The Board remands the claims for a compensable evaluation of tension headaches and an increased rating for GERD and IBS due to inadequate VA examinations.
The deciding factor: The September 2023 examinations did not address the severity of the Veteran's conditions without the ameliorative effects of medication, as required by Jones v. Shinseki, 26 Vet. App. 56, 63 (2012).
- Claimed conditions
- tension headaches, gastroesophageal reflux disease (GERD) and irritable bowel syndrome (IBS)
- How they argued it
- Direct service connection
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- May 28, 2025
- Citation
- A25047521
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.
- Denied
The Board denied service connection for various conditions, including tension headaches, bilateral plantar fasciitis, and a bilateral hearing loss disability. The Board also denied an initial compensable rating for the Veteran's headache disability.
- Denied
The Board denied the Veteran's claim for an initial compensable rating for tension headaches, alternatively diagnosed as migraine headaches, finding that the evidence did not show characteristic prostrating attacks averaging one in 2 months over the last several months.
- Remanded (sent back)
The Board remands the matter for a retrospective medical assessment regarding the severity of the Veteran's headaches without medication to determine if an earlier effective date for a 50 percent disability rating is warranted.
- Denied
The Board denied the Veteran's claim for an initial compensable rating for tension headaches, as the evidence did not show characteristic prostrating attacks averaging one in two months over the last several months.
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