GASTROESOPHAGEAL REFLUX DISEASE (GERD)

Summary

The Veteran, an Army Veteran who served from September 7, 2005, to January 17, 2009, appeals the denial of service connection for gastroesophageal reflux disease (GERD), claiming it is secondary to his service-connected posttraumatic stress disorder (PTSD). The Board reviewed the evidence of record at the time of the last agency decision. The Veteran's service treatment records showed no complaints or treatment for GERD during service. Post-service VA treatment records indicated denial of GERD symptoms until April 2024, when the Veteran reported persistent GERD symptoms, including chest pain, vomiting, and difficulty swallowing, which he attributed to the high stress of his PTSD. However, the Board found no competent medical evidence linking the GERD to PTSD. The Veteran's own assertion of a nexus was deemed insufficient, as he is not a medical expert. While the Board acknowledged the low threshold for indicating a potential association between a current disability and a service-connected condition under McLendon v. Nicholson, it found the evidence lacking. The medical records did not indicate a nexus, and the Veteran's subjective reports lacked specific observations linking his GERD to PTSD. Therefore, the Board denied service connection for GERD as secondary to PTSD, finding the evidence persuasively weighed against the claim and the benefit of the doubt doctrine inapplicable. The claim was denied.

Rationale

No in-service complaints or treatment for GERD.; Post-service VA records show denial of GERD symptoms until April 2024.; Veteran's assertion of nexus to PTSD is not medically competent.; No competent medical evidence links GERD to PTSD.; Evidence persuasively weighs against secondary service connection.

Full Decision Text

Citation Nr: A26036828
Decision Date: 04/21/26	Archive Date: 04/21/26

DOCKET NO. 250915-586563
DATE: April 21, 2026

ORDER

Entitlement to service connection for gastroesophageal reflux disease (GERD), to include as secondary to service-connected posttraumatic stress disorder (PTSD),   is denied.

FINDING OF FACT

The evidence of record persuasively weighs against finding that the Veteran's gastroesophageal reflux disease (GERD) is secondary to service-connected PTSD; or is otherwise related to an in-service injury or disease.

CONCLUSION OF LAW

The criteria for service connection for gastroesophageal reflux disease (GERD) are not met.  38 U.S.C. §§ 1110, 1131, 5107; 38 C.F.R. §§ 3.102, 3.310.

REASONS AND BASES FOR FINDING AND CONCLUSION

The Veteran served on active duty in the United States Army from September 7, 2005 to January 17, 2009.

This matter comes before the Board of Veterans' Appeals (Board) on appeal from an October 2024 rating decision of the Department of Veterans Affairs (VA) Regional Office (RO).

In the September 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 October 2024 agency of original jurisdiction (AOJ) decision 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. 

Entitlement to service connection for gastroesophageal reflux disease (GERD)

The Veteran seeks entitlement to service connection for gastroesophageal reflux disease (GERD). Specifically, the Veteran contends that his symptoms are secondary to his service-connected posttraumatic stress disorder. 

Service connection may be granted for any current disability that is the result of a disease contracted or an injury sustained in the line of duty during active military service. 38 U.S.C. § 1110; 38 C.F.R. § 3.303 (a). 

Service connection on a direct basis generally requires evidence of three elements: (1) a current disability; (2) in-service incurrence or aggravation of a disease or injury; and (3) a causal relationship or nexus between the current disability and the disease or injury incurred or aggravated during active service. Shedden v. Principi, 381 F.3d 1163, 1166-67 (Fed. Cir. 2004).

Service connection may be established on a secondary basis for a disability which is due to or the result of service-connected disease or injury. 38 C.F.R. § 3.310(a).  Establishing service connection on a secondary basis requires (1) evidence of a current nonservice-connected disability; (2) evidence of a service-connected disability; and (3) evidence establishing that the service-connected disability either (a) caused, or (b) aggravated, the nonservice-connected disability. 38 C.F.R. § 3.310. Allen v. Brown, 7 Vet. App. 439, 448 (1995) (en banc); see also Spicer v. McDonough, No. 2022-1239 (Fed. Cir. March 8, 2023) (invalidating the requirement of "proximate cause" and instead held a "but for" causation or aggravation is enough to show entitlement to secondary service connection).

When there is an approximate balance of positive and negative evidence regarding any issue material to the determination of a matter, the Secretary shall resolve all reasonable doubt in favor of the claimant. 38 U.S.C. § 5107(b); Gilbert v. Derwinski, 1 Vet. App. 49, 53 (1990); 38 C.F.R. § 3.102. This standard does not require the evidence to be exactly equal; rather, it includes "
2-1239 (Fed. Cir. March 8, 2023) (invalidating the requirement of "proximate cause" and instead held a "but for" causation or aggravation is enough to show entitlement to secondary service connection).

When there is an approximate balance of positive and negative evidence regarding any issue material to the determination of a matter, the Secretary shall resolve all reasonable doubt in favor of the claimant. 38 U.S.C. § 5107(b); Gilbert v. Derwinski, 1 Vet. App. 49, 53 (1990); 38 C.F.R. § 3.102. This standard does not require the evidence to be exactly equal; rather, it includes "scenarios where the evidence is not in equipoise but nevertheless is in approximate balance. Put differently, if the positive and negative evidence is in approximate balance (which includes but is not limited to equipoise), the claimant receives the benefit of the doubt." Lynch v. McDonough, 21 F.4th 776 (Fed. Cir. 2021).

Turning to the evidence of record, the Veteran's service treatment records contain no complaints or treatment of GERD or GERD symptoms. At post-deployment medical examinations in September 2007 and January 2008, the Veteran denied vomiting or frequent indigestion, and no referrals for GI treatment was indicated.

After separation from service, VA treatment records indicate that the Veteran denied heartburn and reflux in June 2009. In June 2017, the Veteran denied nausea, vomiting, regurgitation, or dysphagia. VA treatment records indicate the first complaints of GERD symptoms in April 2024. The occasional GERD with symptom onset approximately four months prior, as well as additional lower GI symptoms, such as upset stomach, bloating, abdominal pain, and burning with certain foods. The Veteran was diagnosed with "gastritic upset" and prescribed omeprazole. 

In an August 2024 statement, the Veteran endorsed symptoms of chest pain, vomiting, difficulty swallowing, and regurgitation. He reported taking daily medication for these symptoms. He asserted that these symptoms had their onset post-service, while he was seeking treatment for his service-connected PTSD and trialing medications for that condition. He contends that the symptoms are related to the "high stress" of his PTSD symptoms but also stated that the symptoms are most prominent during his "time of resting." 

The claims file contains no further evidence regarding the nature and etiology of the claimed disability.

The Board notes that the Veteran has not asserted entitlement to service connection on a direct basis, and the record does not reasonably raise the existence of a direct nexus to an in-service event, disease, or injury. The Veteran explicitly contends that his GERD symptoms began after separation from service and are secondary to his PTSD. Therefore, the Board's adjudication will only address entitlement to service connection on a secondary basis. 

Having considered the above, the Board finds that the evidence of record persuasively weighs against finding that the Veteran's GERD is secondary to service-connected posttraumatic stress disorder.

As an initial matter, the Board notes that the Veteran is currently service connected for irritable bowel syndrome (IBS) as secondary to PTSD. Therefore, the Board will restrict its inquiry to evidence regarding the specifically claimed condition of GERD or other conditions of the esophagus, which involve dysphagia and related symptoms. See Diagnostic Code 7206. Other gastrointestinal symptoms, such as upset stomach, bloating, and abdominal pain, are covered by the award of service connection for IBS.  

To that end, VA treatment records indicate that the Veteran reported GERD symptoms in April 2024. Additionally, the Veteran has been service-connected for PTSD since October 13, 2010. Therefore, the first two elements of secondary service connection are satisfied. 

However, the claims file contains no competent evidence of record indicating a relationship between the two conditions. While the Veteran believes that the claimed GERD symptoms are due to or the result of his PTSD, the Veteran is not competent to provide a nexus opinion regarding this issue. The issue is medically complex, as it requires knowledge of the interaction between multiple organ systems in the body, and the record does not show that the Veteran has the skills or medical training to make such a determination. Jandreau v. Nicholson, 492 F.3d 1372, 1377 n.4 (Fed. Cir. 2007); see also Kahana v. Shinseki, 24. Vet. App. 428 (2011). There is no evidence from a medical provider endorsing a nexus between the Veteran's GERD and his PTSD. The appointment notes from the treating medical provider do not attribute the Veteran's symptoms to his PTSD, and there are no medical opinions endorsing a relationship between the two conditions.
 issue is medically complex, as it requires knowledge of the interaction between multiple organ systems in the body, and the record does not show that the Veteran has the skills or medical training to make such a determination. Jandreau v. Nicholson, 492 F.3d 1372, 1377 n.4 (Fed. Cir. 2007); see also Kahana v. Shinseki, 24. Vet. App. 428 (2011). There is no evidence from a medical provider endorsing a nexus between the Veteran's GERD and his PTSD. The appointment notes from the treating medical provider do not attribute the Veteran's symptoms to his PTSD, and there are no medical opinions endorsing a relationship between the two conditions.  

To that end, the Board notes that the Veteran has not been provided with a VA examination in connection with this claim. However, the Board finds that such an examination is not necessary to render a decision under the circumstances of this case.

Pursuant to McLendon v. Nicholson, in disability compensation claims, VA must provide a VA medical examination when there is (1) competent evidence of a current disability or persistent or recurrent symptoms of a disability, and (2) evidence establishing that an event, injury, or disease occurred in service or establishing certain diseases manifesting during an applicable presumptive period for which the claimant qualifies, and (3) an indication that the disability or persistent or recurrent symptoms of a disability may be associated with the Veteran's service or with another service-connected disability, but (4) insufficient competent medical evidence on file for the Secretary to make a decision on the claim. McLendon v. Nicholson, 20 Vet. App. 79 (2006).

Here the Board finds that the first McLendon element, evidence of a current disability or persistent or recurrent symptoms of a disability, is satisfied due to the Veteran's reports of persistent GERD symptoms. The Board also finds that the Veteran's service-connected condition of PTSD is sufficient to satisfy the second element.

The third McLendon element requires an indication that the current disability may be related to the service-connected disability. The Court of Appeals of Veteran's Claims (CAVC) has held that the requirement that a disability "may be associated" with a service-connected disability is a "low threshold" standard. McLendon, 20 Vet. App. at 83. "The types of evidence that 'indicate' that a current disability 'may be associated' with military service include, but are not limited to, medical evidence that suggests a nexus but is too equivocal or lacking in specificity to support a decision on the merits, or credible evidence of continuity of symptomatology such as pain or other symptoms capable of lay observation." McLendon, 20 Vet. App. at 83. 

The Board acknowledges that the evidentiary threshold necessary to satisfy this requirement is low. However, the Board finds that the claims file lacks the requisite evidence indicating an association between the Veteran's GERD symptoms and his PTSD. The medical evidence of record does not indicate a nexus between the two conditions. The sole supporting evidence of a nexus is the Veteran's August 2024 statement. However, the Veteran does not provide any observations to support his assertions, such as reports that the timing of his GERD symptoms correspond with times of high stress. The Veteran's pure assertions of a nexus are too intangible to meet even the "low threshold" standard of procuring a VA examination and/or opinion under McLendon. Thus, the third element of McLendon is not satisfied, and a remand is not warranted for a VA examination regarding sleep apnea. 38 U.S.C. § 5103A(d); McLendon, 20 Vet. App. at 82-83; 38 C.F.R. § 3.159(c)(4).

Consequently, the Board finds that the probative evidence of record is persuasively against a finding that the Veteran's GERD is caused or aggravated by a service-connected disability. Accordingly, the claim for service connection for GERD is denied.

In denying the claim, the Board has considered the applicability of the benefit of the doubt doctrine. However, as the evidence persuasively weighs against the claim, that doctrine is not applicable. 38 U.S.C. § 5107; see Lynch, 21 F.4th at 781; 38 C.F.R. § 3.102.

 

JONATHAN B. KRAMER

Veterans Law Judge

Board of Veterans' Appeals

Attorney for the Board	Utter, Margaret M.

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.