The Veteran's posttraumatic headaches are currently rated as non-compensable, and the TBI residuals are rated together with PTSD. The Board finds no basis for a separate compensable rating for TBI.,For the TBI component of his disability picture, the Veteran does not have subjective symptoms that moderately interfere with work, instrumental activities of daily living, or family relationships.
The deciding factor: The Veteran's headaches do not meet the criteria for a higher rating under Diagnostic Code 8100 due to lack of characteristic prostrating attacks. The TBI residuals are rated together with PTSD and there is no separate compensable rating warranted.
- Claimed conditions
- Posttraumatic Headaches, Traumatic Brain Injury (TBI) Residuals
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating
- Not verified here — check the original decision
- Decision date
- August 23, 2023
- Citation
- 23046915
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 23046915.
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 service-connected posttraumatic headaches have been rated at a 50 percent evaluation, which is the maximum rating available under Diagnostic Code 8100 for very frequent completely prostrating and prolonged attacks productive of severe economic inadaptability.
- Whole decision: Denied
The Veteran's claim for a compensable rating for posttraumatic headaches was denied. The Board dismissed the claims for TDIU and SMC due to service-connected posttraumatic headaches as it did not have jurisdiction over these issues.
- Whole decision: Denied
The Veteran's service-connected disabilities do not meet the criteria for specially adapted housing (SAH) or special home adaptation (SHA) grant due to his respiratory disability, which is presumed by the PACT Act. The Board found that the Veteran does not have a permanent and total disability resulting in anatomical loss of use of both hands, burns, or residuals of an inhalational injury.
- Whole decision: Granted
The Veteran's TBI residuals, including migraines and depressive disorder with anxious distress, are rated at 50 percent effective February 9, 2017. An earlier effective date of April 29, 2019, for SMC due to loss of use of a creative organ is granted.
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