The Veteran's claim for a higher rating for her service-connected tension headaches and migraine headaches is denied as the evidence does not show very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability.,From April 10, 2013, the TDIU claim is rendered moot due to the assignment of a 100 percent combined schedular rating for multiple disabilities. The issue of TDIU prior to April 10, 2013, remains remanded.,The Veteran's claims for increased ratings for degenerative disc disease of lumbar spine at L5 with coccydynia are remanded due to the need for additional VA examination and opinion regarding flare-ups and functional impairment.
The deciding factor: The evidence does not meet the criteria for a rating in excess of 50 percent for tension headaches and migraine headaches as there is no documentation of very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability.,From April 10, 2013, the Veteran's TDIU claim is moot due to her already having a combined schedular rating of 100 percent for multiple disabilities. The issue remains remanded as it is inextricably intertwined with the other claims.,The need for additional VA examination and opinion regarding flare-ups and functional impairment was identified, as the previous VA examiner's opinions were inconsistent and inadequate.
- Claimed conditions
- Tension headaches, Migraine headaches
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- March 18, 2022
- Citation
- 22015671
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 22015671.
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.
- Granted
The Veteran's service connection claims for traumatic brain injury and migraine headaches due to right eye removal are granted. The claim for a compensable evaluation of xeroderma of the right eye is remanded.
- 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.
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