The Board denied service connection for tension headaches, finding that the Veteran's current condition is not related to his active-duty service and is not proximately due to or the result of his service-connected PTSD.,The Board also denied service connection for obstructive sleep apnea as secondary to PTSD. The Board found that the weight of evidence does not support a finding that the Veteran's OSA was caused by his service-connected PTSD.
The deciding factor: The VA examiner concluded that tension-type headaches were less likely than not incurred in or caused by an in-service injury, event, or illness. The examiner also noted other medical conditions known to cause headaches (e.g., constipation, neck pain/condition) and lack of evidence linking PTSD exacerbations with resultant headache.,The VA examiner concluded that the Veteran's obstructive sleep apnea was less likely than not caused by his service-connected PTSD. The examiner pointed out that obesity is a highly causative clinical risk factor for OSA, which the Veteran had been counseled to address.
- Claimed conditions
- Tension headaches, Obstructive sleep apnea (OSA)
- How they argued it
- Secondary to another service-connected condition
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- April 20, 2023
- Citation
- 23023252
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 23023252.
What this means for you
A denial is a starting point, not the end of the road. You can see why this claim fell short — and, if you are still inside the one-year window, the appeal lanes that may remain open to you.
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 Board has granted service connection for gastroesophageal reflux disease (GERD) and obstructive sleep apnea (OSA), finding that both conditions are secondary to the Veteran's service-connected lower back condition and sinusitis, respectively.
- 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.
Free starter guide for your own claim
Reading this because you were denied or under-rated? Get the plain-English next steps — your appeal options, the deadline that protects you, and how appeals like yours turn out. One email, no spam.
We will only use this to send the guide. No spam, unsubscribe any time. We never sell your information.
We are not the VA. Veterans’ Rights is an independent resource built for veterans. We are not the U.S. Department of Veterans Affairs, not part of the government, and not endorsed by any government agency.
This is general information, not legal advice. For advice about your own situation, talk to a VA-accredited representative — many help for free.