The Board remands the claims for service connection for cluster headaches and sleep disturbances as secondary to cluster headaches due to a pre-decisional duty to assist error.
The deciding factor: The VA examiners did not address whether the Veteran's cluster headaches were aggravated by his service-connected PTSD, which is required for a complete opinion on the claim.
- Claimed conditions
- cluster headaches, sleep disturbances
- How they argued it
- Secondary to another service-connected condition
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- March 12, 2025
- Citation
- A25022805
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 Board granted an effective date of January 19, 2016, for the award of service connection for chronic fatigue syndrome, cluster headaches, back muscle pain, rhinosinusitis, and right knee painful joint.
- Granted
The Board granted an effective date of November 26, 2018 for the award of a 50 percent rating for the Veteran's service-connected cluster headaches.
- Partly granted
The appeal for service connection for depression was dismissed as it is subsumed by the already service-connected PTSD. A 50 percent rating for cluster headaches was granted, and a higher rating for autoimmune hepatitis was denied.
- Denied
The Board denied service connection for right foot plantar fasciitis, left ankle achilles tendinopathy, post-traumatic (concussion) headaches, and TBI. The appeal for an earlier effective date was also denied.
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.