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Denied

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

MICHELLE L. KANE

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.

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