Secondary service connection

Shoulder impairment secondary to a neck (cervical spine) condition: BVA grant rates and what wins

From 2017 to 2026, the Board of Veterans' Appeals decided shoulder impairment claimed as secondary to a neck (cervical spine) condition in 425 decisions. It granted the issue in 9.9% of them, below the 15.2% grant rate for all shoulder impairment issues, denied it in 20.7%, and remanded it in 69.6%. Counting only decisions on the merits, 32.3% were granted.

Decisions

425

2017–2026

Granted

9.9%

All shoulder impairment: 15.2%

Granted on the merits

32.3%

Granted ÷ (granted + denied)

Remanded

69.6%

Denied: 20.7%

See all shoulder impairment decisions, direct and secondary.

Shoulder impairment secondary to a neck (cervical spine) condition: outcomes by year

YearIssues decidedGrantedDeniedRemandedOther
2017
36
8.3%22.2%69.4%0.0%
2018
47
10.6%29.8%59.6%0.0%
2019
51
5.9%17.6%74.5%2.0%
2020
63
7.9%28.6%63.5%0.0%
2021
74
6.8%17.6%75.7%0.0%
2022
83
7.2%18.1%74.7%0.0%
2023
66
7.6%22.7%69.7%0.0%
2024
55
16.4%16.4%67.3%0.0%
2025
47
23.4%12.8%63.8%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 Other: dismissed, withdrawn or no clear outcome.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 shoulder impairment decisions

For each kind of supporting evidence: how often the Board granted the shoulder impairment 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 opinion6369.7%19.6%+50.1 pts
Favorable VA exam4168.8%27.2%+41.6 pts
Private medical opinion12645.1%24.1%+21.0 pts
Lay statement35729.7%58.3%−28.7 pts
  • The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 73.8% of the decisions that granted shoulder impairment.
  • The Board found the veteran's statements credible in 38.1% of grants and 14.8% 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 shoulder impairment was still granted when the record contained the negative item, not that the item helped.

In the recordDecisionsGranted when presentWhen absentDifference
Unfavorable VA exam36430.2%50.0%−19.8 pts
Negative nexus opinion30928.3%50.0%−21.7 pts

How these claims are argued

A secondary claim says a neck (cervical spine) condition caused shoulder impairment 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)

5.2%

granted, of 213 issues (40.3% of all)

Causation only

caused by the disability, 3.310(a)

13.0%

granted, of 315 issues (59.7% of all)

Medical link namedIssuesGranted

Nerve involvement

Granted “Service connection for a right shoulder disorder secondary to the veteran's service-connected cervical spine disability with bilateral radiculopathy was granted.” 25008104 (2025)

Denied “Pain attributed to radiculopathy from service-connected cervical spine.” A25109807 (2025)

7912.7%

Based on words in the AI-written summary and reasons for each issue, not a reading of the full decision. 17.2% of the 528 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 shoulder impairment

Most common reasons in grants

  1. Caused by the service-connected disability10
  2. Service connection established4
  3. Current diagnosis established4
  4. Related to service-connected cervical spine disability2

Most common reasons in denials

  1. No in-service complaints, treatment or diagnosis20
  2. VA examiner: less likely than not related to service15
  3. Preponderance of the evidence against the claim8
  4. Aggravated by the service-connected disability7
  5. Current diagnosis established7
  6. Service records negative or silent6
  7. No current diagnosis6
  8. No continuity of symptomatology2

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 shoulder impairment decisions

Granted

Citation Nr. A25108787A. C. Mackenzie · 2025

Left shoulder pain caused by cervical pain disability; Evidence weighs in favor of service connection; Resolving doubt in Veteran's favor

Citation Nr. A25105380T. Raymond · 2025

Secondary to service-connected cervical strain; Supported by private medical opinion; No contrary medical opinions of record

Citation Nr. A25099695Ray Barto Slabbekorn, Jr. · 2025

Favorable finding of diagnosis from RO decision; Lay statements regarding pain during military physical training; Private chiropractic opinion linking condition to service; Benefit of the doubt applied due to approximate balance of evidence

Denied

Citation Nr. 26004509Eric S. Leboff · 2026

No in-service complaints or diagnoses for right shoulder disability.; No medical opinion linking current disability to service or service-connected cervical spine strain.; Veteran's lay statement regarding onset outweighed by lack of medical evidence.

Citation Nr. A25109807Jonathan B. Kramer · 2025

No current diagnosis of left shoulder disability.; Pain attributed to radiculopathy from service-connected cervical spine.; No evidence of functional impairment.

Citation Nr. A25093699Ray Barto Slabbekorn, Jr. · 2025

C&P examiner provided negative nexus opinion regarding service connection; C&P examiner provided negative nexus opinion regarding secondary connection to cervical/lumbar spine conditions; Veteran's lay statements not competent to establish medical causal relationship; Evidence weighs against finding of service connection

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 shoulder impairment.
  2. A neck (cervical spine) condition is already service connected.
  3. Medical evidence linking them (a nexus opinion): shoulder impairment 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

Shoulder impairment secondary to other conditions

See all conditions secondary to a neck (cervical spine) condition.

Rules that apply to secondary shoulder impairment claims

Research your shoulder impairment case

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

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How these numbers are calculated

  • Counts decisions in which the Board decided a shoulder impairment 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.