Secondary service connection
Migraine secondary to a psychiatric disorder: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to a psychiatric disorder in 1,393 decisions. It granted the issue in 40.7% of them, above the 30.7% grant rate for all migraine issues, denied it in 8.4%, and remanded it in 50.0%. Counting only decisions on the merits, 82.9% were granted.
Decisions
1,393
2017–2026
Granted
40.7%
All migraine: 30.7%
Granted on the merits
82.9%
Granted ÷ (granted + denied)
Remanded
50.0%
Denied: 8.4%
See all migraine decisions, direct and secondary.
Migraine secondary to a psychiatric disorder: outcomes by year
| Year | Decisions | Granted | Denied | Remanded |
|---|---|---|---|---|
| 2017 | 35 | 20.0% | 17.1% | 57.1% |
| 2018 | 109 | 50.5% | 4.6% | 44.0% |
| 2019 | 179 | 55.3% | 8.4% | 36.3% |
| 2020 | 166 | 38.6% | 6.0% | 54.8% |
| 2021 | 129 | 33.3% | 8.5% | 58.1% |
| 2022 | 127 | 33.9% | 10.2% | 54.3% |
| 2023 | 176 | 37.5% | 8.0% | 54.0% |
| 2024 | 196 | 35.7% | 12.2% | 50.5% |
| 2025 | 209 | 41.1% | 7.7% | 50.2% |
| 2026 | 67 | 50.7% | 4.5% | 44.8% |
Evidence in granted and denied migraine decisions
For each kind of supporting evidence: how often the Board granted the migraine 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 | 582 | 95.8% | 58.5% | +37.3 pts |
| Private medical opinion | 707 | 90.9% | 66.2% | +24.7 pts |
| Favorable VA exam | 213 | 93.8% | 79.6% | +14.2 pts |
| Treating physician opinion | 69 | 92.5% | 82.3% | +10.2 pts |
| Buddy statement | 41 | 78.6% | 83.0% | −4.4 pts |
| Lay statement | 1,127 | 80.1% | 95.9% | −15.8 pts |
| Combat service | 59 | 57.7% | 83.9% | −26.2 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 74.1% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 27.3% of grants and 13.7% 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 migraine 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 | 895 | 80.6% | 87.3% | −6.7 pts |
| Unfavorable VA exam | 1,111 | 81.4% | 90.4% | −8.9 pts |
Why the Board granted or denied migraine
Most common reasons in grants
- Caused by the service-connected disability95
- Current diagnosis established69
- Aggravated by the service-connected disability57
- Service connection established32
- Criteria for secondary service connection met8
- Criteria for service connection met7
- VA examiner: less likely than not related to service6
- Supported by medical literature6
Most common reasons in denials
- VA examiner: less likely than not related to service17
- No in-service complaints, treatment or diagnosis9
- Service records negative or silent8
- Preponderance of the evidence against the claim8
- No current diagnosis7
- Aggravated by the service-connected disability5
- Current diagnosis established5
- Caused by the service-connected disability3
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 migraine decisions
Granted
Veteran service connected for generalized anxiety disorder; Veteran's wife provided credible testimony on onset and continuation; Mild cognitive impairment proximately due to generalized anxiety disorder
Migraines found secondary to service-connected acquired psychiatric disability.; Private medical opinion found migraines aggravated by psychiatric condition and treatment.; VA treatment records support aggravation by medication.; Prior VA exam insufficient as it did not address aggravation by psychiatric disorder.
Granted secondary to service-connected psychiatric disorder.; Private opinion found nexus.; No conflicting evidence presented.
Denied
No nexus between headaches and service or TERA; VA opinions found less likely than not related; March 2024 opinion discounted for lack of chronicity evidence; January 2025 opinion inadequate for not addressing obesity as intermediate step
Headaches did not meet prostrating attack criteria; Evidence persuasively weighs against compensable rating
Headaches claimed as secondary to psychiatric disorder.; Psychiatric disorder denied service connection.; Cannot grant secondary claim when primary condition is not service-connected.
Rules that apply to secondary migraine 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 4.124a · DC 8100
Schedule of ratings: neurological conditions
Read it in VA Law Explorer - M21-1 V.iii.12.A.3
Migraine: rating criteria, lay evidence of prostration, headache journals
Read it in VA Law Explorer - M21-1 IV.i.3.B.1.b
Reviewing a headache examination report
Read it in VA Law Explorer
Research your migraine 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 migraine issue claimed as secondary to a psychiatric disorder, 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.