Insomnia Secondary to Tinnitus: VA Evidence and Rating

VA can grant insomnia secondary to tinnitus, and the Board of Veterans' Appeals did so in April 2025 on a VA examiner's opinion that the veteran's insomnia disorder was caused by his service-connected tinnitus. The rating is where these claims get complicated. Tinnitus is capped at a single 10% rating, insomnia has no diagnostic code of its own, and Board judges have split on whether insomnia gets its own rating or is rated together with tinnitus. Both questions turn on the same evidence: a clinical diagnosis of insomnia disorder, not just a note that the ringing makes sleep hard.

What the Board did with insomnia secondary to tinnitus

In A25034700 (April 15, 2025), the veteran wrote that he drowned out the ringing with a television, music and a fan to fall asleep and used over-the-counter sleep aids. He submitted an Insomnia Severity Index showing very severe trouble falling asleep and moderate trouble staying asleep. A September 2023 VA examiner diagnosed insomnia disorder and found it at least as likely as not caused by his tinnitus, reasoning that sleep disturbance is a common complaint among people with tinnitus and that more severe tinnitus goes with more sleep problems. The Board found the evidence at least in approximate balance and granted service connection for insomnia. In the same decision it denied a tinnitus rating above 10%, because 10% is the maximum.

The grant rested on a named diagnosis and an examiner who tied it to the veteran's tinnitus. A record that says only "poor sleep" gives a rater much less to work with.

For context, Claim Raven's analysis of Board decisions shows secondary claims were granted in 35.1% of 19,189 condition records and remanded in 41.5%, compared with 41.2% granted among 40,026 direct claims. On Claim Raven's statistics page, secondary claims with an opinion the Board described as strong went with favorable outcomes in 94.1% of 2,973 records, against 1.7% with a weak opinion. These are outcomes in already-disputed Board appeals from mostly 2024 to 2025, and the Board's quality coding partly reflects its own conclusion, so they describe patterns, not your odds.

How insomnia is rated when tinnitus is the cause

Tinnitus is rated under Diagnostic Code 6260 in 38 C.F.R. § 4.87 at 10%, and Note (2) allows only a single rating whether the sound is in one ear, both ears or the head. Insomnia is not listed in the rating schedule, so VA rates it by analogy to a mental disorder under the General Rating Formula in 38 C.F.R. § 4.130, whose levels include "chronic sleep impairment."

Two 2025 Board decisions reached different answers on a separate rating:

• In A25021662 (March 10, 2025), VA had rated insomnia together with tinnitus under one combined code. The Board granted a separate insomnia rating. It reasoned that tinnitus and insomnia are rated under different criteria and different exam forms, and that the veteran's symptoms did not overlap: trouble hearing on the phone from tinnitus, and fatigue, poor memory and concentration, and irritability from insomnia.
• In A25029901 (April 1, 2025), the Board quoted VA's adjudication manual, M21-1 V.iii.13.1.l, that a separate evaluation "is not warranted for insomnia that is considered secondary to, or a symptom of, another disability." It rated "tinnitus with insomnia" as one disability under the mental disorders code for unspecified anxiety disorder and raised it from 10% to 30% based on the insomnia symptoms.

VA's own manual points toward the combined approach, so expect it at the regional office: insomnia caused by tinnitus evaluated together with tinnitus rather than as a second rating. That can still pay more than tinnitus alone, because the combined disability can be scored on the mental disorders formula, as it was in A25029901. A separate rating has come from a Board judge who read the rules differently, not from the manual. Either way, 38 C.F.R. § 4.14 bars paying twice for the same symptom. If you are already service connected for PTSD, depression or anxiety, VA usually treats insomnia as part of that mental health rating instead. The insomnia condition guide explains the current version of the manual rule and the rating levels, and the M21-1 insomnia update explainer walks through the symptom-or-disorder question.

What the medical guidance supports

The 2024 VA/DoD tinnitus clinical practice guideline tells clinicians to ask how tinnitus affects sleep and to check for co-occurring insomnia, and it says tinnitus can make co-occurring insomnia worse, while insomnia can in turn affect how severe tinnitus feels. An older study of tinnitus-clinic patients found that continuing sleep trouble went with louder and more severe reported tinnitus. That two-way relationship supports both a causation theory and an aggravation theory, and it is why the order of events in your records matters.

If insomnia existed before tinnitus, the claim is about aggravation under 38 C.F.R. § 3.310. The regulation's text asks for a baseline from medical evidence before the worsening and pays only the increase above it. After Spicer v. McDonough (2023), VA also cannot use that regulation to reject a claim where your sleep problem would be less severe but for tinnitus. Older sleep complaints are the baseline, not a reason to stop.

Separate insomnia disorder from other sleep problems

A sleep complaint can have several sources, and the opinion has to sort them out:

A useful sleep note records when you went to bed, when the ringing was noticeable, whether you woke, and how you functioned the next day. It should not assign a medical cause.

Questions for the clinician about tinnitus and insomnia

• Do I meet the criteria for insomnia disorder, and when is it first documented?
• In my history, does tinnitus explain the insomnia, make it worse, or neither?
• Have sleep apnea, mood conditions, pain, medicines and schedule been ruled in or out?
• Which of my sleep symptoms are distinct from anything VA already rates?

The guide to nexus letters for secondary conditions explains how to frame causation and aggravation for any secondary opinion.

A pending bill would change tinnitus ratings

Section 108 of the Take Care of America's Veterans Act, H.R. 9237, would end a separate compensable rating for tinnitus in claims filed after it becomes law, except for 10% when tinnitus is tied to service-connected hearing loss that is otherwise noncompensable. The bill says the change could not reduce compensation already in effect, and the introduced text does not mention secondary service connection. It is not law: the latest House action, on July 16, 2026, postponed further proceedings, and the Senate version, S. 4744, has been on the Senate calendar since June 11, 2026 (checked September 23, 2026). The analysis of the bill covers the details. The tinnitus condition guide covers the current rule.

Sources and scope

Checked September 23, 2026: the current eCFR text of 38 C.F.R. §§ 3.310, 4.14, 4.87 (DC 6260) and 4.130; the Spicer opinion; the 2024 VA/DoD tinnitus guideline; the linked study; the text and action history of H.R. 9237 and S. 4744 through the congress.gov data service; and the full text of Board decisions A25034700, A25021662 and A25029901, each binding only its own appeal. Claim Raven, which publishes this guide, sells claim-preparation tools such as the nexus readiness check on this page.