The Board has found pre-decisional duty-to-assist errors in the claim for service connection for migraine including migraine variants, to include as secondary to service-connected PTSD with insomnia. New VA medical opinions are required on remand to address causation and aggravation of the Veteran's migraine condition by his service-connected PTSD with insomnia.
The deciding factor: The Board found that there were pre-decisional duty-to-assist errors in this case, specifically regarding the lack of an adequate opinion addressing both causation and aggravation of the Veteran's migraine condition by his service-connected PTSD with insomnia. The VA examiner neglected to address the Veteran's separately diagnosed insomnia disorder and its potential link to the Veteran's migraine headaches.
- Claimed conditions
- migraine including migraine variants
- How they argued it
- Secondary to another service-connected condition
- Exposure basis
- None
- Rating assigned
- None in this decision
- Decision date
- April 17, 2026
- Citation
- A26036249
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. Look up the original decision on VA.gov (opens in a new tab) using citation A26036249.
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 service-connected migraine including migraine variants was increased from a 10 percent to a 30 percent rating effective September 23, 2023. The appellant is eligible for attorney fees based on past-due benefits awarded in the June 2024 rating decision.
- Denied
The Veteran's initial rating for his migraine including migraine variant condition was denied as the evidence did not support a higher rating due to lack of very frequent completely prostrating and prolonged attacks.
- Granted
The Board has granted an initial 50 percent rating for migraine including migraine variants, effective from September 30, 2021. The appeal regarding a TDIU is being remanded.
- Dismissed
The appeal for neck pain pinched nerve severe arthritis cervical spine is dismissed as a matter of law. Service connection and increased ratings are granted for major depression, mental disorder anxiety and PTSD, carpal tunnel syndrome (both wrists), and migraine including migraine variants.
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