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.

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%

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.

RatingCriteria
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

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.

Migraine secondary to a back condition: outcomes by year

YearIssues decidedGrantedDeniedRemandedOther
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 Other: dismissed, withdrawn or no clear outcome.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.

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 recordDecisionsGranted when presentWhen absentDifference
Positive nexus opinion8392.6%26.6%+66.0 pts
Private medical opinion12779.7%29.6%+50.1 pts
Favorable VA exam4577.8%50.5%+27.2 pts
Lay statement29555.4%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 recordDecisionsGranted when presentWhen absentDifference
Negative nexus opinion25453.5%65.6%−12.1 pts
Unfavorable VA exam30153.1%72.7%−19.6 pts

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 namedIssuesGranted

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)

1540.0%

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.

Why the Board granted or denied migraine

Most common reasons in grants

  1. Caused by the service-connected disability10
  2. Current diagnosis established9
  3. Aggravated by the service-connected disability9
  4. Service connection established4
  5. Evidence evenly balanced2

Most common reasons in denials

  1. VA examiner: less likely than not related to service8
  2. Preponderance of the evidence against the claim6
  3. Aggravated by the service-connected disability5
  4. No in-service complaints, treatment or diagnosis4
  5. No direct service connection established2
  6. No current diagnosis2
  7. Criteria for service connection not met2
  8. 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.

Recent migraine decisions

Granted

Citation Nr. A26019357S. Merrick · 2026

Approximate balance of evidence; Benefit of the doubt applied; Persuasive private treating physician opinions

Citation Nr. A26008788Michael A. Pappas · 2026

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.

Citation Nr. A26008790Michael A. Pappas · 2026

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

Citation Nr. A26008297Michael Martin · 2026

No diagnosis of headaches during or after service; Unfavorable VA examiner opinion; Evidence persuasively weighs against claim

Citation Nr. A25084263J. Nichols · 2025

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.

Citation Nr. 25009862M. C. Wilson · 2025

August 2024 VA exam persuasive; No medical evidence linking headaches to herbicide exposure; Headaches unrelated to service-connected back disability

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 migraine.
  2. A back condition is already service connected.
  3. 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).

Other conditions secondary to a back condition

Migraine secondary to other conditions

See all conditions secondary to a back condition.

Rules that apply to secondary migraine claims

Research your migraine case

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

Open VA Law Explorer

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.