Migraines & headaches decisions — 2008

The Board has determined that further development is necessary to properly adjudicate all issues on appeal, including verifying the veteran's claims of helicopter crashes and examining his current conditions.

The veteran's appeal is being remanded for additional development, including obtaining service medical records and scheduling VA examinations to determine the etiology of his claimed conditions.

The veteran's cephalalgia is currently rated at 30 percent, which is the maximum rating available under DC 8100 for migraine headaches. The veteran also has a current 50 percent rating for PTSD and a non-compensable rating for bilateral hearing loss prior to January 22, 2002. His healed fracture of the right fibula is rated at 10 percent.

The Board has decided to remand the case for further development due to additional evidence not being considered in the previous decision.

The veteran's service-connected disabilities alone do not render him so helpless as to be unable to care for himself, protect himself from the hazards or dangers incident to his environment, or attend to the needs of nature. The Board finds that the preponderance of the probative evidence is against the veteran's claim for entitlement to SMC.