Migraines & headaches decisions — 2006

The Board has remanded the case for further development due to the inextricably intertwined nature of the claims regarding headaches and residuals of a contusion to the head. The veteran needs to be scheduled for a VA examination to determine if any current headaches are related to the in-service contusion.

The veteran's claims of CUE in the February 1984 and September 1999 rating decisions have been denied. The February 1984 decision granted service connection for residuals of craniotomy with a 10 percent evaluation, while the September 1999 decision separated his single service-connected status-post craniotomy disability into four separate entities (loss of skull, headaches, tinnitus, and forehead scar) and assigned an effective date of August 31, 1993.

The Board found that the veteran's diagnosed anxiety disorder is not related to his military service and denied service connection for this condition. The issue of increased evaluation for psychophysiologic musculoskeletal disorder (manifested by headaches) remains pending.

The veteran's claims for increased ratings and service connection were denied. The prostate condition warranted a 60% rating, but no more. The fungus of the hands and feet did not meet criteria for an increased rating. Headaches were not incurred in or aggravated by service.

The Board denied the veteran's claims for service connection for depression, an initial rating in excess of 10 percent for a back disorder, and an initial rating in excess of 30 percent for a headache disorder. The claim for a compensable rating for hypertension was also denied.

The Board found no evidence of a psychiatric disability in service and denied the veteran's claims for service connection for an acquired psychiatric disorder other than PTSD. The Board also found that there was insufficient evidence to establish a nexus between the veteran's migraine headaches and his military service, thus denying the claim for service connection for migraine headaches.

The Board found that the veteran's claimed conditions, including bilateral hearing loss, tinnitus, headaches, sinusitis, and respiratory disability, were not incurred or aggravated by service. The VA examiners concluded that these conditions are not related to his military noise exposure.

The Board has granted a 50 percent evaluation for the veteran's service-connected headaches, finding that these meet the criteria for very frequent and severe prostrating attacks.

The Board denied the veteran's claims for service connection for headaches, equilibrium problems and dizziness, and cognitive processing problems as a result of exposure to ionizing radiation due to lack of evidence linking these conditions to his military service.

The veteran's PTSD is rated at the highest possible rating of 100 percent, indicating that his symptoms are so severe that they render him unable to obtain or retain substantially gainful employment. The veteran's headaches are also considered a symptom of his PTSD and warrant a separate noncompensable rating.

The Board found that the veteran's current headaches were not incurred in or aggravated by service and may not be presumed to be related to service.

The veteran's claims for service connection for various conditions, including chronic fatigue syndrome, skin problems, headaches, muscle pain and joint pain, gastrointestinal issues, sleep disturbances, visual disturbances, and urinary tract problems, were denied. The Board found that the evidence did not support a finding of service connection for any of these conditions.

The Board has granted a higher initial evaluation of 30 percent for the veteran's migraine headaches, resolving all reasonable doubt in his favor. The evidence shows that he experiences characteristic prostrating attacks on average once a month.

The Board has determined that the veteran's headaches are related to his service-connected dysthymic disorder and had their onset during active military service, granting service connection for headaches.

The Board found that the veteran's vascular headaches were not incurred in or aggravated by service.

The veteran's claims for service connection for migraine headaches, depressive disorder (not otherwise specified), rashes, fatigue, and abdominal pain have been granted as manifestations of undiagnosed illness. The veteran is not entitled to service connection for these conditions on a direct basis.

The Board denied the veteran's claims for service connection for PTSD, head injury residuals, migraines, whiteouts or TIA, pulmonary condition (related to asbestos exposure), and back condition (related to a head injury). The reasons were that there was no evidence of chronic conditions related to these issues during service or post-service.

The Board denied the veteran's claims for increased ratings for his major depressive disorder, lumbar spine disability, and migraine headaches. The claim for a rating in excess of 50 percent for migraine headaches was dismissed due to the veteran's withdrawal.

The veteran's appeal is being remanded for a videoconference hearing before the Board of Veterans' Appeals.

The veteran's appeals for increased ratings were denied. The right chest gunshot wound and right knee conditions are rated at the minimum levels, while headaches receive a separate rating.