Headaches are one of the most commonly reported effects of a head injury, and one of the most commonly misunderstood parts of a TBI rating. The confusion comes from the fact that the regulation treats them two different ways depending on whether they carry their own diagnosis.
This guide is part of our series on VA claims for traumatic brain injury. Our migraine and headache guides cover the rating criteria in more depth.
Headaches as a subjective symptom
Under Diagnostic Code 8045, headache is listed among the subjective symptoms facet. When headaches are reported without a separate diagnosis, they are assigned a level of impairment within that facet based on how much they interfere with daily activity.
Headaches with their own diagnosis
The same regulation instructs that residuals with a distinct diagnosis be evaluated under the diagnostic code for that condition. Diagnosed post-traumatic or migraine headaches are therefore commonly evaluated under the migraine criteria in 38 CFR 4.124a, which turn on the frequency of prostrating attacks and their economic effect.
38 CFR 4.14 still applies: the headaches cannot also be counted inside the subjective symptoms facet if they are being rated under their own code.
Where veterans start
Every case is different, and there is no obligation at any step. When veterans want to understand what their records actually support, these are the two most common starting points:
- Medical records review
A licensed physician reviews your records for a $250 flat fee and identifies which conditions the available evidence may support. The fee is refunded in full if nothing supportable is identified.
- Nexus letter
When the records support one, a licensed provider writes the medical opinion that addresses the link between your condition and your service.
Why documentation of frequency matters
The migraine criteria are built around frequency and severity over time, not around a single examination. Treatment records, prescriptions, missed work, and a contemporaneous log of attacks describe that pattern in a way a one-time exam cannot.
The VA's page on evidence needed for a disability claim explains the categories of evidence the VA considers, including lay statements.
Secondary headaches
When headaches develop after a head injury that is already service connected, 38 CFR 3.310 provides the path for service connection as a secondary condition. Our secondary service connection guide explains how that theory works.
This guide is educational. It summarizes the VA's own published rules and links to the exact sources it relies on. It is not legal or claims advice, and it is not a substitute for an accredited representative, who can advise you about your specific claim. Accredited help is free - search the VA's accreditation database to find a Veterans Service Organization, accredited agent, or attorney.
Frequently asked questions
Are headaches after a TBI rated separately?
They can be. Diagnostic Code 8045 directs that a residual with its own diagnosis be evaluated under that condition's own diagnostic code, so diagnosed post-traumatic headaches are commonly rated under the migraine criteria rather than folded into the facet table.
What is a prostrating attack?
The migraine criteria in 38 CFR 4.124a use the term prostrating, describing attacks severe enough to require stopping activity. The regulation ties the evaluation levels to how often prostrating attacks occur and whether they are productive of severe economic inadaptability.
Can headaches be secondary to a service-connected TBI?
Yes. 38 CFR 3.310 provides for service connection of a condition proximately due to or aggravated by an already service-connected disability.