{"page":"https://casescribe.ai/explorer/secondary/hypertension-secondary-to-diabetes","generated_at":"2026-10-03T18:34:27.639Z","data_as_of":{"decisions":944125,"first_year":2017,"last_year":2026,"latest_decision":"2026-04-30","cfr":"2026-10-01","m21":"2026-09-29"},"about":{"publisher":"CaseScribe AI (VA Law Explorer)","source":"Public Board of Veterans' Appeals decisions (appeals of VA decisions, not VA's first decisions), M21-1 Adjudication Procedures Manual, 38 CFR Parts 3 and 4.","method":"Outcomes are issue-level: each condition the Board decided in a decision counts once. Decision data is extracted by AI and can contain errors. Rates describe past appeals and do not predict any claim.","disclaimer":"For research only. CaseScribe AI is not a law firm and this is not legal advice. Verify figures against the source decisions and regulations.","attribution":"Cite as: VA Law Explorer, CaseScribe AI, with the page URL."},"data":{"claim":"Hypertension secondary to diabetes","secondary_condition":"Hypertension","service_connected_disability":"diabetes","decisions":2919,"years":"2017-2026","granted_pct":14.9,"denied_pct":25.2,"remanded_pct":58,"granted_on_merits_pct":37.1,"by_year":[{"year":2017,"issues":423,"granted_pct":7.8,"denied_pct":38.8,"remanded_pct":48},{"year":2018,"issues":476,"granted_pct":13.2,"denied_pct":33.2,"remanded_pct":51.1},{"year":2019,"issues":413,"granted_pct":13.3,"denied_pct":16.9,"remanded_pct":67.3},{"year":2020,"issues":476,"granted_pct":9.5,"denied_pct":25.6,"remanded_pct":63.9},{"year":2021,"issues":460,"granted_pct":11.5,"denied_pct":25.2,"remanded_pct":62.2},{"year":2022,"issues":308,"granted_pct":19.5,"denied_pct":17.5,"remanded_pct":62.7},{"year":2023,"issues":172,"granted_pct":32.6,"denied_pct":14,"remanded_pct":53.5},{"year":2024,"issues":98,"granted_pct":29.6,"denied_pct":15.3,"remanded_pct":53.1},{"year":2025,"issues":75,"granted_pct":38.7,"denied_pct":18.7,"remanded_pct":41.3},{"year":2026,"issues":35,"granted_pct":34.3,"denied_pct":5.7,"remanded_pct":60}],"benefit_of_doubt_in_grants_pct":77,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":334,"granted_pct_with":81.6,"granted_pct_without":26.4},{"evidence":"va_exam_unfavorable","decisions_with":2117,"granted_pct_with":31.1,"granted_pct_without":62.4},{"evidence":"nexus_positive","decisions_with":529,"granted_pct_with":84.5,"granted_pct_without":16.6},{"evidence":"nexus_negative","decisions_with":1780,"granted_pct_with":27.9,"granted_pct_without":57.8},{"evidence":"private_opinion","decisions_with":870,"granted_pct_with":49.4,"granted_pct_without":29.1},{"evidence":"treating_physician","decisions_with":162,"granted_pct_with":62.9,"granted_pct_without":35},{"evidence":"lay_statement","decisions_with":1969,"granted_pct_with":30.9,"granted_pct_without":58.2},{"evidence":"buddy_statement","decisions_with":71,"granted_pct_with":41.4,"granted_pct_without":37},{"evidence":"combat_service","decisions_with":260,"granted_pct_with":40.7,"granted_pct_without":36.7}],"top_reasons":{"granted":[{"reason":"caused by the service-connected disability","decisions":70},{"reason":"current diagnosis established","decisions":57},{"reason":"aggravated by the service-connected disability","decisions":42},{"reason":"service connection established","decisions":39},{"reason":"hypertension diagnosed","decisions":5},{"reason":"va examiner: less likely than not related to service","decisions":4}],"denied":[{"reason":"va examiner: less likely than not related to service","decisions":145},{"reason":"no in-service complaints, treatment or diagnosis","decisions":120},{"reason":"preponderance of the evidence against the claim","decisions":68},{"reason":"service records negative or silent","decisions":63},{"reason":"aggravated by the service-connected disability","decisions":38},{"reason":"no continuity of symptomatology","decisions":25}]},"recent_examples":{"granted":[{"case_id":"A26040129","year":2026,"judge":"W. DAKNIS","rationale":"VA examiner's opinion on hypertension was inadequate.; Board found Veteran's hypertension secondary to DMII based on multiple opinions.; November 2023 opinion noted DMII likely worsened kidney disease and hypertension."},{"case_id":"26005076","year":2026,"judge":"L. M. BARNARD","rationale":"Granted secondary to DM; VA clinicians opined DM causes/aggravates hypertension; Resolved doubt in Veteran's favor"},{"case_id":"26003998","year":2026,"judge":"RYAN T. KESSEL","rationale":"Hypertension aggravated by service-connected diabetes; Favorable VA opinion on secondary aggravation; Equipoise standard met"}],"denied":[{"case_id":"26005112","year":2026,"judge":"MICHELLE L. KANE","rationale":"Hypertension claimed secondary to diabetes mellitus, which was not service-connected.; Condition did not onset during service or within one year of separation.; No continuity of symptoms from service to diagnosis."},{"case_id":"A26004251","year":2026,"judge":"STEVEN D. REISS","rationale":"No evidence of in-service incurrence or aggravation; Condition diagnosed many years after service; Chronic kidney disease noted as secondary to hypertension and diabetes"},{"case_id":"A25110534","year":2025,"judge":"J. PARKER","rationale":"No in-service diagnosis or complaints of hypertension.; Hypertension manifested decades after service, not continuously or within one year of separation.; No direct nexus between hypertension and service or toxic exposures.; Secondary claim to diabetes denied as diabetes is not service-connected."}]},"how_argued":{"note":"From keyword matches in each issue's AI summary and rationale, not the full decision. Only issues whose text names a medical link are counted under pathways; one issue can name several. A link named in a denial was often the argument the Board rejected.","issues":2936,"aggravation_discussed":{"issues":1282,"granted_pct":11.6},"causation_only":{"issues":1654,"granted_pct":17.3},"issues_naming_a_pathway_pct":4.9,"pathways":[{"pathway":"Weight gain or obesity","issues":87,"granted_pct":8,"examples":[{"case_id":"A25044272","year":2025,"outcome":"GRANTED","quote":"Aggravation of obesity by diabetes led to hypertension"},{"case_id":"24020368","year":2024,"outcome":"DENIED","quote":"Obesity and family history identified as risk factors"}]},{"pathway":"Nerve involvement","issues":37,"granted_pct":16.2,"examples":[{"case_id":"24001172","year":2024,"outcome":"GRANTED","quote":"Favorable VA examiner opinion linking hypertension to diabetes/neuropathy.."},{"case_id":"21025543","year":2021,"outcome":"DENIED","quote":"Medical opinions found less likely than not caused/aggravated by diabetes/neuropathy.."}]},{"pathway":"Stress","issues":14,"granted_pct":0,"examples":[{"case_id":"22006095","year":2022,"outcome":"DENIED","quote":"The Veteran claimed hypertension secondary to service-connected type II diabetes mellitus, diabetic retinopathy, cataracts, or other trauma and stressor-related disorder."}]}]},"how_va_rates":{"citation":"38 CFR 4.104","diagnostic_code":"7101","name":"Hypertensive vascular disease (hypertension and isolated systolic hypertension)","url":"https://www.ecfr.gov/current/title-38/section-4.104","levels":[{"criteria":"Diastolic pressure predominantly 130 or more","rating":60},{"criteria":"Diastolic pressure predominantly 120 or more","rating":40},{"criteria":"Diastolic pressure predominantly 110 or more, or; systolic pressure predominantly 200 or more","rating":20},{"criteria":"Diastolic pressure predominantly 100 or more, or; systolic pressure predominantly 160 or more, or; minimum evaluation for an individual with a history of diastolic pressure predominantly 100 or more who requires continuous medication for control","rating":10}],"notes":["Note (1): Hypertension or isolated systolic hypertension must be confirmed by readings taken two or more times on at least three different days. For purposes of this section, the term hypertension means that the diastolic blood pressure is predominantly 90mm. or greater, and isolated systolic hypertension means that the systolic blood pressure is predominantly 160mm. or greater with a diastolic blood pressure of less than 90mm.","Note (2): Evaluate hypertension due to aortic insufficiency or hyperthyroidism, which is usually the isolated systolic type, as part of the condition causing it rather than by a separate evaluation.","Note (3): Evaluate hypertension separately from hypertensive heart disease and other types of heart disease."]},"requirements":"38 CFR 3.310: a current diagnosis, a service-connected disability, and medical evidence that it caused (3.310(a)) or aggravated (3.310(b)) the condition."}}