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Veterans Law

Sleep Apnea Secondary to PTSD: VA Disability Ratings and Benefits

Alyse Phillips

September 12, 2019

Updated: December 11, 2024

Sleep Apnea Secondary to PTSD: VA Disability Ratings and Benefits

CCK Law: Our Vital Role in Veterans Law

IMPORTANT 2024 UPDATE: VA has proposed significant rule changes that will likely make it more complex to obtain a high rating for sleep apnea. Veterans who obtained a VA rating for sleep apnea before the rules change will be “grandfathered in” (i.e., will be able to use the original criteria). Therefore, veterans should not delay unnecessarily in filing a claim for their sleep apnea.

If a veteran has service-connected post-traumatic stress disorder (PTSD) and then develops or aggravates sleep apnea as a result, the sleep apnea may also be eligible for VA disability compensation. This is referred to as sleep apnea secondary to PTSD.

In this article, CCK Law will explain:

  • Secondary service connection is when a service-connected VA disability causes another condition to develop or worsen, resulting in the second condition being eligible for VA disability compensation.
  • PTSD and sleep apnea are often associated. Sleep apnea is a potentially serious sleep disorder in which a person’s breathing is repeatedly interrupted during the course of the night.
  • A veteran can receive a VA rating for sleep apnea secondary to PTSD by demonstrating that their sleep apnea is “at least as likely as not” the result of their PTSD.
Who We Are: Chisholm Chisholm & Kilpatrick is the leading veterans law firm in the US. CCK Law has secured more than $1 billion in wrongfully denied benefits for veterans and their families. With more court experience than any firm, CCK has argued many of the cases that have shaped veterans law.

What is Sleep Apnea Secondary to PTSD?

VA Rating for Sleep Apnea Secondary to PTSD

Post-traumatic stress disorder (PTSD) is a mental health condition that can occur in people who have experienced or witnessed a distressing, shocking, or otherwise traumatic event. The symptoms of PTSD can often be very debilitating and have a negative impact on an individual’s life. Unfortunately, many veterans experience PTSD stemming from their military service, and they are entitled to VA disability compensation.

PTSD may lead to sleep apnea, a potentially serious sleep disorder in which a person’s breathing is repeatedly interrupted during sleep. There is significant research linking PTSD and sleep apnea. A study involving 195 Iraq and Afghanistan veterans found that 69.2% had a high risk for obstructive sleep apnea (OSA), with this risk increasing as PTSD symptom severity did. Another study reported that 63% of individuals with PTSD were diagnosed with sleep apnea (PDF), compared to 7% in those without PTSD.

However, VA has often denied a link between the medical conditions in the past, so veterans should be fully prepared to demonstrate the connection between their disabilities.

If a veteran can prove that service-connected PTSD caused their sleep apnea, then they may claim be able to claim VA disability compensation for sleep apnea, too, even if their sleep apnea symptoms appeared after service. This is referred to as “secondary service connection,” or sleep apnea secondary to PTSD.

To file a successful VA claim for sleep apnea secondary to PTSD, veterans must prove:

Keep in mind that a VA claim for sleep apnea secondary to PTSD may be filed with the initial PTSD claim or as a supplemental claim if the sleep apnea symptoms develop at a later date.

What is Post-Traumatic Stress Disorder (PTSD)?

How to Get the Highest Rating for Post-Traumatic Stress Disorder (PTSD)

Post-traumatic stress disorder (PTSD) is a mental health condition that can occur after experiencing a distressing, shocking, or otherwise traumatic event. The symptoms of PTSD can be debilitating, impairing an individual’s ability to work and maintain relationships. Common examples of PTSD symptoms include:

  • Re-experiencing the trauma through memories, flashbacks, and nightmares
  • Avoiding people, places, and activities that are reminders of the trauma
  • Having difficulty sleeping and concentrating
  • Being hypervigilant
  • Displaying irritability or aggression
  • Having difficulty maintaining relationships with others

Unfortunately, many veterans experience PTSD stemming from their military service.

What is Sleep Apnea?

How to WIN Your Sleep Apnea VA Disability Claim

Sleep apnea is a potentially serious sleep disorder in which a person’s breathing is repeatedly interrupted during the course of the night. There are three main types of sleep apnea, including the following:

  • Obstructive Sleep Apnea – the most common form of sleep apnea; occurs when the throat muscles intermittently relax and block your airway during sleep
  • Central Sleep Apnea – occurs when your brain doesn’t send proper signals to the muscles that control breathing
  • Complex (Mixed) Sleep Apnea Syndrome – occurs when someone has both obstructive sleep apnea and central sleep apnea

The signs and symptoms of these three types of sleep apnea tend to overlap, sometimes making it difficult to determine which type you have.  Generally speaking, the most common symptoms of sleep apnea include: loud snoring, gasping for air during sleep, awakening with a dry mouth, morning headache, insomnia, hypersomnolence (i.e. excessive daytime sleepiness), and difficulty concentrating.

For a VA claim for sleep apnea secondary to PTSD, VA will require that a polysomnography, or sleep study, be conducted. Even if you have been previously diagnosed with sleep apnea, VA will not consider that diagnosis enough evidence to verify eligibility for compensation without having undergone a sleep study.

What is Secondary Service Connection?

Secondary Conditions to PTSD: VA Claims and Ratings

According to 38 CFR § 3.310, secondary service connection is when a disability is due to or aggravated by a service-connected condition.

In cases of secondary service connections, the medical nexus opinion must link a veteran’s secondary disability to their already service-connected disability, as opposed to, e.g., an in-service event, injury, or illness.

If you are in the initial claims stage, then we encourage you to try the free CCK VA Claim Builder tool. This tool helps veterans determine what is needed to build a strong VA claim the first time around.

How to Prove VA Sleep Apnea Secondary to PTSD

Here are examples of evidence that may support a VA claim of sleep apnea secondary to PTSD:

  • Medical records: Detailed documentation of both PTSD and sleep apnea diagnoses, including treatment histories, is crucial. These records should highlight the onset and progression of both conditions. Include evidence of any known specific contributors among PTSD symptoms or treatment (e.g., PTSD medication). Include a disability benefits questionnaire (DBQ) for sleep apnea (PDF).
  • Sleep study results: VA requires a sleep study confirming a sleep apnea diagnosis before granting service connection.
  • Lay evidence: Veterans can submit lay evidence detailing the overlapping onset and progression of PTSD and sleep apnea. Lay evidence may include letters from family members, friends, or fellow service members who have observed both the veteran’s sleep disturbances and PTSD symptoms and can corroborate their claims that it affects their quality of life..
  • Nexus letter: A nexus letter for sleep apnea secondary to PTSD is a medical opinion from a qualified healthcare provider that explicitly links the veteran’s sleep apnea to their service-connected PTSD. The letter should state that it is “at least as likely as not” that the sleep apnea is caused or aggravated by PTSD. CCK Law encourages veterans to consider asking their independent medical examiner to cite research supporting the connection between PTSD and sleep apnea.
  • C&P exam: Veterans should expect VA to schedule a compensation and pension (C&P) exam for sleep apnea secondary to PTSD. The examiner will review the evidence listed above and submit a DBQ to VA.

What Is the VA Rating for Sleep Apnea Secondary to PTSD?

VA evaluates sleep apnea under 38 CFR § 4.97-13, Diagnostic Code 6847 — Sleep Apnea Syndromes (Obstructive, Central, Mixed). Veterans are assigned a 0, 30, 50, or 100 percent sleep apnea VA rating based on the severity of their condition.

The VA rating for a secondary disability claim like sleep apnea secondary to PTSD is combined with a veteran’s other ratings using “VA math,” resulting in a combined rating that is used to determine monthly compensation. You can use CCK Law’s VA Disability Calculator to automatically calculate a combined rating.

Call CCK Law Today

VA often incorrectly rejects claims for sleep apnea secondary to PTSD. Therefore, it is important to provide adequate medical evidence. Military veterans should also be prepared to hire a VA-accredited and court-experienced advocate to appeal if necessary.

A VA-accredited law firm may also be in the best position to ensure that VA is following its rules and moving the claim forward efficiently, particularly with the criteria for sleep apnea likely to change in the near future.

If you need assistance or your VA rating for sleep apnea secondary to PTSD is denied, contact CCK Law, the most experienced veterans law firm in the U.S. You may call 800-544-9144 or request a free case evaluation online.

About the Author

Bio photo of Alyse Phillips

Alyse is a Supervising Attorney at Chisholm Chisholm & Kilpatrick. Since joining the firm in August of 2016, she has specialized in representing disabled veterans and their dependents before the United States Department of Veterans Affairs and the United States Court of Appeals for Veterans Claims.

See more about Alyse