Secondary service connection
Migraine secondary to TBI: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to TBI in 532 decisions. It granted the issue in 34.8% of them, above the 30.7% grant rate for all migraine issues, denied it in 18.4%, and remanded it in 45.9%. Counting only decisions on the merits, 65.4% were granted.
Decisions
532
2017–2026
Granted
34.8%
All migraine: 30.7%
Granted on the merits
65.4%
Granted ÷ (granted + denied)
Remanded
45.9%
Denied: 18.4%
See all migraine decisions, direct and secondary.
Migraine secondary to TBI: outcomes by year
| Year | Decisions | Granted | Denied | Remanded |
|---|---|---|---|---|
| 2017 | 21 | 23.8% | 14.3% | 52.4% |
| 2018 | 34 | 35.3% | 17.6% | 44.1% |
| 2019 | 66 | 27.3% | 25.8% | 47.0% |
| 2020 | 64 | 32.8% | 23.4% | 43.8% |
| 2021 | 48 | 25.0% | 25.0% | 45.8% |
| 2022 | 62 | 32.3% | 25.8% | 43.5% |
| 2023 | 67 | 32.8% | 10.4% | 56.7% |
| 2024 | 87 | 40.2% | 10.3% | 49.4% |
| 2025 | 53 | 50.9% | 17.0% | 32.1% |
| 2026 | 30 | 43.3% | 13.3% | 40.0% |
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 |
|---|---|---|---|---|
| Favorable VA exam | 134 | 88.8% | 49.1% | +39.7 pts |
| Positive nexus opinion | 140 | 87.3% | 49.7% | +37.6 pts |
| Combat service | 68 | 76.2% | 63.5% | +12.7 pts |
| Private medical opinion | 167 | 68.5% | 63.4% | +5.1 pts |
| Lay statement | 458 | 64.8% | 69.7% | −4.9 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 72.4% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 39.5% of grants and 10.2% 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 | 313 | 62.2% | 69.7% | −7.6 pts |
| Unfavorable VA exam | 427 | 62.6% | 79.2% | −16.6 pts |
Why the Board granted or denied migraine
Most common reasons in grants
- Caused by the service-connected disability16
- Current diagnosis established15
- Service connection established9
- Criteria for service connection met4
- Service connection granted4
- Headaches linked to service-connected TBI3
- Secondary to TBI3
- Criteria for secondary service connection met2
Most common reasons in denials
- Preponderance of the evidence against the claim14
- No in-service complaints, treatment or diagnosis8
- No current diagnosis6
- Service records negative or silent6
- VA examiner: less likely than not related to service6
- Service connection established2
- Migraines granted secondary to TBI2
- TBI not service-connected2
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
Severance of migraine headaches was improper; Secondary to restored TBI
Headaches are a residual of in-service TBI.; Criteria for secondary service connection met.
RO granted service connection for TBI, headaches secondary to TBI, and head scars as residuals of TBI.; Board is bound by favorable findings from RO.; Entitlement to service connection for headaches is granted.
Denied
Headaches did not meet prostrating attack criteria; Evidence persuasively weighs against compensable rating
Underlying TBI residuals claim denied; No direct service connection asserted for migraines; Migraines diagnosed post-service, not linked to TBI residuals
Primary TBI claim denied; No credible evidence of in-service TBI
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 TBI, 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.