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Veterans Law

Sleep Apnea Secondary to PTSD Veterans (VA) Benefits

Alyse Phillips

September 12, 2019

Updated: June 25, 2024

tired man suffering from sleep apnea secondary to PTSD


What is Sleep Apnea?

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 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.

How Does VA Diagnose Sleep Apnea?

In order to confirm a sleep apnea diagnosis for VA disability compensation purposes, VA requires that a sleep study be conducted.  If you have been previously diagnosed with sleep apnea, but have not undergone a sleep study, VA will not consider that diagnosis enough evidence to verify eligibility for compensation.

What is Post-Traumatic Stress Disorder (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.  Unfortunately, many veterans experience PTSD stemming from their military service.  The symptoms of PTSD can often be very debilitating and have a negative impact on an individual’s life.  Common examples of PTSD symptoms include the following:

  • Re-experiencing the trauma through recurrent memories, flashbacks, and nightmares
  • Avoidance of people, places, and activities that are reminders of the trauma
  • Increased arousal such as difficulty sleeping and concentrating
  • Hypervigilance
  • Irritable or aggressive behavior
  • Difficulty maintaining relationships with others

Relationship Between Sleep Apnea and PTSD

Research shows that veterans with PTSD have a higher risk of developing sleep apnea.  There is also a direct correlation regarding the severity of the two conditions insofar as the more severe a veteran’s PTSD is, the more severe their sleep apnea will be.  This is due in part to the fact that many factors that can aggravate PTSD can also aggravate sleep apnea.  For example, sleep deprivation, insomnia, hyperarousal, and daytime sleepiness all affect both PTSD and sleep apnea.

If a veteran has both of these conditions, they may be entitled to VA disability benefits.

 Secondary Service Connection for Sleep Apnea

In order to receive VA disability benefits, veterans’ conditions must be service-connected.  To establish direct service connection, a veteran must demonstrate three things:

  • A current, diagnosed condition;
  • An in-service event, injury, or illness; and
  • A nexus (i.e. link) between the diagnosed condition and the in-service event.

Both sleep apnea and PTSD may be granted service connection if VA decides that these elements are met.  However, due to the relationship between the two conditions, veterans have an alternative path to service connection known as secondary service connection.  A secondary service-connected condition is one that resulted from an already service-connected condition.  In cases of secondary service connection, the medical nexus opinion must link a veteran’s secondary disability to their already service-connected disability.

Therefore, if veterans are service-connected for PTSD and later develop sleep apnea, they may be able to establish secondary service connection.

How to Prove Your Sleep Apnea is Secondary to Your PTSD

As mentioned above, secondary service connection is dependent upon establishing a nexus between the two conditions.  As such, it may be helpful to have a doctor submit a letter stating that there is a causal relationship between your sleep apnea and your PTSD.  Specifically, it may be beneficial for the doctor to state that they believe your sleep apnea is at least as likely as not caused by your PTSD.  In addition, you can submit lay evidence detailing the overlapping onset and progression of your PTSD and sleep apnea symptomatology.

Secondary Service Connection and Aggravation (VA Claims)

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