RHEUMATOID ARTHRITIS

J. PARKER · 2026 · Case ID: A26036931

GRANTED

Summary

The Veteran, who served from April 1995 to April 2000, appeals the denial of service connection for rheumatoid arthritis (RA) as secondary to his service-connected major depressive disorder with anxious distress. The Board found a current diagnosis of RA and acknowledged the service connection for the psychiatric disorder. The central issue was whether the RA was caused or aggravated by the psychiatric condition. The Board determined the evidence was in relative equipoise regarding secondary causation. The Veteran credibly testified that RA symptoms emerged around 2018-2019, with a formal diagnosis in 2020, and that medical advice suggested a link between the psychiatric condition and RA. A private medical opinion from Dr. P.D. was submitted, stating it was at least as likely as not that the RA was etiologically related to the psychiatric disorder. Dr. P.D. cited medical literature discussing the bidirectional relationship between depression and autoimmune diseases, explaining how mental health disorders can trigger physiological processes affecting the immune system. The opinion concluded that the stress from service and the service-connected psychiatric disorder likely activated the Veteran's hypothalamic pituitary-adrenal axis and sympathoadrenal system, leading to immune dysfunction and the current RA. The Board found this opinion probative and, resolving reasonable doubt in the Veteran's favor, granted service connection for rheumatoid arthritis as secondary to the service-connected psychiatric disorder.

Rationale

Current diagnosis of rheumatoid arthritis established.; Service-connected major depressive disorder with anxious distress.; Private medical opinion found RA etiologically related to psychiatric disorder.; Resolving doubt in Veteran's favor.

Special Benefit

NO SPECIAL BENEFIT

Docket No.

210712-172057

Full Decision Text

Citation Nr: A26036931
Decision Date: 04/21/26 Archive Date: 04/21/26

DOCKET NO. 210712-172057
DATE: April 21, 2026

ORDER

Service connection for rheumatoid arthritis as secondary to the service-connected major depressive disorder with anxious distress (psychiatric disorder) is granted.

FINDINGS OF FACT

1. The evidence shows a current diagnosis for rheumatoid arthritis.

2. The current rheumatoid arthritis is etiologically related to the service-connected psychiatric disorder.

CONCLUSION OF LAW

Resolving reasonable doubt in the Veteran's favor, the criteria for service connection for rheumatoid arthritis as secondary to the service-connected major depressive disorder with anxious distress have been met. 38 U.S.C. §§ 1110, 5103, 5103A, 5107; 38 C.F.R. §§ 3.102, 3.159, 3.303, 3.304, 3.310.

REASONS AND BASES FOR FINDINGS AND CONCLUSION

The Veteran, who is the appellant, served on active duty from April 1995 to April 2000.

This appeal is before the Board of Veterans' Appeals (Board) on appeal from an April 2021 Appeals Modernization Act (AMA) rating decision. In the July 2021 VA Form 10182, Decision Review Request: Board Appeal (Notice of Disagreement), the Veteran elected the Hearing docket. A Board hearing was held on March 27, 2025.

Therefore, the Board may only consider the evidence of record at the time of the April 2021 agency of original jurisdiction (AOJ) decision on appeal, as well as any evidence submitted by the Veteran or representative at the hearing or within 90 days following the hearing. 38 C.F.R. § 20.302(a). If evidence was submitted either (1) during the period after the AOJ issued the decision on appeal and prior to the Board hearing, or (2) more than 90 days following the hearing, the Board did not consider it in its decision. 38 C.F.R. §§ 20.300, 20.302(a), 20.801.

Service connection for rheumatoid arthritis

Service connection may be granted for a disability resulting from disease or injury incurred in or aggravated by active service. 38 U.S.C. § 1110; 38 C.F.R. § 3.303(a). Service connection may be granted for any disease diagnosed after 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 generally requires (1) medical evidence of a current disability; (2) medical or, in certain circumstances, lay evidence of in service incurrence or aggravation of a disease or injury; and (3) medical evidence of a nexus between the claimed in service disease or injury and the current disability.

Establishing service connection on a secondary basis requires evidence sufficient to show (1) that a current disability exists and (2) that the current disability was either (a) caused by or (b) aggravated by a service-connected disability. 38 C.F.R. § 3.310(a)-(b). Secondary causation exists when, but for the service-connected disability, the non-service-connected was caused by a service-connected disability either in a direct, etiological way or via multiple steps in a causal chain. Spicer v. McDonough, 61 F.4th 1360, 1365 (Fed. Cir. 2023) (citations omitted). Secondary aggravation exists when the non-service-connected disability not caused by a service-connected disability would be less severe were it not for a service-connected disability. Id. at 1364. For example, secondary aggravation may be established where the natural progression of the non-service-connected disability could have been arrested or improved but for the service-connected disability. Id.

The evidence shows a current diagnosis for rheumatoid arthritis, which is a "chronic" disease under 38 C.F.R. § 3.309(a). Therefore, the presumptive provisions of 38 C.F.R. § 3.303(b) for "chronic" in-service symptoms and "continuous" post service symptoms apply. Walker v. Shinseki, 708 F.3d 1331 (Fed. Cir. 2013).

Where the evidence shows a "chronic disease" in service or "continuity of symptoms" after service, the disease shall be presumed to have been incurred in service. For the showing of "chronic" disease in service, there is required a combination of manifestations sufficient to identify the disease entity, and sufficient observation to establish chronicity at the time. With chronic disease as such in service, subsequent manifestations of the same chronic disease at any later date, however remote, are service-connected, unless clearly attributable to intercurrent causes. If a condition noted during service is not shown to be chronic, then generally, a showing of "continuity of symptoms" after service is required for service connection. 38 C.F.R. § 3.303(b).

Additionally, where a veteran served 90 days or more of active service, and certain chronic diseases, such as arthritis, become manifest to a degree of 10 percent or more within one year after the date of separation from such service, such disease shall be presumed to have been incurred in service, even though there is no evidence of such disease during the period of service. 38 C.F.R. §§ 3.307, 3.309(a). While the disease need not be diagnosed within the presumption period, it must be shown, by acceptable lay or medical evidence, that there were characteristic manifestations of the disease to the required degree during that time. Id.

The Veteran generally appeals for service connection for rheumatoid arthritis (RA) as etiologically related to the service-connected psychiatric disorder. See March 2025 Board hearing transcript. In the April 2021 rating decision on appeal, the AOJ found a current diagnosis of rheumatoid arthritis. The Board is bound by this favorable finding. Additionally, the Board notes that major depressive disorder with anxious distress is a service-connected disability.

The question before the Board is whether the claimed RA was either caused or worsened in severity by the service-connected psychiatric disorder. The Board finds that the evidence is at least in relative equipoise on the question of whether the current RA is secondary to the service-connected psychiatric disorder. 38 C.F.R. § 3.310. The Veteran credibly testified during the March 2025 Board hearing noticing RA symptoms starting to emerge in 2018 or 2019, with a formal diagnosis in 2020. The Veteran testified that doctors have advised that the psychiatric condition could affect RA symptoms, and that the RA symptoms have not further deteriorated since starting treatment for the service-connected psychiatric disorder.

The record includes a March 2025 private medical opinion, in which Dr. P.D. opined it is at least as likely as not that the current RA is etiologically related to the service-connected psychiatric disorder. Dr. P.D. explained that medical literature shows that individuals with mental health disorders have a significantly higher risk of developing an autoimmune disease compared to individuals without mental health disorders. Dr. P.D. cited and discussed several medical articles and studies, including one that specifically discusses the bidirectional relationship between depression and rheumatoid arthritis, which demonstrates how mental health disorders can trigger physiological processes which affect the endocrine, reproductive, digestive, immune, and neurologic systems. Further, Dr. P.D. explained that, in the Veteran's case, it is more likely than not that the stress experienced during active service and continues to experience secondary to the service-connected psychiatric disorder is activating the hypothalamic pituitary-adrenal axis and the sympathoadrenal system, which has resulted in the endocrine and immune system dysfunction that ultimately caused the current RA.

Because Dr. P.D.'s opinion considers the relationship between the claimed RA and the service-connected psychiatric disorder, and because Dr. P.D.'s opinion is premised upon multiple medical studies and is supported by a rationale, the Board finds that Dr. P.D.'s opinion is probative in establishing that the current RA was caused or worsened by the service-connected psychiatric disorder.

Resolving reasonable doubt in the Veteran's favor, the Board finds that the current RA is secondary to the service-connected psychiatric disorder; therefore, the criteria for secondary service connection for RA have been met. 38 U.S.C. § 5107(b); 38 C.F.R. §§ 3.102, 3.310. As
Because Dr. P.D.'s opinion considers the relationship between the claimed RA and the service-connected psychiatric disorder, and because Dr. P.D.'s opinion is premised upon multiple medical studies and is supported by a rationale, the Board finds that Dr. P.D.'s opinion is probative in establishing that the current RA was caused or worsened by the service-connected psychiatric disorder.

Resolving reasonable doubt in the Veteran's favor, the Board finds that the current RA is secondary to the service-connected psychiatric disorder; therefore, the criteria for secondary service connection for RA have been met. 38 U.S.C. § 5107(b); 38 C.F.R. §§ 3.102, 3.310. As service connection is being granted on a secondary basis (38 C.F.R. § 3.310), there is no need to discuss entitlement to service connection on any other basis, as other theories of service connection have been rendered moot, leaving no question of law or fact to decide. See 38 U.S.C. § 7104.

J. PARKER

Veterans Law Judge

Board of Veterans' Appeals

Attorney for the Board E. Choi, Counsel

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.

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