{"page":"https://casescribe.ai/explorer/secondary/hypertension-secondary-to-sleep-apnea","generated_at":"2026-10-03T18:34:29.841Z","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 sleep apnea","secondary_condition":"Hypertension","service_connected_disability":"sleep apnea","decisions":567,"years":"2017-2026","granted_pct":24.2,"denied_pct":14.8,"remanded_pct":60,"granted_on_merits_pct":62,"by_year":[{"year":2017,"issues":27,"granted_pct":22.2,"denied_pct":37,"remanded_pct":29.6},{"year":2018,"issues":36,"granted_pct":33.3,"denied_pct":16.7,"remanded_pct":47.2},{"year":2019,"issues":49,"granted_pct":26.5,"denied_pct":16.3,"remanded_pct":57.1},{"year":2020,"issues":60,"granted_pct":16.7,"denied_pct":16.7,"remanded_pct":66.7},{"year":2021,"issues":79,"granted_pct":16.5,"denied_pct":17.7,"remanded_pct":65.8},{"year":2022,"issues":64,"granted_pct":21.9,"denied_pct":14.1,"remanded_pct":64.1},{"year":2023,"issues":78,"granted_pct":21.8,"denied_pct":10.3,"remanded_pct":67.9},{"year":2024,"issues":77,"granted_pct":26,"denied_pct":7.8,"remanded_pct":63.6},{"year":2025,"issues":71,"granted_pct":36.6,"denied_pct":12.7,"remanded_pct":50.7},{"year":2026,"issues":27,"granted_pct":22.2,"denied_pct":18.5,"remanded_pct":59.3}],"benefit_of_doubt_in_grants_pct":85.4,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":72,"granted_pct_with":90.2,"granted_pct_without":53.5},{"evidence":"va_exam_unfavorable","decisions_with":447,"granted_pct_with":56.9,"granted_pct_without":90.9},{"evidence":"nexus_positive","decisions_with":158,"granted_pct_with":87.5,"granted_pct_without":35.8},{"evidence":"nexus_negative","decisions_with":373,"granted_pct_with":56.1,"granted_pct_without":78.9},{"evidence":"private_opinion","decisions_with":251,"granted_pct_with":69.4,"granted_pct_without":50.6},{"evidence":"lay_statement","decisions_with":403,"granted_pct_with":51.3,"granted_pct_without":88.9}],"top_reasons":{"granted":[{"reason":"current diagnosis established","decisions":17},{"reason":"caused by the service-connected disability","decisions":14},{"reason":"service connection established","decisions":14},{"reason":"va examiner: less likely than not related to service","decisions":5},{"reason":"aggravated by the service-connected disability","decisions":3},{"reason":"veteran diagnosed with hypertension","decisions":3}],"denied":[{"reason":"va examiner: less likely than not related to service","decisions":16},{"reason":"no in-service complaints, treatment or diagnosis","decisions":9},{"reason":"service records negative or silent","decisions":7},{"reason":"current diagnosis established","decisions":5},{"reason":"aggravated by the service-connected disability","decisions":4},{"reason":"preponderance of the evidence against the claim","decisions":3}]},"recent_examples":{"granted":[{"case_id":"26004650","year":2026,"judge":"MARTIN B. PETERS","rationale":"May 2023 private opinion by treating doctor found hypertension related to OSA and noted onset during service.; Previous VA opinions were inadequate due to inconsistencies or lack of nexus.; Benefit of the doubt applied in favor of the veteran."},{"case_id":"A26032094","year":2026,"judge":"C. CRAWFORD","rationale":"Current diagnosis of hypertension supported by VA treatment records and VA examination.; Private medical opinion found hypertension caused/aggravated by PTSD and sleep apnea.; VA opinion lacked explanation and did not consider sleep apnea connection."},{"case_id":"A26018177","year":2026,"judge":"EMILY TAMLYN","rationale":"VA opinions did not address secondary theory of OSA aggravation.; Private opinion highly probative; detailed rationale on OSA mechanisms linking to cardiovascular disease.; Evidence in approximate balance; benefit of doubt applied."}],"denied":[{"case_id":"A26038392","year":2026,"judge":"DAVID H. ROBERTSON","rationale":"No in-service onset or treatment for hypertension; Hypertension diagnosis predated OSA diagnosis; Private opinion lacked probative value due to timeline and chronic pain rationale; March 2025 VA examiner could not establish baseline severity for aggravation claim; May 2025 VA examiner found less lik… [truncated, 46 chars omitted]"},{"case_id":"A26038316","year":2026,"judge":"J. PARKER","rationale":"Current diagnosis of hypertension; No evidence of in-service chronic symptoms or prolonged duration; Symptoms did not manifest within one year of service separation; Veteran not obese, negating secondary theory via obesity; Private opinion linking sleep apnea to hypertension denied as sleep apnea it… [truncated, 29 chars omitted]"},{"case_id":"A26020570","year":2026,"judge":"THOMAS H. O'SHAY","rationale":"No competent medical evidence linking hypertension to sleep apnea; VA opinion found probative and persuasive; Veteran's lay assertion of causation is not competent medical evidence"}]},"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":568,"aggravation_discussed":{"issues":211,"granted_pct":14.2},"causation_only":{"issues":357,"granted_pct":30},"issues_naming_a_pathway_pct":11.3,"pathways":[{"pathway":"Weight gain or obesity","issues":33,"granted_pct":9.1,"examples":[{"case_id":"24002969","year":2024,"outcome":"GRANTED","quote":"October 2020 opinion considered obesity as intermediate step."},{"case_id":"A26038316","year":2026,"outcome":"DENIED","quote":"Veteran not obese, negating secondary theory via obesity"}]},{"pathway":"Stress","issues":20,"granted_pct":45,"examples":[{"case_id":"A25034893","year":2025,"outcome":"GRANTED","quote":"OSA mechanisms (hypoxia, stress response) contribute to hypertension"},{"case_id":"22056333","year":2022,"outcome":"DENIED","quote":"The veteran's contentions that hypertension was related to engine room stress or untreated sleep apnea were not considered competent medical opinions."}]}]},"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."}}