Secondary service connection
Migraine secondary to tinnitus: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to tinnitus in 1,203 decisions. It granted the issue in 34.2% of them, above the 30.7% grant rate for all migraine issues, denied it in 9.7%, and remanded it in 55.2%. Counting only decisions on the merits, 77.8% were granted.
Decisions
1,203
2017–2026
Granted
34.2%
All migraine: 30.7%
Granted on the merits
77.8%
Granted ÷ (granted + denied)
Remanded
55.2%
Denied: 9.7%
See all migraine decisions, direct and secondary.
Migraine secondary to tinnitus: outcomes by year
| Year | Decisions | Granted | Denied | Remanded |
|---|---|---|---|---|
| 2018 | 79 | 53.2% | 11.4% | 31.6% |
| 2019 | 103 | 48.5% | 6.8% | 43.7% |
| 2020 | 76 | 39.5% | 11.8% | 48.7% |
| 2021 | 84 | 25.0% | 16.7% | 57.1% |
| 2022 | 83 | 30.1% | 9.6% | 59.0% |
| 2023 | 110 | 24.5% | 8.2% | 67.3% |
| 2024 | 210 | 29.0% | 9.0% | 61.0% |
| 2025 | 336 | 33.6% | 8.0% | 58.3% |
| 2026 | 106 | 36.8% | 10.4% | 51.9% |
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 | 448 | 96.3% | 41.6% | +54.7 pts |
| Private medical opinion | 586 | 86.3% | 57.4% | +28.9 pts |
| Favorable VA exam | 139 | 95.8% | 73.9% | +21.9 pts |
| Combat service | 48 | 81.8% | 77.7% | +4.2 pts |
| Treating physician opinion | 48 | 75.9% | 78.0% | −2.1 pts |
| Lay statement | 958 | 74.2% | 92.4% | −18.1 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 73.0% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 28.0% of grants and 5.1% 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 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 | 844 | 72.8% | 89.4% | −16.5 pts |
| Unfavorable VA exam | 1,004 | 75.1% | 92.7% | −17.6 pts |
Why the Board granted or denied migraine
Most common reasons in grants
- Caused by the service-connected disability64
- Current diagnosis established47
- Aggravated by the service-connected disability44
- Service connection established26
- Criteria for secondary service connection met7
- VA examiner: less likely than not related to service7
- Private medical opinion found persuasive3
- Granted secondary to tinnitus3
Most common reasons in denials
- VA examiner: less likely than not related to service41
- No in-service complaints, treatment or diagnosis26
- Service records negative or silent17
- Preponderance of the evidence against the claim7
- No current diagnosis6
- Current diagnosis established2
- Caused by the service-connected disability2
- Aggravated 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.
Secondary to service-connected tinnitus; Approximate balance of evidence; Benefit of the doubt applied
Favorable private medical opinion; Migraines proximately due to tinnitus; Resolved doubt in Veteran's favor
Denied
Persuasively weighs against in-service origin; VA examiner opined less likely than not related to service; Service treatment records negative for headaches
Private medical opinion lacked objective rationale and established causation.; VA medical opinions found migraines less likely than not due to tinnitus.; Service treatment records did not establish a causal link.
No in-service complaints, diagnosis, or treatment for headaches.; VA examiner opined less likely than not related to service or TERA.; Medical literature did not support causative relationship between tinnitus/TERA and headaches.; Lay testimony insufficient for complex medical issues.
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 tinnitus, 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.