Secondary service connection
Cervical spine limitation of motion secondary to a back condition: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided cervical spine limitation of motion claimed as secondary to a back condition in 1,600 decisions. It granted the issue in 8.7% of them, below the 13.3% grant rate for all cervical spine limitation of motion issues, denied it in 17.4%, and remanded it in 72.8%. Counting only decisions on the merits, 33.3% were granted.
Decisions
1,600
2017–2026
Granted
8.7%
All cervical spine limitation of motion: 13.3%
Granted on the merits
33.3%
Granted ÷ (granted + denied)
Remanded
72.8%
Denied: 17.4%
See all cervical spine limitation of motion decisions, direct and secondary.
Cervical spine limitation of motion secondary to a back condition: outcomes by year
| Year | Issues decided | Granted | Denied | Remanded | Other |
|---|---|---|---|---|---|
| 2017 | 101 | 5.0% | 26.7% | 64.4% | 4.0% |
| 2018 | 130 | 3.8% | 21.5% | 71.5% | 3.1% |
| 2019 | 167 | 1.8% | 25.7% | 71.3% | 1.2% |
| 2020 | 194 | 9.3% | 16.0% | 73.7% | 1.0% |
| 2021 | 226 | 7.5% | 19.9% | 71.7% | 0.9% |
| 2022 | 208 | 5.8% | 9.6% | 84.6% | 0.0% |
| 2023 | 205 | 11.2% | 14.6% | 73.2% | 1.0% |
| 2024 | 172 | 14.0% | 16.9% | 68.0% | 1.2% |
| 2025 | 155 | 14.8% | 11.6% | 72.9% | 0.6% |
| 2026 | 47 | 19.1% | 17.0% | 63.8% | 0.0% |
Each row counts issues (each condition the Board decided), so the shares add up to 100%. Other: dismissed, withdrawn or no clear outcome. Years with fewer than 20 issues are left out.
Evidence in granted and denied cervical spine limitation of motion decisions
For each kind of supporting evidence: how often the Board granted the cervical spine limitation of motion issue on the merits when the decision mentioned it, compared with decisions that did not. These are associations, not causes, and evidence is recorded per decision, not per issue.
| In the record | Decisions | Granted when present | When absent | Difference |
|---|---|---|---|---|
| Positive nexus opinion | 244 | 82.8% | 14.3% | +68.5 pts |
| Private medical opinion | 488 | 52.5% | 15.7% | +36.8 pts |
| Favorable VA exam | 140 | 60.0% | 29.3% | +30.7 pts |
| Treating physician opinion | 67 | 53.6% | 31.9% | +21.7 pts |
| Buddy statement | 44 | 45.5% | 33.0% | +12.4 pts |
| Combat service | 57 | 35.3% | 33.3% | +2.0 pts |
| Lay statement | 1,286 | 30.2% | 58.7% | −28.5 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 79.1% of the decisions that granted cervical spine limitation of motion.
- The Board found the veteran's statements credible in 25.9% of grants and 9.0% of denials.
Negative evidence in the record
An unfavorable exam or a negative nexus opinion often sits in the same record as favorable evidence, and the Board weighs them against each other. So these rows show how often cervical spine limitation of motion was still granted when the record contained the negative item, not that the item helped.
| In the record | Decisions | Granted when present | When absent | Difference |
|---|---|---|---|---|
| Negative nexus opinion | 1,108 | 29.3% | 52.8% | −23.5 pts |
| Unfavorable VA exam | 1,325 | 30.7% | 54.3% | −23.6 pts |
How these claims are argued
A secondary claim says a back condition caused cervical spine limitation of motion or made it worse, and names how. Below: whether the Board's decision discussed aggravation, and the medical link each decision names, with how often those issues were granted.
Aggravation discussed
made worse by the disability, 3.310(b)
3.7%
granted, of 782 issues (48.7% of all)
Causation only
caused by the disability, 3.310(a)
13.4%
granted, of 823 issues (51.3% of all)
| Medical link named | Issues | Granted |
|---|---|---|
Nerve involvement Granted “VA examinations diagnosed cervical strain and radiculopathy.” A26002100 (2026) Denied “Lack of in-service documentation for radiculopathy” 25007525 (2025) | 79 | 16.5% |
Altered gait or overuse Granted “A private nurse practitioner opined that the neck condition was as likely as not aggravated by these service-connected conditions due to altered gait.” A26023906 (2026) Denied “P.'s opinion lacked probative value due to false premise (no antalgic gait)..” 25011672 (2025) | 59 | 28.8% |
Chronic pain Granted “Private physician opined more likely than not that neck pain resulted from service-connected back condition.” A25057922 (2025) Denied “The veteran claimed service connection for a cervical spine disability, alleging it was caused by service or aggravated by his service-connected low back disability due to radiating pain.” 24008162 (2024) | 17 | 11.8% |
Weight gain or obesity Denied “Degenerative disc disease attributed to age and obesity.” 24026242 (2024) | 13 | 0.0% |
Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 10.4% of the 1,605 issues name at least one medical link; the rest only say “secondary to” the disability. One issue can name several links. Granted is the share of those issues granted (remands count as not granted). A link named in a denial was often the argument the Board rejected.
Why the Board granted or denied cervical spine limitation of motion
Most common reasons in grants
- Caused by the service-connected disability29
- Current diagnosis established12
- Service connection established9
- Aggravated by the service-connected disability6
- Current cervical spine disability diagnosed3
- Service records negative or silent3
- Secondary service connection criteria met2
- No contrary opinion of record2
Most common reasons in denials
- No in-service complaints, treatment or diagnosis58
- VA examiner: less likely than not related to service52
- Service records negative or silent27
- Preponderance of the evidence against the claim26
- Aggravated by the service-connected disability13
- No current diagnosis10
- Current diagnosis established10
- No continuity of symptomatology8
Numbers are decisions that gave the reason. Reasons are short phrases extracted by AI from each decision; common wordings of the same reason are grouped. Benefit of the doubt is reported above.
Recent cervical spine limitation of motion decisions
Granted
Current diagnosis of cervical strain and degenerative arthritis; In-service injury reported (forklift incident); Consistent statements regarding neck and back pain; Private opinion found condition more likely than not service-related; VA provider concluded cervicalgia secondary to intervertebral disc disorder; VA examination found pinched nerves, herniated discs, and cervicalgia due to service; Benefit of the doubt resolved in Veteran's favor
Evidence in relative equipoise; Benefit of the doubt applied; Private physician opinion found probative
Favorable private medical opinion linking cervical disability to lumbar disability; Inadequate VA medical opinion; Benefit of the doubt afforded to veteran
Denied
Favorable AOJ finding for diagnosis of cervical strain.; Negative nexus opinions from VA examiners (Feb 2023, Sep 2024).; Private opinion less persuasive due to lack of baseline severity analysis.
No chronicity of cervical spine symptoms during or after service.; Veteran's statements regarding in-service neck injury lacked credibility.; Medical opinions found no direct service connection or secondary causation from low back condition.
Lumbar spine disability not service-connected; No evidence of in-service onset or event; No nexus to service-connected psychiatric disability or scar
What VA needs to grant a secondary claim
Secondary service connection means VA disability benefits for a condition caused or made worse by a disability that is already service connected (38 CFR 3.310). The claim needs three things:
- A current diagnosis of cervical spine limitation of motion.
- A back condition is already service connected.
- Medical evidence linking them (a nexus opinion): cervical spine limitation of motion was caused by a back condition (3.310(a)), or was made worse beyond its natural progress by it (aggravation, 3.310(b)).
VA's procedures for these claims are in M21-1 V.ii.2.D. When the evidence for and against is about even, VA must decide in the veteran's favor (38 CFR 3.102).
Other conditions secondary to a back condition
- Paralysis of sciatic nerve secondary to a back condition325 decisions · 57.8% granted
- Radiculopathy secondary to a back condition1,181 decisions · 49.9% granted
- Major depressive disorder secondary to a back condition770 decisions · 47.4% granted
- Paralysis of sciatic nerve or external popliteal nerve secondary to a back condition2,436 decisions · 38.7% granted
- Sleep apnea secondary to a back condition1,166 decisions · 38.2% granted
- Ulnar nerve paralysis secondary to a back condition628 decisions · 34.6% granted
- Peripheral nerve conditions secondary to a back condition307 decisions · 32.2% granted
- Peripheral nerve disorders secondary to a back condition1,204 decisions · 27.8% granted
- Erectile dysfunction secondary to a back condition619 decisions · 27.6% granted
- Degenerative arthritis of the spine secondary to a back condition679 decisions · 23.7% granted
- Urinary incontinence secondary to a back condition408 decisions · 22.8% granted
- Hypertension secondary to a back condition330 decisions · 20.0% granted
- Migraine secondary to a back condition347 decisions · 18.7% granted
- Hip impairment secondary to a back condition1,856 decisions · 13.6% granted
- Knee conditions secondary to a back condition2,083 decisions · 12.3% granted
- Ankle impairment secondary to a back condition322 decisions · 11.2% granted
- Shoulder impairment secondary to a back condition647 decisions · 7.3% granted
- Foot impairment secondary to a back condition354 decisions · 6.2% granted
Cervical spine limitation of motion secondary to other conditions
See all conditions secondary to a back condition or neck conditions as a primary or secondary condition.
Rules that apply to secondary cervical spine limitation of motion claims
- 38 CFR 3.310
Secondary service connection and aggravation
Read it in VA Law Explorer - M21-1 V.ii.2.D
Secondary service connection and aggravation of non-service-connected disabilities
Read it in VA Law Explorer - 38 CFR 3.102
Reasonable doubt (benefit of the doubt)
Read it in VA Law Explorer
Research your cervical spine limitation of motion case
Narrow by year, judge, evidence or secondary condition, read the decisions, and export a research memo.
How these numbers are calculated
- Counts decisions in which the Board decided a cervical spine limitation of motion issue claimed as secondary to a back condition, by the outcome of that issue.
- The primary disability is read from the decision text ("secondary to …") and grouped by name, so spellings such as "PTSD" and "posttraumatic stress disorder" count together.
- Secondary claims also include aggravation of a non-service-connected condition by a service-connected one (38 CFR 3.310(b)).
- The data comes from CaseScribe's AI extraction of public BVA decisions (2017–2026) and can contain errors. It is updated automatically as new decisions are added.