Secondary service connection
Hypertension secondary to sleep apnea: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided hypertension claimed as secondary to sleep apnea in 567 decisions. It granted the issue in 24.2% of them, above the 17.6% grant rate for all hypertension issues, denied it in 14.8%, and remanded it in 60.0%. Counting only decisions on the merits, 62.0% were granted.
Decisions
567
2017–2026
Granted
24.2%
All hypertension: 17.6%
Granted on the merits
62.0%
Granted ÷ (granted + denied)
Remanded
60.0%
Denied: 14.8%
See all hypertension decisions, direct and secondary.
Hypertension secondary to sleep apnea: outcomes by year
| Year | Decisions | Granted | Denied | Remanded |
|---|---|---|---|---|
| 2017 | 26 | 23.1% | 34.6% | 30.8% |
| 2018 | 36 | 33.3% | 16.7% | 47.2% |
| 2019 | 49 | 26.5% | 16.3% | 57.1% |
| 2020 | 60 | 16.7% | 16.7% | 66.7% |
| 2021 | 79 | 16.5% | 17.7% | 65.8% |
| 2022 | 64 | 21.9% | 14.1% | 64.1% |
| 2023 | 78 | 21.8% | 10.3% | 67.9% |
| 2024 | 77 | 26.0% | 7.8% | 63.6% |
| 2025 | 71 | 36.6% | 12.7% | 50.7% |
| 2026 | 27 | 22.2% | 18.5% | 59.3% |
Evidence in granted and denied hypertension decisions
For each kind of supporting evidence: how often the Board granted the hypertension issue on the merits when the decision mentioned it, compared with decisions that did not. These are associations, not causes, and evidence is recorded per decision, not per issue.
| In the record | Decisions | Granted when present | When absent | Difference |
|---|---|---|---|---|
| Positive nexus opinion | 158 | 87.5% | 35.8% | +51.7 pts |
| Favorable VA exam | 72 | 90.2% | 53.5% | +36.7 pts |
| Private medical opinion | 251 | 69.4% | 50.6% | +18.8 pts |
| Lay statement | 403 | 51.3% | 88.9% | −37.6 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 85.4% of the decisions that granted hypertension.
- The Board found the veteran's statements credible in 16.8% of grants and 7.1% of denials.
Negative evidence in the record
An unfavorable exam or a negative nexus opinion often sits in the same record as favorable evidence, and the Board weighs them against each other. So these rows show how often hypertension was still granted when the record contained the negative item, not that the item helped.
| In the record | Decisions | Granted when present | When absent | Difference |
|---|---|---|---|---|
| Negative nexus opinion | 373 | 56.1% | 78.9% | −22.8 pts |
| Unfavorable VA exam | 447 | 56.9% | 90.9% | −34.0 pts |
Why the Board granted or denied hypertension
Most common reasons in grants
- Current diagnosis established17
- Caused by the service-connected disability14
- Service connection established14
- VA examiner: less likely than not related to service5
- Aggravated by the service-connected disability3
- Veteran diagnosed with hypertension3
- Secondary to sleep apnea2
- Hypertension secondary to OSA2
Most common reasons in denials
- VA examiner: less likely than not related to service16
- No in-service complaints, treatment or diagnosis9
- Service records negative or silent7
- Current diagnosis established5
- Aggravated by the service-connected disability4
- Preponderance of the evidence against the claim3
- No continuity of symptomatology3
- Continuity of symptomatology since service3
Numbers are decisions that gave the reason. Reasons are short phrases extracted by AI from each decision; common wordings of the same reason are grouped. Benefit of the doubt is reported above.
Recent hypertension decisions
Granted
May 2023 private opinion by treating doctor found hypertension related to OSA and noted onset during service.; Previous VA opinions were inadequate due to inconsistencies or lack of nexus.; Benefit of the doubt applied in favor of the veteran.
Current diagnosis of hypertension supported by VA treatment records and VA examination.; Private medical opinion found hypertension caused/aggravated by PTSD and sleep apnea.; VA opinion lacked explanation and did not consider sleep apnea connection.
VA opinions did not address secondary theory of OSA aggravation.; Private opinion highly probative; detailed rationale on OSA mechanisms linking to cardiovascular disease.; Evidence in approximate balance; benefit of doubt applied.
Denied
No in-service onset or treatment for hypertension; Hypertension diagnosis predated OSA diagnosis; Private opinion lacked probative value due to timeline and chronic pain rationale; March 2025 VA examiner could not establish baseline severity for aggravation claim; May 2025 VA examiner found less likely than not related to right ankle disability
Current diagnosis of hypertension; No evidence of in-service chronic symptoms or prolonged duration; Symptoms did not manifest within one year of service separation; Veteran not obese, negating secondary theory via obesity; Private opinion linking sleep apnea to hypertension denied as sleep apnea itself is not service-connected
No competent medical evidence linking hypertension to sleep apnea; VA opinion found probative and persuasive; Veteran's lay assertion of causation is not competent medical evidence
Rules that apply to secondary hypertension claims
- 38 CFR 3.310
Secondary service connection and aggravation
Read it in VA Law Explorer - M21-1 V.ii.2.D
Secondary service connection and aggravation of non-service-connected disabilities
Read it in VA Law Explorer - 38 CFR 3.102
Reasonable doubt (benefit of the doubt)
Read it in VA Law Explorer - 38 CFR 4.104 · DC 7101
Schedule of ratings: cardiovascular system
Read it in VA Law Explorer - M21-1 V.iii.5.3
Hypertension: definitions, blood pressure readings required, predominant blood pressure
Read it in VA Law Explorer - M21-1 V.iii.11.2.e
When hypertension is or is not a complication of diabetes
Read it in VA Law Explorer
Research your hypertension case
Narrow by year, judge, evidence or secondary condition, read the decisions, and export a research memo.
How these numbers are calculated
- Counts decisions in which the Board decided a hypertension issue claimed as secondary to sleep apnea, by the outcome of that issue.
- The primary disability is read from the decision text ("secondary to …") and grouped by name, so spellings such as "PTSD" and "posttraumatic stress disorder" count together.
- Secondary claims also include aggravation of a non-service-connected condition by a service-connected one (38 CFR 3.310(b)).
- The data comes from CaseScribe's AI extraction of public BVA decisions (2017–2026) and can contain errors. It is updated automatically as new decisions are added.