MIGRAINE

Summary

The veteran, who served from July 2017 to July 2021 and November 2021 to April 2022, including service in Qatar, appeals the denial of service connection for tension headaches (claimed as migraines) and bilateral carpal tunnel syndrome. The veteran contended that his headaches were caused by environmental exposures (TERA) or service-connected tinnitus, while his carpal tunnel syndrome began during service. The Board denied service connection for both conditions. For headaches, the VA examiner opined that they were less likely than not related to service or TERA, citing multifactorial etiology and lack of in-service complaints. The Board found the examiner's opinion competent and probative, noting the medical literature did not support a causative link and lay testimony was insufficient for complex medical issues. For carpal tunnel syndrome, the VA examiner found it less likely than not related to service or TERA, citing no in-service complaints, diagnosis, or documented chronicity, with an onset in 2024. The Board found the examiner's opinion competent and probative, concluding the evidence persuasively weighed against service connection for both conditions. The benefit of the doubt doctrine was not applied as the evidence favored one side.

Rationale

No in-service complaints, diagnosis, or treatment for headaches.; VA examiner opined less likely than not related to service or TERA.; Medical literature did not support causative relationship between tinnitus/TERA and headaches.; Lay testimony insufficient for complex medical issues.

Full Decision Text

Citation Nr: A26032375
Decision Date: 04/08/26	Archive Date: 04/08/26

DOCKET NO. 250210-513232
DATE: April 8, 2026

ORDER

Entitlement to service connection for tension headaches (claimed as migraines headaches) is denied.

Entitlement to service connection for left and right wrist carpal tunnel syndrome is denied.

FINDING OF FACT

1. The evidence is persuasively against finding that the Veteran's headache condition had its onset during his active duty service or within one year after separation from service, or is otherwise related to his active duty service, to include as secondary to service-connected tinnitus or participation in a toxic exposure risk activity (TERA).

2. The evidence is persuasively against finding that the Veteran's right and left carpal tunnel syndrome had its onset during his active-duty service or within one-year post active-duty service; or is otherwise related to his active-duty service, to include as secondary participation in a TERA.

CONCLUSION OF LAW

1. The criteria for entitlement to service connection for migraine headaches have not been met. 38 U.S.C. §§ 1110, 1111, 5107(b); 38 C.F.R. §§ 3.102, 3.303(a), 3.310, 3.317.

2. The criteria for entitlement to service connection for bilateral carpal tunnel syndrome have not been met. 38 U.S.C. §§ 1110, 1111, 5107(b); 38 C.F.R. §§ 3.102, 3.303(a), 3.310, 3.317.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran had active duty service from July 2017 to July 2021 and from November 2021 to April 2022.

The VA Form 10182 deferred the claims for left and right side carpal tunnel syndrome, the claims were addressed in a February 2025 decision that was issued prior to the receipt of the VA Form 10182. Therefore, in interpreting the Veteran's election in the most favorable light, the Board has construed the Veteran's VA Form 10182 to appeal the February 2025 rating decision's adjudication of service connection for left and right carpal tunnel syndrome on the merits. See Terry v. McDonough, 37 Vet. App. 1 (2023).

In the February 2025 VA Form 10182, Decision Review Request: Board Appeal (Notice of Disagreement), the Veteran elected the Evidence Submission docket.

Therefore, the Board may only consider the evidence of record at the time of the January 2025 AOJ decision on appeal addressing headaches, and the February 2025 decision on appeal addressing service connection for carpal tunnel syndrome, as well as any evidence submitted by the Veteran or his representative with, or within 90 days from receipt of, the VA Form 10182. 38 C.F.R. § 20.303. If evidence was submitted either (1) during the period after the AOJ issued the decision on appeal and prior to the date the Board received the VA Form 10182, or (2) more than 90 days following the date the Board received the VA Form 10182, the Board did not consider it in its decision. 38 C.F.R. §§ 20.300, 20.303, 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 claims, considering the new evidence in addition to the evidence previously considered. Id. Specific instructions for filing a Supplemental Claim are included with this decision. 

The Board acknowledges the Veteran's appeal for right knee impairment on the February 2025 VA Form 10182. However, in March 2025, the Board issued a letter explaining that the January 2025 rating decision was a proposed rating reduction, but was not an implementing decision that finalized a reduction, and therefore cannot be appealed. A decision on the merits as to these issues was issued in November 2025; the Veteran has until November 2026 to avail himself of the appeal options attached to that decision. 

Service Connection

Service connection on a direct basis requires (1) competent and credible evidence confirming the Veteran has the claimed disability or at least has since filing the claim; (2) competent and credible evidence of in-service incurrence or aggravation of a relevant disease or injury; and (3) competent and credible evidence of a nexus or link
, in March 2025, the Board issued a letter explaining that the January 2025 rating decision was a proposed rating reduction, but was not an implementing decision that finalized a reduction, and therefore cannot be appealed. A decision on the merits as to these issues was issued in November 2025; the Veteran has until November 2026 to avail himself of the appeal options attached to that decision. 

Service Connection

Service connection on a direct basis requires (1) competent and credible evidence confirming the Veteran has the claimed disability or at least has since filing the claim; (2) competent and credible evidence of in-service incurrence or aggravation of a relevant disease or injury; and (3) competent and credible evidence of a nexus or link between the in-service injury or disease and the current disability.  See Shedden v. Principi, 381 F.3d 1163, 1167 (Fed. Cir. 2004). Service connection may be granted for any disease diagnosed after discharge, when the evidence, including that pertinent to service, establishes that the disease was incurred in service. See 38 U.S.C. § 1113(b); 38 C.F.R. § 3.303(d).    

Service connection may also be granted on a secondary basis for a disability if it is proximately due to or the result of a service-connected disease or injury. 38 C.F.R. § 3.310. Establishing service connection on a secondary basis requires evidence sufficient to show that a current disability exists and that the current disability was either proximately caused by or proximately aggravated by a service-connected disability. Allen v. Brown, 7 Vet. App. 439, 448 (1995).

In determining whether service connection is warranted, the Board shall consider the benefit-of-the-doubt doctrine. 38 U.S.C. § 5107 (b); 38 C.F.R. § 3.102. That is, the claimant is entitled to the benefit of the doubt when the evidence is in "approximate" balance, i.e., "nearly equal," but does not require that the evidence be in exact equipoise. Lynch v. McDonough, 21 F.4th 776 (Fed. Cir. 2021).

A veteran who has a qualifying period of service as defined in paragraph (a)(5) of this section shall be presumed to have been exposed to fine particulate matter during such service, unless there is affirmative evidence to establish that the veteran was not exposed to fine particulate matter during that service. 38 C.F.R. § 3.320(a)(4).

The term "qualifying period of service" means any period of active military, naval, air, or space service in: (i) the Southwest Asia theater of operations during the Persian Gulf War, or (ii) Afghanistan, Syria, Djibouti, or Uzbekistan on or after September 19, 2001, during the Persian Gulf War. 38 C.F.R. § 3.320(a)(5).

The term "Southwest Asia theater of operations" means Iraq, Kuwait, Saudi Arabia, the neutral zone between Iraq and Saudi Arabia, Bahrain, Qatar, the United Arab Emirates, Oman, the Gulf of Aden, the Gulf of Oman, the Persian Gulf, the Arabian Sea, the Red Sea, and the airspace above these locations, as defined in § 3.317(e)(2). 38 C.F.R. § 3.320(a)(6)(i). The term "Persian Gulf War" means August 2, 1990, through date to be prescribed by Presidential proclamation or law, as defined in § 3.2(i). 38 C.F.R. § 3.320(a)(6)(ii).

Service connection for tension headaches (claimed as migraines headaches).

The Veteran contends that his in-service environmental exposures (TERA), and alternatively, his service-connected tinnitus are the cause of his migraine headache disability.

The Veteran's service treatment records do not show in-service complaints, diagnosis, or treatment for headaches. However, the Veteran's records indicate service in Qatar. This triggered VA's obligation to obtain an opinion concerning whether the Veteran's claimed headaches are related to participation in any TERA.

The Veteran submitted an article discussing the prevalence of headaches in patients with subjective tinnitus. 

On examination in October 2024, the Veteran endorsed headaches that had worsened in severity. He reported treating with over the counter ibuprofen. 

In the October 2024 medical opinion, the examiner opined that the Veteran's claimed headache condition was less likely than not related to his active service, to include as a result of participation in TERA. Specifically, the examiner stated the Veteran's tension headaches claimed as migraines are less likely than not related to TERA. The exact cause of tension
 indicate service in Qatar. This triggered VA's obligation to obtain an opinion concerning whether the Veteran's claimed headaches are related to participation in any TERA.

The Veteran submitted an article discussing the prevalence of headaches in patients with subjective tinnitus. 

On examination in October 2024, the Veteran endorsed headaches that had worsened in severity. He reported treating with over the counter ibuprofen. 

In the October 2024 medical opinion, the examiner opined that the Veteran's claimed headache condition was less likely than not related to his active service, to include as a result of participation in TERA. Specifically, the examiner stated the Veteran's tension headaches claimed as migraines are less likely than not related to TERA. The exact cause of tension headaches is not known. However, several factors, such as genetics and environment, are thought to be involved. Muscle contractions in the head and neck are considered a major factor in the development of a tension headaches. Other causes of tension headaches include neck strain, eye strain, temporomandibular jaw disorder, degenerative arthritis in the neck, sleep disorders, anxiety, and depression; as the etiology is multifactorial, the exact etiology could not be determined. Additionally, and for the same reasons, the examiner found the Veteran's tension headaches were less likely than not secondary to tinnitus.

The Veteran can provide competent reports of factual matters of which he has first-hand knowledge, such as experiencing pain in service, reporting to sick call, being placed on limited duty, and undergoing physical therapy. See Washington v. Nicholson, 19 Vet. App. 362, 368 (2005). Lay evidence can be competent and sufficient to establish a diagnosis of a condition when (1) a lay person is competent to identify the medical condition (noting that sometimes the lay person will be competent to identify the condition where the condition is simple, for example a broken leg, and sometimes not, for example, a form of cancer), (2) the lay person is reporting a contemporaneous medical diagnosis, or (3) lay testimony describing symptoms at the time supports a later diagnosis by a medical professional. See Jandreau v. Nicholson, 492 F. 3d 1372 (Fed. Cir. 2007). In such cases, the Board is within its province to weigh that testimony and to make a determination as to whether the evidence supports a finding of service incurrence and continuity of symptomatology sufficient to establish service connection. See Barr v. Nicholson, 21. Vet. App. 303 (2007). Similarly, laypersons are competent to diagnose and provide nexus opinions to some extent, notably where the diagnosis or opinion is not of a complex nature. Id.; see also Davidson v. Shinseki, 581 F.3d 1313 (Fed. Cir. 2009).

The Board finds that the Veteran's tension headaches are not causally related to his military service, to include as due to tinnitus. The evidence shows that the Veteran did not have any complaints, treatment or diagnosis during service. However, the October 2024 VA medical opinion provided rationale that the Veteran's headaches had an unknown etiology, but the medical literature did not support a causative relationship between the Veteran's tinnitus or his participation in TERA and his tension headaches. Thus, the Board finds the VA medical opinion to be competent and probative evidence. Nieves-Rodriguez v. Peake, 22 Vet. App. 295 (2008).

Although lay persons are competent to provide opinions on some medical issues, whether the Veteran's tension headaches were caused by his service is outside the realm of common knowledge of a lay person because it involves complex medical issues that go beyond a simple and immediately observable cause-and-effect relationship. See Kahana v. Shinseki, 24 Vet. App. 428 (2011); Jandreau, 492 F.3d. at 1377 n.4.

To the extent that the Veteran contended, in his March 2025 appeal brief, that service connection is warranted on the basis of aggravation from a service-connected condition, the argument was prior to the rating decision on appeal. Therefore, the AOJ did not commit a duty to assist error by not asking the VA examiner to address this argument in the October 2024 opinion. Further, while the Board acknowledges the submitted article concerning the prevalence of different types of headache in patients with subjective tinnitus, the article's thesis addressed the influence of headaches on tinnitus symptoms; here, the Veteran is contending that his tinnitus caused or aggravated his headaches. Further, the study discussed used a population of 286 patients in the general public and was not focused on veterans, let alone a subtype of veterans with environmental exposures. Finally, the article does not address the causation or aggravation of this particular Veteran's headaches and is therefore less than prob
 the rating decision on appeal. Therefore, the AOJ did not commit a duty to assist error by not asking the VA examiner to address this argument in the October 2024 opinion. Further, while the Board acknowledges the submitted article concerning the prevalence of different types of headache in patients with subjective tinnitus, the article's thesis addressed the influence of headaches on tinnitus symptoms; here, the Veteran is contending that his tinnitus caused or aggravated his headaches. Further, the study discussed used a population of 286 patients in the general public and was not focused on veterans, let alone a subtype of veterans with environmental exposures. Finally, the article does not address the causation or aggravation of this particular Veteran's headaches and is therefore less than probative in this case. The Board is capable of evaluating the probative value of this medical evidence as it does not require medical training to assess its content. See, e.g., Harvey v. Shulkin, 30 Vet. App. 10, 20 (2018) (holding that the Board may weigh and evaluate medical treatise evidence).

In summary, the evidence of record persuasively weighs against the claim for entitlement to service connection for tension headaches. 38 U.S.C. § 5107(b). Thus, the benefit of the doubt doctrine is not for application. See Lynch v. McDonough, 21 F.4th 776 (Fed. Cir. 2021). The appeal is denied.

Entitlement to service connection for left and right carpal tunnel syndrome.

The Veteran contends that he has bilateral carpal tunnel syndrome that began during active duty service. 

The Veteran's service treatment records do not reflect any complaints, treatment, or diagnosis of carpal tunnel syndrome or another wrist condition.

On examination in January 2025, the examiner indicated a 2024 diagnosis for left and right carpal tunnel syndrome. The Veteran reported experiencing bilateral numbness and tingling that has progressed. He indicated that he has sought treatment with VA providers and uses a wrist brace regularly.

In the accompanying medical opinion, the examiner explained that carpal tunnel syndrome occurs when the median nerve the wrist is squeezed or compressed, as risk factors include repetitive motion, injury, and inflammation, it is a multifactorial condition typically arising from a combination of patient-specific, occupational, social, and environmental factors. Therefore, a single, specific cause is usually not identified unless a clear physical finding directly explains the patient's symptoms. It was therefore the examiner's opinion that carpal tunnel syndrome was less likely than not related to any participation in TERA, and less likely than not directly related to military service because the onset of diagnosis was 2024 according to EMG studies, and there is no documented chronicity of treatment or symptoms during active duty. 

The Board finds that the Veteran's left and right side carpal tunnel syndrome is not causally related to his military service, to include as due to participation in TERA. The evidence shows that the Veteran did not have any complaints, treatment or diagnosis during service. The January 2025 VA medical opinion provided rationale that the Veteran's carpal tunnel syndrome had an unknown etiology, but the evidence did not support a causative relationship between the Veteran's service. Thus, the Board finds the VA medical opinion to be competent and probative evidence. Nieves-Rodriguez v. Peake, 22 Vet. App. 295 (2008).

In summary, the evidence of record persuasively weighs against the claim entitlement to service connection for left and right carpal tunnel syndrome. The appeal is denied. In reaching the conclusions stated above, the Board has considered the applicability of the benefit of the doubt doctrine.  As the evidence persuasively favors one side or the other, the doctrine is not for application.  See Lynch, supra; 38 U.S.C. § 5107; 38 C.F.R. § 3.102.

 

 

J. Kirby

Veterans Law Judge

Board of Veterans' Appeals

Attorney for the Board	M. E. Lee

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.