{"page":"https://casescribe.ai/explorer/secondary/migraine-secondary-to-ptsd","generated_at":"2026-10-03T18:34:24.062Z","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 PTSD","secondary_condition":"Migraine","service_connected_disability":"PTSD","decisions":1732,"years":"2017-2026","granted_pct":37.1,"denied_pct":8.8,"remanded_pct":52.6,"granted_on_merits_pct":80.9,"by_year":[{"year":2017,"issues":60,"granted_pct":21.7,"denied_pct":23.3,"remanded_pct":46.7},{"year":2018,"issues":98,"granted_pct":39.8,"denied_pct":8.2,"remanded_pct":45.9},{"year":2019,"issues":164,"granted_pct":41.5,"denied_pct":7.9,"remanded_pct":50},{"year":2020,"issues":160,"granted_pct":39.4,"denied_pct":10.6,"remanded_pct":48.8},{"year":2021,"issues":198,"granted_pct":31.3,"denied_pct":10.6,"remanded_pct":56.6},{"year":2022,"issues":164,"granted_pct":30.5,"denied_pct":9.1,"remanded_pct":59.8},{"year":2023,"issues":215,"granted_pct":34,"denied_pct":7.9,"remanded_pct":57.7},{"year":2024,"issues":295,"granted_pct":41,"denied_pct":6.4,"remanded_pct":50.2},{"year":2025,"issues":286,"granted_pct":41.6,"denied_pct":7.3,"remanded_pct":50.7},{"year":2026,"issues":99,"granted_pct":36.4,"denied_pct":7.1,"remanded_pct":55.6}],"benefit_of_doubt_in_grants_pct":73.9,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":273,"granted_pct_with":93.9,"granted_pct_without":76.6},{"evidence":"va_exam_unfavorable","decisions_with":1409,"granted_pct_with":78.6,"granted_pct_without":93.4},{"evidence":"nexus_positive","decisions_with":587,"granted_pct_with":97.1,"granted_pct_without":56.9},{"evidence":"nexus_negative","decisions_with":1119,"granted_pct_with":78.1,"granted_pct_without":86.4},{"evidence":"private_opinion","decisions_with":765,"granted_pct_with":90.5,"granted_pct_without":65.2},{"evidence":"treating_physician","decisions_with":99,"granted_pct_with":82.6,"granted_pct_without":80.7},{"evidence":"lay_statement","decisions_with":1402,"granted_pct_with":78.1,"granted_pct_without":94.8},{"evidence":"buddy_statement","decisions_with":70,"granted_pct_with":85.7,"granted_pct_without":80.7},{"evidence":"combat_service","decisions_with":166,"granted_pct_with":84.1,"granted_pct_without":80.5}],"top_reasons":{"granted":[{"reason":"current diagnosis established","decisions":60},{"reason":"caused by the service-connected disability","decisions":53},{"reason":"service connection established","decisions":51},{"reason":"aggravated by the service-connected disability","decisions":34},{"reason":"criteria for service connection met","decisions":13},{"reason":"va examiner: less likely than not related to service","decisions":11}],"denied":[{"reason":"va examiner: less likely than not related to service","decisions":23},{"reason":"no in-service complaints, treatment or diagnosis","decisions":18},{"reason":"preponderance of the evidence against the claim","decisions":11},{"reason":"service records negative or silent","decisions":11},{"reason":"current diagnosis established","decisions":9},{"reason":"no current diagnosis","decisions":8}]},"recent_examples":{"granted":[{"case_id":"A26040383","year":2026,"judge":"A. JAEGER","rationale":"Private physician's opinion found causal and aggravating relationship between PTSD/tinnitus and migraines.; VA treatment records and co-worker corroborated reports of headaches/migraines.; Resolving doubt in Veteran's favor due to conflicting medical opinions."},{"case_id":"A26036912","year":2026,"judge":"L. M. BARNARD","rationale":"Credible testimony of stress-triggered headaches; Consistent with service-connected PTSD/alcohol use disorder; Benefit of the doubt applied"},{"case_id":"A26037110","year":2026,"judge":"KRISTY L. ZADORA","rationale":"Private opinion linked migraines to tinnitus and PTSD; Opinion cited shared physiological/psychological pathways; No contrary VA opinion on secondary connection"}],"denied":[{"case_id":"A26040339","year":2026,"judge":"B.T. KNOPE","rationale":"Service records did not establish chronic headaches or onset during service; Significant gap between separation and first treatment for headaches; Post-service records reflect denial or absence of headaches"},{"case_id":"26004269","year":2026,"judge":"PAULETTE VANCE BURTON","rationale":"No objective evidence of in-service onset or continuity of symptoms.; Multiple negative nexus opinions from VA examiners.; Migraines not listed under Camp Lejeune presumptive conditions.; Correlation between PTSD and migraines, but no causal link to service established."},{"case_id":"A26029270","year":2026,"judge":"MICHAEL MARTIN","rationale":"Headaches did not meet prostrating attack criteria; Evidence persuasively weighs against compensable rating"}]},"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":1739,"aggravation_discussed":{"issues":676,"granted_pct":30.3},"causation_only":{"issues":1063,"granted_pct":41.3},"issues_naming_a_pathway_pct":15,"pathways":[{"pathway":"Stress","issues":181,"granted_pct":63,"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":"A25021048","year":2025,"outcome":"DENIED","quote":"The Board noted that while migraines can be triggered by stress, no causal link between psychiatric illness and migraines has been established in medical literature."}]},{"pathway":"Sleep disruption","issues":51,"granted_pct":62.7,"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."}]},{"pathway":"Medication side effects","issues":17,"granted_pct":41.2,"examples":[{"case_id":"A25098547","year":2025,"outcome":"GRANTED","quote":"Service connection for migraines is granted as secondary to the Veteran's service-connected PTSD with alcohol and opioid use disorder in remission."}]},{"pathway":"Weight gain or obesity","issues":10,"granted_pct":0,"examples":[{"case_id":"A24086560","year":2024,"outcome":"DENIED","quote":"The Veteran sought service connection for migraines as secondary to his service-connected PTSD, with obesity as an intermediate step."}]}]},"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."}}