under the diagnostic code (DC) for the primary SC disability, and
an evaluation under a mental disorders DC is not warranted unless the primary SC disability causing the insomnia is another properly diagnosed mental disorder.
The VA notes in their 5/27/2026 guidance “• a current diagnosis of insomnia disorder meeting DSM-5 diagnostic criteria (meaning the insomnia is not associated with any other underlying disease or injury).”
However, this statement is a misrepresentation of the DSM-5. A DSM-5 diagnosis of insomnia disorder does NOT mean it is not associated with any other underlying disease or injury.
The VA notes in their guidance “DSM-5 revised the diagnostic terminology from “primary insomnia” to “insomnia disorder.” In both the current and prior versions of DSM, the diagnostic criteria includes ruling out all other potential causes.” This statement is not true. It is a misrepresentation of what the DSM-5 actually says. The VA DOES NOT REQUIRE RULING OUT ALL OTHER POTENTIAL CAUSES.
Whoever wrote this for the VA should be fired, and again, this should have gone through a proposed rulemaking where actual experts could have commented on it and helped the VA realize the error.
Keeping in mind I am not an attorney:
The VA should be sued over the erroneous guidance they are giving and their misrepresentation of the DSM-5.
If anyone does sue the VA over this, I would very much like to help.
You can read more from me about insomnia and VA policy here (and my reflections on what the DSM-5 actually does say)