{
 "generated": "2026-09-09",
 "page": "https://vetaid.ai/blog/tinnitus-secondary-conditions#secondary-evidence",
 "method": {
  "corpus": "Every published Board of Veterans' Appeals decision indexed by VetAid (va.gov/vetapp, 1992 through 2026-06-30; 2893 issues matched). Issue text matched the pattern 'secondary to [service-connected] tinnitus' so that tinnitus is the PRIMARY condition; the claimed condition is classified from the words before 'secondary'.",
  "counts_are": "appealed issues decided by the Board, not initial claims; a remand is not an outcome; one decision can hold several issues",
  "example_selection": "AMA-era decisions from 2025-2026, most recent first, issue text under 260 characters, at least one grant, one denial and one remand per family, read in full by a reviewer; quotes are verbatim sentences of the official text",
  "reviewer_signoff": null
 },
 "cohort": {
  "total_directed_issues": 2893,
  "by_family": {
   "other": {
    "remanded": 254,
    "dismissed": 11,
    "denied": 106,
    "granted": 42,
    "referred": 1,
    "vacated": 1
   },
   "vertigo": {
    "remanded": 254,
    "denied": 88,
    "granted": 64,
    "dismissed": 9,
    "withdrawn": 1
   },
   "mental": {
    "remanded": 260,
    "granted": 119,
    "denied": 91,
    "dismissed": 19,
    "withdrawn": 1,
    "referred": 1
   },
   "headache": {
    "remanded": 488,
    "denied": 117,
    "granted": 259,
    "dismissed": 22
   },
   "hypertension": {
    "denied": 19,
    "remanded": 28,
    "dismissed": 2,
    "granted": 1
   },
   "sleep": {
    "granted": 158,
    "remanded": 348,
    "dismissed": 24,
    "denied": 101,
    "withdrawn": 4
   }
  }
 },
 "regulation": {
  "cite": "38 CFR 3.310",
  "ecfr_version": "2026-07-01",
  "a": "Except as provided in § 3.300(c), disability which is proximately due to or the result of a service-connected disease or injury shall be service connected. When service connection is thus established for a secondary condition, the secondary condition shall be considered a part of the original condition.",
  "b": "Any increase in severity of a nonservice-connected disease or injury that is proximately due to or the result of a service-connected disease or injury, and not due to the natural progress of the nonservice-connected disease, will be service connected. However, VA will not concede that a nonservice-connected disease or injury was aggravated by a service-connected disease or injury unless the baseline level of severity of the nonservice-connected disease or injury is established by medical evidence created before the onset of aggravation or by the earliest medical evidence created at any time between the onset of aggravation and the receipt of medical evidence establishing the current level of severity of the nonservice-connected disease or injury.",
  "page": "/cfr/3.310"
 },
 "examples": [
  {
   "cit": "A26060071",
   "family": "sleep",
   "disp": "granted",
   "theory": "causation or aggravation",
   "judge": "Rebecca N. Poulson",
   "date": "2026-06-29",
   "claimed": "obstructive sleep apnea",
   "why": "A private physician's opinion that reviewed the records and cited literature carried the issue. The Board called it the most probative evidence of record.",
   "quotes": [
    "The most probative evidence of record indicates that the Veteran's obstructive sleep apnea is caused or aggravated by the Veteran's tinnitus.",
    "D.A. concluded, \"after reviewing the Veteran's pertinent medical records, recent medical literature, and an interview with the Veteran, it is my expert medical opinion that it is more likely than not that the Veteran's sleep apnea is caused by and/or aggravated by his service-connected tinnitus.\""
   ],
   "va_url": "https://www.va.gov/vetapp26/Files6/A26060071.txt",
   "source_chars": 22574
  },
  {
   "cit": "A26060232",
   "family": "sleep",
   "disp": "granted",
   "theory": "causation (but-for)",
   "judge": "Martin T. Mitchell",
   "date": "2026-06-29",
   "claimed": "obstructive sleep apnea",
   "why": "Two opinions conflicted: a July 2022 private internist for the veteran, a December 2022 VA examiner against. The Board resolved the conflict for the veteran and found tinnitus a but-for cause.",
   "quotes": [
    "The Veteran's service-connected tinnitus is a but-for cause of his current OSA.",
    "In a July 2022 private medical opinion, the examining internal medicine physician opined that \"it is more likely than not that his obstructive sleep apnea is the direct result of the effects of his tinnitus\" because tinnitus and OSA are often comorbidities and recent medical scholarship reflects that tinnitus frequently disturbs an individual's sleep patterns.",
    "In a December 2022 VA medical opinion, the examiner opined the Veteran's OSA is \"less likely than not proximately due to or the result of\" his tinnitus because \"mechanical and structural problems cause the interruptions in breathing during sleep\" and therefore OSA symptomology, and there is no \"physiologic connection or objective medical evidence or literature\" which explains how tinnitus can physically interfere with the Veteran's breathing."
   ],
   "va_url": "https://www.va.gov/vetapp26/Files6/A26060232.txt",
   "source_chars": 15815
  },
  {
   "cit": "A26036578",
   "family": "sleep",
   "disp": "denied",
   "theory": "causation or aggravation",
   "judge": "John J. Crowley",
   "date": "2026-04-20",
   "claimed": "sleep apnea",
   "why": "The only nexus opinion of record was the VA examiner's, and it pointed to obesity (BMI 36.2 at the sleep study). No contrary medical opinion was submitted.",
   "quotes": [
    "The examiner concluded that there is no scientific basis to date that obstructive sleep apnea is due to or the result of tinnitus or vertigo.",
    "Citing medical literature, the examiner explained that the major risk factors for obstructive sleep apnea are obesity."
   ],
   "va_url": "https://www.va.gov/vetapp26/Files4/A26036578.txt",
   "source_chars": 12991
  },
  {
   "cit": "A26057207",
   "family": "sleep",
   "disp": "remanded",
   "theory": "causation",
   "judge": "L. M. Barnard",
   "date": "2026-06-17",
   "claimed": "obstructive sleep apnea",
   "why": "The veteran had a favorable private opinion, but the Board found it inadequate: it treated insomnia and sleep apnea as the same thing and leaned on comorbidity studies. A favorable opinion without a rationale gets a remand, not a grant.",
   "quotes": [
    "In this regard, the examiner appeared to conflate sleep disturbances, such as insomnia, with sleep apnea.",
    "The Board also notes that the Veteran is already service-connected for insomnia as secondary to tinnitus."
   ],
   "va_url": "https://www.va.gov/vetapp26/Files6/A26057207.txt",
   "source_chars": 5886
  },
  {
   "cit": "A26036680",
   "family": "mental",
   "disp": "granted",
   "theory": "causation",
   "judge": "Shereen M. Marcus",
   "date": "2026-04-20",
   "claimed": "depressive disorder with anxious distress",
   "why": "Here the VA examiner's own opinion was favorable and cited literature. When the C&P opinion supports the theory, the Board grants.",
   "quotes": [
    "The examiner determined that the psychiatric condition was at least as likely as not proximately due to or the result of his service-connected tinnitus.",
    "The examiner stated that medical literature supported the relationship between depression, anxiety and tinnitus and that several studies had indicated a strong correlation between anxiety and tinnitus."
   ],
   "va_url": "https://www.va.gov/vetapp26/Files4/A26036680.txt",
   "source_chars": 117283
  },
  {
   "cit": "26006090",
   "family": "mental",
   "disp": "granted",
   "theory": "aggravation",
   "judge": "B.T. Knope",
   "date": "2026-06-02",
   "claimed": "acquired psychiatric disorder (claimed as PTSD and bipolar disorder)",
   "why": "The direct-service theory had a negative VA opinion. The aggravation theory, supported by a 2026 private opinion, won anyway. Secondary aggravation is a separate route from direct service connection.",
   "quotes": [
    "Resolving all reasonable doubt in favor of the Veteran, his acquired psychiatric disorder was worsened by his already service-connected tinnitus.",
    "Further, the evidence, including the credible statements from the Veteran, in conjunction with the opinion from the Veteran's February 2026 private physician, reflect that his psychiatric disorder has been caused by and/or aggravated by his service-connected tinnitus.",
    "In arriving at this conclusion, the Board acknowledges the negative evidence, including the opinion from the May 2020 VA examiner, which indicates the Veteran's psychiatric disorder is not related directly to active-duty service."
   ],
   "va_url": "https://www.va.gov/vetapp26/Files6/26006090.txt",
   "source_chars": 4865
  },
  {
   "cit": "A25111291",
   "family": "mental",
   "disp": "denied",
   "theory": "causation",
   "judge": "A. C. Mackenzie",
   "date": "2025-12-31",
   "claimed": "major depressive disorder (claimed as depression and anxiety)",
   "why": "The claim failed on the first element, a current diagnosis, before nexus was ever reached. A veteran's own report of anxiety and depression was not accepted as a diagnosis.",
   "quotes": [
    "The evidence of record persuasively weighs against finding that the Veteran has a current anxiety and depression diagnosis or persistent or recurrent symptoms of anxiety and depression.",
    "Regarding the Veteran's anxiety symptoms, the VA examiner concluded that they are well within the range of healthy human emotional experience and are not indicative of pathology."
   ],
   "va_url": "https://www.va.gov/vetapp25/Files12/A25111291.txt",
   "source_chars": 14922
  },
  {
   "cit": "A26057532",
   "family": "mental",
   "disp": "remanded",
   "theory": "aggravation",
   "judge": "S. B. Mays",
   "date": "2026-06-18",
   "claimed": "acquired psychiatric disorder (PTSD and major depressive disorder)",
   "why": "The 2019 VA examiner answered causation but not aggravation. The Board sent it back for an addendum opinion on aggravation alone. An opinion that skips aggravation is incomplete.",
   "quotes": [
    "However, the 2019 examiner did not address whether the service-connected tinnitus aggravated the Veteran's acquired psychiatric disorder.",
    "Secondary Service Connection by Aggravation - Are the diagnosed acquired psychiatric disorders (at least as likely as not) aggravated (any incremental increase in disability regardless of permanence) by the service-connected tinnitus?"
   ],
   "va_url": "https://www.va.gov/vetapp26/Files6/A26057532.txt",
   "source_chars": 7073
  },
  {
   "cit": "A26056204",
   "family": "headache",
   "disp": "granted",
   "theory": "aggravation",
   "judge": "Ardie A. Bland",
   "date": "2026-06-15",
   "claimed": "migraines",
   "why": "A negative VA opinion contained a concession, that tinnitus-related anxiety triggers headaches, and the Board used the examiner's own words to find aggravation.",
   "quotes": [
    "While the February 2025 VA examiner gave a negative secondary service connection opinion, the examiner stated that the Veteran's anxiety associated with their tinnitus can be a trigger for their headaches.",
    "The Board finds that this is sufficient to support a finding that the Veteran's migraines are aggravated by his service-connected tinnitus."
   ],
   "va_url": "https://www.va.gov/vetapp26/Files6/A26056204.txt",
   "source_chars": 20468
  },
  {
   "cit": "A26059115",
   "family": "headache",
   "disp": "granted",
   "theory": "aggravation",
   "judge": "Michael Martin",
   "date": "2026-06-24",
   "claimed": "chronic headaches",
   "why": "A private physician cited studies correlating tinnitus and headaches; the VA examiner said the literature does not support causation. With the evidence in balance, reasonable doubt went to the veteran.",
   "quotes": [
    "Resolving all reasonable doubt in the Veteran's favor, it is at least as likely as not that his chronic headaches were aggravated by his service-connected tinnitus.",
    "Mitchell opined that the Veteran's headaches were more likely than not secondary to his service-connected tinnitus.",
    "The medical literature does not support the idea that tinnitus causes migraine headaches."
   ],
   "va_url": "https://www.va.gov/vetapp26/Files6/A26059115.txt",
   "source_chars": 25041
  },
  {
   "cit": "A26055598",
   "family": "headache",
   "disp": "denied",
   "theory": "causation and aggravation",
   "judge": "John J. Crowley",
   "date": "2026-06-12",
   "claimed": "migraine headaches",
   "why": "The examiner conceded that tinnitus can aggravate headaches, yet the claim was denied: there was no medical evidence of a baseline severity, which 38 CFR 3.310(b) requires before aggravation can be conceded.",
   "quotes": [
    "The examiner found that the Veteran's service-connected tinnitus is known to cause aggravation of the Veteran's headache but is not known to directly cause migraine conditions.",
    "With regard to aggravation, the examiner indicated that medical evidence is not sufficient to support a determination of a baseline level of severity and there is no clear medical evidence that indicates tinnitus causes an aggravation of migraines."
   ],
   "va_url": "https://www.va.gov/vetapp26/Files6/A26055598.txt",
   "source_chars": 10538
  },
  {
   "cit": "A26051266",
   "family": "headache",
   "disp": "remanded",
   "theory": "causation or aggravation",
   "judge": "Christopher Seppanen",
   "date": "2026-06-01",
   "claimed": "migraine headaches",
   "why": "VA never obtained a medical opinion on the secondary theory, so the Board remanded for one. A private treatment record raising the link was enough to trigger VA's duty to assist.",
   "quotes": [
    "No medical opinion has been obtained regarding the Veteran's contentions that his migraine headaches are related to his service-connected tinnitus.",
    "The Board finds that a remand is warranted to correct a pre-decisional duty to assist error."
   ],
   "va_url": "https://www.va.gov/vetapp26/Files6/A26051266.txt",
   "source_chars": 4776
  }
 ]
}