Listing 7.08 Disorders of Thrombosis and Hemostasis in 2026: How SSA Evaluates Hemophilia A and B, Von Willebrand Disease, Immune Thrombocytopenia, Thrombotic Thrombocytopenic Purpura, Heparin-Induced Thrombocytopenia, and the Three-Complication Rule
Bleeding and clotting disorders can put you in the hospital more than any other blood disease group. Some people bleed into joints and cannot walk without pain. Some people throw pulmonary emboli despite therapeutic anticoagulation. Some have platelet counts so low they cannot risk a fall. That is exactly what Listing 7.08 is for.
The listing is straightforward once you know the shape of it. Three complications inside a rolling 12-month period, each at least 30 days apart, each requiring hospitalization. That is the pathway. What varies is what counts as a complication, and how SSA evaluates whether your specific disease produces those complications.
See If You Qualify
The exact text of Listing 7.08
7.08 Disorders of thrombosis and hemostasis, with complications requiring at least three hospitalizations within a 12-month period and occurring at least 30 days apart. Each hospitalization must last at least 48 hours, which can include hours in a hospital emergency department immediately before the hospitalization (see 7.00G).
That is the entire rule text. No paragraphs A through H. No alternate paths. Three qualifying hospitalizations inside 12 months, 30 days apart, 48 hours each. Section 7.00G explains what qualifies as a hospitalization and what counts as a complication.
Section 7.00G: what counts as a complication
Under 7.00G, complications of thrombosis and hemostasis disorders include:
- Bleeding events. Spontaneous or trauma-related hemorrhage requiring inpatient management, transfusion, or procedural intervention. Includes joint bleeds, intracranial hemorrhage, GI bleeding, retroperitoneal bleeding, muscle compartment bleeding.
- Thrombotic events. Deep vein thrombosis, pulmonary embolism, stroke, myocardial infarction, mesenteric ischemia, portal or splanchnic vein thrombosis, cerebral venous sinus thrombosis.
- Complications of anticoagulation. Major bleeding on anticoagulation, warfarin skin necrosis, coumarin embryopathy management, HIT with thrombosis.
- Complications of factor replacement. Inhibitor development requiring bypassing agents, anaphylaxis to factor products, treatment failure requiring immune tolerance induction.
- Plasma exchange or plasmapheresis admissions. Especially for TTP, atypical HUS, and complex ITP.
- Splenectomy or other surgical management for platelet disorders.
SSA reads this broadly. Any inpatient admission causally linked to the underlying coagulopathy counts.
The 48-hour rule and how ER hours count
Under 7.00G, each qualifying hospitalization must be at least 48 hours in duration. ER hours count when they immediately precede the admission. If you arrive in the ER at 8 PM Monday, are admitted at 3 AM Tuesday, and are discharged at 9 AM Wednesday, that is 7 hours ER plus 30 hours inpatient, totaling 37 hours. That does not meet 48.
If you arrive in the ER at 8 PM Monday, are admitted at midnight, and are discharged at 8 AM Thursday, that is 4 hours ER plus 80 hours inpatient, totaling 84 hours. That meets 48 easily.
The ER arrival time is the anchor. Pull it from every ER record and every hospitalization discharge summary. It is often buried in the ER tracker log, not the discharge summary. Ask the hospital medical records department specifically for the ER arrival timestamp.
The 30-day spacing rule
Two hospitalizations that end on Day 1 and start on Day 31 or later meet the spacing rule. If one ends Day 1 and the next starts Day 28, that is only 27 days apart and does not qualify as a separate event. SSA uses this rule to distinguish a single medical episode with a bounce-back from three genuinely separate complications.
Practical example: hemophilia patient admitted for right ankle joint bleed Jan 1-4, readmitted Jan 25-28 for the same ankle bleeding again. That is 21 days apart, so it does not count as two events for 7.08. If the second admission had been Feb 4-7, that is 31 days apart and does count.
The 12-month rolling window
SSA uses a rolling 12-month window, not a calendar year. If your three qualifying hospitalizations occurred in March, July, and February of the following year, that is 11 months and 3 weeks, which fits inside 12 months. If they occurred in January, June, and February of the year after that, the January admission is now 13 months before the February one and no longer counts toward the same 12-month window.
When you file, pick your best 12-month window. Move it backward or forward across your medical history to capture the three closest qualifying events.
Hemophilia A and B: what SSA looks for
Hemophilia A is factor VIII deficiency. Hemophilia B is factor IX deficiency. Both are X-linked recessive. Severity is defined by baseline factor level:
- Severe: factor level less than 1 percent
- Moderate: factor level 1 to 5 percent
- Mild: factor level 5 to 40 percent
Severe hemophilia produces spontaneous joint bleeds (hemarthrosis), muscle bleeds, and intracranial hemorrhage. Even on prophylactic factor replacement, breakthrough bleeds requiring hospitalization are common. The classic pattern that meets 7.08 is three joint or muscle bleeds in a year with inpatient management.
Factor replacement in 2026 includes standard half-life products (recombinant factor VIII, recombinant factor IX), extended half-life products (BeneFIX, Idelvion, Rebinyn, Alprolix), and non-factor therapies. Emicizumab (Hemlibra) subcutaneous weekly has changed how hemophilia A is treated by producing hemostatic activity equivalent to factor level of about 15 percent even in the presence of inhibitors. Etranacogene dezaparvovec (Hemgenix) gene therapy for hemophilia B and valoctocogene roxaparvovec (Roctavian) for hemophilia A produce sustained factor expression after a single infusion. Even with these advances, spontaneous bleeds do occur and can drive 7.08 admissions.
Inhibitor development
About 25 percent of severe hemophilia A patients develop inhibitors against factor VIII. Inhibitors are alloantibodies that neutralize infused factor. Once an inhibitor develops, standard factor replacement no longer works, and bypassing agents are needed:
- Recombinant activated factor VII (NovoSeven)
- Activated prothrombin complex concentrate (FEIBA)
- Emicizumab (for hemophilia A with inhibitors, produces baseline hemostasis)
Immune tolerance induction (ITI) requires months to years of near-daily factor infusions to eradicate the inhibitor. During ITI, breakthrough bleeds are common. Inhibitor patients often have the strongest 7.08 case because their bleeds are harder to manage and admissions are longer.
Von Willebrand disease
Von Willebrand disease (VWD) is the most common inherited bleeding disorder, affecting about 1 percent of the general population but only a small fraction with clinically significant disease. Types:
- Type 1. Partial quantitative deficiency of vWF. Mild bleeding, usually mucocutaneous.
- Type 2. Qualitative defects. Subtypes A, B, M, N with distinct clinical patterns.
- Type 3. Severe quantitative deficiency (vWF less than 5 percent). Severe bleeding resembling hemophilia.
VWD type 3 is the form most likely to meet 7.08 through repeated bleeding episodes. Treatment includes desmopressin (for type 1 and some type 2), vWF concentrate (Humate-P, Wilate, Vonvendi), and factor VIII concentrate (since vWF stabilizes FVIII).
Immune thrombocytopenia (ITP)
ITP is autoimmune destruction of platelets. Adult ITP is usually chronic. Platelet counts below 30,000/mm3 carry meaningful bleeding risk. Below 10,000/mm3 the risk of spontaneous intracranial hemorrhage rises sharply.
Standard first-line treatment is corticosteroids (prednisone, dexamethasone). IVIG or anti-D immunoglobulin (in Rh-positive non-splenectomized patients) is used for rapid response. Second-line options include:
- Thrombopoietin receptor agonists (romiplostim, eltrombopag, avatrombopag)
- Rituximab
- Splenectomy
- Fostamatinib (SYK inhibitor)
- Efgartigimod (FcRn inhibitor) approved in 2023 for chronic ITP
The 7.08 pattern for ITP is admissions for platelet crises requiring IVIG or high-dose steroids, admissions for major bleeding episodes, and admissions for splenectomy or other procedural management.
Thrombotic thrombocytopenic purpura (TTP)
TTP is a medical emergency. It involves microangiopathic hemolytic anemia, severe thrombocytopenia, and multi-organ ischemia driven by ADAMTS13 deficiency (activity less than 10 percent). Untreated mortality was historically over 90 percent. With plasma exchange it drops to about 15 to 20 percent.
Acquired TTP recurs. Relapse rate over five years is 30 to 40 percent. Each relapse means another admission for plasma exchange (usually 5 to 14 days). Caplacizumab (Cablivi) has reduced admission duration but has not eliminated recurrence.
Diagnostic evidence SSA wants:
- ADAMTS13 activity level (less than 10 percent supports diagnosis)
- ADAMTS13 inhibitor titer
- Peripheral smear showing schistocytes
- Elevated LDH, low haptoglobin, elevated indirect bilirubin
- Platelet count usually less than 30,000
Heparin-induced thrombocytopenia (HIT)
HIT is a paradoxical prothrombotic disorder caused by antibodies against heparin-platelet factor 4 complexes. About 30 to 50 percent of HIT patients develop thrombosis. Diagnosis relies on the 4T score and confirmatory testing (SRA, HIPA, PF4 ELISA with functional assay).
HIT admissions involve stopping heparin, switching to alternative anticoagulants (argatroban, bivalirudin, fondaparinux, DOACs), managing acute thrombosis, and extending admission for line placement or vascular imaging.
Antiphospholipid syndrome
APS is autoimmune with lupus anticoagulant, anticardiolipin, or anti-beta-2-glycoprotein I antibodies. Manifestations include recurrent thrombosis, pregnancy loss, and catastrophic APS (CAPS). Triple-positive patients have the highest thrombotic risk. Warfarin remains standard; DOACs are inferior for triple-positive APS.
Chronic thromboembolic pulmonary hypertension (CTEPH)
CTEPH is a form of pulmonary hypertension caused by unresolved organized pulmonary emboli. Patients often meet Listing 3.09 (pulmonary hypertension) as well as 7.08 depending on the pattern. Pulmonary endarterectomy is potentially curative; balloon pulmonary angioplasty and riociguat are alternatives.
Documentation checklist
- Complete hematology clinic records for at least 24 months
- Every ER visit and hospital admission with ER arrival time, admission time, discharge date
- Discharge summaries showing the reason for each admission and length of stay
- Baseline factor levels for hemophilia (VIII or IX)
- Inhibitor titer results (Bethesda units) for hemophilia
- vWF antigen, vWF activity (ristocetin cofactor), factor VIII level for VWD
- ADAMTS13 activity and inhibitor for TTP
- Platelet count trend for ITP
- PF4 ELISA and functional assay for HIT
- Antiphospholipid antibody panel for APS (all three tests, on two occasions 12 weeks apart)
- Imaging for thrombotic events (venous Doppler, CT PA, MR venography)
- Hematologist summary letter identifying the specific disorder and the qualifying complications
Worked case 1: DeShawn, 34, Texas, severe hemophilia A with inhibitor
DeShawn has severe hemophilia A (factor VIII less than 1 percent) with high-titer inhibitor (Bethesda 45 BU). He is on emicizumab prophylaxis and NovoSeven for breakthrough bleeds. In an 8-month window he had:
- Right knee hemarthrosis admission: 6 days inpatient in November 2025
- Left iliopsoas muscle bleed with compartment concern: 4 days inpatient in February 2026
- Oral trauma bleed requiring bypassing agent and airway monitoring: 3 days inpatient in June 2026
Three admissions, all 30+ days apart, all 48+ hours. His attorney filed under 7.08. DDS approved at initial review in September 2026.
Worked case 2: Cynthia, 41, Ohio, chronic ITP
Cynthia has refractory chronic ITP with baseline platelets around 8,000 to 15,000. She has failed prednisone, IVIG, rituximab, romiplostim, and splenectomy. In a 12-month window she had:
- Admission for platelet count 3,000 with epistaxis requiring IVIG and platelet transfusion: 5 days inpatient in April 2025
- Admission for GI bleed with platelets 6,000: 8 days inpatient in September 2025
- Admission for menorrhagia requiring uterine artery embolization and blood transfusion: 4 days inpatient in March 2026
Her attorney filed under 7.08. DDS approved at initial in June 2026.
Worked case 3: Ramon, 58, California, APS with recurrent VTE
Ramon has triple-positive antiphospholipid syndrome. Despite warfarin with INR 2.5 to 3.5, he has recurrent thrombotic events. In a 12-month window:
- Bilateral pulmonary embolism admission: 6 days inpatient in December 2024
- Portal vein thrombosis admission with acute mesenteric ischemia: 14 days inpatient in May 2025
- Left middle cerebral artery stroke admission: 9 days inpatient in November 2025
His attorney filed under 7.08. DDS approved at initial in January 2026.
Common denial reasons and how to counter them
"Hospitalizations were less than 48 hours"
Counter: request ER tracker logs from each hospital to obtain ER arrival times. Add ER hours to inpatient hours. Under 7.00G, ER time immediately before admission counts. Recalculate and submit corrected totals.
"Two admissions were less than 30 days apart"
Counter: find a different 12-month window that captures three qualifying events with proper spacing. The rolling window can move.
"Bleeding episode was not a complication of the coagulopathy"
Counter: get a hematology letter specifying that each event was caused by or worsened by the underlying disorder. This is especially important when a trauma or procedure triggered a bleed that would not have hospitalized a normal patient.
"Diagnosis not established"
Counter: submit factor levels, antibody titers, ADAMTS13 activity, genetic testing, or peripheral smear findings appropriate to the specific disorder. Ask your hematologist for a diagnostic summary letter.
What to do this week if you might meet 7.08
- Pull all hospital records from the last 24 months. Ask hematology, primary care, and the hospitals directly. Get ER arrival times and full discharge summaries.
- Build a hospitalization timeline. Date in, date out, ER arrival, reason. Highlight any 12-month window that contains three events.
- Get a hematology summary letter. Ask your hematologist to identify the disorder, list the qualifying complications, and confirm each admission was disease-related.
Frequently asked questions
Does emicizumab prophylaxis disqualify me from 7.08?
No. Emicizumab reduces bleeding rates but does not eliminate them. If you still have three qualifying hospitalizations in a 12-month window while on emicizumab, you meet 7.08. SSA does not require you to be off treatment or untreated to qualify.
Do outpatient infusions count as hospitalizations?
No. Outpatient factor infusion, outpatient IVIG, and outpatient plasma exchange without inpatient admission do not count. Only actual hospital admissions of 48 hours or more count under 7.00G.
What if my platelets improved on TPO agonists after the qualifying admissions?
The 7.08 evaluation looks at the alleged onset period. If you had three qualifying admissions in a 12-month window, current improvement does not disqualify you. SSA may schedule a continuing disability review later, but initial approval is based on the historical pattern.
Can pregnancy-related VTE admissions count?
Yes if they are complications of an underlying thrombophilia (factor V Leiden, prothrombin gene mutation, APS, protein C or S deficiency). Get a genetic testing panel and antiphospholipid panel documented, and have your hematologist confirm the thrombotic events were driven by the underlying disorder.
Does gene therapy for hemophilia change my eligibility?
Gene therapy in 2026 produces sustained factor expression that can substantially reduce bleeding. If gene therapy eliminates your bleeding, you likely will not qualify going forward. However, if you already had three qualifying admissions before gene therapy, you meet 7.08 for that historical window. Post-therapy improvement is grounds for continuing review, not retroactive denial.
How do I document intracranial hemorrhage on anticoagulation?
Head CT or MRI at the time of the event, discharge summary with the diagnosis, and hematology or neurology follow-up notes. This is a major bleeding event and clearly qualifies as a complication.
What if I have both a bleeding disorder and a clotting disorder?
Some patients have both (for example, hemophilia carrier with APS, or vWD with thrombosis on hormonal therapy). Combined presentations often produce more admissions and stronger 7.08 cases. Document each event with the specific mechanism.
See If You Qualify