The Board remands the claim for a GI condition to obtain an addendum medical opinion regarding service connection on direct and secondary theories of entitlement, including obesity as an intermediate step.
The deciding factor: The July 2023 VA medical opinions were found inadequate due to their use of the 'proximate cause' standard in addressing secondary service connection, which has been deemed unlawful by Spicer v. McDonough, 61 F.4th 1360 (Fed. Cir. 2023).
- Claimed conditions
- gastroesophageal reflux disease, hernia hiatal with stricture of esophagus
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- April 14, 2025
- Citation
- A25034251
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.
- Partly granted
The Board granted service connection for gastroesophageal reflux disease, obstructive sleep apnea, and chronic obstructive pulmonary disease but denied service connection for irritable bowel syndrome. The Board also denied an increased rating for the Veteran's service-connected psychiatric condition.
- Granted
The Board granted service connection for prostate cancer status post radical prostatectomy, erectile dysfunction, urinary incontinence, gastroesophageal reflux disease, and an acquired psychiatric disorder.
- Granted
The Veteran's service-connected headaches were granted a rating of 50 percent, and she was also granted TDIU, DEA, and SMC for the period from March 27, 2017, to August 20, 2017.
- Dismissed
The appeal for service connection for obstructive sleep apnea and gastroesophageal reflux disease has been withdrawn by the Veteran.
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