The Veteran's appeal for an increased rating for his service-connected migraine headaches has been denied. The Board found that the current 50 percent rating is the maximum available under the schedular criteria and that referral for extraschedular consideration was not warranted.,The claim for an earlier effective date for the service-connected migraine headaches has also been denied as there was no determination made in the 2017 rating decision regarding such. The Veteran's attorney raised the issue of TDIU, but the RO did not fully develop this prior to April 2019.
The deciding factor: The Veteran’s migraine headaches are rated at the maximum schedular level (50 percent), and there is no basis for a higher evaluation on an extraschedular basis. The rating criteria do not define 'prostrating,' but the term is used to describe very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability.,The 2017 rating decision did not address the issue of an earlier effective date for the service-connected migraine headaches, as no increase was granted. The Veteran's attorney raised the issue of TDIU prior to April 2019, but the RO did not fully develop this claim.
- Claimed conditions
- migraine headaches
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating assigned
- 50%
- Decision date
- November 7, 2019
- Citation
- 19184050
Veterans Law Judge
Decisions by this judge: 2,592 · Granted: 19% (granted or partly granted, in the vetted decisions on this site)
Judge attribution: 2025 complete; earlier years partial.
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 19184050.
What this means for you
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What you can do next
Related decisions
Other Board decisions on a similar condition or argued the same way.
- Remanded (sent back)
The Board has remanded the claims for bilateral hearing loss, migraine headaches, and PTSD due to additional development of records and examination.
- Remanded (sent back)
The Board has remanded the cases for additional development due to incomplete medical records and insufficient opinions regarding the relationship between service, including a stick injury in England, and current left eye disability (including amblyopia and cataracts) as well as migraine headaches.
- Granted
The Veteran's migraine headaches are productive of very frequent, completely prostrating and prolonged attacks capable of producing severe economic inadaptability. The Board has granted a 50 percent disability rating for the Veteran's service-connected migraine headaches.
- Granted
The Veteran's claim for a higher rating for his service-connected migraine headaches was granted with an effective date of February 28, 2023.
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