Secondary service connection
Migraine secondary to a psychiatric disorder: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to a psychiatric disorder in 1,393 decisions. It granted the issue in 40.7% of them, above the 30.7% grant rate for all migraine issues, denied it in 8.4%, and remanded it in 50.0%. Counting only decisions on the merits, 82.9% were granted.
Decisions
1,393
2017–2026
Granted
40.7%
All migraine: 30.7%
Granted on the merits
82.9%
Granted ÷ (granted + denied)
Remanded
50.0%
Denied: 8.4%
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 psychiatric disorder: outcomes by year
| Year | Issues decided | Granted | Denied | Remanded | Other |
|---|---|---|---|---|---|
| 2017 | 35 | 20.0% | 17.1% | 57.1% | 5.7% |
| 2018 | 109 | 50.5% | 4.6% | 44.0% | 0.9% |
| 2019 | 179 | 55.3% | 8.4% | 36.3% | 0.0% |
| 2020 | 166 | 38.6% | 6.0% | 54.8% | 0.6% |
| 2021 | 130 | 33.1% | 8.5% | 58.5% | 0.0% |
| 2022 | 127 | 33.9% | 10.2% | 54.3% | 1.6% |
| 2023 | 176 | 37.5% | 8.0% | 54.0% | 0.6% |
| 2024 | 196 | 35.7% | 12.2% | 50.5% | 1.5% |
| 2025 | 209 | 41.1% | 7.7% | 50.2% | 1.0% |
| 2026 | 67 | 50.7% | 4.5% | 44.8% | 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 Other: dismissed, withdrawn or no clear outcome.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 | 582 | 95.8% | 58.5% | +37.3 pts |
| Private medical opinion | 707 | 90.9% | 66.2% | +24.7 pts |
| Favorable VA exam | 213 | 93.8% | 79.6% | +14.2 pts |
| Treating physician opinion | 69 | 92.5% | 82.3% | +10.2 pts |
| Buddy statement | 41 | 78.6% | 83.0% | −4.4 pts |
| Lay statement | 1,127 | 80.1% | 95.9% | −15.8 pts |
| Combat service | 59 | 57.7% | 83.9% | −26.2 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 74.1% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 27.3% 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 | 895 | 80.6% | 87.3% | −6.7 pts |
| Unfavorable VA exam | 1,111 | 81.4% | 90.4% | −8.9 pts |
How these claims are argued
A secondary claim says a psychiatric disorder 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)
38.1%
granted, of 572 issues (41.0% of all)
Causation only
caused by the disability, 3.310(a)
42.5%
granted, of 822 issues (59.0% of all)
| Medical link named | Issues | Granted |
|---|---|---|
Stress Granted “VA examiner opined migraines at least as likely as not due to PTSD-related stress” 26000465 (2026) Denied “Service records were negative for headaches, and the Veteran consistently denied headaches during medical visits, despite a vocational report mentioning occasional migraines during stress.” 24022747 (2024) | 128 | 62.5% |
Sleep disruption Granted “Service connection for headaches was granted as secondary to the Veteran's service-connected PTSD, persistent depressive disorder, generalized anxiety disorder, and insomnia.” 26001880 (2026) Denied “The veteran claimed service connection for headaches, asserting they were caused by or aggravated by medication for his service-connected insomnia disorder, major depressive disorder, and sleep disturbances.” A24077556 (2024) | 41 | 53.7% |
Medication side effects Granted “The Board relied on a private medical opinion stating the migraines were at least as likely as not aggravated by the psychiatric condition and its treatment, as well as VA treatment records indicating medication side effects.” A26038608 (2026) Denied “Veteran's claim based on medication side effect theory.” A24077556 (2024) | 20 | 45.0% |
Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 14.3% of the 1,394 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 disability95
- Current diagnosis established69
- Aggravated by the service-connected disability57
- Service connection established32
- Criteria for secondary service connection met8
- Criteria for service connection met7
- VA examiner: less likely than not related to service6
- Supported by medical literature6
Most common reasons in denials
- VA examiner: less likely than not related to service17
- No in-service complaints, treatment or diagnosis9
- Service records negative or silent8
- Preponderance of the evidence against the claim8
- No current diagnosis7
- Aggravated by the service-connected disability5
- Current diagnosis established5
- Caused by the service-connected disability3
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
Veteran service connected for generalized anxiety disorder; Veteran's wife provided credible testimony on onset and continuation; Mild cognitive impairment proximately due to generalized anxiety disorder
Migraines found secondary to service-connected acquired psychiatric disability.; Private medical opinion found migraines aggravated by psychiatric condition and treatment.; VA treatment records support aggravation by medication.; Prior VA exam insufficient as it did not address aggravation by psychiatric disorder.
Granted secondary to service-connected psychiatric disorder.; Private opinion found nexus.; No conflicting evidence presented.
Denied
No nexus between headaches and service or TERA; VA opinions found less likely than not related; March 2024 opinion discounted for lack of chronicity evidence; January 2025 opinion inadequate for not addressing obesity as intermediate step
Headaches did not meet prostrating attack criteria; Evidence persuasively weighs against compensable rating
Headaches claimed as secondary to psychiatric disorder.; Psychiatric disorder denied service connection.; Cannot grant secondary claim when primary condition 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 migraine.
- A psychiatric disorder is already service connected.
- Medical evidence linking them (a nexus opinion): migraine was caused by a psychiatric disorder (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 psychiatric disorder
- Sleep apnea secondary to a psychiatric disorder4,474 decisions · 33.1% granted
- Erectile dysfunction secondary to a psychiatric disorder1,061 decisions · 31.9% granted
- Gastroesophageal reflux disease (GERD) secondary to a psychiatric disorder591 decisions · 25.4% granted
- Diabetes mellitus secondary to a psychiatric disorder418 decisions · 21.3% granted
- Hypertension secondary to a psychiatric disorder1,487 decisions · 20.1% granted
Migraine secondary to other conditions
- 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
- Migraine secondary to a back condition347 decisions · 18.7% granted
See all conditions secondary to a psychiatric disorder.
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 psychiatric disorder, 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.