Secondary service connection
Hypertension secondary to diabetes: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided hypertension claimed as secondary to diabetes in 2,919 decisions. It granted the issue in 14.9% of them, below the 17.6% grant rate for all hypertension issues, denied it in 25.2%, and remanded it in 58.0%. Counting only decisions on the merits, 37.1% were granted.
Decisions
2,919
2017–2026
Granted
14.9%
All hypertension: 17.6%
Granted on the merits
37.1%
Granted ÷ (granted + denied)
Remanded
58.0%
Denied: 25.2%
How VA rates hypertension
Once service connection is granted, VA assigns a disability rating from the rating schedule: 38 CFR 4.104, diagnostic code 7101 (Hypertensive vascular disease (hypertension and isolated systolic hypertension)). The rating is the same whether the condition is service connected directly or as secondary to another disability.
| Rating | Criteria |
|---|---|
| 60% | Diastolic pressure predominantly 130 or more |
| 40% | Diastolic pressure predominantly 120 or more |
| 20% | Diastolic pressure predominantly 110 or more, or; systolic pressure predominantly 200 or more |
| 10% | Diastolic pressure predominantly 100 or more, or; systolic pressure predominantly 160 or more, or; minimum evaluation for an individual with a history of diastolic pressure predominantly 100 or more who requires continuous medication for control |
- Note (1): Hypertension or isolated systolic hypertension must be confirmed by readings taken two or more times on at least three different days. For purposes of this section, the term hypertension means that the diastolic blood pressure is predominantly 90mm. or greater, and isolated systolic hypertension means that the systolic blood pressure is predominantly 160mm. or greater with a diastolic blood pressure of less than 90mm.
- Note (2): Evaluate hypertension due to aortic insufficiency or hyperthyroidism, which is usually the isolated systolic type, as part of the condition causing it rather than by a separate evaluation.
- Note (3): Evaluate hypertension separately from hypertensive heart disease and other types of heart disease.
Text of 38 CFR 4.104 as of Feb 27, 2026. Confirm the current text at the source before relying on it.
See all hypertension decisions, direct and secondary.
Hypertension secondary to diabetes: outcomes by year
| Year | Issues decided | Granted | Denied | Remanded | Other |
|---|---|---|---|---|---|
| 2017 | 423 | 7.8% | 38.8% | 48.0% | 5.4% |
| 2018 | 476 | 13.2% | 33.2% | 51.1% | 2.5% |
| 2019 | 413 | 13.3% | 16.9% | 67.3% | 2.4% |
| 2020 | 476 | 9.5% | 25.6% | 63.9% | 1.1% |
| 2021 | 460 | 11.5% | 25.2% | 62.2% | 1.1% |
| 2022 | 308 | 19.5% | 17.5% | 62.7% | 0.3% |
| 2023 | 172 | 32.6% | 14.0% | 53.5% | 0.0% |
| 2024 | 98 | 29.6% | 15.3% | 53.1% | 2.0% |
| 2025 | 75 | 38.7% | 18.7% | 41.3% | 1.3% |
| 2026 | 35 | 34.3% | 5.7% | 60.0% | 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 hypertension decisions
For each kind of supporting evidence: how often the Board granted the hypertension 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 | 529 | 84.5% | 16.6% | +67.9 pts |
| Favorable VA exam | 334 | 81.6% | 26.4% | +55.2 pts |
| Treating physician opinion | 162 | 62.9% | 35.0% | +27.9 pts |
| Private medical opinion | 870 | 49.4% | 29.1% | +20.2 pts |
| Combat service | 260 | 40.7% | 36.7% | +4.0 pts |
| Lay statement | 1,969 | 30.9% | 58.2% | −27.4 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 77.0% of the decisions that granted hypertension.
- The Board found the veteran's statements credible in 20.7% of grants and 5.7% 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 hypertension 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 | 1,780 | 27.9% | 57.8% | −29.8 pts |
| Unfavorable VA exam | 2,117 | 31.1% | 62.4% | −31.3 pts |
How these claims are argued
A secondary claim says diabetes caused hypertension 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)
11.6%
granted, of 1,282 issues (43.7% of all)
Causation only
caused by the disability, 3.310(a)
17.3%
granted, of 1,654 issues (56.3% of all)
| Medical link named | Issues | Granted |
|---|---|---|
Weight gain or obesity Granted “Aggravation of obesity by diabetes led to hypertension” A25044272 (2025) Denied “Obesity and family history identified as risk factors” 24020368 (2024) | 87 | 8.0% |
Nerve involvement Granted “Favorable VA examiner opinion linking hypertension to diabetes/neuropathy..” 24001172 (2024) Denied “Medical opinions found less likely than not caused/aggravated by diabetes/neuropathy..” 21025543 (2021) | 37 | 16.2% |
Stress Denied “The Veteran claimed hypertension secondary to service-connected type II diabetes mellitus, diabetic retinopathy, cataracts, or other trauma and stressor-related disorder.” 22006095 (2022) | 14 | 0.0% |
Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 4.9% of the 2,936 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 hypertension
Most common reasons in grants
- Caused by the service-connected disability70
- Current diagnosis established57
- Aggravated by the service-connected disability42
- Service connection established39
- Hypertension diagnosed5
- VA examiner: less likely than not related to service4
- New and material evidence submitted to reopen claim4
- New and material evidence received to reopen claim4
Most common reasons in denials
- VA examiner: less likely than not related to service145
- No in-service complaints, treatment or diagnosis120
- Preponderance of the evidence against the claim68
- Service records negative or silent63
- Aggravated by the service-connected disability38
- No continuity of symptomatology25
- Continuity of symptomatology since service15
- No current diagnosis15
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 hypertension decisions
Granted
VA examiner's opinion on hypertension was inadequate.; Board found Veteran's hypertension secondary to DMII based on multiple opinions.; November 2023 opinion noted DMII likely worsened kidney disease and hypertension.
Granted secondary to DM; VA clinicians opined DM causes/aggravates hypertension; Resolved doubt in Veteran's favor
Hypertension aggravated by service-connected diabetes; Favorable VA opinion on secondary aggravation; Equipoise standard met
Denied
Hypertension claimed secondary to diabetes mellitus, which was not service-connected.; Condition did not onset during service or within one year of separation.; No continuity of symptoms from service to diagnosis.
No evidence of in-service incurrence or aggravation; Condition diagnosed many years after service; Chronic kidney disease noted as secondary to hypertension and diabetes
No in-service diagnosis or complaints of hypertension.; Hypertension manifested decades after service, not continuously or within one year of separation.; No direct nexus between hypertension and service or toxic exposures.; Secondary claim to diabetes denied as diabetes is not service-connected.
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 hypertension.
- Diabetes is already service connected.
- Medical evidence linking them (a nexus opinion): hypertension was caused by diabetes (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 diabetes
- Peripheral arterial occlusive disease (buerger's disease) secondary to diabetes335 decisions · 37.3% granted
- Retinal dystrophy (including retinitis pigmentosa macular degeneration) secondary to diabetes416 decisions · 37.0% granted
- Peripheral nerve disorders secondary to diabetes3,602 decisions · 33.6% granted
- Kidney disease secondary to diabetes906 decisions · 26.5% granted
- Erectile dysfunction secondary to diabetes1,811 decisions · 25.8% granted
- Sleep apnea secondary to diabetes994 decisions · 23.0% granted
- Cataract extraction secondary to diabetes372 decisions · 22.6% granted
- Glaucoma secondary to diabetes482 decisions · 10.6% granted
Hypertension secondary to other conditions
See all conditions secondary to diabetes or hypertension as a primary or secondary condition.
Rules that apply to secondary hypertension 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 4.104 · DC 7101
Schedule of ratings: cardiovascular system
Read it in VA Law Explorer - M21-1 V.iii.5.3
Hypertension: definitions, blood pressure readings required, predominant blood pressure
Read it in VA Law Explorer - M21-1 V.iii.11.2.e
When hypertension is or is not a complication of diabetes
Read it in VA Law Explorer
Research your hypertension 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 hypertension issue claimed as secondary to diabetes, 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.