{"page":"https://casescribe.ai/explorer/secondary/migraine-secondary-to-tinnitus","generated_at":"2026-10-03T18:34:26.008Z","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 tinnitus","secondary_condition":"Migraine","service_connected_disability":"tinnitus","decisions":1203,"years":"2017-2026","granted_pct":34.2,"denied_pct":9.7,"remanded_pct":55.2,"granted_on_merits_pct":77.8,"by_year":[{"year":2018,"issues":79,"granted_pct":53.2,"denied_pct":11.4,"remanded_pct":31.6},{"year":2019,"issues":103,"granted_pct":48.5,"denied_pct":6.8,"remanded_pct":43.7},{"year":2020,"issues":76,"granted_pct":39.5,"denied_pct":11.8,"remanded_pct":48.7},{"year":2021,"issues":84,"granted_pct":25,"denied_pct":16.7,"remanded_pct":57.1},{"year":2022,"issues":85,"granted_pct":29.4,"denied_pct":9.4,"remanded_pct":58.8},{"year":2023,"issues":110,"granted_pct":24.5,"denied_pct":8.2,"remanded_pct":67.3},{"year":2024,"issues":210,"granted_pct":29,"denied_pct":9,"remanded_pct":61},{"year":2025,"issues":336,"granted_pct":33.6,"denied_pct":8,"remanded_pct":58.3},{"year":2026,"issues":106,"granted_pct":36.8,"denied_pct":10.4,"remanded_pct":51.9}],"benefit_of_doubt_in_grants_pct":73,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":139,"granted_pct_with":95.8,"granted_pct_without":73.9},{"evidence":"va_exam_unfavorable","decisions_with":1004,"granted_pct_with":75.1,"granted_pct_without":92.7},{"evidence":"nexus_positive","decisions_with":448,"granted_pct_with":96.3,"granted_pct_without":41.6},{"evidence":"nexus_negative","decisions_with":844,"granted_pct_with":72.8,"granted_pct_without":89.4},{"evidence":"private_opinion","decisions_with":586,"granted_pct_with":86.3,"granted_pct_without":57.4},{"evidence":"treating_physician","decisions_with":48,"granted_pct_with":75.9,"granted_pct_without":78},{"evidence":"lay_statement","decisions_with":958,"granted_pct_with":74.2,"granted_pct_without":92.4},{"evidence":"combat_service","decisions_with":48,"granted_pct_with":81.8,"granted_pct_without":77.7}],"top_reasons":{"granted":[{"reason":"caused by the service-connected disability","decisions":64},{"reason":"current diagnosis established","decisions":47},{"reason":"aggravated by the service-connected disability","decisions":44},{"reason":"service connection established","decisions":26},{"reason":"criteria for secondary service connection met","decisions":7},{"reason":"va examiner: less likely than not related to service","decisions":7}],"denied":[{"reason":"va examiner: less likely than not related to service","decisions":41},{"reason":"no in-service complaints, treatment or diagnosis","decisions":26},{"reason":"service records negative or silent","decisions":17},{"reason":"preponderance of the evidence against the claim","decisions":7},{"reason":"no current diagnosis","decisions":6},{"reason":"current diagnosis established","decisions":2}]},"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":"26004859","year":2026,"judge":"WILLIAM H. DONNELLY","rationale":"Secondary to service-connected tinnitus; Approximate balance of evidence; Benefit of the doubt applied"},{"case_id":"A26036829","year":2026,"judge":"B. D. WATSON","rationale":"Favorable private medical opinion; Migraines proximately due to tinnitus; Resolved doubt in Veteran's favor"}],"denied":[{"case_id":"A26035860","year":2026,"judge":"DAVID H. ROBERTSON","rationale":"Persuasively weighs against in-service origin; VA examiner opined less likely than not related to service; Service treatment records negative for headaches"},{"case_id":"A26033629","year":2026,"judge":"MICHAEL MARTIN","rationale":"Private medical opinion lacked objective rationale and established causation.; VA medical opinions found migraines less likely than not due to tinnitus.; Service treatment records did not establish a causal link."},{"case_id":"A26032375","year":2026,"judge":"J. KIRBY","rationale":"No in-service complaints, diagnosis, or treatment for headaches.; VA examiner opined less likely than not related to service or TERA.; Medical literature did not support causative relationship between tinnitus/TERA and headaches.; Lay testimony insufficient for complex medical issues."}]},"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":1205,"aggravation_discussed":{"issues":570,"granted_pct":26.3},"causation_only":{"issues":635,"granted_pct":41.1},"issues_naming_a_pathway_pct":5.5,"pathways":[{"pathway":"Stress","issues":33,"granted_pct":48.5,"examples":[{"case_id":"A26001255","year":2026,"outcome":"GRANTED","quote":"A private physician opined it was at least as likely as not that the headaches were caused by the tinnitus, citing increased neural activity and stress as precursors."},{"case_id":"24012054","year":2024,"outcome":"DENIED","quote":"Migraines have genetic component and are linked to hypertension/stress."}]},{"pathway":"Sleep disruption","issues":16,"granted_pct":25,"examples":[{"case_id":"A26011562","year":2026,"outcome":"GRANTED","quote":"August 2023 private opinion found aggravation by tinnitus/insomnia."}]}]},"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."}}