Secondary service connection
Migraine secondary to hypertension: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to hypertension in 374 decisions. It granted the issue in 23.0% of them, below the 30.7% grant rate for all migraine issues, denied it in 14.7%, and remanded it in 59.6%. Counting only decisions on the merits, 61.0% were granted.
Decisions
374
2017–2026
Granted
23.0%
All migraine: 30.7%
Granted on the merits
61.0%
Granted ÷ (granted + denied)
Remanded
59.6%
Denied: 14.7%
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 |
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 hypertension: outcomes by year
| Year | Issues decided | Granted | Denied | Remanded | Other |
|---|---|---|---|---|---|
| 2018 | 22 | 18.2% | 13.6% | 45.5% | 22.7% |
| 2019 | 41 | 46.3% | 7.3% | 46.3% | 0.0% |
| 2020 | 32 | 28.1% | 25.0% | 46.9% | 0.0% |
| 2021 | 41 | 14.6% | 22.0% | 61.0% | 2.4% |
| 2022 | 42 | 16.7% | 4.8% | 76.2% | 2.4% |
| 2023 | 36 | 22.2% | 11.1% | 66.7% | 0.0% |
| 2024 | 56 | 17.9% | 10.7% | 69.6% | 1.8% |
| 2025 | 63 | 28.6% | 20.6% | 50.8% | 0.0% |
| 2026 | 23 | 13.0% | 17.4% | 65.2% | 4.3% |
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 Other: dismissed, withdrawn or no clear outcome.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 record | Decisions | Granted when present | When absent | Difference |
|---|---|---|---|---|
| Positive nexus opinion | 77 | 88.7% | 44.3% | +44.4 pts |
| Favorable VA exam | 54 | 90.0% | 49.5% | +40.5 pts |
| Private medical opinion | 119 | 80.0% | 48.8% | +31.2 pts |
| Lay statement | 295 | 56.1% | 81.5% | −25.3 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 67.4% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 16.3% of grants and 12.7% 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 | 234 | 57.7% | 68.2% | −10.4 pts |
| Unfavorable VA exam | 300 | 57.3% | 79.2% | −21.9 pts |
How these claims are argued
A secondary claim says hypertension 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)
17.5%
granted, of 143 issues (38.1% of all)
Causation only
caused by the disability, 3.310(a)
26.3%
granted, of 232 issues (61.9% of all)
Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 5.3% of the 375 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
- Caused by the service-connected disability22
- Current diagnosis established10
- Service connection established7
- Aggravated by the service-connected disability6
- Criteria for secondary service connection met3
- Conflicting medical opinions2
- Favorable VA opinion linking headaches to hypertension2
- Criteria for service connection met2
Most common reasons in denials
- VA examiner: less likely than not related to service10
- Preponderance of the evidence against the claim5
- Aggravated by the service-connected disability4
- No current diagnosis4
- No in-service complaints, treatment or diagnosis4
- Continuity of symptomatology since service2
- No continuity of symptomatology2
- No competent medical evidence links headaches to hypertension2
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
Criteria met for entitlement to service connection for headaches, secondary to stroke, sleep apnea and hypertension.; Veteran's headaches were caused by his service-connected stroke, sleep apnea and hypertension.; Benefit of the doubt afforded to the Veteran.
VA examiner considered Veteran's medical history including hypertension care management records.; Hypertension and diabetes mellitus can cause headaches due to blood pressure and blood sugar fluctuations.; Resolving reasonable doubt in Veteran's favor due to relative equipoise.
Evidence in approximate balance.; Benefit of doubt resolved in Veteran's favor.; Headaches attributed to hypertension by medical opinions.
Denied
No medical diagnosis for headaches; No objective findings on examination; No medical evidence or history to substantiate complaints; No medical literature supports link between hypertension and headaches; Symptoms described as mild and unsubstantiated
Service treatment records silent for headache complaints.; Private medical records silent for headache complaints.; VA examiner opined less likely than not related to or aggravated by hypertension.; Board found VA examiner's opinion probative and persuasive.; Medical literature did not demonstrate causal relationship between tension headaches and herbicide exposure.; Evidence weighed against finding condition due to or aggravated by service or service-connected disability.
VA examiners opined less likely than not service-related.; Lack of in-service complaints and post-service risk factors noted.; Veteran's lay opinion inadequate to rebut examiner findings.; Claim as secondary to hypertension denied due to lack of service connection for hypertension.
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.
- Hypertension is already service connected.
- Medical evidence linking them (a nexus opinion): migraine was caused by hypertension (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 hypertension
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 a back condition347 decisions · 18.7% granted
See all conditions secondary to hypertension.
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 hypertension, 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.