Secondary Condition Claim · VASRD 6847
A condition caused or aggravated by an already service-connected disability can be granted its own service connection as a secondary condition under 38 CFR § 3.310. Here's how that works for Sleep Apnea Syndromes when it develops after Gastroesophageal Reflux Disease (GERD).
GERD can cause airway irritation during sleep
Primary condition · VASRD 7206
Gastroesophageal Reflux Disease (GERD)
GERD causes acid from the stomach to leak into the esophagus, leading to heartburn and discomfort.
Secondary condition · VASRD 6847
Sleep Apnea Syndromes
Sleep apnea is a disorder where breathing repeatedly stops or becomes shallow during sleep, fragmenting rest and often leading to loud snoring, daytime fatigue, and difficulty concentrating. Left untreated, it's also linked to higher blood pressure and heart strain, which is part of why the VA rates it based on treatment need rather than just the diagnosis.
The VA rates Sleep Apnea Syndromes the same way whether it's claimed directly or as secondary to Gastroesophageal Reflux Disease (GERD) — severity of Sleep Apnea Syndromes itself determines the percentage.
| Rating | Criteria |
|---|---|
| 50% | Must use a CPAP machine to sleep safely. |
| 0% | Sleep apnea present, but no machine needed. |
Example combined rating
30% Gastroesophageal Reflux Disease (GERD) + 50% Sleep Apnea Syndromes = 65%
The VA combines ratings with Table I of 38 CFR 4.25, not simple addition — 30% and 50% combine to 65%, not 80%. These figures are illustrative; your actual rating for each condition depends on your own evaluation.
Primary condition
Full Gastroesophageal Reflux Disease (GERD) guide
Secondary condition
Full Sleep Apnea Syndromes guide
See how Gastroesophageal Reflux Disease (GERD) and Sleep Apnea Syndromes combine with the rest of your service-connected conditions using the official VA combined-ratings formula.
Open the calculator