Shoulder or Arm Limitation Secondary to Back or Neck Strain (VA Claims)

Shoulder or Arm Limitation (VA diagnostic code 5201) is sometimes claimed as secondary to service-connected Back or Neck Strain (code 5237) under 38 CFR 3.310. This page reports what published Board of Veterans' Appeals decisions on that pairing show. It is an encyclopedic reference, not a forecast.

What published Board decisions show

Across 248 published Board (BVA) decisions in our index where shoulder or arm limitation was claimed as secondary to back or neck strain, the outcomes broke down as follows. These are historical aggregates of decided appeals, not a prediction for any individual claim.

6%

Granted

50%

Denied

42%

Remanded

Granted 15Denied 123Remanded 103 (sent back for more development)

Counting only appeals that were granted or denied (setting aside remands), about 11% were granted. A remand is not a loss; it means the Board needed more evidence before deciding.

Source: aggregate of published BVA decisions indexed by RateMyVSO. Secondary service connection rule: 38 CFR § 3.310. Figures describe decided appeals and can change as new decisions are indexed.

Why shoulder or arm limitation is claimed secondary to back or neck strain

Documented mechanism (plausible)

Cervical strain can directly limit arm motion.

This rationale is generated from the data for this specific pairing, not hand-written per page. The grant and denial figures above come only from the decision data, never from the rationale text.

Whether that medical link exists in any one case is a medical question decided on that case's own evidence (the nexus).

What a secondary claim on this pairing needs

Under 38 CFR 3.310 a secondary claim turns on three elements:

A current diagnosis: a medical diagnosis of shoulder or arm limitation (the secondary).
A service-connected primary: Back or Neck Strain, already service-connected (the primary). A 0% primary still counts.
A medical nexus: a medical opinion linking the shoulder or arm limitation to the back or neck strain, showing the primary caused or aggravated it.

See the Secondary Claim guide for the caused-versus-aggravated split, and the Nexus Letter guide for what makes the medical opinion strong.

Frequently Asked Questions

Does Back or Neck Strain have to be highly rated to support a shoulder or arm limitation secondary claim?

No. 38 CFR 3.310 looks at whether the service-connected Back or Neck Strain caused or aggravated the shoulder or arm limitation, not at how severe the Back or Neck Strain rating is. Even a 0% service-connected primary can anchor a secondary claim.

What do the percentages on this page mean?

They are the historical outcomes of 248 published Board decisions on this exact pairing: 6% granted, 50% denied, 42% remanded. They describe decided appeals already on record. They do not predict what would happen in any individual case.