The Veteran's tension headaches prior to May 18, 2013 were not manifested by characteristic prostrating attacks averaging one in two months over the last several months. The Veteran’s tension headaches are rated by analogy to Diagnostic Code 8100 for migraines. As the preponderance of the evidence is against finding that the Veteran's tension headache symptoms approximated the criteria for a compensable rating, his claim for a compensable rating prior to May 18, 2013 was denied.
The deciding factor: The Veteran did not experience characteristic prostrating attacks or prostrating attacks of non-migraine headache pain, and they did not impact his ability to work.
- Claimed conditions
- Tension headaches, Bipolar disorder with attention deficit hyperactivity disorder and posttraumatic stress disorder
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- September 12, 2018
- Citation
- 18134317
This is a plain-language summary generated by AI from a public Board of Veterans’ Appeals decision. It can contain errors — always verify against the original. Look up the original decision on VA.gov (opens in a new tab) using citation 18134317.
What this means for you
A remand is not a loss. The Board sent the case back for more development — often a new exam or missing records — before making a final decision. Many remands later end in a grant, and the decision spells out exactly what the Board wanted to see.
What you can do next
Related decisions
Other Board decisions on a similar condition or argued the same way.
- Granted
The Veteran's initial evaluation for tension headaches to include migraines is granted, with a rating of 50 percent effective from May 23, 2023.
- Remanded (sent back)
The Veteran's claim for a compensable disability rating for tension and migraine headaches is remanded due to the inadequacy of the September 2020 VA examination report, which did not consider the ameliorative effects of medication.
- Granted
The Veteran's tension headaches, which have been service-connected since the grant of service connection, are found to be very frequent and completely prostrating with prolonged attacks productive of severe economic inadaptability. The Board grants an initial 50 percent rating for tension headaches prior to December 1, 2020.
- Granted
The Veteran's tension headaches are rated at a 30 percent rating, effective December 26, 2024. The Board found that the Veteran experienced characteristic prostrating attacks occurring on an average of once a month over the last several months, warranting this rating. A higher rating is denied.
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