{"page":"https://casescribe.ai/explorer/secondary/sleep-apnea-secondary-to-ptsd","generated_at":"2026-10-03T18:34:25.387Z","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":"Sleep apnea secondary to PTSD","secondary_condition":"Sleep apnea","service_connected_disability":"PTSD","decisions":11479,"years":"2017-2026","granted_pct":31.7,"denied_pct":13.5,"remanded_pct":53.8,"granted_on_merits_pct":70.1,"by_year":[{"year":2017,"issues":293,"granted_pct":14.3,"denied_pct":30.7,"remanded_pct":51.9},{"year":2018,"issues":660,"granted_pct":22.6,"denied_pct":19.2,"remanded_pct":55.9},{"year":2019,"issues":1037,"granted_pct":23.8,"denied_pct":17.6,"remanded_pct":57.7},{"year":2020,"issues":1245,"granted_pct":22.7,"denied_pct":18.1,"remanded_pct":58.2},{"year":2021,"issues":1182,"granted_pct":22.7,"denied_pct":19.5,"remanded_pct":56.9},{"year":2022,"issues":1181,"granted_pct":22.7,"denied_pct":14.6,"remanded_pct":62},{"year":2023,"issues":1449,"granted_pct":31.7,"denied_pct":10.6,"remanded_pct":56.8},{"year":2024,"issues":1938,"granted_pct":41.5,"denied_pct":8,"remanded_pct":49.5},{"year":2025,"issues":1816,"granted_pct":43.6,"denied_pct":8.4,"remanded_pct":47.2},{"year":2026,"issues":689,"granted_pct":47.8,"denied_pct":9.3,"remanded_pct":41.7}],"benefit_of_doubt_in_grants_pct":77.6,"evidence_on_merits":[{"evidence":"va_exam_favorable","decisions_with":1182,"granted_pct_with":84.3,"granted_pct_without":67.5},{"evidence":"va_exam_unfavorable","decisions_with":9475,"granted_pct_with":68,"granted_pct_without":85.2},{"evidence":"nexus_positive","decisions_with":3841,"granted_pct_with":93.5,"granted_pct_without":34.5},{"evidence":"nexus_negative","decisions_with":8226,"granted_pct_with":67.6,"granted_pct_without":78.6},{"evidence":"private_opinion","decisions_with":5202,"granted_pct_with":84.1,"granted_pct_without":41.2},{"evidence":"treating_physician","decisions_with":644,"granted_pct_with":75.4,"granted_pct_without":69.7},{"evidence":"lay_statement","decisions_with":8132,"granted_pct_with":62.5,"granted_pct_without":91.2},{"evidence":"buddy_statement","decisions_with":805,"granted_pct_with":74.7,"granted_pct_without":69.8},{"evidence":"combat_service","decisions_with":1206,"granted_pct_with":70.3,"granted_pct_without":70.1}],"top_reasons":{"granted":[{"reason":"current diagnosis established","decisions":481},{"reason":"service connection established","decisions":331},{"reason":"caused by the service-connected disability","decisions":189},{"reason":"aggravated by the service-connected disability","decisions":117},{"reason":"va examiner: less likely than not related to service","decisions":115},{"reason":"service records negative or silent","decisions":32}],"denied":[{"reason":"va examiner: less likely than not related to service","decisions":395},{"reason":"no in-service complaints, treatment or diagnosis","decisions":277},{"reason":"service records negative or silent","decisions":207},{"reason":"preponderance of the evidence against the claim","decisions":174},{"reason":"no current diagnosis","decisions":68},{"reason":"current diagnosis established","decisions":54}]},"recent_examples":{"granted":[{"case_id":"A26040643","year":2026,"judge":"JENNIFER HWA","rationale":"Private medical opinion from treating provider found more probative; Opinion linked sleep apnea to PTSD based on medical literature and Veteran's history; Resolved doubt in Veteran's favor"},{"case_id":"A26040792","year":2026,"judge":"RAY BARTO SLABBEKORN, JR.","rationale":"Current diagnosis of sleep apnea established.; Private physician opinion found at least as likely as not that sleep apnea was directly attributable to long-term consequences of service-connected PTSD and related conditions.; No contrary medical opinion of record."},{"case_id":"A26040879","year":2026,"judge":"JONATHAN HAGER","rationale":"Current disability (OSA) demonstrated; Service connection for PTSD with persistent depressive disorder and insomnia established; Private medical opinion linked OSA to PTSD based on literature and PTSD symptomology; Private opinion found OSA at least as likely as not due to PTSD; No conflicting medic… [truncated, 20 chars omitted]"}],"denied":[{"case_id":"A26040554","year":2026,"judge":"DELYVONNE M. WHITEHEAD","rationale":"Weight of evidence against service connection; VA examiner found sleep apnea less likely than not related to PTSD; Sleep apnea multifactorial, not directly caused by PTSD"},{"case_id":"A26040339","year":2026,"judge":"B.T. KNOPE","rationale":"No evidence of sleep apnea during service or continuous symptoms; VA examiner opined less likely related to service, more likely due to obesity; Private opinions lacked probative value as they did not apply research to veteran's circumstances"},{"case_id":"A26039460","year":2026,"judge":"KRISTY L. ZADORA","rationale":"Granted service connection at 50% as secondary to PTSD; Did not meet criteria for rating higher than 50%; Condition required CPAP machine without complications"}]},"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":11490,"aggravation_discussed":{"issues":5516,"granted_pct":23.9},"causation_only":{"issues":5974,"granted_pct":38.8},"issues_naming_a_pathway_pct":34.4,"pathways":[{"pathway":"Weight gain or obesity","issues":2910,"granted_pct":34.2,"examples":[{"case_id":"26000195","year":2026,"outcome":"GRANTED","quote":"Opinion not probative as it failed to consider evidence linking binge eating/night eating to obesity"},{"case_id":"26000852","year":2026,"outcome":"DENIED","quote":"Examiners cited lack of nexus and alternative causes (obesity, age) for OSA."}]},{"pathway":"Sleep disruption","issues":1080,"granted_pct":28.9,"examples":[{"case_id":"26000166","year":2026,"outcome":"GRANTED","quote":"Earlier VA opinions found PTSD causes chronic sleep impairment."},{"case_id":"A26000039","year":2026,"outcome":"DENIED","quote":"Veteran denied sleep problems in service."}]},{"pathway":"Stress","issues":133,"granted_pct":53.4,"examples":[{"case_id":"A26001491","year":2026,"outcome":"GRANTED","quote":"The Board relied on a private medical opinion that linked OSA to PTSD symptoms, stress, hyperarousal, and indirectly to obesity, outweighing a VA opinion that disassociated OSA from herbicide exposure."},{"case_id":"A24064685","year":2024,"outcome":"DENIED","quote":"The veteran claimed OSA was due to service, specifically citing stress during Hurricane Katrina, service in Iraq, and as secondary to his service-connected PTSD."}]},{"pathway":"Medication side effects","issues":87,"granted_pct":43.7,"examples":[{"case_id":"A26005231","year":2026,"outcome":"GRANTED","quote":"Service connection is granted on a secondary basis because the Board found the Veteran's service-connected acquired psychiatric disorder (PTSD with secondary alcohol use disorder, cocaine use disorder, opioid use disorder) caused or..."},{"case_id":"A24079117","year":2024,"outcome":"DENIED","quote":"Private opinions flawed due to misidentification of medication side effects and timing of weight gain."}]},{"pathway":"Nerve involvement","issues":82,"granted_pct":41.5,"examples":[{"case_id":"A25005012","year":2025,"outcome":"GRANTED","quote":"concluded PTSD, strain, radiculopathy led to obesity, contributing to OSA."},{"case_id":"25008510","year":2025,"outcome":"DENIED","quote":"The Veteran claims OSA is secondary to service-connected PTSD, diabetes mellitus II, and bilateral sciatic nerve peripheral neuropathy associated with DMII."}]},{"pathway":"Reduced activity or mobility","issues":65,"granted_pct":64.6,"examples":[{"case_id":"A26001655","year":2026,"outcome":"GRANTED","quote":"Opinion noted Veteran's obesity, chronic pain, limited mobility, and PTSD medication causing weight gain."},{"case_id":"A24048650","year":2024,"outcome":"DENIED","quote":"The Veteran asserted that PTSD led to emotional eating and weight gain, while the back disability limited mobility and exercise, both contributing to sleep apnea."}]},{"pathway":"Chronic pain","issues":50,"granted_pct":58,"examples":[{"case_id":"A26001655","year":2026,"outcome":"GRANTED","quote":"Opinion noted Veteran's obesity, chronic pain, limited mobility, and PTSD medication causing weight gain."}]},{"pathway":"Altered gait or overuse","issues":38,"granted_pct":39.5,"examples":[{"case_id":"A25045848","year":2025,"outcome":"GRANTED","quote":"The Board found the evidence persuasively favored the Veteran, granting service connection based on a credible private medical opinion that linked OSA to PTSD and its treatment, despite negative VA opinions."},{"case_id":"A25033889","year":2025,"outcome":"DENIED","quote":"Symptoms of OSA (daytime sleepiness) are already compensated by the 70 percent rating for PTSD.."}]}]},"how_va_rates":{"citation":"38 CFR 4.97","diagnostic_code":"6847","name":"Sleep Apnea Syndromes (Obstructive, Central, Mixed)","url":"https://www.ecfr.gov/current/title-38/section-4.97","levels":[{"criteria":"Chronic respiratory failure with carbon dioxide retention or cor pulmonale, or; requires tracheostomy","rating":100},{"criteria":"Requires use of breathing assistance device such as continuous airway pressure (CPAP) machine","rating":50},{"criteria":"Persistent day-time hypersomnolence","rating":30},{"criteria":"Asymptomatic but with documented sleep disorder breathing","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."}}