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Veterans Law

Migraines Secondary to PTSD VA Disability Benefits

Robert Chisholm

July 5, 2020

Updated: June 20, 2024

man outside with hand over face due to migraine

CCK Law: Our Vital Role in Veterans Law

Overview of PTSD

Post-traumatic stress disorder (PTSD) is a mental health condition caused by experiencing a distressing, shocking, or otherwise traumatic event.  Many veterans experience PTSD stemming from events they witnessed or experienced during their military service.  PTSD can be diagnosed by a medical professional, whether it be a therapist, psychiatrist, or general practitioner.  It is important to note that the severity of PTSD symptoms vary from person to person.  However, the most common symptoms include the following:

  • Re-experiencing the trauma through intrusive, distressing recollections of the event, flashbacks, and nightmares
  • Emotional numbness and avoidance of places, people, and activities that are reminders of the trauma
  • Increased arousal such as difficulty sleeping and concentrating, feeling jumpy, and being easily irritated and angered

PTSD can either be short-term or chronic depending on the individual and the circumstances.  Regardless, the main treatments for people with PTSD are medications (e.g., antidepressants), psychotherapy (“talk therapy”), or both.  Veterans may be able to receive VA disability benefits for PTSD if they experienced a traumatic event during service and now have the above-mentioned symptoms as a result.

What Are Migraine Headaches?

Migraine headaches are a type of headache characterized by intense pain that can be accompanied by nausea, vomiting, sensitivity to light and sound, lightheadedness, and blurred vision.  Migraines can be debilitating and can last anywhere from hours to days depending on the person.  It is unclear what causes migraines, but triggers can include hormonal imbalance, alcohol, stress, sensory stimulation, certain foods, changes in the environment, or certain pre-existing conditions.  Treatments for migraines include rest, avoiding triggering stimuli, diet modification, medications, and stress management.

Migraines Among Veterans

Migraines are fairly common in the general population; however, they may be even more common among veterans.  Research shows that approximately 36 percent of the service members who had served in Operation Iraqi Freedom had reported migraines compared to 12 percent in the U.S. civilian population.

Winning VA Disability Rating for Migraines

Relationship Between PTSD and Migraines

A growing body of literature currently supports an association between migraine headaches and PTSD.  One study shows that among the general population, approximately 22 to 30 percent of migraine sufferers fulfilled PTSD criteria.  In a veteran population, the prevalence of PTSD was even greater with almost 50 percent of those with migraines fulfilling diagnostic criteria for PTSD.  Another study looked at the type of traumatic events that were most closely associated with the presence of migraines.  The results showed that the following traumatic events were most common in individuals who experience migraines: learning about a family member or close friend who was hurt or killed, observing someone being hurt or killed, experiencing a violent attack.  Many veterans experienced all of the above-mentioned traumatic events while serving on active duty.

Veterans may be able to receive VA disability benefits for their migraine headaches due to PTSD if they are already service-connected for PTSD.

Secondary Service Connection for Migraine Headaches

A secondary service-connected condition is one that resulted from a separate condition that is already service-connected.  For example, a veteran’s service-connected PTSD may later cause migraine headaches.  In this case, the veteran’s migraines may warrant secondary service connection if they are the result of their service-connected PTSD.  Veterans will need to demonstrate two things to VA in order to be granted secondary service connection for migraines:

  • A diagnosis for migraine headaches; and
  • Medical evidence showing the link between their service-connected PTSD and migraine headaches

Evidence to Submit for Migraines Secondary to PTSD

In claims for secondary service connection, proving a nexus (i.e., link) is especially important.  Again, a medical nexus opinion links the veteran’s secondary disability (i.e., migraines) to their already service-connected disability (i.e., PTSD).  The nexus between the veteran’s primary condition and secondary condition must be clearly established in order to be granted service connection on a secondary basis.  As such, medical opinions from either VA healthcare providers or private doctors are critical pieces of evidence in claims for secondary service connection.  Importantly, any medical records showing a connection between those conditions are also worth submitting to VA.

Lay evidence may also be helpful to support a claim for secondary service connection, meaning veterans can submit lay statements outlining how their PTSD caused or aggravated their migraine headaches.

About the Author

Bio photo of Robert Chisholm

Robert is a Founding Partner of CCK Law. His law practice focuses on representing disabled veterans in the United States Court of Appeals for Veterans Claims and before the Department of Veterans Affairs. As a veterans lawyer Robert has been representing disabled veterans since 1990. During his extensive career, Robert has successfully represented veterans before the Board of Veterans Appeals, Court of Appeals for Veterans Claims, and the United States Court of Appeals for the Federal Circuit.

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