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Board of Veterans' Appeals · AMA series

Entitlement to an increased compensable disability rating for hemorrhoids is denied.

July 30, 2026Citation Nr. A26069933Docket 250725-570014va.gov source

  • Hemorrhoids (increased compensable disability rating)Denied
  • Migraine headaches (increased disability rating higher than 50 percent)Denied

Board reasoning

The Board determined that the hemorrhoids did not meet the criteria for a higher rating at any point during the appeal period, noting that the symptoms more nearly approximated noncompensable or lower ratings and discounted any medication effects per Ingram v. Collins. For migraines, the Board found no basis to grant a rating higher than 50 percent, noting the criteria are a laddered, non-incidentally inclusive scale, that the current 50 percent rating already reflects very frequent, completely prostrating and prolonged attacks with severe economic impact, and that there is no evidence supporting a higher rating or a separate rating for symptoms outside DC 8100.

Issues

  • Hemorrhoids (increased compensable disability rating)Denied
  • Migraine headaches (increased disability rating higher than 50 percent)Denied

Authorities

  • Johnson v. Wilkie, 30 Vet. App. 245defines prostrating as requiring full impact and notes the laddered nature of DC 8100
  • Pierce v. Principi, 18 Vet. App. 440explains interpretation of “productive of severe economic inadaptability”
  • Morgan v. Wilkie, 31 Vet. App. 162duty to maximize benefits and exhaust schedular alternatives before extraschedular
  • Doucette v. Shulkin, 28 Vet. App. 366Board not required to address issues not raised

Extracted with gpt-5-nano-2025-08-07. Citations are kept only when they appear in the decision text.