Chronic Fatigue Syndrome

Of the ten condition cornerstones I've pulled from the BVA dataset, chronic fatigue syndrome has the lowest grant rate of any of them. 911 cases. 16.1% granted. 58.3% denied. And 369 of those 531 denials are tagged with the same single reason: diagnosis missing.

That is not a nexus story. That is not a severity story. That is a story about the front door of the claim being closed before anything else gets argued. The Board can't grant service connection for chronic fatigue syndrome if it doesn't agree that the veteran has chronic fatigue syndrome, and across the cases I read, the diagnostic disagreement is where the file falls apart far more often than the medical opinion. The condition has strict diagnostic criteria, the VA's examiners often don't apply those criteria fully, and the appellant ends up at the Board with a chart that says "fatigue" instead of a chart that says "chronic fatigue syndrome." I want to walk through why this happens, what the Fukuda criteria actually require, where the Gulf War presumption under 38 CFR § 3.317 fits in, how DC 6354's five-tier rating schedule works, and what the 16.1% grant rate is actually telling us about this claim type.

TL;DR

• Chronic fatigue syndrome is the lowest-grant cornerstone condition in my BVA dataset. 911 cases, 16.1% granted (147), 58.3% denied (531), 25.6% remanded (233).
• Diagnosis-missing accounts for 369 of 531 denials, roughly 70% of all denials. This is the wall.
• 393 cases invoke the Gulf War presumption under 38 CFR § 3.317. Even with that lever, the presumptive lane only grants at 23.3%.
• Strong nexus grants at 83.7%. Only 43 cases have strong nexus. The rest of the file usually never gets to that question.
• DC 6354 has five rating tiers: 10%, 20%, 40%, 60%, 100%. The high tiers exist. The Board awarded 100% in 7 of these cases.
• Lay statements quoted in the decision: 20.6% grant when quoted vs 13.4% when not. The gap is real but small here, because the diagnostic wall sits in front of it.

911 Cases. and a 16.1% Grant Rate

When I rank the major condition cornerstones I've written about by BVA grant rate, the ordering is rough but real. PTSD and anxiety sit at the top of the mental-health cluster around 47-50%. COPD and sinusitis sit in the 30-31% range. Fibromyalgia, also a Gulf War presumptive, sits at 23.2%. Chronic fatigue syndrome sits at the bottom at 16.1%.

That is the lowest number I have for any cornerstone condition I've analyzed, and it caught me off guard the first time I sorted the table. Chronic fatigue is a recognized Gulf War presumptive. The regulatory framework exists. The diagnostic code exists. The rating schedule reaches 100%. And the Board still grants it less than one time in six.

The full outcome split across the 911 cases:

• Granted: 147 (16.1%)
• Denied: 531 (58.3%)
• Remanded: 233 (25.6%)
• Dismissed: handful, rounding into the others

The denial-heavy distribution is the headline. Most claim types I've looked at run roughly 30-30-40 across granted, denied, and remanded. This one is the inverse. The Board is denying chronic fatigue claims outright at almost twice the average rate, and the remand share is suppressed compared to other respiratory or mental-health cornerstones.

A high denial rate paired with a low remand rate usually means the Board is deciding on the merits and concluding the case doesn't make it across a threshold. The threshold here, as I'll walk through, is almost always the diagnostic threshold. The Board isn't sending the file back for more development. It's looking at the medical evidence, finding no diagnosis of CFS that meets the recognized criteria, and denying.

The Diagnosis Wall: 369 of 531 Denials

If I had to summarize the entire chronic fatigue claim pattern at the BVA in one sentence, it would be this: the disagreement isn't about whether the veteran is tired. It's about whether the veteran has chronic fatigue syndrome as a diagnosable medical condition.

The denial-reason breakdown for the 531 denied cases:

• diagnosis_missing: 369
• severity_insufficient: 45
• nexus_gap: 26
• other / unclassified: roughly the remainder

369 of 531 is roughly 70 percent. The next-largest category is severity at 45 cases. Then nexus at 26. The conversation most veterans expect to have at the Board, "did your service cause this?", barely happens here. The conversation that does happen is "do you actually have this?"

Read that again. Seventy percent of chronic fatigue denials at the Board are about the diagnosis itself, not about service connection.

This is unusual. Across the broader dataset, diagnosis-missing is rarely the dominant denial reason for any condition. For COPD, the modal denial reason is nexus gap. For sinusitis, it's a mix of nexus gap and severity. For most respiratory and orthopedic claims, the diagnosis exists in the chart and the fight is over the link to service. For chronic fatigue, the fight is over the chart itself.

The pattern is consistent in the language I see in denied decisions. The Board describes "subjective fatigue complaints," "non-specific tiredness," "fatigue not meeting the criteria for chronic fatigue syndrome," "no formal diagnosis of CFS in the record." The fatigue is acknowledged. The diagnosis isn't.

Why this happens has a clinical explanation that lives outside my data, but the explanation is well-supported in the medical literature. Chronic fatigue syndrome has strict diagnostic criteria that require an affirmative process of exclusion, symptom characterization, and duration assessment. C&P examiners, many of whom are general medical providers rather than specialists, frequently document the fatigue, evaluate against the most obvious differential diagnoses, and stop short of the full criteria walk-through that CFS requires.

The result on paper is "fatigue, etiology unclear" instead of "chronic fatigue syndrome." Those are not the same diagnosis for VA rating purposes.

The Fukuda Criteria Trap

To understand the diagnostic wall, you have to understand what a clean CFS diagnosis actually requires.

What the Fukuda criteria demand

The recognized framework is the CDC's 1994 Fukuda criteria (sometimes refined by later case definitions like the Canadian Consensus Criteria or the 2015 Institute of Medicine criteria, which the IOM proposed renaming the condition "Systemic Exertion Intolerance Disease"). The VA's rating schedule at 38 CFR § 4.88a uses a definition that incorporates the core Fukuda elements.

The criteria require:

• Clinically evaluated, unexplained, persistent or relapsing chronic fatigue that is of new or definite onset, is not the result of ongoing exertion, is not substantially alleviated by rest, and results in substantial reduction in previous levels of occupational, educational, social, or personal activities
• The concurrent occurrence of four or more specified symptoms, all of which must have persisted or recurred during six or more consecutive months of illness and must not have predated the fatigue
• The symptoms include impaired short-term memory or concentration, sore throat, tender lymph nodes, muscle pain, multi-joint pain without joint swelling or redness, headaches of a new type or severity, unrefreshing sleep, and post-exertional malaise lasting more than 24 hours
• Other medical conditions that explain the fatigue must be excluded

That is a multi-part diagnostic process that requires the examiner to (a) measure the duration, (b) characterize the fatigue itself, (c) catalog the concurrent symptoms, (d) rule out competing diagnoses, and (e) document the functional impact. It's not a one-line conclusion.

The C&P exams I see in denied decisions rarely walk through all of this. The exam acknowledges fatigue. It notes that the veteran reports symptoms. It sometimes runs basic lab work to rule out anemia, thyroid disease, or sleep apnea. And it concludes with language like "chronic fatigue, etiology undetermined" or "fatigue, possibly related to depression."

Either of those conclusions is enough for the Board to find that a CFS diagnosis isn't supported. The diagnosis-missing denial follows automatically.

The veterans whose claims do get granted often have one or more of three things in the file: a specialist's diagnosis (rheumatology, internal medicine, infectious disease) that explicitly addresses the Fukuda criteria, a private medical opinion that walks through the criteria and concludes the veteran meets them, or a long treatment history where the diagnosis has been established and re-affirmed across multiple providers.

The veterans whose claims get denied usually have a chart that reads "fatigue" without the structured diagnostic workup behind it.

Gulf War Presumption: 393 Cases, Still Not Enough

The Gulf War presumption under 38 USC § 1117 and 38 CFR § 3.317 is one of the strongest regulatory tools in VA law. It allows service connection for undiagnosed illnesses and certain medically unexplained chronic multisymptom illnesses for veterans with qualifying service during the Persian Gulf War. The statute covers the Southwest Asia theater and also names Afghanistan, Israel, Egypt, Turkey, Syria, and Jordan.

Chronic fatigue syndrome is specifically named in § 3.317 as one of the medically unexplained chronic multisymptom illnesses that qualifies. For Gulf War veterans, the regulation provides what should be a clean path to service connection without a traditional nexus opinion.

The dataset reflects veterans trying to use this lane:

• Gulf War presumptive cases (in the CFS subset): 393
• Burn-pit or PACT exposure theory tagged in the decision: 88
• Smaller numbers in other presumptive categories

393 of 911 cases, 43 percent of the entire CFS appeal pool, invoke the Gulf War presumption. That's a higher presumptive-invocation rate than almost any other cornerstone condition.

And yet the presumptive lane grants at only 23.3 percent. That's better than the 16.1% overall rate, but it's far below what a presumption should deliver. Compare it to sinusitis or COPD under the PACT Act burn-pit presumption, or Parkinson's under the Agent Orange presumption. Those comparisons describe other regulatory levers; they do not make CFS itself a § 1120 burn-pit presumptive disease.

Why doesn't the presumption work as well here? Because the presumption is for chronic fatigue syndrome, the diagnosed condition. It doesn't presume the diagnosis itself. It presumes the service connection of that diagnosis when the veteran qualifies under § 3.317.

If the C&P examiner concludes the veteran has fatigue without meeting CFS criteria, the presumption doesn't engage. The Board can find Gulf War service. The Board can find covered symptoms. The Board cannot grant CFS as a presumptive condition when the medical record doesn't support a CFS diagnosis in the first place.

This is the asymmetry that traps the claim. Veterans assume the Gulf War presumption is a substitute for the diagnostic workup. It isn't. It's a substitute for the nexus opinion. The diagnostic step still has to be cleared.

There's a parallel pathway under § 3.317 for an "undiagnosed illness": chronic objective signs or symptoms that, after history, examination, and testing, cannot be attributed to a known clinical diagnosis. That is different from the MUCMI definition, which concerns a diagnosed illness without conclusive pathophysiology or etiology. The undiagnosed-illness lane can sometimes apply when persistent fatigue does not meet CFS criteria and remains medically unexplained. The CFS-specific lane still requires support for the CFS diagnosis.

DC 6354. The Five-Tier Rating Schedule

For the 16.1% of cases that do clear the diagnostic threshold and reach the rating phase, the rating schedule itself is unusually generous compared to most condition cornerstones.

The five-tier DC 6354 schedule

DC 6354 (chronic fatigue syndrome) under 38 CFR § 4.88b uses a five-tier schedule:

• 10%: Signs and symptoms of CFS that wax and wane but result in periods of incapacitation of less than 1 week total duration per year, OR symptoms controlled by continuous medication
• 20%: Signs and symptoms that are nearly constant and restrict routine daily activities by less than 25 percent of pre-illness level, OR symptoms that wax and wane resulting in periods of incapacitation of at least 1 but less than 2 weeks total duration per year
• 40%: Signs and symptoms that are nearly constant and restrict routine daily activities by 25 to 50 percent of pre-illness level, OR symptoms that wax and wane resulting in periods of incapacitation of at least 2 but less than 4 weeks total duration per year
• 60%: Signs and symptoms that are nearly constant and restrict routine daily activities to 50 to 75 percent of pre-illness level, OR symptoms that wax and wane resulting in periods of incapacitation of at least 4 but less than 6 weeks total duration per year
• 100%: Signs and symptoms that are nearly constant and so severe as to restrict routine daily activities to less than 50 percent of pre-illness level, OR symptoms that wax and wane resulting in periods of incapacitation of at least 6 weeks total duration per year

The 100% tier exists schedularly. Unlike fibromyalgia (DC 5025), which caps at 40% on the rating schedule, CFS at 100% is reachable without a TDIU bridge.

The rating distribution among granted cases in my dataset:

• 10%: 12 cases
• 40%: 8 cases
• 60%: 35 cases (the modal tier among grants)
• 100%: 7 cases

The 60% rating being modal among grants is striking. For most condition cornerstones, the modal grant lands at 10% or 30%. For CFS, the modal grant lands at 60%. That tells me something specific about the selection: the veterans who get past the diagnostic wall tend to be the ones whose symptoms are well-documented as severe. Mild CFS cases probably either don't get the formal diagnosis or settle at the regional office level. The Board sees the severe cases that the front door has filtered for.

Seven veterans were rated 100% schedular under DC 6354 in this dataset. That's a small number, but it's not zero, and 100% schedular is meaningfully different from 100% via TDIU. A 100% schedular rating triggers certain ancillary benefits (CHAMPVA, education benefits for dependents under DEA, automatic Special Monthly Compensation considerations) that TDIU doesn't always trigger. For a veteran whose condition genuinely restricts routine daily activities to less than 50 percent of pre-illness level, DC 6354 has a 100% door.

Why Presumptive Connection Wins Only 23% Here

I want to sit with the presumptive-lane number a little longer because it's such an anomaly.

The connection-type breakdown for chronic fatigue:

• Direct: 361 cases, 19.7% grant
• Presumptive: 258 cases, 23.3% grant
• Secondary: 104 cases, 14.4% grant
• Aggravation: small number, 19.0% grant

The presumptive lane is the highest of the four, but the gap between presumptive and direct is only about 4 percentage points. For comparison, the presumptive-versus-direct gap for sinusitis was 22 points (52.4% vs 30.5%). For COPD, the gap was 4.5 points (43.2% vs 38.7%). For Parkinson's, the gap is roughly 1 point (44.7% vs 43.7%), but both lanes start from a much higher base.

What this means in practice: the Gulf War presumption is technically engaged in 393 cases and used as the basis for the connection theory in 258. But because the diagnostic wall blocks most of these cases before the connection analysis matters, the presumption can't do most of the work it should.

A working presumption removes the nexus question. It doesn't remove the diagnosis question. Section 3.317 says, in effect: if you served in covered locations during covered periods and you have a qualifying diagnosed condition like CFS, the condition is presumed connected to your service. It does not say: if you served in covered locations and you report fatigue, the VA will presume you have CFS.

The structural mismatch is between the diagnostic difficulty of CFS and the strength of the presumption that follows the diagnosis. Veterans whose claims clear the diagnostic step get a clean presumptive lane. Veterans whose claims don't clear the diagnostic step never benefit from the presumption at all, because the presumption sits behind a door they can't open.

This is the part where my data and the regulatory framework agree completely. The fight in this claim type is at the diagnosis. Once the diagnosis is established, the connection theory becomes accessible. As long as the diagnosis is contested, the connection theory is irrelevant.

Strong Nexus Saves 84%. But Only 43 Cases Have It

The nexus quality breakdown across the 911 CFS cases:

• Strong nexus: 43 cases, 83.7% grant
• Adequate nexus: 162 cases, 56.8% grant
• Weak nexus: 237 cases, 0.0% grant
• Missing nexus: 276 cases, 0.4% grant
• Not applicable: 193 cases, 9.3% grant

Strong nexus wins almost as much for CFS as it does for everything else. 83.7% is a normal strong-nexus grant rate, slightly below the dataset's 89.5% overall, but well within the range.

The problem is that only 43 of 911 cases achieved strong nexus. That's roughly 5 percent. For COPD, 347 of 3,218 cases had strong nexus, about 11 percent. For sinusitis, 362 of 2,181 had strong, about 17 percent. For CFS, the strong-nexus rate is half or less of those condition cornerstones.

The reason is downstream of the diagnostic issue. A nexus opinion is the medical link between a diagnosed condition and military service. When the diagnosis itself is contested, the nexus opinion has nothing stable to link to. The examiner can't write a strong nexus letter for a condition the examiner isn't comfortable diagnosing in the first place. So the file ends up with a "fatigue of unclear etiology" entry and no nexus opinion, or a nexus opinion that hedges on the diagnosis itself.

The 237 cases coded as weak nexus and 276 as missing nexus, together more than half of the entire CFS subset, are mostly cases where the medical record never got to a place where a nexus discussion was possible. The denial that follows is denominated as "diagnosis missing," but the upstream cause is the absence of a structured workup against the Fukuda criteria.

The 43 cases with strong nexus and an 83.7% grant rate represent the path that works. Get to a real diagnosis from a clinician who can write the diagnostic basis explicitly, and the connection theory follows. Without the diagnosis foundation, the nexus opinion can't carry the case.

The Lay Statement Variable

Lay statements quoted in the Board's decision are usually a meaningful grant-rate predictor across condition cornerstones. For sinusitis, the gap was 30+ percentage points. For PTSD claims, it can run higher. For chronic fatigue, the gap is smaller:

• Lay statement quoted in the decision: 374 cases, 20.6% grant
• Lay statement not quoted: 522 cases, 13.4% grant

A 7-point gap is real but modest compared to other conditions. Why is the lay-statement effect smaller here? Because lay statements describe symptoms, and the Board agrees the veteran has symptoms in most CFS cases. The fight isn't over whether the veteran reports fatigue. It's over whether the documented clinical record meets the diagnostic criteria. A lay statement can articulate functional impact ("I sleep 14 hours and still wake exhausted, I can't work, I had to drop out of graduate school"), but it can't substitute for the medical workup against Fukuda criteria.

In the cases where lay statements do move the dial, they usually do so by giving the Board a concrete picture of functional impairment that supports the higher rating tiers under DC 6354. The diagnosis still has to exist in the medical record. The lay statement helps with severity once the diagnosis is established.

If you're preparing a CFS claim, the lay statement still matters. It's worth doing well, and the 20.6% versus 13.4% spread says quoted statements do better. But it's not the primary lever on this claim type. The primary lever is upstream.

What I Can't Tell You From This Data

I owe you the honest read on the limits of this analysis.

I can't tell you whether your individual symptom profile would meet Fukuda criteria on a careful clinical evaluation. That's a question for an internist, rheumatologist, or specialist in chronic fatigue medicine, working from your records and your symptom history. The dataset shows me what the Board did with the records in front of it. It doesn't show me which veterans had a CFS diagnosis available and didn't pursue it, or which veterans were misdiagnosed at the front end.

I can't tell you whether your service qualifies under § 1117 and § 3.317. The covered locations and Persian Gulf War period are specific. Service in the broader Southwest Asia theater from August 2, 1990 onward generally qualifies, and the statute now names six additional countries. Service in adjacent regions sometimes does not qualify under this framework even when it qualifies under a different toxic-exposure presumption. The current statute is where the answer lives, and VA's exposure tracking can miss some qualifying service.

I can't tell you whether the alternative "undiagnosed illness" lane under § 3.317 would catch your case where the specific CFS diagnosis didn't. That depends on how your symptoms present, how the C&P examiner characterizes them, and whether the regional office initially evaluated under the right framework. The Board does grant undiagnosed-illness cases when the diagnosis is unclear but the multisystem symptom complex is documented. That lane has its own analytic patterns I haven't broken out here.

I can't tell you whether you'd be better off pursuing a CFS claim or pursuing the underlying functional limitations through other conditions (depression, fibromyalgia, irritable bowel, sleep disorder) that may have clearer paths to service connection in your record. That's a strategic question that requires looking at the full picture of your claim.

And I can't tell you why the C&P workup tends to be incomplete for CFS specifically. The reasons are probably some mix of examiner specialty mismatch, time constraints on the exam, the structural difficulty of the Fukuda criteria, and the absence of an objective biomarker for CFS. The data shows the result. It doesn't fully explain the cause.

What the data can tell you is the structural shape of the problem. The denial wall here is upstream of nexus, upstream of severity, upstream of connection theory. It's at the diagnosis itself.

The Three Documentation Pieces That Matter

If I were filing or appealing a CFS claim today, the three pieces of the file that would matter most to me are downstream of one upstream priority: securing a clinical diagnosis that walks through the recognized criteria.

One: A specialist evaluation that addresses the Fukuda criteria explicitly. This is the single highest-yield investment in a CFS claim. A rheumatologist, internist, or infectious disease specialist who is comfortable with chronic fatigue syndrome can produce a clinical record that walks through the diagnostic criteria, documents the duration of symptoms, characterizes the fatigue, catalogs the concurrent symptoms, and rules out competing diagnoses. That's a different record than a primary care note that says "fatigue, chronic." The Board reads the language. The diagnostic walk-through is what gets the diagnosis recognized.

Two: A treatment history documenting persistence and functional impact. The Fukuda criteria require six months of symptoms. The DC 6354 rating tiers require documented periods of incapacitation or restricted routine activities. A treatment record that spans multiple years, captures multiple provider visits, and documents how the symptoms restrict your daily activities is what supports both the diagnosis and the rating tier. The veterans who clear the diagnostic wall and also clear into the 60% or 100% tiers usually have rich longitudinal records, not a single recent evaluation.

Three: A nexus or presumptive framework that engages with the diagnosis. If you served in a covered Gulf War location during a covered period, the § 3.317 presumption is your lane and you should file the claim under it. If your service doesn't qualify for the presumption, the direct-connection path requires a nexus opinion that explicitly identifies a CFS diagnosis (not "fatigue") and links it to a documented in-service exposure or event. Generic "fatigue is related to service" language doesn't move CFS claims. Specific "this veteran meets the Fukuda criteria for chronic fatigue syndrome, with onset following [documented in-service event/exposure], and the connection is at least as likely as not" language does.

None of this guarantees a grant. The 16.1% overall rate is what it is, and the structural problems with C&P workup for this condition won't be solved by any single veteran's claim strategy. But the cases that do win at the Board are the cases where the diagnostic foundation is solid, and that foundation is something you can invest in before the C&P exam, not after it.

Bottom Line

Chronic fatigue syndrome is rated under 38 CFR § 4.88b DC 6354 with a five-tier rating schedule running 10%, 20%, 40%, 60%, and 100%. It is presumptively service-connected for qualifying Gulf War veterans under 38 USC § 1117 and 38 CFR § 3.317. And yet across 911 BVA cases, the grant rate is 16.1%, the lowest of any cornerstone condition I've analyzed. The wall is diagnostic, not regulatory. 369 of 531 denials are tagged "diagnosis missing," meaning the Board concluded the medical record didn't support a CFS diagnosis under the recognized criteria. The Gulf War presumption is invoked in 393 cases but grants at only 23.3%, because the presumption removes the nexus question rather than the diagnosis question. Strong nexus opinions grant at 83.7%, but only 43 of 911 cases achieve strong nexus, because a nexus opinion can't link a contested diagnosis to service. The single highest-yield action on a CFS claim is securing a specialist evaluation that walks through the Fukuda criteria explicitly, because the diagnostic foundation is what every other piece of the claim depends on. The rating ladder is generous when the claim clears the front door, with 60% as the modal grant tier and 7 cases reaching 100% schedular in this dataset. For Gulf War veterans, the presumption is real and worth invoking. For all veterans, the diagnosis is the entire claim.

Methodology and Limitations

• Data source: Outcome statistics, nexus-quality coding, denial-reason classification, connection-type tagging, and rating-tier distribution are drawn from Claim Raven's analysis of 101,518 condition records drawn from 49,876 Board decisions, including 911 chronic fatigue cases. Rating schedule framework is drawn from 38 CFR § 4.88a (diagnostic definition) and § 4.88b (rating tiers under DC 6354). The Gulf War presumption framework is from 38 USC § 1117 and 38 CFR § 3.317. Fukuda diagnostic criteria are paraphrased from the CDC's 1994 case definition for CFS. 2026 VA disability compensation rates referenced for context where applicable (100% single vet = $4,044.91/month).
• Sample size: 911 BVA decisions involving chronic fatigue syndrome, with outcomes split 16.1% granted (147), 58.3% denied (531), 25.6% remanded (233). Connection-type subdivisions cover 361 direct, 258 presumptive, 104 secondary, and smaller aggravation. The coded decisions include 393 Gulf War invocations and 88 burn-pit or PACT exposure-theory invocations; those tags can overlap, and a burn-pit exposure theory is not itself proof that CFS appears on the § 1120 disease list.
• Classification approach: Cases coded as "chronic_fatigue" based on the condition extraction from BVA decisions. Diagnosis-missing denial-reason coding reflects the Board's primary articulated reason in each decision. Nexus quality (strong/adequate/weak/missing/not_applicable) is assigned based on the Board's treatment of the medical opinion language.
• Limitations:
• The 911 CFS cases reached the BVA. Claims granted at the regional office without appeal aren't in this dataset, and the overall VA grant rate for CFS is almost certainly higher than 16.1%.
• The diagnosis-missing classification reflects the Board's reading of the medical record, not an independent assessment of whether the veteran would meet diagnostic criteria on careful clinical evaluation. Some of these veterans may have CFS that was inadequately worked up at the regional level.
• The Gulf War presumption analysis here describes regulatory framework. Whether a particular veteran's service qualifies under § 3.317 depends on the specific covered location and period analysis on the record.
• The alternative "undiagnosed illness" lane under § 3.317 is not separately broken out in this analysis. Some CFS-coded cases may have been more strategically pursued as undiagnosed-illness claims.
• Rating-tier distribution among grants reflects the 62 cases where a tier was clearly coded in the dataset. Not every grant has a clearly coded tier.
• Lay-statement quotation in the Board's decision is a proxy for whether the lay evidence was substantive enough that the Board engaged with it directly. Some non-quoted lay statements were still considered and weighed.
• These observations describe BVA patterns. They are not predictions of individual outcomes.