The Veteran's claims for increased ratings for tension headaches, back disability, right knee disability, and left knee disability were denied as the evidence did not show very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability.,The Veteran's claim for an initial compensable rating for a skin disability was denied due to lack of at least 5 percent of body or exposed areas affected.
The deciding factor: The evidence did not show very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability, which is required for a higher rating under DC 8100 for tension headaches. The Veteran's back disability was rated based on the General Rating Formula for Diseases and Injuries of the Spine with no associated IVDS.
- Claimed conditions
- Tension headaches, Lumbar degenerative disc disease (back disability), Right knee degenerative joint disease (right knee disability), Left knee degenerative joint disease (left knee disability), Skin disability (lichen planus – multiple papular lesions on the glans penis)
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating
- Not verified here — check the original decision
- Decision date
- June 30, 2020
- Citation
- 20043945
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 20043945.
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: 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.
- Whole decision: 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.
- Whole decision: 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.
- Whole decision: 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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