Secondary service connection

Gastroesophageal reflux disease (GERD) secondary to PTSD: BVA grant rates and what wins

From 2017 to 2026, the Board of Veterans' Appeals decided gastroesophageal reflux disease (GERD) claimed as secondary to PTSD in 1,237 decisions. It granted the issue in 25.3% of them, above the 19.4% grant rate for all gastroesophageal reflux disease (GERD) issues, denied it in 13.3%, and remanded it in 60.0%. Counting only decisions on the merits, 65.5% were granted.

Decisions

1,237

2017–2026

Granted

25.3%

All gastroesophageal reflux disease (GERD): 19.4%

Granted on the merits

65.5%

Granted ÷ (granted + denied)

Remanded

60.0%

Denied: 13.3%

See all gastroesophageal reflux disease (GERD) decisions, direct and secondary.

Gastroesophageal reflux disease (GERD) secondary to PTSD: outcomes by year

YearIssues decidedGrantedDeniedRemandedOther
2017
65
6.2%38.5%50.8%4.6%
2018
84
14.3%21.4%64.3%0.0%
2019
102
10.8%18.6%69.6%1.0%
2020
123
17.1%18.7%63.4%0.8%
2021
121
16.5%23.1%60.3%0.0%
2022
124
19.4%8.1%66.9%5.6%
2023
113
26.5%6.2%66.4%0.9%
2024
179
29.6%8.4%62.0%0.0%
2025
245
39.2%6.1%52.7%2.0%
2026
85
49.4%5.9%44.7%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 Other: dismissed, withdrawn or no clear outcome.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 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 recordDecisionsGranted when presentWhen absentDifference
Positive nexus opinion33991.5%34.4%+57.1 pts
Private medical opinion43684.0%41.6%+42.4 pts
Favorable VA exam14578.9%62.1%+16.8 pts
Treating physician opinion6777.5%64.4%+13.1 pts
Combat service12558.5%66.6%−8.1 pts
Lay statement92161.6%79.6%−18.0 pts
  • The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 81.8% of the decisions that granted gastroesophageal reflux disease (GERD).
  • The Board found the veteran's statements credible in 24.3% of grants and 15.8% 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 recordDecisionsGranted when presentWhen absentDifference
Negative nexus opinion88365.1%67.0%−1.9 pts
Unfavorable VA exam1,04364.4%78.4%−14.0 pts

How these claims are argued

A secondary claim says PTSD 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)

18.8%

granted, of 581 issues (46.8% of all)

Causation only

caused by the disability, 3.310(a)

30.9%

granted, of 660 issues (53.2% of all)

Medical link namedIssuesGranted

Weight gain or obesity

Granted “VA opinions inadequate regarding the role of obesity and PTSD.” A26003861 (2026)

Denied “Obesity identified as a risk factor for GERD..” A26016382 (2026)

11323.9%

Stress

Granted “The Board found a plausible link between GERD symptoms, which began during stressful deployments in 2003/2004, and the Veteran's service, despite conflicting VA opinions.” A26001758 (2026)

Denied “The VA examiner opined GERD was less likely than not related to PTSD, despite noting a potential link between stress and GERD symptoms, due to the GERD's onset predating PTSD service connection and remaining stable.” A25064689 (2025)

9556.8%

Medication side effects

Granted “A VA examiner found the GERD etiologically linked to these conditions, citing NSAID use for pain, stress from PTSD, and associations with sleep apnea and hypertension.” A26025302 (2026)

Denied “A VA examination confirmed GERD but opined it was less likely than not related to service, attributing it to NSAID use for back pain.” A24086296 (2024)

5429.6%

Sleep disruption

Granted “The Veteran contends that his GERD is exacerbated by anxiety and sleep disturbances related to his service-connected PTSD.” A26020699 (2026)

1060.0%

Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 20.4% of the 1,241 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

  1. Current diagnosis established40
  2. Service connection established28
  3. Caused by the service-connected disability16
  4. Aggravated by the service-connected disability12
  5. VA examiner: less likely than not related to service5
  6. Private opinion found GERD secondary to PTSD4
  7. Criteria for secondary service connection met4
  8. Secondary to PTSD4

Most common reasons in denials

  1. VA examiner: less likely than not related to service32
  2. No in-service complaints, treatment or diagnosis30
  3. Preponderance of the evidence against the claim23
  4. No current diagnosis15
  5. Service records negative or silent11
  6. Current diagnosis established6
  7. Aggravated by the service-connected disability4
  8. Continuity of symptomatology since service3

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

Citation Nr. A26034826Michael J. Skaltsounis · 2026

Private opinion found probative for GERD etiology; Link between PTSD and GERD explained via sympathetic nervous system; Benefit of the doubt applied

Citation Nr. A26033219Gayle Strommen · 2026

Secondary to service-connected PTSD; Private medical opinion found probative; At least as likely as not caused by PTSD

Citation Nr. A26030400J.P. Norman · 2026

Conflicting medical opinions from private psychologist and VA examiner.; Board found evidence evenly balanced.; Applied benefit-of-the-doubt rule.; AOJ committed pre-decisional error in development of secondary claims.

Denied

Citation Nr. A26036828Jonathan B. Kramer · 2026

No in-service complaints or treatment for GERD.; Post-service VA records show denial of GERD symptoms until April 2024.; Veteran's assertion of nexus to PTSD is not medically competent.; No competent medical evidence links GERD to PTSD.; Evidence persuasively weighs against secondary service connection.

Citation Nr. A26017941J.P. Norman · 2026

No in-service diagnosis or complaints of GERD; Less likely than not nexus to service; GERD not a MUCMI for presumptive service connection

Citation Nr. A26016382J. Kirby · 2026

Veteran denied frequent indigestion/heartburn in post-deployment assessments.; VA examiners opined GERD unrelated to PTSD and not aggravated by it.; Obesity identified as a risk factor for GERD.

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:

  1. A current diagnosis of gastroesophageal reflux disease (GERD).
  2. PTSD is already service connected.
  3. Medical evidence linking them (a nexus opinion): gastroesophageal reflux disease (GERD) was caused by PTSD (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 PTSD

Gastroesophageal reflux disease (GERD) secondary to other conditions

See all conditions secondary to PTSD.

Rules that apply to secondary gastroesophageal reflux disease (GERD) claims

Research your gastroesophageal reflux disease (GERD) case

Narrow by year, judge, evidence or secondary condition, read the decisions, and export a research memo.

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How these numbers are calculated

  • Counts decisions in which the Board decided a gastroesophageal reflux disease (GERD) issue claimed as secondary to PTSD, 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.