Obesity as a VA Disability: Direct and Secondary Claims After Adams v. Collins

• A July 2025 court ruling, Adams v. Collins, struck down VA’s blanket rule that obesity can never be a compensable disability.
• Obesity still has no dedicated rating code in the VA’s rating schedule — the well-established path remains claiming it as the link connecting a service-connected condition to another condition it caused, like sleep apnea or diabetes.
• A direct obesity claim is legally possible now, but Adams’s own case was sent back to the Board to work out how such a claim would actually be rated — there is no proven path yet.
• VA’s three-part test for the secondary route: your service-connected condition caused the weight gain, the weight gain was a substantial factor in the new condition, and the new condition would not have occurred without it.
• Sleep apnea, type 2 diabetes, hypertension, heart disease, and joint or back problems are the conditions most often linked to obesity in a VA claim.
• If your obesity-related secondary claim was denied before July 2025 specifically because VA said obesity could not be considered, you may be able to file a Supplemental Claim citing Adams v. Collins as new legal evidence.

• The Court Ruling That Changed Everything: Adams v. Collins
• Why the VA Used to Deny Obesity Claims
• How to Claim Obesity as a Secondary Condition
• Can You Claim Obesity Directly?
• Conditions Commonly Linked to Obesity
• If Your Claim Was Denied Before Adams v. Collins
• Frequently Asked Questions

Yes, obesity can now factor into a VA disability claim — but not the way recent headlines suggest. A July 2025 court ruling opened the door to obesity being considered a disability in its own right, while the long-standing, proven path remains claiming it as the cause of another condition, like sleep apnea or diabetes.

This article is for veterans whose weight changed because of a service-connected condition, or its treatment, and the family members helping them sort out what that means for a claim.

The Court Ruling That Changed Everything: Adams v. Collins

For years, the VA’s position was simple: obesity is not a disease, so it can never be its own compensable disability, no matter what caused it. On July 8, 2025, the Court of Appeals for Veterans Claims ruled in Adams v. Collins, No. 23-5064, that this blanket rule was wrong. The court held that what determines whether something is a disability is whether it causes functional impairment — not whether it fits a narrow legal definition of “disease” or “injury.” The ruling sent the veteran’s claim, obesity secondary to his service-connected PTSD, back to the Board of Veterans’ Appeals to be reconsidered under the correct standard.

Why the VA Used to Deny Obesity Claims

Since 2017, the VA had relied on a General Counsel opinion, VAOPGCPREC 1-2017, that treated obesity as categorically ineligible for direct service connection — obesity by itself was never ratable, full stop. The one exception the VA carved out was treating obesity as an “intermediate step”: a bridge connecting an already-rated condition to a new condition it caused, even though obesity itself stayed off the books. Adams v. Collins did not erase that memo entirely, but it rejected the part that closed the door on obesity ever being a disability in its own right.

How to Claim Obesity as a Secondary Condition

The secondary-condition path has a real track record, and it does not depend on Adams v. Collins to work. The VA’s three-part test asks:

• Did your service-connected disability cause you to become obese?
• Was that obesity a substantial factor in causing your new condition?
• Would the new condition not have occurred but for the obesity?

Example: a service-connected knee injury limits your ability to exercise. Reduced activity leads to significant weight gain, and that weight gain contributes to high blood pressure. Under this framework, the high blood pressure can be service-connected, with obesity as the documented link in the chain, even though the obesity itself never gets its own rating. VA Secondary Conditions covers the broader rules for connecting a new condition to one you are already rated for.

Can You Claim Obesity Directly?

What Adams v. Collins actually changed is narrower than the headlines suggest. The court did not rule that obesity is now a rated disability, and it did not hand the veteran a rating — it sent his case back to the Board to work through whether his obesity itself causes functional impairment worth compensating. There is still no diagnostic code for obesity in the VA’s rating schedule, so even a successful direct claim would need the VA to work out how to rate it, likely through an extraschedular or analogous rating. This is genuinely unsettled ground. Do not expect an automatic rating for obesity itself — the secondary-condition path above remains the more reliable route today.

Conditions Commonly Linked to Obesity

Obesity commonly contributes to sleep apnea, type 2 diabetes, hypertension, coronary artery disease, and joint or back conditions from the added strain on your body. Each of these has its own diagnostic code and rating criteria, and each can be claimed as secondary to obesity caused by a service-connected condition. Navigating VA Disability for Sleep Apnea walks through the rating criteria for one of the most common of these secondary claims.

Mental health conditions cut both ways here too. Medication side effects and reduced activity are a well-documented path to weight gain, which is why the PTSD VA Rating Guide and this one often come up together in the same claim file.

If Your Claim Was Denied Before Adams v. Collins

If your secondary claim for a condition linked to obesity was denied specifically because the VA said obesity could not be considered, Adams v. Collins may give you grounds to file a Supplemental Claim with the decision cited as new legal evidence. A Veterans Service Organization or accredited attorney can review the reasoning the VA used in your original denial and tell you whether it is worth reopening. Ratings and rules keep shifting — 2026 VA Disability Rating Changes covers what else has moved across the disability schedule this year.

Frequently Asked Questions

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