Secondary service connection
Migraine secondary to a neck (cervical spine) condition: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to a neck (cervical spine) condition in 661 decisions. It granted the issue in 34.5% of them, above the 30.7% grant rate for all migraine issues, denied it in 12.1%, and remanded it in 52.3%. Counting only decisions on the merits, 74.0% were granted.
Decisions
661
2017–2026
Granted
34.5%
All migraine: 30.7%
Granted on the merits
74.0%
Granted ÷ (granted + denied)
Remanded
52.3%
Denied: 12.1%
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 a neck (cervical spine) condition: outcomes by year
| Year | Issues decided | Granted | Denied | Remanded | Other |
|---|---|---|---|---|---|
| 2017 | 49 | 28.6% | 16.3% | 53.1% | 2.0% |
| 2018 | 49 | 38.8% | 12.2% | 46.9% | 2.0% |
| 2019 | 73 | 27.4% | 21.9% | 49.3% | 1.4% |
| 2020 | 77 | 26.0% | 11.7% | 62.3% | 0.0% |
| 2021 | 76 | 30.3% | 11.8% | 55.3% | 2.6% |
| 2022 | 63 | 31.7% | 12.7% | 54.0% | 1.6% |
| 2023 | 71 | 39.4% | 11.3% | 47.9% | 1.4% |
| 2024 | 101 | 34.7% | 5.9% | 57.4% | 2.0% |
| 2025 | 65 | 44.6% | 7.7% | 47.7% | 0.0% |
| 2026 | 41 | 53.7% | 12.2% | 34.1% | 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 Other: dismissed, withdrawn or no clear outcome.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 record | Decisions | Granted when present | When absent | Difference |
|---|---|---|---|---|
| Positive nexus opinion | 229 | 94.7% | 48.6% | +46.2 pts |
| Favorable VA exam | 115 | 92.6% | 67.4% | +25.2 pts |
| Private medical opinion | 299 | 83.0% | 61.1% | +21.9 pts |
| Treating physician opinion | 66 | 85.7% | 72.2% | +13.5 pts |
| Combat service | 41 | 78.9% | 73.7% | +5.2 pts |
| Lay statement | 550 | 73.4% | 77.8% | −4.4 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 75.0% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 37.7% of grants and 20.0% 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 | 423 | 70.1% | 81.3% | −11.2 pts |
| Unfavorable VA exam | 549 | 71.9% | 86.7% | −14.8 pts |
How these claims are argued
A secondary claim says a neck (cervical spine) 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)
14.7%
granted, of 156 issues (23.5% of all)
Causation only
caused by the disability, 3.310(a)
40.7%
granted, of 509 issues (76.5% of all)
| Medical link named | Issues | Granted |
|---|---|---|
Nerve involvement Granted “Secondary to service-connected neck and radiculopathy” A26021340 (2026) Denied “The Veteran claimed migraine headaches as secondary to cervical radiculopathy.” A20010365 (2020) | 18 | 55.6% |
Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 3.9% of the 665 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 disability63
- Current diagnosis established18
- Service connection established13
- Aggravated by the service-connected disability5
- Criteria for service connection met5
- Secondary to cervical spine disability3
- VA examiner's opinion found inadequate2
Most common reasons in denials
- No in-service complaints, treatment or diagnosis12
- VA examiner: less likely than not related to service5
- Aggravated by the service-connected disability4
- Primary cervical spine condition not service-connected4
- Preponderance of the evidence against the claim4
- Caused by the service-connected disability3
- Service connection established2
- Current diagnosis established2
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
Secondary service connection established; Related to active duty, environmental exposures, and/or cervical spine/nerve disabilities; Benefit of doubt resolved in Veteran's favor
Private ARNP opinion found more probative than VA examiner's opinion; VA examiner's opinion inadequate for failing to address aggravation; Evidence in equipoise, doubt resolved in veteran's favor
Secondary to service-connected cervical spine disability; VA exam diagnosed tension headaches; Private opinion linked headaches to neck condition
Denied
Primary cervical spine condition not service-connected.; Secondary claim denied as a matter of law.; Direct service connection for headaches not raised.
No current diagnosis of migraines found; Issue is medically complex, requiring specialized knowledge; Veteran not competent to diagnose migraines
No known medical literature supports a causal relationship between migraines and cervical strain.; VA examiner's opinion found dispositive.; Evidence persuasively against the claim.
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 neck (cervical spine) condition is already service connected.
- Medical evidence linking them (a nexus opinion): migraine was caused by a neck (cervical spine) 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 neck (cervical spine) condition
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 tinnitus1,013 decisions · 31.9% granted
- Migraine secondary to hypertension346 decisions · 23.7% granted
- Migraine secondary to a back condition347 decisions · 18.7% granted
See all conditions secondary to a neck (cervical spine) 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 neck (cervical spine) 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.