Secondary service connection
Sleep apnea secondary to PTSD: BVA grant rates and what wins
From 2018 to 2026, the Board of Veterans' Appeals decided sleep apnea claimed as secondary to PTSD in 11,186 decisions. It granted the issue in 32.1% of them, above the 26.7% grant rate for all sleep apnea issues, denied it in 13.1%, and remanded it in 53.8%. Counting only decisions on the merits, 71.1% were granted.
Decisions
11,186
2018–2026
Granted
32.1%
All sleep apnea: 26.7%
Granted on the merits
71.1%
Granted ÷ (granted + denied)
Remanded
53.8%
Denied: 13.1%
See all sleep apnea decisions, direct and secondary.
Sleep apnea secondary to PTSD: outcomes by year
| Year | Decisions | Granted | Denied | Remanded |
|---|---|---|---|---|
| 2018 | 660 | 22.6% | 19.2% | 55.9% |
| 2019 | 1,034 | 23.9% | 17.5% | 57.6% |
| 2020 | 1,244 | 22.7% | 18.1% | 58.1% |
| 2021 | 1,182 | 22.7% | 19.5% | 56.9% |
| 2022 | 1,181 | 22.7% | 14.6% | 62.0% |
| 2023 | 1,447 | 31.7% | 10.6% | 56.9% |
| 2024 | 1,935 | 41.5% | 8.1% | 49.6% |
| 2025 | 1,815 | 43.6% | 8.4% | 47.2% |
| 2026 | 688 | 47.8% | 9.3% | 41.6% |
Evidence in granted and denied sleep apnea decisions
For each kind of supporting evidence: how often the Board granted the sleep apnea 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 | 3,787 | 93.5% | 35.7% | +57.9 pts |
| Private medical opinion | 5,104 | 84.6% | 42.5% | +42.1 pts |
| Favorable VA exam | 1,154 | 84.8% | 68.6% | +16.2 pts |
| Buddy statement | 789 | 76.0% | 70.7% | +5.3 pts |
| Treating physician opinion | 631 | 75.8% | 70.7% | +5.0 pts |
| Combat service | 1,166 | 71.6% | 71.0% | +0.6 pts |
| Lay statement | 7,884 | 63.6% | 91.6% | −28.0 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 77.4% of the decisions that granted sleep apnea.
- The Board found the veteran's statements credible in 21.2% of grants and 10.7% 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 sleep apnea 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 | 8,023 | 68.7% | 79.2% | −10.4 pts |
| Unfavorable VA exam | 9,252 | 69.1% | 85.6% | −16.6 pts |
Why the Board granted or denied sleep apnea
Most common reasons in grants
- Current diagnosis established475
- Service connection established327
- Caused by the service-connected disability187
- Aggravated by the service-connected disability116
- VA examiner: less likely than not related to service113
- Service records negative or silent31
- Secondary to PTSD23
- Criteria for secondary service connection met22
Most common reasons in denials
- VA examiner: less likely than not related to service373
- No in-service complaints, treatment or diagnosis257
- Service records negative or silent198
- Preponderance of the evidence against the claim169
- No current diagnosis63
- Current diagnosis established53
- Aggravated by the service-connected disability25
- Caused by the service-connected disability12
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 sleep apnea decisions
Granted
Private medical opinion from treating provider found more probative; Opinion linked sleep apnea to PTSD based on medical literature and Veteran's history; Resolved doubt in Veteran's favor
Current diagnosis of sleep apnea established.; Private physician opinion found at least as likely as not that sleep apnea was directly attributable to long-term consequences of service-connected PTSD and related conditions.; No contrary medical opinion of record.
Current disability (OSA) demonstrated; Service connection for PTSD with persistent depressive disorder and insomnia established; Private medical opinion linked OSA to PTSD based on literature and PTSD symptomology; Private opinion found OSA at least as likely as not due to PTSD; No conflicting medical opinion in record
Denied
Weight of evidence against service connection; VA examiner found sleep apnea less likely than not related to PTSD; Sleep apnea multifactorial, not directly caused by PTSD
No evidence of sleep apnea during service or continuous symptoms; VA examiner opined less likely related to service, more likely due to obesity; Private opinions lacked probative value as they did not apply research to veteran's circumstances
Granted service connection at 50% as secondary to PTSD; Did not meet criteria for rating higher than 50%; Condition required CPAP machine without complications
Rules that apply to secondary sleep apnea 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 4.97 · DC 6847
Schedule of ratings: respiratory system
Read it in VA Law Explorer - M21-1 IV.i.3.B.1.l
Reviewing a sleep disorders examination
Read it in VA Law Explorer
Research your sleep apnea 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 sleep apnea 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.