How the Board ruled on migraine and headache claims, 2021–2025

Migraine / headaches (direct service connection)

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

59.5% granted of 2,930 decided cases (margin of error 57.7–61.2%). 1,742 granted, 1,188 denied, 3,950 sent back to VA (remanded, not decided), 635 dismissed.

What convinced the Board in granted cases

• The Board gave little or no weight to negative VA opinions that ignored the veteran's reports of headaches since service, overlooked in-service records, gave no rationale, or skipped the secondary theory. (5 of 12 decisions read; e.g. A24061623, 21004943, A25002335)
• A favorable medical opinion, private or VA, carried the claim when it reviewed the record and gave a clear, reasoned explanation of the link. (4 of 12 decisions read; e.g. 22016092, 23017354, 23055111)
• Most grants also relied on in-service headache complaints plus credible statements from the veteran or family that headaches continued after service. (7 of 12 decisions read; e.g. 22049087, A25002335, 21056435)

Common reasons in denied cases

• The Board denied when a VA examiner gave a detailed, record-based opinion against a link, and the veteran's belief that the headaches were the same was not competent medical evidence. (3 of 8 decisions read; e.g. 21063027, 21054533, 21075909)
• Claims failed when service records showed no chronic headache problem, the first diagnosis came many years later, or later records contradicted the reported continuity. (4 of 8 decisions read; e.g. A25027795, 21054533, 21075909)
• Some claims failed because there was no current diagnosed headache disability, and the veteran could not diagnose one himself. (3 of 8 decisions read; e.g. 21017611, A24010738, A21003033)

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Migraine / headaches (exposure claims)

Exposure (e.g. Agent Orange, Camp Lejeune, burn pits)

31.5% granted of 73 decided cases (margin of error 22.0–42.9%). 23 granted, 50 denied, 147 sent back to VA (remanded, not decided), 9 dismissed.

What convinced the Board in granted cases

• Most grants rested on a VA examiner's own favorable opinion, often a Gulf War or toxic-exposure exam, supported by medical literature or the veteran's credible history. (6 of 12 decisions read; e.g. A25038433, 24000636, 22047891)
• Credible, consistent reports of headaches that began in or soon after service and continued afterward supported the grant. (5 of 12 decisions read; e.g. 21020352, A21004810, 24000636)
• Negative VA opinions lost weight when they resorted to speculation without explaining why, or wrongly said there was no headache diagnosis. (2 of 12 decisions read, few decisions; e.g. 24003674, 22035810)

Common reasons in denied cases

• A thorough VA opinion found no link between the headaches and the exposure, often citing no known scientific association, and no other medical opinion rebutted it. (8 of 13 decisions read; e.g. 21031746, 21035980, 21056677)
• The veteran's own belief that exposure caused the headaches was not competent medical evidence. (5 of 13 decisions read; e.g. 21056677, 21063144, 21072920)
• Service records were silent or showed only a brief episode, or the headaches were tied to another cause such as a post-service accident or a non-service-connected condition. (5 of 13 decisions read; e.g. 21023489, 24026155, 21046956)

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Migraine / headaches secondary to any service-connected condition

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

65.4% granted of 684 decided cases (margin of error 61.7–68.8%). 447 granted, 237 denied, 1,289 sent back to VA (remanded, not decided), 48 dismissed.

What convinced the Board in granted cases

• The Board gave significant weight to private opinions that reviewed the file, interviewed the veteran, cited medical literature applied to this veteran, and explained how the service-connected condition caused or worsened the headaches. (6 of 12 decisions read; e.g. A21010717, 21042390, 21026252)
• The Board gave little or no weight to VA opinions that addressed only causation or only aggravation, ignored in-service headache records, were conclusory, or used the wrong standard without a full rationale. (4 of 12 decisions read; e.g. A21010717, A24050708, A24070866)
• The Board credited the veteran's own consistent accounts of headache symptoms and their onset, including reports made to treating doctors. (3 of 12 decisions read; e.g. A25008394, A24001578, 21026252)

Common reasons in denied cases

• Most denials had no medical opinion linking the headaches to a service-connected condition; the veteran's own belief about the cause was not competent medical evidence. (8 of 12 decisions read; e.g. 22052788, 24015750, A21017178)
• The Board relied on VA opinions against a link that reviewed the history and explained their reasoning, where no contrary opinion was offered. (4 of 12 decisions read; e.g. 21014585, 21074448, 21011344)
• The Board gave little weight to general medical articles not tied to the veteran's own case, and to a private opinion linking headaches to a condition that was not service connected. (2 of 12 decisions read, few decisions; e.g. 23053260, A21011282)

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Migraine / headaches secondary to PTSD

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

75.7% granted of 115 decided cases (margin of error 67.1–82.6%). 87 granted, 28 denied, 191 sent back to VA (remanded, not decided), 10 dismissed.

What convinced the Board in granted cases

• The Board credited opinions that explained how PTSD causes or worsens headaches (stress as a main trigger, the body's stress-hormone response) and backed this with medical studies. (8 of 19 decisions read; e.g. A24049208, 24000777, 22049495)
• Private opinions were given high weight when they reviewed the entire record, addressed both cause and worsening, and gave a logical, well-reasoned rationale. (6 of 19 decisions read; e.g. 22049495, A24025215, 21027551)
• Negative VA opinions lost weight when they gave no rationale on PTSD, relied only on when headaches started or on PTSD records not mentioning headaches, missed later records, or contradicted themselves. (6 of 19 decisions read; e.g. 24015391, A24049208, A25029164)

Common reasons in denied cases

• A VA opinion applied to the veteran's own records found PTSD did not cause or worsen the headaches, and no medical opinion of equal weight rebutted it; a general article alone was given less weight. (6 of 14 decisions read; e.g. 21014585, 21021611, A24031444)
• The Board found no current headache disorder diagnosed apart from other conditions. (4 of 14 decisions read; e.g. 21076777, 21028845, A24010282)
• The records pointed to a different start or cause, such as head injuries after service or repeated denials of headaches in treatment records. (4 of 14 decisions read; e.g. 22049001, 23056278, A25001579)

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Migraine / headaches secondary to depression / psychiatric disorder

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

72% granted of 93 decided cases (margin of error 62.2–80.1%). 67 granted, 26 denied, 118 sent back to VA (remanded, not decided), 5 dismissed.

What convinced the Board in granted cases

• The Board credited private or VA opinions, backed by medical literature, explaining that psychiatric stress can trigger or worsen migraines. (5 of 10 decisions read; e.g. 21042390, A24042172, 22000108)
• Negative VA opinions lost weight when they contradicted their own explanation, ignored lay reports of symptoms, or were otherwise inadequate. (4 of 10 decisions read; e.g. A25003290, 21044613, 22004908)
• Where positive and negative opinions were roughly balanced, the Board resolved the doubt in the veteran's favor. (3 of 10 decisions read; e.g. 23050009, 21032780, A25039040)

Common reasons in denied cases

• A thorough VA opinion found the headaches were not caused or worsened by the psychiatric condition, and it was given the most weight. (3 of 12 decisions read; e.g. 24016570, 21005318, 23051191)
• Records weighed against the claim, such as denying headaches at separation or in treatment notes, and the veteran's own account was not enough. (4 of 12 decisions read; e.g. 24000425, 22049001, A25001579)
• The psychiatric condition was not service-connected, so a favorable opinion linking the headaches to it could not support the claim. (3 of 12 decisions read; e.g. A21011282, 22055698, A23018072)

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Migraine / headaches secondary to tinnitus

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

65.9% granted of 88 decided cases (margin of error 55.5–75.0%). 58 granted, 30 denied, 175 sent back to VA (remanded, not decided), 7 dismissed.

What convinced the Board in granted cases

• Most grants came when the Board found a favorable opinion, usually private, at least as persuasive as the negative VA opinion, so the evenly balanced evidence was resolved for the veteran. (6 of 11 decisions read; e.g. A25000768, A25029382, A24058738)
• Favorable opinions carried weight when they cited medical studies showing headaches and tinnitus share underlying mechanisms and applied that to the veteran's own case. (4 of 11 decisions read; e.g. A25000768, 23054161, 21034851)
• Negative VA opinions lost weight when they were conclusory, cited no literature, ignored the private opinion, or skipped the veteran's report that tinnitus worsens the headaches. (2 of 11 decisions read, few decisions; e.g. A24025454, A25025311)

Common reasons in denied cases

• The Board denied when a VA examiner gave a reasoned opinion, addressing both cause and worsening, that tinnitus did not cause the headaches, often pointing to other triggers or a lack of supporting literature. (5 of 8 decisions read; e.g. A23001899, 24000729, 21037372)
• Private opinions got less weight when they were tenuous, or cited an article without applying it to the veteran's own history or any clinical findings. (2 of 8 decisions read, few decisions; e.g. A23001899, 21027404)
• Some claims failed because no current migraine diagnosis was shown, or the veteran's accounts of when headaches began conflicted with the records. (3 of 8 decisions read; e.g. A21009779, 21057543, 22049001)

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Migraine / headaches secondary to neck (cervical spine)

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

77% granted of 61 decided cases (margin of error 65.1–85.8%). 47 granted, 14 denied, 89 sent back to VA (remanded, not decided), 0 dismissed.

What convinced the Board in granted cases

• The Board granted when a physician explained how the neck condition causes headaches, such as cervical disc disease causing cervicogenic headaches or neck muscle tension causing head pain, based on an accurate history. (6 of 10 decisions read; e.g. 23053947, 24020291, A25003631)
• Private opinions outweighed VA opinions that relied on generic online articles not about the neck, never discussed the veteran's history, or could not give an opinion without speculating. (2 of 10 decisions read, few decisions; e.g. A24042501, 21046776)
• Some grants rested on a VA examiner's own favorable opinion, linking headaches to neck arthritis, with no contrary opinion in the record. (2 of 10 decisions read, few decisions; e.g. 24003268, 21046776)

Common reasons in denied cases

• No competent medical opinion linked the headaches to service or a service-connected condition, and the veteran's own belief about the cause was not competent evidence. (4 of 12 decisions read; e.g. A23000770, 22003883, A24055072)
• VA opinions were given more weight when they had a clear rationale and accurate history, such as noting silent service records or in-service denials of headaches. (3 of 12 decisions read; e.g. 22055101, A24031757, 21019824)
• Other denials found the neck condition was not service-connected, so a secondary claim was not available, or found no chronic diagnosed headache disorder. (3 of 12 decisions read; e.g. 21045693, 22003883, A24015545)

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Migraine / headaches secondary to traumatic brain injury (TBI)

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

51.3% granted of 39 decided cases (margin of error 36.2–66.1%). 20 granted, 19 denied, 52 sent back to VA (remanded, not decided), 2 dismissed.

What convinced the Board in granted cases

• VA opinions against the claim lost weight when they relied on silent service records, ignored the veteran's reports of headaches, skipped aggravation, or used the wrong causation standard for secondary claims. (5 of 10 decisions read; e.g. A21010028, A24060831, A25011052)
• The Board granted on favorable medical opinions. These included a private opinion that reviewed the file and lay statements and cited research, and VA examiners who tied the headaches to the TBI or found the TBI made them worse. (5 of 10 decisions read; e.g. A25000037, A21004623, 24001366)
• The Board credited the veteran's consistent account that headaches began after the in-service head injury and continued since, which often put the evidence in approximate balance. (6 of 10 decisions read; e.g. A25017268, 22055229, 21045321)

Common reasons in denied cases

• The Board most often denied because the TBI itself was not service-connected or not shown in service, leaving no service-connected condition for the headaches to stem from. (7 of 12 decisions read; e.g. 21057495, A25007995, 23047469)
• The Board denied when a VA opinion explained the headaches were unlikely tied to the injury, citing literature or the many other causes of migraine, and no competent opinion rebutted it. (3 of 12 decisions read; e.g. 21004389, 21059114, A24055072)
• Other denials rested on no headache complaints in service and a long gap before treatment, no current disorder, or a private opinion that did not address what caused the TBI. (3 of 12 decisions read; e.g. 23004296, A21003290, 22001394)

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Migraine / headaches secondary to sinusitis / rhinitis

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

77.1% granted of 35 decided cases (margin of error 61.0–87.9%). 27 granted, 8 denied, 50 sent back to VA (remanded, not decided), 4 dismissed.

What convinced the Board in granted cases

• The Board gave strong weight to private opinions with a real rationale, such as explaining that the headaches came from sinus pressure and congestion, citing research, and fitting the veteran's own history. (4 of 11 decisions read; e.g. A25015966, A25003595, 21016410)
• Negative VA opinions lost weight when they ignored in-service headache records or never addressed whether sinusitis caused the headaches; sometimes a VA examiner's own favorable opinion carried the claim. (4 of 11 decisions read; e.g. 22054389, A24050708, 21072009)
• The Board credited veterans' statements that their headaches started with constant sinus congestion and continued since service. (4 of 11 decisions read; e.g. 21072009, A25003595, 21016410)

Common reasons in denied cases

• Reasoned VA opinions, some citing medical literature finding no link between sinus conditions and migraines, outweighed the other evidence. (5 of 9 decisions read; e.g. 23031475, A24031287, 21027882)
• The veteran's own belief that sinusitis caused the headaches was not competent medical evidence. (3 of 9 decisions read; e.g. 21063790, 21063742, 21019824)

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Migraine / headaches secondary to sleep apnea

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

Small sample: 29 decided cases, too few for a reliable percentage. 21 granted, 8 denied, 46 sent back to VA (remanded, not decided), 1 dismissed.

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Migraine / headaches secondary to hypertension

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

Small sample: 19 decided cases, too few for a reliable percentage. 7 granted, 12 denied, 48 sent back to VA (remanded, not decided), 1 dismissed.

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Migraine / headaches secondary to low back (lumbar spine)

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

Small sample: 18 decided cases, too few for a reliable percentage. 9 granted, 9 denied, 51 sent back to VA (remanded, not decided), 2 dismissed.

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Migraine / headaches secondary to dental / jaw

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

Small sample: 12 decided cases, too few for a reliable percentage. 11 granted, 1 denied, 17 sent back to VA (remanded, not decided), 0 dismissed.

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