Medical research can be powerful evidence in a VA disability claim. In fact, VA regulations recognize that medical treatises, scientific articles, research reports, and other authoritative medical writings may constitute competent medical evidence that can help you prove your claim. Studies may show a relationship between an exposure and a disease, explain how a condition develops, or identify symptoms that can be early signs of a later diagnosis.
But submitting a medical article that discusses a possible connection may not be enough. In Sacks v. West, 11 Vet. App. 314 (1998), the Court of Appeals for Veterans’ Claims explained that the value of medical research depends on how specific and conclusive it is and how closely it relates to the facts of the claim.
What Happened in Sacks v. West?
The veteran in Sacks sought service connection for pemphigus vulgaris, a condition that can cause sores on the skin and inside the mouth. His service records documented mouth sores or blisters, and he submitted a medical journal article explaining that pemphigus vulgaris can initially appear through mouth sores.
What Did the Court Decide?
The Court recognized that medical research can support a veteran’s claim. The article was relevant because it described mouth sores similar to those documented during service.
But the article discussed pemphigus vulgaris only in general terms. It did not explain whether this veteran’s in-service sores were actually early signs of his later-diagnosed condition. The Court found the article too general and inconclusive, standing alone, to establish the required medical nexus.
The Court also recognized that medical articles and treatises can provide important support when combined with a medical professional’s opinion. Research may provide the scientific basis for a claim, while an individualized opinion explains whether it applies to the veteran.
How Can Medical Research Support a VA Claim?
Medical research can show that a claimed relationship is scientifically recognized. A medical professional can then consider that research with the veteran’s service history, exposures, symptoms, records, and diagnosis.
In simple terms, research supports the medical theory, while the medical opinion explains why that theory applies to the veteran.
Why the Specificity of Medical Research Matters
The specificity, reliability, and relevance of the medical research are important. Peer-reviewed studies, reputable medical journals, and other authoritative publications generally provide a stronger foundation than blogs, generalized health websites, or unsupported internet articles.
Peer review does not automatically prove a claim, and Sacks did not require medical literature to be peer reviewed. But credible scientific research gives a medical professional a stronger basis for applying the science to the veteran’s condition.
What Does Sacks Mean for Your VA Claim?
Medical research can strengthen a VA disability claim, but an article showing that two things can be related may leave an important question unanswered: Does that research explain what happened in your case?
Often, the strongest evidence combines reliable scientific research with a medical opinion explaining how it applies to the veteran’s symptoms, history, exposures, and diagnosis. Sacks reminds us that medical research is most persuasive when the science is sufficiently specific and the evidence explains how that science applies to the individual veteran.