Secondary service connection
Migraine secondary to PTSD: BVA grant rates and what wins
From 2018 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to PTSD in 1,673 decisions. It granted the issue in 37.7% of them, above the 31.3% grant rate for all migraine issues, denied it in 8.2%, and remanded it in 52.8%. Counting only decisions on the merits, 82.0% were granted.
Decisions
1,673
2018–2026
Granted
37.7%
All migraine: 31.3%
Granted on the merits
82.0%
Granted ÷ (granted + denied)
Remanded
52.8%
Denied: 8.2%
See all migraine decisions, direct and secondary.
Migraine secondary to PTSD: outcomes by year
| Year | Decisions | Granted | Denied | Remanded |
|---|---|---|---|---|
| 2018 | 97 | 40.2% | 8.2% | 45.4% |
| 2019 | 164 | 41.5% | 7.9% | 50.0% |
| 2020 | 159 | 39.6% | 10.7% | 48.4% |
| 2021 | 197 | 31.0% | 10.7% | 56.9% |
| 2022 | 162 | 30.9% | 9.3% | 59.9% |
| 2023 | 215 | 34.0% | 7.9% | 57.7% |
| 2024 | 294 | 41.2% | 6.5% | 50.3% |
| 2025 | 286 | 41.6% | 7.3% | 50.7% |
| 2026 | 99 | 36.4% | 7.1% | 55.6% |
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 | 572 | 97.2% | 58.3% | +38.9 pts |
| Private medical opinion | 739 | 91.3% | 66.3% | +25.0 pts |
| Favorable VA exam | 267 | 93.8% | 78.1% | +15.7 pts |
| Combat service | 160 | 86.3% | 81.5% | +4.7 pts |
| Buddy statement | 67 | 85.7% | 81.9% | +3.8 pts |
| Treating physician opinion | 95 | 83.8% | 81.9% | +2.0 pts |
| Lay statement | 1,355 | 79.2% | 95.5% | −16.2 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 73.7% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 28.3% of grants and 13.0% 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 | 1,081 | 79.3% | 87.5% | −8.3 pts |
| Unfavorable VA exam | 1,364 | 80.0% | 93.2% | −13.1 pts |
Why the Board granted or denied migraine
Most common reasons in grants
- Current diagnosis established60
- Caused by the service-connected disability53
- Service connection established50
- Aggravated by the service-connected disability34
- Criteria for service connection met13
- VA examiner: less likely than not related to service11
- No contrary medical opinion of record9
- Secondary to PTSD6
Most common reasons in denials
- VA examiner: less likely than not related to service21
- No in-service complaints, treatment or diagnosis16
- Service records negative or silent11
- Current diagnosis established9
- Preponderance of the evidence against the claim9
- No current diagnosis5
- Continuity of symptomatology since service3
- Caused by the service-connected disability2
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
Private physician's opinion found causal and aggravating relationship between PTSD/tinnitus and migraines.; VA treatment records and co-worker corroborated reports of headaches/migraines.; Resolving doubt in Veteran's favor due to conflicting medical opinions.
Credible testimony of stress-triggered headaches; Consistent with service-connected PTSD/alcohol use disorder; Benefit of the doubt applied
Private opinion linked migraines to tinnitus and PTSD; Opinion cited shared physiological/psychological pathways; No contrary VA opinion on secondary connection
Denied
Service records did not establish chronic headaches or onset during service; Significant gap between separation and first treatment for headaches; Post-service records reflect denial or absence of headaches
No objective evidence of in-service onset or continuity of symptoms.; Multiple negative nexus opinions from VA examiners.; Migraines not listed under Camp Lejeune presumptive conditions.; Correlation between PTSD and migraines, but no causal link to service established.
Headaches did not meet prostrating attack criteria; Evidence persuasively weighs against compensable rating
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 PTSD, 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 (2018–2026) and can contain errors. It is updated automatically as new decisions are added.