Secondary service connection
Diabetes mellitus secondary to hypertension: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided diabetes claimed as secondary to hypertension in 477 decisions. It granted the issue in 14.5% of them, below the 20.2% grant rate for all diabetes issues, denied it in 26.8%, and remanded it in 57.7%. Counting only decisions on the merits, 35.0% were granted.
Decisions
477
2017–2026
Granted
14.5%
All diabetes: 20.2%
Granted on the merits
35.0%
Granted ÷ (granted + denied)
Remanded
57.7%
Denied: 26.8%
How VA rates diabetes
Once service connection is granted, VA assigns a disability rating from the rating schedule: 38 CFR 4.119, diagnostic code 7913 (Diabetes mellitus). The rating is the same whether the condition is service connected directly or as secondary to another disability.
| Rating | Criteria |
|---|---|
| 100% | Requiring more than one daily injection of insulin, restricted diet, and regulation of activities (avoidance of strenuous occupational and recreational activities) with episodes of ketoacidosis or hypoglycemic reactions requiring at least three hospitalizations per year or weekly visits to a diabetic care provider, plus either progressive loss of weight and strength or complications that would be compensable if separately evaluated |
| 60% | Requiring one or more daily injection of insulin, restricted diet, and regulation of activities with episodes of ketoacidosis or hypoglycemic reactions requiring one or two hospitalizations per year or twice a month visits to a diabetic care provider, plus complications that would not be compensable if separately evaluated |
| 40% | Requiring one or more daily injection of insulin, restricted diet, and regulation of activities |
| 20% | Requiring one or more daily injection of insulin and restricted diet, or; oral hypoglycemic agent and restricted diet |
| 10% | Manageable by restricted diet only |
- Note (1): Evaluate compensable complications of diabetes separately unless they are part of the criteria used to support a 100-percent evaluation. Noncompensable complications are considered part of the diabetic process under DC 7913.
- Note (2): When diabetes mellitus has been conclusively diagnosed, do not request a glucose tolerance test solely for rating purposes.
Text of 38 CFR 4.119 as of Feb 27, 2026. Confirm the current text at the source before relying on it.
See all diabetes decisions, direct and secondary.
Diabetes mellitus secondary to hypertension: outcomes by year
| Year | Issues decided | Granted | Denied | Remanded | Other |
|---|---|---|---|---|---|
| 2017 | 33 | 9.1% | 57.6% | 30.3% | 3.0% |
| 2018 | 35 | 5.7% | 31.4% | 62.9% | 0.0% |
| 2019 | 38 | 5.3% | 26.3% | 63.2% | 5.3% |
| 2020 | 49 | 12.2% | 28.6% | 59.2% | 0.0% |
| 2021 | 60 | 10.0% | 25.0% | 65.0% | 0.0% |
| 2022 | 56 | 5.4% | 25.0% | 69.6% | 0.0% |
| 2023 | 71 | 12.7% | 21.1% | 64.8% | 1.4% |
| 2024 | 59 | 27.1% | 25.4% | 47.5% | 0.0% |
| 2025 | 54 | 25.9% | 14.8% | 59.3% | 0.0% |
| 2026 | 25 | 32.0% | 28.0% | 36.0% | 4.0% |
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 diabetes decisions
For each kind of supporting evidence: how often the Board granted the diabetes 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 | 86 | 75.0% | 19.1% | +55.9 pts |
| Favorable VA exam | 49 | 75.0% | 28.4% | +46.6 pts |
| Private medical opinion | 158 | 43.8% | 27.8% | +16.0 pts |
| Lay statement | 339 | 25.5% | 68.2% | −42.7 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 69.6% of the decisions that granted diabetes.
- The Board found the veteran's statements credible in 7.2% of grants and 3.9% 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 diabetes 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 |
|---|---|---|---|---|
| Unfavorable VA exam | 373 | 31.3% | 54.8% | −23.5 pts |
| Negative nexus opinion | 315 | 27.7% | 53.6% | −25.9 pts |
How these claims are argued
A secondary claim says hypertension caused diabetes 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)
8.7%
granted, of 229 issues (47.7% of all)
Causation only
caused by the disability, 3.310(a)
19.5%
granted, of 251 issues (52.3% of all)
| Medical link named | Issues | Granted |
|---|---|---|
Weight gain or obesity Granted “Obesity contributes to other service-connected conditions” 26002007 (2026) Denied “Diabetes likely due to independent risk factors (obesity, family history)..” 26000895 (2026) | 55 | 9.1% |
Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 14.6% of the 480 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 diabetes
Most common reasons in grants
- Service connection established9
- Caused by the service-connected disability8
- Current diagnosis established6
- Aggravated by the service-connected disability3
Most common reasons in denials
- No in-service complaints, treatment or diagnosis25
- VA examiner: less likely than not related to service21
- Preponderance of the evidence against the claim13
- Service records negative or silent12
- No continuity of symptomatology7
- Hypertension not service-connected3
- No evidence of diabetes during service3
- Caused by the service-connected disability3
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 diabetes decisions
Granted
Evidence in equipoise regarding diabetes causation by hypertension medication; Benefit of the doubt applied to grant service connection; No evidence of diabetes in service treatment records
Granted as secondary to service-connected hypertension; At least as likely as not that DM is a result of hypertension; Hypertension is a significant risk factor for diabetes
Multiple VA opinions support a link between diabetes and medications for service-connected conditions.; Veteran's testimony supported by medical evidence regarding beta blocker use and diabetes risk.; One VA opinion specifically linked diabetes to hydrochlorothiazide (HCTZ) use.
Denied
Service records negative for diabetes during service.; Earliest diagnosis over 15 years post-service.; VA examiner found no link to service or exposures.; No competent medical opinion supporting service connection.
Weight of the evidence does not show diabetes mellitus is etiologically related to service.; No competent medical opinion supports a link between diabetes mellitus and service or service-connected hypertension.; VA opinions found diabetes mellitus less likely than not related to ship fire exposure or hypertension.
No in-service complaints, findings, treatment, or diagnoses of diabetes.; STRs show normal endocrine system and urinalysis at separation.; Initial diagnosis post-service in 2000; private records suggest onset around that time.; VA opinions consistently found diabetes less likely than not related to service.; No medical literature supports hypertension causing or aggravating diabetes.; BPOT exposure not causally linked to diabetes by medical literature.; Diabetes attributed to obesity and family history.
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 diabetes.
- Hypertension is already service connected.
- Medical evidence linking them (a nexus opinion): diabetes was caused by hypertension (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 hypertension
Diabetes mellitus secondary to other conditions
See all conditions secondary to hypertension or diabetes as a primary or secondary condition.
Rules that apply to secondary diabetes 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 - 38 CFR 4.119 · DC 7913
Schedule of ratings: endocrine system
Read it in VA Law Explorer - 38 CFR 3.309(e)
Presumptive service connection (herbicide exposure)
Read it in VA Law Explorer - M21-1 V.iii.11.1
Diabetes: evaluation, scope of the claim, effective dates
Read it in VA Law Explorer - M21-1 V.iii.11.2
Complications of diabetes and when to rate them separately
Read it in VA Law Explorer
Research your diabetes 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 diabetes issue claimed as secondary to hypertension, 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.