Secondary service connection
Gastroesophageal reflux disease (GERD) secondary to a psychiatric disorder: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided gastroesophageal reflux disease (GERD) claimed as secondary to a psychiatric disorder in 682 decisions. It granted the issue in 24.5% of them, above the 19.4% grant rate for all gastroesophageal reflux disease (GERD) issues, denied it in 12.9%, and remanded it in 61.6%. Counting only decisions on the merits, 65.5% were granted.
Decisions
682
2017–2026
Granted
24.5%
All gastroesophageal reflux disease (GERD): 19.4%
Granted on the merits
65.5%
Granted ÷ (granted + denied)
Remanded
61.6%
Denied: 12.9%
See all gastroesophageal reflux disease (GERD) decisions, direct and secondary.
Gastroesophageal reflux disease (GERD) secondary to a psychiatric disorder: outcomes by year
| Year | Issues decided | Granted | Denied | Remanded | Other |
|---|---|---|---|---|---|
| 2017 | 24 | 8.3% | 41.7% | 45.8% | 4.2% |
| 2018 | 40 | 7.5% | 15.0% | 75.0% | 2.5% |
| 2019 | 45 | 8.9% | 15.6% | 75.6% | 0.0% |
| 2020 | 66 | 15.2% | 24.2% | 60.6% | 0.0% |
| 2021 | 64 | 10.9% | 18.8% | 70.3% | 0.0% |
| 2022 | 63 | 19.0% | 11.1% | 68.3% | 1.6% |
| 2023 | 73 | 21.9% | 11.0% | 67.1% | 0.0% |
| 2024 | 102 | 26.5% | 5.9% | 63.7% | 3.9% |
| 2025 | 149 | 41.6% | 7.4% | 50.3% | 0.7% |
| 2026 | 59 | 40.7% | 8.5% | 49.2% | 1.7% |
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 Other: dismissed, withdrawn or no clear outcome.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 gastroesophageal reflux disease (GERD) decisions
For each kind of supporting evidence: how often the Board granted the gastroesophageal reflux disease (GERD) 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 | 178 | 92.5% | 35.5% | +57.0 pts |
| Private medical opinion | 243 | 82.5% | 43.8% | +38.8 pts |
| Favorable VA exam | 92 | 84.2% | 60.1% | +24.1 pts |
| Treating physician opinion | 40 | 77.8% | 64.6% | +13.2 pts |
| Lay statement | 516 | 61.2% | 81.5% | −20.3 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 73.1% of the decisions that granted gastroesophageal reflux disease (GERD).
- The Board found the veteran's statements credible in 31.1% of grants and 8.0% 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 gastroesophageal reflux disease (GERD) 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 | 486 | 64.7% | 67.7% | −3.0 pts |
| Unfavorable VA exam | 566 | 64.9% | 69.7% | −4.8 pts |
How these claims are argued
A secondary claim says a psychiatric disorder caused gastroesophageal reflux disease (GERD) 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)
19.7%
granted, of 274 issues (40.0% of all)
Causation only
caused by the disability, 3.310(a)
27.5%
granted, of 411 issues (60.0% of all)
| Medical link named | Issues | Granted |
|---|---|---|
Weight gain or obesity Granted “Obesity as intermediate step” 26004219 (2026) Denied “The veteran claimed it was secondary to service-connected psychiatric disability and medications, or alternatively due to weight gain from psychiatric conditions.” A25021976 (2025) | 57 | 22.8% |
Stress Granted “The examiner noted the known association between anxiety, stress, depression, and GERD.” A26003581 (2026) Denied “The Veteran claimed acid reflux disorder due to military stress and worry, and later asserted it was secondary to depressive disorder.” A24067420 (2024) | 52 | 53.8% |
Medication side effects Granted “G's opinion, considered highly probative, linked NSAID use and MDD to GERD.” A26017683 (2026) Denied “The veteran claimed service connection for GERD, asserting it was secondary to his service-connected other specified anxiety disorder (claimed as PTSD) and/or NSAID treatment for his service-connected left knee arthroplasty.” A25081262 (2025) | 42 | 40.5% |
Sleep disruption Granted “Private medical opinion found GERD related to emotional stress and sleep disturbance from depressive disorder.” A25010928 (2025) Denied “The claim was also denied as secondary to generalized anxiety disorder and chronic migraines, insomnia, and tinnitus due to a lack of medical evidence supporting these links.” A26002925 (2026) | 15 | 53.3% |
Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 21.3% of the 685 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 gastroesophageal reflux disease (GERD)
Most common reasons in grants
- Caused by the service-connected disability27
- Current diagnosis established16
- Service connection established14
- VA examiner: less likely than not related to service3
- Aggravated by the service-connected disability3
- Secondary service connection criteria met3
- No contrary medical opinion of record2
- VA opinions were inadequate2
Most common reasons in denials
- VA examiner: less likely than not related to service24
- No in-service complaints, treatment or diagnosis17
- Service records negative or silent11
- Preponderance of the evidence against the claim9
- No current diagnosis7
- Caused by the service-connected disability5
- Aggravated by the service-connected disability2
- Current diagnosis established2
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 gastroesophageal reflux disease (GERD) decisions
Granted
Symptoms met criteria for 30% rating under pre-amendment DC 7346; Persistently recurrent epigastric distress, dysphagia, pyrosis, regurgitation, substernal pain; Caused considerable impairment of health
Evidence in equipoise; Private and VA nurse opinions supported secondary connection; Benefit of the doubt applied
Prior favorable finding of GERD; Probative non-VA opinion linking GERD to anxiety disorder and treatment; Benefit of the doubt resolved in Veteran's favor
Denied
No current diagnosed disability.; Prerequisite for secondary service connection not met.; Lack of competent medical evidence.
No diagnosis of GERD at time of August 2020 rating decision; First diagnosis of GERD occurred in May 2021, after the decision under review; Lay evidence regarding diagnosis and etiology is not competent or credible without medical evidence
Private clinician's opinion found inadequate.; Lack of specific rationale addressing veteran's history.; Cited studies suggested statistical overlaps, not direct causation.
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 gastroesophageal reflux disease (GERD).
- A psychiatric disorder is already service connected.
- Medical evidence linking them (a nexus opinion): gastroesophageal reflux disease (GERD) was caused by a psychiatric disorder (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 psychiatric disorder
- Migraine secondary to a psychiatric disorder1,181 decisions · 41.2% granted
- Sleep apnea secondary to a psychiatric disorder4,474 decisions · 33.1% granted
- Erectile dysfunction secondary to a psychiatric disorder1,061 decisions · 31.9% granted
- Diabetes mellitus secondary to a psychiatric disorder418 decisions · 21.3% granted
- Hypertension secondary to a psychiatric disorder1,487 decisions · 20.1% granted
Gastroesophageal reflux disease (GERD) secondary to other conditions
See all conditions secondary to a psychiatric disorder.
Rules that apply to secondary gastroesophageal reflux disease (GERD) 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 gastroesophageal reflux disease (GERD) 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 gastroesophageal reflux disease (GERD) issue claimed as secondary to a psychiatric disorder, 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.