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GASTROESOPHAGEAL REFLUX DISEASE (GERD)

DUSTIN L. WARE · 2026 · Case ID: A26026589

GRANTED

Summary

The Veteran, an Army Veteran who served from February 1989 to February 1993, appeals the denial of service connection for GERD and IBS as secondary to his service-connected PTSD. The Board reviewed the evidence, noting that the Veteran's PTSD and current diagnoses of GERD and IBS were established. The Regional Office provided multiple negative VA medical opinions between July 2023 and February 2025, stating insufficient evidence or lack of a causal relationship between PTSD and GERD/IBS, though some noted stress can worsen symptoms. The Veteran submitted several private medical opinions from a psychiatric pharmacist, a certified family nurse practitioner, and a physician assistant. These private opinions cited medical literature suggesting a link between PTSD and gastrointestinal issues, including GERD and IBS, through common etiology, neurobiological factors, and stress exacerbation. Given the conflicting evidence, the Board found the evidence in approximate balance. Applying the benefit of the doubt, the Board resolved the doubt in the Veteran's favor, granting service connection for GERD and IBS as secondary to his service-connected PTSD.

Rationale

Current diagnosis of GERD established.; PTSD is a service-connected disability.; Evidence in approximate balance regarding secondary connection.; Benefit of the doubt applied in Veteran's favor.

Service Branch
ARMY
Special Benefit
NO SPECIAL BENEFIT
Docket No.
250506-540576

Full Decision Text

Citation Nr: A26026589
Decision Date: 03/24/26	Archive Date: 03/24/26

DOCKET NO. 250506-540576
DATE: March 24, 2026

ORDER

Service connection for (GERD), as secondary to the service-connected posttraumatic stress disorder (PTSD), is granted. 

Service connection for irritable bowel syndrome (IBS), as secondary to the service-connected PTSD, is granted. 

FINDINGS OF FACT

1. Resolving all reasonable doubt in the Veteran's favor, his GERD is caused by his service-connected PTSD. 

2. Resolving all reasonable doubt in the Veteran's favor, his IBS is caused by his service-connected PTSD. 

CONCLUSIONS OF LAW

1. The criteria for service connection for GERD, as secondary to service-connected PTSD, have been met. 38 U.S.C. §§ 1110, 1131, 5107; 38 C.F.R. §§ 3.102, 3.310.

2. The criteria for service connection for IBS, as secondary to service-connected PTSD, have been met. 38 U.S.C. §§ 1110, 1131, 5107; 38 C.F.R. §§ 3.102, 3.310.

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The Veteran served on active duty in the U.S. Army from February 1989 to February 1993. 

This matter is before the Board of Veterans' Appeals (the Board) on appeal from a February 12, 2025, and February 26, 2025, Department of Veterans Affairs (VA) Regional Office (RO) rating decisions. 

The first February 2025 rating decision confirmed and continued the previous denial of service connection for IBS as secondary to PTSD and deferred a decision on entitlement to service connection for GERD. 

The second February 2025 rating decision confirmed the previous denial of service connection for GERD as secondary to PTSD. 

In the May 2025 VA Form 10182, Decision Review Request: Board Appeal (Notice of Disagreement), the Veteran elected the Direct Review docket.  Therefore, the Board may only consider the evidence of record at the time of the February 12 and 26, 2025, agency of original jurisdiction (AOJ) rating decisions on appeal. 38 C.F.R. § 20.301. Any evidence submitted after the AOJ decision on appeal cannot be considered by the Board. 38 C.F.R. §§ 20.300, 20.301, 20.801. 

If the Veteran would like VA to consider any evidence that was submitted that the Board could not consider, the Veteran may file a Supplemental Claim (VA Form 20-0995) and submit or identify this evidence. 38 C.F.R. § 3.2501. If the evidence is new and relevant, VA will issue another decision on the claim, considering the new evidence in addition to the evidence previously considered. Id. Specific instructions for filing a Supplemental Claim are included with this decision. 

Service Connection

Service connection may be granted for a disability resulting from injury or disease that was incurred in, or aggravated by, military service. 38 U.S.C. §§ 1110, 1131; 38 C.F.R. §§ 3.303, 3.304. Service connection may be granted for any disease diagnosed after a veteran's discharge when all the evidence, including that pertinent to service, establishes that the disease was incurred in service. 38 C.F.R. § 3.303(d).

Service connection may also be established on a secondary basis for a disability that is due to or the result of a service-connected disease or injury. 38 C.F.R. § 3.310(a). Service connection for a disability can be granted on a secondary basis if a Veteran has a (1) current disability; (2) a separate disability already subject to service connection; and (3) the first disability is due to or the result of, or is aggravated by, the service-connected disability. Allen v. Brown, 7 Vet. App. 439 (1995); 38 C.F.R. § 3.310.

When there is an approximate balance of positive and negative evidence regarding the merits of an issue material to the determination of the matter, the benefit of the doubt in resolving each such issue shall be given to the claimant. 38 U.S.C. § 5107(b); 38 C.F.R. § 3.102.

1. Entitlement to service connection for GERD.

2. Entitlement to service connection for IBS. 

The Veteran contends that he developed GERD and IBS as the
 is due to or the result of, or is aggravated by, the service-connected disability. Allen v. Brown, 7 Vet. App. 439 (1995); 38 C.F.R. § 3.310.

When there is an approximate balance of positive and negative evidence regarding the merits of an issue material to the determination of the matter, the benefit of the doubt in resolving each such issue shall be given to the claimant. 38 U.S.C. § 5107(b); 38 C.F.R. § 3.102.

1. Entitlement to service connection for GERD.

2. Entitlement to service connection for IBS. 

The Veteran contends that he developed GERD and IBS as the result of service, to include due to his service-connected PTSD.  See June 2024 statement. 

In this case, both February 2025 rating decisions on appeal contain favorable findings of a current diagnosis and a finding that the disability for which the Veteran is claiming secondary service connection to, PTSD, is service connected. In other words, the current disability element and separate service-connected disability element of the claim have been established. Allen, supra; 38 C.F.R. § 3.310.  The Board shall not disturb these favorable findings.  The remaining question is whether the Veteran's IBS and GERD are due to or aggravated by his service-connected PTSD.  

In this regard, the AOJ provided negative VA medical opinions in July 2023, December 2023, May 2024, November 2024, and February 2025. 

The July 2023 VA medical opinion indicates that there is insufficient medical evidence to support a claim that PTSD causes GERD.  The July 2023 VA medical opinion with respect to IBS indicates that medical literature does not show a possible influence of psychosocial factors in the expression of IBS symptoms, and that there is insufficient medical literature to support the claim that PTSD causes IBS. 

The December 2023 VA medical opinion indicates that GERD and IBS are separate entities from PTSD and a thorough medical review of medical literature does not demonstrate a causal relationship.  With respect to aggravation, the examiner indicated that the Veteran's GERD and IBS have not been aggravated and a baseline level of severity could not be established. 

The May 2024 VA medical opinion indicates that while there are some studies that show that IBS is associated with mental health disorders, these do not include PTSD.  The examiner went on to state that studies show that most people with IBS show worsening of symptoms during periods of increased stress.  It was further noted that although stress can make symptoms worse, it does not cause them.  With respect to GERD, it was noted that studies show a higher risk of GERD in individual with mental health disorders, but that no causal relationship has been established. 

The November 2024 VA opinion indicates that the Veteran's GERD and are likely due to several different factors, and that there is no medical evidence that the claimed conditions are due to his PTSD.  

The February 2025 VA opinion is with respect to GERD only and essentially re-affirms the November 2024 VA medical opinion.    

The Veteran submitted several private opinions.  

A March 2023 letter from C.N., a psychiatric pharmacist, indicates that there are numerous physical complications that can stem from PTSD, including GERD, which is a common comorbidity amongst PTSD patients.  It is noted that while a link between GERD and PTSD is not clearly defined, increased levels of stress and anxiety have been associated with gastrointestinal symptoms.  It was further noted that some of the Veteran's psychiatric medication has been associated with gastrointestinal side effects.  C.N. goes on to state that while a link between PTSD and GERD may be unclear, the potential for mental health medications and symptoms of PTSD and worsening of GERD symptoms cannot be ruled out. 

There is an April 2023 private opinion from G.I., a certified family nurse practitioner, indicating that there is a connection between the Veteran's IBS and PTSD.  G.I. cites medical studies in support of her conclusion. 

There is a September 2023 private opinion from F.B., a certified family nurse practitioner, linking the Veteran's GERD to his PTSD.  F.B. lists appropriate medical literature, noting that increased stress can lead to worsening of GERD symptoms.  F.B. also noted that medical literature suggest a significant positive association between reflux symptoms and PTSD.  F.B. concludes that based on the Veteran's history and the medical literature provided, it is highly suggestive that the Veteran's PTSD was a precipitating factor for his GERD. 

A January 2024 private opinion from F.B., a physician assistant, links the Veteran's IBS to his PTSD.  F.B. reviewed the Veteran's medical history and
 of her conclusion. 

There is a September 2023 private opinion from F.B., a certified family nurse practitioner, linking the Veteran's GERD to his PTSD.  F.B. lists appropriate medical literature, noting that increased stress can lead to worsening of GERD symptoms.  F.B. also noted that medical literature suggest a significant positive association between reflux symptoms and PTSD.  F.B. concludes that based on the Veteran's history and the medical literature provided, it is highly suggestive that the Veteran's PTSD was a precipitating factor for his GERD. 

A January 2024 private opinion from F.B., a physician assistant, links the Veteran's IBS to his PTSD.  F.B. reviewed the Veteran's medical history and contentions, and cited various medical studies.  She indicated that there is an overwhelming amount of medical evidence that links IBS to mental health disorders, through common etiology and neurobiological factors such as brain-gut interactions.  

Given the positive and negative opinions of record, the Board finds that the evidence is in approximate balance as to whether the Veteran's GERD and IBS are related to his service-connected PTSD.  Thus, with reasonable doubt resolved in the Veteran's favor, service connection for GERD and IBS secondary to the service-connected PTSD is warranted.  The Veteran's appeal is granted. 38 U.S.C. § 5107(b); 38 C.F.R. § 3.102; Lynch, 999 F.3d at 1391.

 

 

DUSTIN L. WARE

Veterans Law Judge

Board of Veterans' Appeals

Attorney for the Board	Kuksova, Kseniya

The Board's decision in this case is binding only with respect to the instant matter decided. This decision is not precedential and does not establish VA policies or interpretations of general applicability. 38 C.F.R. § 20.1303. 

Gastroesophageal reflux disease (GERD), Granted, 2026: BVA Decision A26026589 | CaseScribe AI