The Veteran's claim for an effective date prior to January 30, 2014 for the award of service connection for migraine headaches was denied. The Veteran also had a claim for an initial rating in excess of 30 percent for his migraine headaches which was denied.
The deciding factor: The Veteran did not submit a formal or informal application for service connection prior to January 30, 2014, and therefore, VA is precluded from granting an effective date prior to that date. The Veteran's current rating of 30 percent for his migraine headaches was found insufficient as he has not reported very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability.
- Claimed conditions
- migraine headache
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating
- Not verified here — check the original decision
- Decision date
- January 9, 2020
- Citation
- 20002131
Veterans Law Judge
Decisions by this judge: 3,217 · Granted: 46% (granted or partly granted, in the indexed 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. Read the original VA decision (opens in a new tab) using citation 20002131.
What this means for you
A final Board denial may be appealed to the U.S. Court of Appeals for Veterans Claims, generally within 120 days of the Board mailing date. A Supplemental Claim with new and relevant evidence is a separate option. Another Higher-Level Review of the Board decision is not available. Check your own notice: this historical decision does not set your deadline.
What you can do next
Use your own notice and decision stage. A remanded issue is not a final court-appealable denial. VA review guidance and CAVC filing instructions (U.S. federal; reviewed October 7, 2026).
Related decisions
Other Board decisions on a similar condition or argued the same way.
- Whole decision: Remanded (sent back)
The Board has dismissed the appeal for an earlier effective date for the migraine headache disability rating, as it was already granted from August 31, 2007. The issues of increased ratings for PTSD and major depressive disorder with TBI are remanded due to a duty to assist error in not obtaining SSA records.
- Whole decision: Remanded (sent back)
The Board has decided to remand the claim for a higher rating for migraine headaches due to conflicting evidence and need for further clarification.
- Whole decision: Remanded (sent back)
The Board has remanded the claims of service connection for right and left knee conditions, as well as migraine headaches, due to inadequate medical opinions. The Veteran's bilateral knee conditions are related to active service or secondary to his lumbar spine condition. His migraine headaches are related to active service.
- Whole decision: Granted
The Board has determined that the Veteran's migraine headache disability is at least as likely as not caused by his service-connected PTSD, and thus grants service connection for this condition on a secondary basis.
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