{"page":"https://casescribe.ai/explorer/secondary/migraine-secondary-to-tbi","generated_at":"2026-10-03T18:34:26.239Z","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 TBI","secondary_condition":"Migraine","service_connected_disability":"TBI","decisions":532,"years":"2017-2026","granted_pct":34.8,"denied_pct":18.4,"remanded_pct":45.9,"granted_on_merits_pct":65.4,"by_year":[{"year":2017,"issues":22,"granted_pct":22.7,"denied_pct":13.6,"remanded_pct":54.5},{"year":2018,"issues":35,"granted_pct":34.3,"denied_pct":17.1,"remanded_pct":42.9},{"year":2019,"issues":66,"granted_pct":27.3,"denied_pct":25.8,"remanded_pct":47},{"year":2020,"issues":65,"granted_pct":32.3,"denied_pct":23.1,"remanded_pct":44.6},{"year":2021,"issues":48,"granted_pct":25,"denied_pct":25,"remanded_pct":45.8},{"year":2022,"issues":63,"granted_pct":31.7,"denied_pct":25.4,"remanded_pct":42.9},{"year":2023,"issues":68,"granted_pct":33.8,"denied_pct":10.3,"remanded_pct":55.9},{"year":2024,"issues":87,"granted_pct":40.2,"denied_pct":10.3,"remanded_pct":49.4},{"year":2025,"issues":53,"granted_pct":50.9,"denied_pct":17,"remanded_pct":32.1},{"year":2026,"issues":30,"granted_pct":43.3,"denied_pct":13.3,"remanded_pct":40}],"benefit_of_doubt_in_grants_pct":72.4,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":134,"granted_pct_with":88.8,"granted_pct_without":49.1},{"evidence":"va_exam_unfavorable","decisions_with":427,"granted_pct_with":62.6,"granted_pct_without":79.2},{"evidence":"nexus_positive","decisions_with":140,"granted_pct_with":87.3,"granted_pct_without":49.7},{"evidence":"nexus_negative","decisions_with":313,"granted_pct_with":62.2,"granted_pct_without":69.7},{"evidence":"private_opinion","decisions_with":167,"granted_pct_with":68.5,"granted_pct_without":63.4},{"evidence":"lay_statement","decisions_with":458,"granted_pct_with":64.8,"granted_pct_without":69.7},{"evidence":"combat_service","decisions_with":68,"granted_pct_with":76.2,"granted_pct_without":63.5}],"top_reasons":{"granted":[{"reason":"caused by the service-connected disability","decisions":16},{"reason":"current diagnosis established","decisions":15},{"reason":"service connection established","decisions":9},{"reason":"criteria for service connection met","decisions":4},{"reason":"service connection granted","decisions":4},{"reason":"headaches linked to service-connected tbi","decisions":3}],"denied":[{"reason":"preponderance of the evidence against the claim","decisions":14},{"reason":"no in-service complaints, treatment or diagnosis","decisions":8},{"reason":"no current diagnosis","decisions":6},{"reason":"service records negative or silent","decisions":6},{"reason":"va examiner: less likely than not related to service","decisions":6},{"reason":"service connection established","decisions":2}]},"recent_examples":{"granted":[{"case_id":"A26035485","year":2026,"judge":"R. BISIGNANI","rationale":"Severance of migraine headaches was improper; Secondary to restored TBI"},{"case_id":"A26032932","year":2026,"judge":"MICHAEL J. SKALTSOUNIS","rationale":"Headaches are a residual of in-service TBI.; Criteria for secondary service connection met."},{"case_id":"A26032876","year":2026,"judge":"MARJORIE A. AUER","rationale":"RO granted service connection for TBI, headaches secondary to TBI, and head scars as residuals of TBI.; Board is bound by favorable findings from RO.; Entitlement to service connection for headaches is granted."}],"denied":[{"case_id":"A26029270","year":2026,"judge":"MICHAEL MARTIN","rationale":"Headaches did not meet prostrating attack criteria; Evidence persuasively weighs against compensable rating"},{"case_id":"A26026265","year":2026,"judge":"L.M. YASUI","rationale":"Underlying TBI residuals claim denied; No direct service connection asserted for migraines; Migraines diagnosed post-service, not linked to TBI residuals"},{"case_id":"A26001609","year":2026,"judge":"T. V. CASEY","rationale":"Primary TBI claim denied; No credible evidence of in-service TBI"}]},"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":537,"aggravation_discussed":{"issues":81,"granted_pct":12.3},"causation_only":{"issues":456,"granted_pct":38.6},"issues_naming_a_pathway_pct":2.6,"pathways":[]},"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."}}