Secondary service connection
Migraine secondary to PTSD: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to PTSD in 1,732 decisions. It granted the issue in 37.1% of them, above the 30.7% grant rate for all migraine issues, denied it in 8.8%, and remanded it in 52.6%. Counting only decisions on the merits, 80.9% were granted.
Decisions
1,732
2017–2026
Granted
37.1%
All migraine: 30.7%
Granted on the merits
80.9%
Granted ÷ (granted + denied)
Remanded
52.6%
Denied: 8.8%
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 PTSD: outcomes by year
| Year | Issues decided | Granted | Denied | Remanded | Other |
|---|---|---|---|---|---|
| 2017 | 60 | 21.7% | 23.3% | 46.7% | 8.3% |
| 2018 | 98 | 39.8% | 8.2% | 45.9% | 6.1% |
| 2019 | 164 | 41.5% | 7.9% | 50.0% | 0.6% |
| 2020 | 160 | 39.4% | 10.6% | 48.8% | 1.3% |
| 2021 | 198 | 31.3% | 10.6% | 56.6% | 1.5% |
| 2022 | 164 | 30.5% | 9.1% | 59.8% | 0.6% |
| 2023 | 215 | 34.0% | 7.9% | 57.7% | 0.5% |
| 2024 | 295 | 41.0% | 6.4% | 50.2% | 2.4% |
| 2025 | 286 | 41.6% | 7.3% | 50.7% | 0.3% |
| 2026 | 99 | 36.4% | 7.1% | 55.6% | 1.0% |
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 Other: dismissed, withdrawn or no clear outcome.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 | 587 | 97.1% | 56.9% | +40.2 pts |
| Private medical opinion | 765 | 90.5% | 65.2% | +25.2 pts |
| Favorable VA exam | 273 | 93.9% | 76.6% | +17.2 pts |
| Buddy statement | 70 | 85.7% | 80.7% | +5.0 pts |
| Combat service | 166 | 84.1% | 80.5% | +3.6 pts |
| Treating physician opinion | 99 | 82.6% | 80.7% | +1.9 pts |
| Lay statement | 1,402 | 78.1% | 94.8% | −16.7 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 73.9% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 28.6% of grants and 13.8% 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 | 1,119 | 78.1% | 86.4% | −8.3 pts |
| Unfavorable VA exam | 1,409 | 78.6% | 93.4% | −14.8 pts |
How these claims are argued
A secondary claim says PTSD 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)
30.3%
granted, of 676 issues (38.9% of all)
Causation only
caused by the disability, 3.310(a)
41.3%
granted, of 1,063 issues (61.1% 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 “The Board noted that while migraines can be triggered by stress, no causal link between psychiatric illness and migraines has been established in medical literature.” A25021048 (2025) | 181 | 63.0% |
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) | 51 | 62.7% |
Medication side effects Granted “Service connection for migraines is granted as secondary to the Veteran's service-connected PTSD with alcohol and opioid use disorder in remission.” A25098547 (2025) | 17 | 41.2% |
Weight gain or obesity Denied “The Veteran sought service connection for migraines as secondary to his service-connected PTSD, with obesity as an intermediate step.” A24086560 (2024) | 10 | 0.0% |
Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 15.0% of the 1,739 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
- Current diagnosis established60
- Caused by the service-connected disability53
- Service connection established51
- Aggravated by the service-connected disability34
- Criteria for service connection met13
- VA examiner: less likely than not related to service11
- No contrary medical opinion of record9
- Secondary to PTSD6
Most common reasons in denials
- VA examiner: less likely than not related to service23
- No in-service complaints, treatment or diagnosis18
- Preponderance of the evidence against the claim11
- Service records negative or silent11
- Current diagnosis established9
- No current diagnosis8
- Continuity of symptomatology since service3
- Veteran failed to attend scheduled VA examination3
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
Private physician's opinion found causal and aggravating relationship between PTSD/tinnitus and migraines.; VA treatment records and co-worker corroborated reports of headaches/migraines.; Resolving doubt in Veteran's favor due to conflicting medical opinions.
Credible testimony of stress-triggered headaches; Consistent with service-connected PTSD/alcohol use disorder; Benefit of the doubt applied
Private opinion linked migraines to tinnitus and PTSD; Opinion cited shared physiological/psychological pathways; No contrary VA opinion on secondary connection
Denied
Service records did not establish chronic headaches or onset during service; Significant gap between separation and first treatment for headaches; Post-service records reflect denial or absence of headaches
No objective evidence of in-service onset or continuity of symptoms.; Multiple negative nexus opinions from VA examiners.; Migraines not listed under Camp Lejeune presumptive conditions.; Correlation between PTSD and migraines, but no causal link to service established.
Headaches did not meet prostrating attack criteria; Evidence persuasively weighs against compensable rating
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.
- PTSD is already service connected.
- Medical evidence linking them (a nexus opinion): migraine was caused by PTSD (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 PTSD
- Major depressive disorder secondary to PTSD305 decisions · 62.0% granted
- Sleep apnea secondary to PTSD11,479 decisions · 31.7% granted
- Erectile dysfunction secondary to PTSD1,645 decisions · 30.3% granted
- Gastroesophageal reflux disease (GERD) secondary to PTSD1,237 decisions · 25.3% granted
- Irritable colon syndrome (spastic colitis mucous colitis) secondary to PTSD380 decisions · 24.2% granted
- Diabetes mellitus secondary to PTSD551 decisions · 20.3% granted
- Hypertension secondary to PTSD3,194 decisions · 16.5% granted
Migraine secondary to other conditions
- Migraine secondary to a psychiatric disorder1,181 decisions · 41.2% 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 PTSD.
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 PTSD, 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.