How the Board ruled on insomnia and sleep disorder claims, 2021–2025

Insomnia / sleep disorder (direct service connection)

Direct (began in or was caused by service), or theory not stated in the Board order

29% granted of 872 decided cases (margin of error 26.1–32.1%). 253 granted, 619 denied, 1,266 sent back to VA (remanded, not decided), 244 dismissed.

What convinced the Board in granted cases

• The Board granted when a medical opinion, private or VA, linked the sleep problem to service or to a service-connected condition, often as the only adequate opinion of record. (7 of 13 decisions read; e.g. 23019046, A23021029, 21049030)
• The Board accepted credible statements from the veteran and family members about sleep trouble starting in service and continuing since, noting that sleep problems can be observed by a layperson. (6 of 13 decisions read; e.g. A21005024, A25034354, 22022062)
• The Board gave little or no weight to VA opinions that gave no rationale, rested on an inaccurate history, or relied on missing treatment records without considering the lay statements. (3 of 13 decisions read; e.g. A21005024, 21049030, 23019046)

Common reasons in denied cases

• Most denials found no current, separate sleep disorder, often because a VA examiner found the insomnia was a symptom of an already service-connected condition such as PTSD, or of sleep apnea. (8 of 12 decisions read; e.g. A24070002, 24031191, 23055216)
• The Board found the veteran's own belief about a diagnosis or its cause was not competent medical evidence, and no medical opinion supported the claim. (3 of 12 decisions read; e.g. A24048877, A24047059, A25012772)
• The Board denied when service records showed no sleep complaints, or when records tied the current insomnia to another cause, such as pain from conditions that are not service connected. (3 of 12 decisions read; e.g. 24002786, 22054093, A23025428)

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Insomnia / sleep disorder secondary to any service-connected condition

Secondary (caused or worsened by a service-connected condition)

49.8% granted of 223 decided cases (margin of error 43.3–56.3%). 111 granted, 112 denied, 432 sent back to VA (remanded, not decided), 21 dismissed.

What convinced the Board in granted cases

• The Board gave high weight to favorable opinions, often private, that considered how the service-connected condition affected the veteran's sleep, sometimes supported by medical literature, especially when no adequate opinion said otherwise. (4 of 10 decisions read; e.g. A25010348, 23011373, A24042071)
• Negative VA opinions lost weight when they addressed only worsening and not causation, ignored the medical literature or in-service symptoms, or did not explain why an earlier favorable opinion was wrong. (3 of 10 decisions read; e.g. A24042071, A22015374, 23011373)
• The Board linked insomnia or sleep apnea to service-connected PTSD, bipolar disorder, tinnitus, back pain or heart disease, sometimes relying on treatment records and credible testimony tying sleep problems to nightmares. (5 of 10 decisions read; e.g. 24027050, 24008839, A24025893)

Common reasons in denied cases

• The most common reason for denial was no separate sleep disability: insomnia was already a symptom counted in a service-connected PTSD or depression rating, or no sleep disorder was diagnosed. (6 of 13 decisions read; e.g. 21071818, 24009344, A25018064)
• Detailed VA opinions found the sleep problem came from other causes, such as anatomy, obesity or work schedules, and no favorable medical opinion rebutted them; the veteran's own view of the cause was not competent. (4 of 13 decisions read; e.g. 21040892, 23058168, 22015477)
• Some secondary claims failed because the underlying condition, such as Parkinson's disease or a psychiatric disorder, was not service-connected. (2 of 13 decisions read, few decisions; e.g. A23010830, 22055698)

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Insomnia / sleep disorder secondary to PTSD

Secondary (caused or worsened by a service-connected condition)

58.1% granted of 43 decided cases (margin of error 43.3–71.6%). 25 granted, 18 denied, 77 sent back to VA (remanded, not decided), 5 dismissed.

What convinced the Board in granted cases

• The Board granted when medical opinions linked the sleep disorder to PTSD, often citing medical literature, and no stronger opinion pointed the other way. (5 of 10 decisions read; e.g. 22050658, A24051200, 21061947)
• Negative VA opinions lost weight when they ignored medical literature, skipped whether PTSD caused the condition, did not address the veteran's own case, or were outnumbered by positive opinions. (3 of 10 decisions read; e.g. A24042071, A24051200, 21061947)

Common reasons in denied cases

• Most denials found no sleep disorder separate from PTSD; the sleep problems were PTSD symptoms already covered by the PTSD rating, so a separate award would double-count them. (8 of 13 decisions read; e.g. 21076501, 23029096, 24009056)
• An unrebutted VA opinion found the sleep condition, usually sleep apnea, was not caused or worsened by PTSD. (3 of 13 decisions read; e.g. 21023108, 22042795, 23017135)
• The veteran's own belief about a sleep diagnosis or its cause was not competent medical evidence. (3 of 13 decisions read; e.g. 21004951, 24009056, 21054936)

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Insomnia / sleep disorder secondary to depression / psychiatric disorder

Secondary (caused or worsened by a service-connected condition)

42.4% granted of 33 decided cases (margin of error 27.2–59.2%). 14 granted, 19 denied, 71 sent back to VA (remanded, not decided), 2 dismissed.

What convinced the Board in granted cases

• The Board granted when a medical opinion explained why the psychiatric condition causes sleep problems, backed by a rationale. In one case a private psychologist cited several medical treatises. (4 of 10 decisions read; e.g. A24047492, 23018391, 24015818)
• The Board granted when the evidence showed the psychiatric condition worsened (aggravated) the sleep disorder, even though the examiner found no direct causation. (2 of 10 decisions read, few decisions; e.g. 24015818, 21045209)

Common reasons in denied cases

• The Board most often denied because the sleep problems were found to be a symptom of the already service-connected psychiatric condition and not a separate diagnosis, usually based on a thorough VA psychologist's opinion. (6 of 14 decisions read; e.g. 23006078, A23005023, 24025704)
• The Board denied when a VA opinion against a link went unrebutted, with no private opinion on the other side. The veteran's own belief was not competent evidence. (4 of 14 decisions read; e.g. 22042795, 21069597, 21011548)
• The Board denied when the depression or other psychiatric condition was not service-connected, so there was nothing for a secondary claim to rest on. (3 of 14 decisions read; e.g. A24009263, 21067449, 22055698)

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Insomnia / sleep disorder secondary to tinnitus

Secondary (caused or worsened by a service-connected condition)

75.8% granted of 33 decided cases (margin of error 59.0–87.2%). 25 granted, 8 denied, 39 sent back to VA (remanded, not decided), 5 dismissed.

What convinced the Board in granted cases

• The Board gave high weight to private opinions with an adequate rationale and cited literature, sometimes over a VA opinion that blamed the insomnia on anxiety instead. (3 of 13 decisions read; e.g. A25023002, A25010348, A25027643)
• Many grants rested on VA examiners' own favorable opinions, often finding that tinnitus at least worsened (aggravated) the insomnia, some citing studies on insomnia in tinnitus patients. (4 of 13 decisions read; e.g. A25007420, A25023419, A25032457)
• The Board credited veterans' consistent statements that ringing in the ears kept them up at night or hurt their sleep quality, sometimes needing medication. (4 of 13 decisions read; e.g. A24061733, A24013485, A25027643)

Common reasons in denied cases

• Thorough VA opinions tied the sleep problems to other causes, such as anxiety, finances, or shipboard work schedules, and were not outweighed. (3 of 7 decisions read; e.g. A25005305, 21023419, 23058168)
• The sleep problems were found to be part of a psychiatric diagnosis such as depression, not a separate insomnia disability, or no insomnia was diagnosed at all. (3 of 7 decisions read; e.g. 21056711, A25030548, A25039085)
• Records showed no complaints of tinnitus-related sleep trouble to providers, and the veteran's own belief about the cause was not enough. (3 of 7 decisions read; e.g. A25005305, 21023419, 23058168)

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Insomnia / sleep disorder secondary to low back (lumbar spine)

Secondary (caused or worsened by a service-connected condition)

Small sample: 14 decided cases, too few for a reliable percentage. 8 granted, 6 denied, 27 sent back to VA (remanded, not decided), 0 dismissed.

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