Secondary service connection
Migraine secondary to a back condition: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to a back condition in 364 decisions. It granted the issue in 18.4% of them, below the 30.7% grant rate for all migraine issues, denied it in 14.0%, and remanded it in 66.8%. Counting only decisions on the merits, 56.8% were granted.
From Board of Veterans' Appeals decisions: appeals, not VA's first decisions. About these numbers
Decisions
364
2017–2026
Granted
18.4%
All migraine: 30.7%
Granted on the merits
56.8%
Granted ÷ (granted + denied)
Remanded
66.8%
Denied: 14.0%
At a glance
- Most often argued link: nerve involvement, named in 15 issues, 40.0% granted. Details
- Causation only: 23.3% granted; when the decision discussed aggravation: 12.6%. Details
- Positive nexus opinion: 92.6% granted on the merits when in the record, 26.6% without. Details
- Private medical opinion: 79.7% granted on the merits when in the record, 29.6% without. Details
How these claims are argued
A secondary claim says a back condition caused migraine 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)
12.6%
granted, of 174 issues (47.4% of all)
Causation only
caused by the disability, 3.310(a)
23.3%
granted, of 193 issues (52.6% of all)
| Medical link named | Issues | Granted |
|---|---|---|
Nerve involvement Granted “The veteran has a diagnosis of tension headaches, and a private physician opined that the service-connected thoracolumbar spine degenerative joint and disc disease and lumbar radiculopathy aided in the development of and permanently...” 23036133 (2023) | 15 | 40.0% |
Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 10.6% of the 367 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.
Evidence in granted and denied migraine decisions
For each kind of supporting evidence: how often the Board granted the migraine 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 | 83 | 92.6% | 26.6% | +66.0 pts |
| Private medical opinion | 127 | 79.7% | 29.6% | +50.1 pts |
| Favorable VA exam | 45 | 77.8% | 50.5% | +27.2 pts |
| Lay statement | 295 | 55.4% | 64.7% | −9.3 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 76.1% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 34.3% of grants and 13.7% 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 migraine 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 | 254 | 53.5% | 65.6% | −12.1 pts |
| Unfavorable VA exam | 301 | 53.1% | 72.7% | −19.6 pts |
Recent migraine decisions
Granted
Approximate balance of evidence; Benefit of the doubt applied; Persuasive private treating physician opinions
Competent evidence establishes current diagnosis of tension headaches.; Veteran is service-connected for back disabilities.; Conflicting medical opinions (VA negative, private positive) created approximate balance, resolved in Veteran's favor.
Service connection granted as secondary to service-connected back disabilities.; Conflicting medical opinions (negative VA, positive private) resulted in approximate balance.; Benefit of the doubt applied to grant service connection.
Denied
No diagnosis of headaches during or after service; Unfavorable VA examiner opinion; Evidence persuasively weighs against claim
No in-service complaints, diagnosis, or treatment for headaches.; Veteran's statements in 2003 and 2017-2020 denied headaches.; Evidence weighed against secondary connection to lumbosacral strain.
August 2024 VA exam persuasive; No medical evidence linking headaches to herbicide exposure; Headaches unrelated to service-connected back disability
Migraine secondary to a back condition: outcomes by year
| Year | Issues decided | Granted | Denied | Remanded | Other |
|---|---|---|---|---|---|
| 2017 | 23 | 8.7% | 34.8% | 52.2% | 4.3% |
| 2018 | 28 | 7.1% | 21.4% | 71.4% | 0.0% |
| 2019 | 61 | 23.0% | 19.7% | 55.7% | 1.6% |
| 2020 | 32 | 21.9% | 3.1% | 71.9% | 3.1% |
| 2021 | 31 | 12.9% | 12.9% | 74.2% | 0.0% |
| 2022 | 48 | 16.7% | 18.8% | 64.6% | 0.0% |
| 2023 | 39 | 30.8% | 7.7% | 61.5% | 0.0% |
| 2024 | 44 | 15.9% | 6.8% | 77.3% | 0.0% |
| 2025 | 46 | 13.0% | 8.7% | 78.3% | 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.
Why the Board granted or denied migraine
Most common reasons in grants
- Caused by the service-connected disability10
- Current diagnosis established9
- Aggravated by the service-connected disability9
- Service connection established4
- Evidence evenly balanced2
Most common reasons in denials
- VA examiner: less likely than not related to service8
- Preponderance of the evidence against the claim6
- Aggravated by the service-connected disability5
- No in-service complaints, treatment or diagnosis4
- No direct service connection established2
- No current diagnosis2
- Criteria for service connection not met2
- Criteria for entitlement not met1
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.
Background
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 migraine.
- A back condition is already service connected.
- Medical evidence linking them (a nexus opinion): migraine 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).
How VA rates migraine
Once service connection is granted, VA assigns a disability rating from the rating schedule, 38 CFR 4.124a, diagnostic code 8100 (Migraine). The rating is the same whether the condition is service connected directly or as secondary to another disability.
| Rating | Criteria |
|---|---|
| 50% | With very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability |
| 30% | With characteristic prostrating attacks occurring on an average once a month over last several months |
| 10% | With characteristic prostrating attacks averaging one in 2 months over last several months |
| 0% | With less frequent attacks |
- Note (1): There may be an overlap of manifestations of conditions evaluated under the table titled “Evaluation Of Cognitive Impairment And Other Residuals Of TBI Not Otherwise Classified” with manifestations of a comorbid mental or neurologic or other physical disorder that can be separately evaluated under another diagnostic code. In such cases, do not assign more than one evaluation based on the same manifestations. If the manifestations of two or more conditions cannot be clearly separated, assign a single evaluation under whichever set of diagnostic criteria allows the better assessment of overall impaired functioning due to both conditions. However, if the manifestations are clearly separable, assign a separate evaluation for each condition.
- Note (2): Symptoms listed as examples at certain evaluation levels in the table are only examples and are not symptoms that must be present in order to assign a particular evaluation.
- Note (3): “Instrumental activities of daily living” refers to activities other than self-care that are needed for independent living, such as meal preparation, doing housework and other chores, shopping, traveling, doing laundry, being responsible for one's own medications, and using a telephone. These activities are distinguished from “Activities of daily living,” which refers to basic self-care and includes bathing or showering, dressing, eating, getting in or out of bed or a chair, and using the toilet.
- Note (4): The terms “mild,” “moderate,” and “severe” TBI, which may appear in medical records, refer to a classification of TBI made at, or close to, the time of injury rather than to the current level of functioning. This classification does not affect the rating assigned under diagnostic code 8045.
- Note (5): A veteran whose residuals of TBI are rated under a version of § 4.124a, diagnostic code 8045, in effect before October 23, 2008 may request review under diagnostic code 8045, irrespective of whether his or her disability has worsened since the last review. VA will review that veteran's disability rating to determine whether the veteran may be entitled to a higher disability rating under diagnostic code 8045. A request for review pursuant to this note will be treated as a claim for an increased rating for purposes of determining the effective date of an increased rating awarded as a result of such review; however, in no case will the award be effective before October 23, 2008. For the purposes of determining the effective date of an increased rating awarded as a result of such review, VA will apply 38 CFR 3.114, if applicable.
- Note: The ratings under code 8046 apply only when the diagnosis of cerebral arteriosclerosis is substantiated by the entire clinical picture and not solely on findings of retinal arteriosclerosis.
Text of 38 CFR 4.124a as of Feb 27, 2026. Confirm the current text at the source before relying on it.
See all migraine decisions, direct and secondary.
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
- 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
- Cervical spine limitation of motion secondary to a back condition1,553 decisions · 8.8% granted
- Shoulder impairment secondary to a back condition647 decisions · 7.3% granted
- Foot impairment secondary to a back condition354 decisions · 6.2% granted
Migraine secondary to other conditions
- Migraine secondary to a psychiatric disorder1,181 decisions · 41.2% granted
- Migraine secondary to PTSD1,732 decisions · 37.1% granted
- Migraine secondary to TBI481 decisions · 35.8% granted
- Migraine secondary to a neck (cervical spine) condition628 decisions · 34.9% granted
- Migraine secondary to tinnitus1,013 decisions · 31.9% granted
- Migraine secondary to hypertension346 decisions · 23.7% granted
See all conditions secondary to a back condition.
Rules that apply to secondary migraine 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 4.124a · DC 8100
Schedule of ratings: neurological conditions
Read it in VA Law Explorer - M21-1 V.iii.12.A.3
Migraine: rating criteria, lay evidence of prostration, headache journals
Read it in VA Law Explorer - M21-1 IV.i.3.B.1.b
Reviewing a headache examination report
Read it in VA Law Explorer
Research your migraine 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 migraine 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.
Where this data comes from
- Claim
- Regional office decides
- Veteran appeals
- Board decides
- Granted · Denied · Remanded: back to the regional office
Board of Veterans' Appeals decisions show how VA's highest review body applies 38 CFR and weighs evidence on contested claims.
Each one is an appeal: a regional office decided the claim first, and the veteran appealed. So these rates describe the Board, not a veteran's odds at the regional office, where most claims are decided and whose decisions are not public.
More on what Board decisions can and cannot tell you