{"page":"https://casescribe.ai/explorer/secondary/migraine-secondary-to-psychiatric-disorder","generated_at":"2026-10-03T18:34:30.467Z","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":"Migraine secondary to a psychiatric disorder","secondary_condition":"Migraine","service_connected_disability":"a psychiatric disorder","decisions":1393,"years":"2017-2026","granted_pct":40.7,"denied_pct":8.4,"remanded_pct":50,"granted_on_merits_pct":82.9,"by_year":[{"year":2017,"issues":35,"granted_pct":20,"denied_pct":17.1,"remanded_pct":57.1},{"year":2018,"issues":109,"granted_pct":50.5,"denied_pct":4.6,"remanded_pct":44},{"year":2019,"issues":179,"granted_pct":55.3,"denied_pct":8.4,"remanded_pct":36.3},{"year":2020,"issues":166,"granted_pct":38.6,"denied_pct":6,"remanded_pct":54.8},{"year":2021,"issues":130,"granted_pct":33.1,"denied_pct":8.5,"remanded_pct":58.5},{"year":2022,"issues":127,"granted_pct":33.9,"denied_pct":10.2,"remanded_pct":54.3},{"year":2023,"issues":176,"granted_pct":37.5,"denied_pct":8,"remanded_pct":54},{"year":2024,"issues":196,"granted_pct":35.7,"denied_pct":12.2,"remanded_pct":50.5},{"year":2025,"issues":209,"granted_pct":41.1,"denied_pct":7.7,"remanded_pct":50.2},{"year":2026,"issues":67,"granted_pct":50.7,"denied_pct":4.5,"remanded_pct":44.8}],"benefit_of_doubt_in_grants_pct":74.1,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":213,"granted_pct_with":93.8,"granted_pct_without":79.6},{"evidence":"va_exam_unfavorable","decisions_with":1111,"granted_pct_with":81.4,"granted_pct_without":90.4},{"evidence":"nexus_positive","decisions_with":582,"granted_pct_with":95.8,"granted_pct_without":58.5},{"evidence":"nexus_negative","decisions_with":895,"granted_pct_with":80.6,"granted_pct_without":87.3},{"evidence":"private_opinion","decisions_with":707,"granted_pct_with":90.9,"granted_pct_without":66.2},{"evidence":"treating_physician","decisions_with":69,"granted_pct_with":92.5,"granted_pct_without":82.3},{"evidence":"lay_statement","decisions_with":1127,"granted_pct_with":80.1,"granted_pct_without":95.9},{"evidence":"buddy_statement","decisions_with":41,"granted_pct_with":78.6,"granted_pct_without":83},{"evidence":"combat_service","decisions_with":59,"granted_pct_with":57.7,"granted_pct_without":83.9}],"top_reasons":{"granted":[{"reason":"caused by the service-connected disability","decisions":95},{"reason":"current diagnosis established","decisions":69},{"reason":"aggravated by the service-connected disability","decisions":57},{"reason":"service connection established","decisions":32},{"reason":"criteria for secondary service connection met","decisions":8},{"reason":"criteria for service connection met","decisions":7}],"denied":[{"reason":"va examiner: less likely than not related to service","decisions":17},{"reason":"no in-service complaints, treatment or diagnosis","decisions":9},{"reason":"service records negative or silent","decisions":8},{"reason":"preponderance of the evidence against the claim","decisions":8},{"reason":"no current diagnosis","decisions":7},{"reason":"aggravated by the service-connected disability","decisions":5}]},"recent_examples":{"granted":[{"case_id":"A26039820","year":2026,"judge":"STEVEN D. REISS","rationale":"Veteran service connected for generalized anxiety disorder; Veteran's wife provided credible testimony on onset and continuation; Mild cognitive impairment proximately due to generalized anxiety disorder"},{"case_id":"A26038608","year":2026,"judge":"T. RAYMOND","rationale":"Migraines found secondary to service-connected acquired psychiatric disability.; Private medical opinion found migraines aggravated by psychiatric condition and treatment.; VA treatment records support aggravation by medication.; Prior VA exam insufficient as it did not address aggravation by psychi… [truncated, 15 chars omitted]"},{"case_id":"A26037105","year":2026,"judge":"A. S. CARACCIOLO","rationale":"Granted secondary to service-connected psychiatric disorder.; Private opinion found nexus.; No conflicting evidence presented."}],"denied":[{"case_id":"A26034541","year":2026,"judge":"MARJORIE A. AUER","rationale":"No nexus between headaches and service or TERA; VA opinions found less likely than not related; March 2024 opinion discounted for lack of chronicity evidence; January 2025 opinion inadequate for not addressing obesity as intermediate step"},{"case_id":"A26029270","year":2026,"judge":"MICHAEL MARTIN","rationale":"Headaches did not meet prostrating attack criteria; Evidence persuasively weighs against compensable rating"},{"case_id":"A26016570","year":2026,"judge":"A. P. SIMPSON","rationale":"Headaches claimed as secondary to psychiatric disorder.; Psychiatric disorder denied service connection.; Cannot grant secondary claim when primary condition 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":1394,"aggravation_discussed":{"issues":572,"granted_pct":38.1},"causation_only":{"issues":822,"granted_pct":42.5},"issues_naming_a_pathway_pct":14.3,"pathways":[{"pathway":"Stress","issues":128,"granted_pct":62.5,"examples":[{"case_id":"26000465","year":2026,"outcome":"GRANTED","quote":"VA examiner opined migraines at least as likely as not due to PTSD-related stress"},{"case_id":"24022747","year":2024,"outcome":"DENIED","quote":"Service records were negative for headaches, and the Veteran consistently denied headaches during medical visits, despite a vocational report mentioning occasional migraines during stress."}]},{"pathway":"Sleep disruption","issues":41,"granted_pct":53.7,"examples":[{"case_id":"26001880","year":2026,"outcome":"GRANTED","quote":"Service connection for headaches was granted as secondary to the Veteran's service-connected PTSD, persistent depressive disorder, generalized anxiety disorder, and insomnia."},{"case_id":"A24077556","year":2024,"outcome":"DENIED","quote":"The veteran claimed service connection for headaches, asserting they were caused by or aggravated by medication for his service-connected insomnia disorder, major depressive disorder, and sleep disturbances."}]},{"pathway":"Medication side effects","issues":20,"granted_pct":45,"examples":[{"case_id":"A26038608","year":2026,"outcome":"GRANTED","quote":"The Board relied on a private medical opinion stating the migraines were at least as likely as not aggravated by the psychiatric condition and its treatment, as well as VA treatment records indicating medication side effects."},{"case_id":"A24077556","year":2024,"outcome":"DENIED","quote":"Veteran's claim based on medication side effect theory."}]}]},"how_va_rates":{"citation":"38 CFR 4.124a","diagnostic_code":"8100","name":"Migraine","url":"https://www.ecfr.gov/current/title-38/section-4.124a","levels":[{"criteria":"With very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability","rating":50},{"criteria":"With characteristic prostrating attacks occurring on an average once a month over last several months","rating":30},{"criteria":"With characteristic prostrating attacks averaging one in 2 months over last several months","rating":10},{"criteria":"With less frequent attacks","rating":0}],"notes":[]},"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."}}