Secondary service connection

Conditions secondary to sleep apnea

Veterans with service-connected sleep apnea often claim other conditions as caused or worsened by it. This page lists those conditions, what VA needs to grant them, and how they fared when veterans appealed to the Board of Veterans' Appeals.

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 the secondary condition.
  2. Sleep apnea is already service connected.
  3. Medical evidence linking them (a nexus opinion): the secondary condition was caused by sleep apnea (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).

Conditions claimed secondary to sleep apnea

Conditions the Board decided at least 300 times as secondary to this disability, highest appeal grant rate first. Open one for the evidence and reasons behind the decisions.

Sleep apnea claimed secondary to other conditions

The other direction: sleep apnea claimed as caused or worsened by a different service-connected disability.

How VA rates sleep apnea

Once service connection is granted, VA assigns a disability rating from the rating schedule, 38 CFR 4.97, diagnostic code 6847 (Sleep Apnea Syndromes (Obstructive, Central, Mixed)). The rating is the same whether the condition is service connected directly or as secondary to another disability.

RatingCriteria
100%Chronic respiratory failure with carbon dioxide retention or cor pulmonale, or; requires tracheostomy
50%Requires use of breathing assistance device such as continuous airway pressure (CPAP) machine
30%Persistent day-time hypersomnolence
0%Asymptomatic but with documented sleep disorder breathing

Text of 38 CFR 4.97 as of Feb 27, 2026. Confirm the current text at the source before relying on it.

All Board decisions on sleep apnea, direct and secondary: Sleep apnea grant rates.

Positive nexus opinions track with sleep apnea secondary grants

Sleep apnea secondary to a back condition was granted on the merits in 95.7% of Board decisions with a positive nexus opinion, against 38.9% without one.

Orthopedic pain and reduced physical activity leading to secondary claims

Sleep apnea secondary to a knee condition was granted in 46.2% of 983 decisions, and secondary to a back condition in 38.2% of 1,166. Both beat sleep apnea as a whole, granted in 26.4%.

Board grant rate for sleep apnea by claimed primary condition
Granted

Knee condition

46.2%

Back condition

38.2%

Psychiatric disorder

33.1%

PTSD

31.7%

Diabetes

23.0%

Tinnitus

20.7%

Hypertension

14.6%

Sleep apnea overall

26.4%

Share of all Board decisions granted, including remands in the base.

Knee grants rose from 33.3% in 2019 to 59.8% in 2025. Back grants rose from 22.2% in 2017 to 51.4% in 2025. Knee issues argued on causation alone were granted 53.0% of the time, versus 36.0% when aggravation was discussed. The data does not show why.

Weight gain as an intermediate link for secondary service connection

Obesity as an intermediate step is named in only 11 back grants and 6 knee grants. Direct causation by the service-connected disability is named far more often, in 153 back grants and 118 knee grants. These counts cover stated reasons only, not every case where weight was argued.

Mental health conditions as primary service connections

PTSD is the largest primary, with 11,479 decisions granted at 31.7%. Psychiatric disorder claims show 5,568 decisions, granted 33.4% and remanded 54.2%. Their grants rose from 12.0% in 2017 to 47.2% in 2025, a steeper climb than sleep apnea overall, which went from 17.3% to 33.4%.

Grant rate by year: psychiatric primary versus sleep apnea overall
Secondary to psychiatric disorderSleep apnea overall

2017

12.0%
17.3%

2019

28.5%
21.7%

2021

22.5%
21.6%

2023

30.7%
25.6%

2025

47.2%
33.4%

Share of issues granted each year.

The top denial reason was a VA examiner finding the link less likely than not, in 147 decisions.

Role of lay statements and medical evidence in BVA decisions

For psychiatric primaries, a positive nexus came with a 94.1% merits grant rate, versus 37.6% without. A private opinion came with 85.9% versus 43.1%. Knee claims show a similar private opinion split, 88.8% versus 50.0%.

Merits grant rate with and without a positive nexus opinion
With positive nexusWithout positive nexus

Back condition

95.7%
38.9%

Knee condition

95.1%
40.9%

Psychiatric disorder

94.1%
37.6%

Sleep apnea overall

86.9%
33.0%

Decisions reached on the merits only. Association, not cause.

Psychiatric claims with a lay statement were granted 67.9% on the merits, lower than 91.5% without. Across all sleep apnea decisions, buddy statements came with 76.0% versus 52.0%. These are associations. The data does not show whether any evidence type drove the outcome.

Figures from the research data as of Nov 2, 2026. Every number is computed from the data, which is extracted by AI from public decisions and can contain errors.

Rules that apply to secondary claims

Research your secondary case

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

Which conditions secondary to sleep apnea does the Board grant most often, and why?What nexus opinions win claims secondary to sleep apnea?Why does the Board deny conditions claimed secondary to sleep apnea?
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Where this data comes from

  1. Claim
  2. Regional office decides
  3. Veteran appeals
  4. Board decides
  5. Granted · Denied · Remanded: back to the regional office

Board of Veterans' Appeals decisions show how VA's highest review body applies 38 CFR and weighs evidence on contested claims.

Each one is an appeal: a regional office decided the claim first, and the veteran appealed. So these rates describe the Board, not a veteran's odds at the regional office, where most claims are decided and whose decisions are not public.

More on what Board decisions can and cannot tell you