Many veterans with migraines, back pain or other conditions requiring pain relief take medications that can irritate the digestive tract and lead to the development of GERD. Common migraine medications, including NSAIDs and certain triptans, are known to cause acid reflux and heartburn over time. This Hill & Ponton guide explains service connection for GERD secondary to migraine medications, the VA rating criteria, and what it takes to win a disability claim.
How to Establish Service Connection
Research has shown that NSAIDs (nonsteroidal anti-inflammatory drugs), commonly used to treat migraines, can irritate the stomach lining and increase acid production, leading to symptoms like nausea, upper stomach pain, and vomiting. NSAIDs also slow digestion, reduce protective mucus, and weaken the muscle that keeps stomach acid from flowing back into the esophagus. These are factors that contribute to the development or worsening of GERD.
In people with mild GERD, NSAIDs can make symptoms worse, including heartburn, regurgitation, coughing, and a sour taste in the mouth. Over time, frequent acid reflux caused by these medications can damage the esophagus, leading to inflammation (esophagitis) or more serious complications if untreated.
Veterans experiencing GERD related to long-term use of migraine medication may qualify for a secondary service connection if they can demonstrate that their migraine treatment contributed to their GERD or worsened previously existing acid reflux. They will need to provide:
- A diagnosis for both conditions
- Service connection for the primary migraine condition
- A professional opinion (nexus letter) from a doctor about how medications caused or worsened the veteran’s GERD
- Lay evidence such as statements from the veteran, their family and fellow service members detailing the observed effects of migraine treatments on the veteran’s digestive system
VA Ratings for GERD Secondary to Migraines
As of May 2024, the VA may rate GERD secondary to migraine medications at 0%, 10%, 30%, 50% or 80% under Diagnostic Code 7206, depending on the daily symptoms, medication use and required treatments. But the previously used DC 7346 (with ratings of 0%, 10%, 30%, and 60%) still applies to pending claims dating from May 2024 or prior. In this circumstance, the VA can use either diagnostic code, if it’s more favorable to the veteran.
GERD Ratings Under DC 7206
- 80% – Documented history of recurrent or refractory esophageal stricture(s) causing dysphagia with at least one of the symptoms present: (1) aspiration, (2) undernutrition, and/or (3) substantial weight loss as defined by § 4.112(a) and treatment with either surgical correction of esophageal stricture(s) or percutaneous esophago-gastrointestinal tube (PEG tube)
- 50% – Documented history of recurrent or refractory esophageal stricture(s) causing dysphagia which requires at least one of the following (1) dilatation 3 or more times per year, (2) dilatation using steroids at least one time per year, or (3) esophageal stent placement
- 30% – Documented history of recurrent esophageal stricture(s) causing dysphagia which requires dilatation no more than 2 times per year
- 10% – Documented history of esophageal stricture(s) that requires daily medications to control dysphagia otherwise asymptomatic
- 0% – Documented history without daily symptoms or requirement for daily medications
Historical GERD Ratings Under DC 7346
- 60% – Symptoms of pain, vomiting, material weight loss, and hematemesis or melena with moderate anemia; or other symptom combinations productive of severe impairment of health.
- 30% – Persistently recurrent epigastric distress with dysphagia, pyrosis (heartburn), and regurgitation, accompanied by substernal or arm or shoulder pain, productive of considerable impairment of health.
- 10% – Two or more of the symptoms for the 30 percent evaluation of less severity.
- 0% – Asymptomatic or minimal symptoms controlled by diet or medication, not productive of health impairment.
Combining GERD and Migraine Ratings
When GERD is service connected as secondary to migraine medications, the VA assigns a separate disability rating for GERD in addition to the rating already in place for migraines. However, the VA does not simply add the percentages together. Instead, it applies the “whole person” method, starting with a baseline of 100% function and reducing it as new conditions are rated.
For example, if a veteran is rated at 30% for migraines and later receives a 30% rating for GERD, the GERD rating is applied to the remaining 70% of unimpaired function. Thirty percent of 70 is 21, which is then added to the original 30% to get a combined rating of 51%, which the VA rounds down to 50%. In this case, the veteran would be compensated at the 50% level, not 60%.
To make this easier, veterans can use the Hill & Ponton VA Disability Calculator, which automatically estimates combined ratings and monthly compensation based on the VA’s rating formula.
Case Example: GERD as Secondary to Use of NSAIDs and Other Medications for Migraines
Citation Nr: 18146578 (Oct. 31, 2018)
In an appeal for a February 2015 rating decision from the VA Regional Office in St. Paul, Minnesota, the Board of Veterans’ Appeals reviewed the case of a veteran who served on active duty from January 2000 to July 2004 and sought service connection for GERD as secondary to the medications he had taken for many years to treat his service‑connected migraine headaches.
During his July 2016 Board hearing, the veteran testified that he had never experienced heartburn prior to service, but that his GERD began only after years of using migraine medications such as Excedrin, Naproxen, Topamax, Imitrex, Rizatriptan, Amitriptyline, and other prescription and over‑the‑counter drugs.
The Medical Evidence That Helped Win This Claim
Robust Medical Records
VA treatment records documented a long history of gastrointestinal symptoms and the ongoing use of Omeprazole for GERD. The record also confirmed the veteran’s extensive migraine medication history, including multiple medications known to cause or aggravate GERD. The long-term, frequent use of triptans, Amitriptyline, Topamax, Depakote, and Excedrin was confirmed by an April 2013 letter from the veteran’s family physician.
Private Medical Opinion
In July 2016, the veteran submitted a detailed private medical opinion from Dr. L., Pharm.D., who interviewed the Veteran, reviewed his complete medical and medication history, and analyzed lifestyle factors. Dr. L. found that none of the Veteran’s underlying conditions would independently cause GERD, but that several of his migraine medications (including Naproxen, Meloxicam, Etodolac, and Rizatriptan) had well‑documented gastrointestinal side effects, including heartburn and GERD. Using Clinical Pharmacology data, Dr. L. explained that these medications had statistically significant rates of causing reflux symptoms and concluded that the Veteran’s GERD was most likely initiated and worsened by long‑term use of these drugs.
This evidence outweighed the negative opinion of a VA examiner who didn’t interview or examine the veteran and only based their conclusion on a short list of medication (Maxalt, Elavil, Botox, and several supplements), ignoring the broader medication history documented in VA and private records. The examiner also failed to discuss known gastrointestinal side effects of the medications the Veteran had taken consistently for over a decade.
The Board found that the most credible, well‑supported medical evidence showed the veteran’s GERD was proximately caused by the long‑term use of medications prescribed for his service‑connected migraine headaches. The comprehensive private medical opinion was based on accurate facts, clinical data, and sound reasoning, and it aligned with the Veteran’s consistent testimony and medication history. The Board concluded that the Veteran’s GERD was at least as likely as not due to the side effects of his migraine medications and granted secondary service connection.
This case demonstrates how veterans can successfully claim GERD as secondary to service-connected conditions like migraines, back pain or other disabilities treated with long-term medications that contribute to the development of GERD symptoms. Medical evidence and expert opinions linking the primary condition to the secondary one are crucial for building a strong case.
My Claim Was Denied, What Can I Do?
Choosing the best path to appeal a VA decision depends on the specifics of your case and why the VA denied your claim. For guidance on your next steps, contact us for a free review of your case. We’ll help you understand your options and how to move forward.
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