The Board remands the Veteran's claims for service connection for GERD and migraine headaches to the AOJ for correction of pre-decisional duty to assist errors.
The deciding factor: The medical opinions provided were found inadequate as they did not address secondary aggravation, which is required for establishing service connection on a secondary basis.
- Claimed conditions
- gastroesophageal reflux disease (GERD), migraine headaches
- How they argued it
- Secondary to another service-connected condition
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- April 10, 2025
- Citation
- A25033339
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 migraine headaches were granted a 50 percent disability rating, effective August 8, 2023, due to very frequent completely prostrating and prolonged attacks that are productive of severe economic inadaptability.
- Dismissed
The Veteran withdrew his appeals for service connection for gastroesophageal reflux disease (GERD) and pernicious anemia, and the Board dismissed both appeals.
- Granted
The Board granted a 50 percent rating for the Veteran's migraine headaches based on prostrating attacks occurring more than once a month and severe economic inadaptability.
- Granted
The Board granted service connection for migraine headaches as proximately due to the Veteran's service-connected tinnitus.
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