Eligibility for Chronic Fatigue Syndrome and VA Disability Rating

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Leah Bucholz

Leah Bucholz, PA-C, is a Board-Certified Physician Assistant, U.S. Army combat veteran, and nationally recognized medical expert in veterans’ disability claims. A former VA Compensation & Pension examiner, she founded Prestige Veteran Medical Consulting to provide independent, regulation-based medical opinions (“nexus” letters) grounded in the VA’s Schedule for Rating Disabilities (38 CFR). Leah’s work is frequently cited in favorable Board of Veterans’ Appeals decisions, and her content draws directly from authoritative sources such as VA.gov, the eCFR, and the Federal Register.
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At Prestige Veteran Medical Consulting, our blogs are written and reviewed by licensed medical professionals or military veterans with direct experience in the VA claims process. Our team has served as healthcare providers, combat veterans, and former VA examiners — giving us unique insight into both the medical and regulatory side of benefits. Every article is designed to provide accurate, trustworthy, and practical guidance so that veterans and their families can make informed decisions with confidence.

Last Updated on 2 November, 2025

Chronic Fatigue Syndrome (CFS) is a condition that can make every day a constant struggle, especially for veterans whose military service exposed them to harsh physical, psychological, and environmental stressors. This is particularly true for Gulf War veterans who have deployed in support of operations in the Middle East. 

Leah Bucholz analyzes Chronic Fatigue Syndrome and the VA rating process, guiding veterans on securing fair disability compensation. She also sheds light on the relevance of CFS related to Gulf War exposure and those serving in areas that may be presumptively associated with this condition. 

Defining Chronic Fatigue Syndrome

The Centers for Disease Control defines Chronic Fatigue Syndrome, also known as Systemic Exertion Intolerance Disease (SEID) and Myalgic Encephalomyelitis (ME), as a syndrome characterized by severe fatigue lasting longer than six months. In veterans, CFS often arises after military service due to exposure to environmental hazards, infectious diseases, physical trauma, or psychological stress. Diagnosis involves the presence of at least four of the following physical Chronic Fatigue Syndrome symptoms:

  1. Post-exertional malaise
  2. Unrefreshing sleep
  3. Impaired memory or concentration
  4. Muscle or joint pain
  5. Polyarthralgia
  6. Sore throat
  7. Tender lymph nodes or new headaches

 

It is crucial to note that CFS is a clinical diagnosis, meaning there is no specific test or imaging study for confirmation. Diagnosis relies on a constellation of symptoms, and it must be made after excluding other disease processes.

Excluding Other Conditions

It is important to exclude other conditions before Chronic Fatigue Syndrome is diagnosed. Common conditions like obstructive sleep apnea, thyroid disorders, or cancer can cause fatigue. If fatigue is a symptom of another condition, it may not meet the VA criteria for chronic fatigue diagnosis. Veterans are encouraged to follow up with their private treating doctors for comprehensive evaluations.

Military Causes of Chronic Fatigue Syndrome

Various environmental and psychological hazards can trigger or worsen CFS in veterans, especially those deployed to the Gulf War and other hazardous conditions.

Service-related risk factors for CFS include:

  • Toxic exposure to burn pits, chemical agents, and depleted uranium
  • Smoke inhalation from oil well fires and air pollution
  • Infectious diseases contracted in deployment zones
  • Preventive medications and vaccines used during deployment
  • Environmental toxins such as pesticides, industrial solvents, and fuel vapors
  • Physical and mental trauma including PTSD and combat stress
  • Traumatic Brain Injuries (TBIs)

 

Although symptoms of CFS may not appear until years after deployment, these exposures can lead to immune dysfunction, neurological disturbances, and prolonged fatigue long after service ends. Recognizing these military-related risk factors is crucial in establishing a direct or presumptive service connection for Chronic Fatigue Syndrome. 

Chronic Fatigue Syndrome as a Gulf War Presumptive Condition

Chronic Fatigue Syndrome (CFS) is one of the “medically unexplained chronic multisymptom illnesses” often linked to veterans who served during the Gulf War, particularly in Southwest Asia. A VA study on the health of Gulf War Veterans revealed that veterans deployed during the 1990-1991 conflict have a higher likelihood of developing unexplained fatigue. It is believed that factors such as exposure to viral infections, toxins, psychological stress, and hormonal imbalances during military service may have caused this “Gulf War Syndrome” among veterans. 

As an increasing number of Persian Gulf War veterans receive a Chronic Fatigue Syndrome diagnosis, the VA recognizes it as a presumptive condition. This means the VA automatically presumes your condition is service-related, so you don’t have to prove a direct connection. Veterans with successful presumptive claims can access VA monthly disability compensation, health care, and participation in the Gulf War Registry health exam and the Airborne Hazards and Open Burn Pit Registry.

Eligibility Requirements 

Chronic Fatigue Syndrome (CFS) will be presumed service-connected if you served on or after August 2, 1990, in eligible locations, and your symptoms began during service or by December 31, 2026. The condition must have lasted for at least six months and resulted in a VA disability rating of 10% or higher.

Geographical Areas Included

Veterans who served in the Southwest Asia theater of operations are eligible for presumptive service connection for chronic fatigue syndrome (CFS) under 38 CFR § 3.317. Qualifying locations include:

  • Iraq 
  • Kuwait 
  • Saudi Arabia 
  • The neutral zone between Iraq and Saudi Arabia 
  • Bahrain 
  • Qatar 
  • The United Arab Emirates (U.A.E.) 
  • Oman 
  • Afghanistan 
  • Israel 
  • Egypt 
  • Turkey 
  • Syria 
  • Jordan 
  • Gulf of Aden 
  • Gulf of Oman 
  • Waters of the Persian Gulf, the Arabian Sea, and the Red Sea 
  • Airspace above these locations

 

Although CFS is a presumptive condition, many veterans still face challenges during Compensation & Pension (C&P) exams due to the complexity of Gulf War-related illnesses. Therefore, obtaining a Nexus Letter (Independent Medical Opinion) from a qualified physician can significantly support your claim.

Apart from CFS, Gulf War presumptive conditions include functional gastrointestinal disorders, fibromyalgia, and other undiagnosed illnesses. Veterans can explore va.gov for eligibility requirements.

VA Disability Benefits and CFS

Veterans who meet the criteria for Gulf War Illness, including CFS, may be eligible for service-connected disability benefits. The VA presumes a service connection for Chronic Fatigue Syndrome, meaning veterans may not be required to prove that their chronic illness was directly caused by their military service. This presumption simplifies the process of obtaining disability benefits for affected veterans. It’s important to establish a connection between the diagnosed condition and military service, meeting the necessary criteria.

How is Chronic Fatigue Syndrome Diagnosed by the VA?

To establish eligibility for VA disability benefits for Chronic Fatigue Syndrome (CFS) under 38 CFR §4.88a, veterans must be diagnosed with the condition. The VA criteria designed to assess the severity and impact of CFS on the veteran’s daily life are as follows: 

  • Debilitating Fatigue: Veterans must experience extreme fatigue that reduces their daily activities by at least 50% for a minimum of six months.
  • Exclusion of Other Conditions: A comprehensive medical evaluation must be conducted to rule out other potential causes of the symptoms, ensuring that CFS is the primary condition affecting the veteran.
  • Associated Symptoms: The presence of six or more of the following symptoms is crucial for diagnosis:
    • Acute onset of CFS
    • Low-grade fever
    • Nonexudative pharyngitis (sore throat without pus)
    • Tender cervical or axillary lymph nodes
    • Muscle aches or weakness
    • Fatigue lasting over 24 hours after exercise
    • New or worsening headaches
    • Migratory joint pain
    • Neuropsychological issues (e.g., memory or concentration problems)
    • Sleep disturbances

 

Meeting these criteria ensures that the VA accurately evaluates the impact of CFS when determining a veteran’s eligibility for VA disability compensation.

VA Rating Criteria for Chronic Fatigue Syndrome (CFS)

Once the Chronic Fatigue Syndrome is diagnosed, veterans are assigned VA disability ratings governed by 38 CFR § 4.88b, Diagnostic Code 6354. Ranging from 0% to 100%, these ratings are given based on the frequency and intensity of the symptoms, how much they disrupt daily activities, and the presence of incapacitating episodes. 

  • 100% Rating: Symptoms are nearly constant and so severe that they almost completely restrict routine daily activities and may prevent self-care entirely.
  • 60% Rating: Symptoms are nearly constant, limit daily activities to less than 50% of pre-illness levels, and result in incapacitation for at least six weeks each year.
  • 40% Rating: Symptoms restrict daily activities to 50-75% of pre-illness levels, with incapacitation lasting four to six weeks annually.
  • 20% Rating: Symptoms restrict daily activities by less than 25%, with incapacitation occurring for two to four weeks each year.
  • 10% Rating: Symptoms are less severe, causing incapacitation for at least one week per year or are managed with continuous medication.

 

An “incapacitating episode” is defined by the VA as a period during which a physician has prescribed bed rest and medical treatment due to the severity of CFS symptoms.

These ratings can help ensure that veterans receive the appropriate level of VA disability benefits based on the severity of their CFS. For example, a single veteran with persistent brain fog, debilitating fatigue, and a doctor-ordered six weeks of bed rest annually would likely qualify for a 60% chronic fatigue syndrome VA rating, receiving almost $1,395.93 of monthly compensation. 

(View current VA disability compensation rates)

TDIU and Chronic Fatigue Syndrome

Veterans whose chronic fatigue syndrome prevents them from maintaining substantially gainful employment may qualify for Total Disability based on Individual Unemployability (TDIU). This benefit allows veterans to receive 100% compensation, even if their schedular rating is below 100%.

To qualify for TDIU benefits:

  • You must have one service-connected disability rated at least 60% or 
  • Two or more service-connected disabilities, with one rated at 40% or higher and a combined rating of 70% or more

 

CFS symptoms such as debilitating fatigue, mental fog, and post-exertional crashes can make it impossible to maintain regular employment. Veterans can submit medical records, a personal statement, and a nexus letter connecting their unemployability to CFS. 

Secondary Service Connection: When CFS Is Linked to Other Conditions

Chronic fatigue syndrome often develops alongside other health conditions. When CFS is caused or worsened by another service-connected condition, veterans may qualify for what is known as a secondary service connection. These secondary conditions can intensify symptoms and lead to higher VA ratings and monthly compensation when properly documented.

Common secondary conditions linked to CFS include:

  • Post-Traumatic Stress Disorder (PTSD): The constant stress, anxiety, and sleep disruption caused by PTSD can lead to or worsen chronic fatigue.
  • Sleep Disorders: Issues such as sleep apnea, insomnia, or restless leg syndrome prevent restful sleep and intensify daytime exhaustion.
  • Fibromyalgia: This condition causes widespread pain and stiffness that often coexist with fatigue, making daily activities difficult.
  • Anxiety and Depression: Ongoing mental health challenges drain energy, impair concentration, and make CFS symptoms more severe.
  • Irritable Bowel Syndrome (IBS): Frequent abdominal pain and digestive distress from IBS can increase overall fatigue and discomfort.
  • Cardiovascular Problems: Reduced heart function or circulation issues can leave veterans feeling constantly weak or short of breath.
  • Chronic Pain Conditions: Persistent pain from arthritis, neuropathy, or injuries can exhaust the body and aggravate CFS symptoms.

 

For example, a veteran rated 50% for service-connected PTSD, 30% for sleep apnea, and 40% for secondary chronic fatigue syndrome could receive a combined VA disability rating of around 80%. (38 CFR §4.25).

Medical nexus letters from qualified professionals linking CFS to other service-connected disabilities may be crucial in some cases to establish their links and prove your secondary VA claim effectively.

How to File a VA Claim for Chronic Fatigue Syndrome 

To file a VA disability claim for chronic fatigue syndrome, veterans must prove that their condition is service-connected, whether directly, presumptively, or secondarily. VA.gov has step by step instructions that are available in user friendly help documents for Veterans navigating their claim on their own. 

Considerations When Filing a Claim:

  1. Obtain a Diagnosis: Get a medical diagnosis of chronic fatigue syndrome from a qualified healthcare provider, meeting the VA criteria under 38 CFR § 4.88a.
  2. Gather Medical Evidence: Include all medical records showing symptoms, treatment history, and duration. Submit any Chronic Fatigue Syndrome DBQ completed by your provider.
  3. Establish Service Connection: Show direct exposure or qualify for presumptive service (e.g., Gulf War). If claiming secondary to PTSD or sleep apnea, provide a nexus letter from a qualified medical expert linking the conditions.
  4. Submit VA Form 21-526EZ: Submit a fully developed claim (FDC) on VA Form 21-526EZ via VA.gov or a Veterans Service Officer (VSO).
  5. Attend a Compensation & Pension (C&P) exam: If requested, attend a C&P exam where a VA examiner evaluates the severity and daily impact of your CFS symptoms.
  6. Track Your Claim: Monitor the status of your claim through eBenefits or VA.gov, and respond to any requests promptly.

 

Seeking professional advice from accredited legal professionals can help ensure a thorough and accurate claim submission. If the VA disability claim is denied or the approved ratings are low, veterans have the option to appeal the decision through avenues such as a Higher-Level Review, a Supplemental Claim, or by appealing directly to the Board of Veterans’ Appeals (BVA).

What to Expect at a C&P Examination for CFS

The Compensation & Pension (C&P) exam for Chronic Fatigue Syndrome is a critical part of the VA disability process. During this exam, a VA clinician evaluates:

  • Symptom severity, duration, and frequency
  • Functional Impact (e.g., reduced activity, missed work, difficulty with hygiene)
  • Incapacitation periods requiring bed rest and treatment

 

Veterans should clearly articulate how their CFS impacts their lives. For example:

“I’m unable to work more than two hours before needing to lie down. Even basic tasks like showering leave me exhausted for the rest of the day.”

Leah Bucholz suggests that veterans review the VA Chronic Fatigue Syndrome Disability Benefits Questionnaire (DBQ) for situational awareness. The examiner will complete the form assessing:

  • Diagnosis 
  • Fatigue severity and frequency
  • Duration of incapacitating episodes
  • Impact on daily living (e.g., work, hygiene, mobility)
  • Cognitive impairments like brain fog or forgetfulness

 

Being honest and specific during the C&P exam can help ensure an accurate VA rating for fatigue.

Mistakes to Avoid in Your VA Claim for Chronic Fatigue Syndrome 

Securing a fair VA rating for Chronic Fatigue Syndrome requires thorough preparation and medical documentation. Unfortunately, many veterans weaken their claims by overlooking or misunderstanding what the VA needs to approve benefits. Avoid these common pitfalls to strengthen your case and protect your rightful compensation.

1. Submitting a Claim Without a Confirmed Diagnosis

The VA requires proof that symptoms such as fatigue, sleep disturbance, and cognitive impairment have persisted for at least 6 months and cannot be explained by another medical condition. Without a valid medical diagnosis from a qualified healthcare provider, even strong symptom descriptions may not meet VA standards.

2. Failing to Rule Out Other Conditions

CFS shares symptoms with disorders like hypothyroidism, anemia, or sleep apnea. Veterans must often undergo testing to exclude these possibilities. When other causes aren’t ruled out, VA examiners may determine the fatigue isn’t service-related, leading to denial.

3. Weak or Missing Nexus Evidence

The nexus or the medical link between CFS and service is the backbone of your VA claim. Many veterans lose cases by not including a medical nexus opinion connecting their fatigue to exposures or stressors from deployments. A well-written nexus letter grounded in VA regulations can make the difference.

4. Inadequate Documentation of Functional Limitations

Your VA rating for Chronic Fatigue Syndrome depends on how it limits your daily life. Keep detailed records of reduced activity, missed workdays, and post-exertional fatigue. A daily symptom journal or lay statements from family members showing how CFS affects you can strengthen your file.

5. Not Claiming Your Gulf War Presumption 

Veterans may benefit from a presumptive service connection under the Gulf War Presumption, eliminating the need to directly link their CFS to service. Many veterans miss out on faster approvals and higher benefits by failing to claim this presumption. Always verify whether your service dates and location meet Gulf War eligibility before filing.

If the presumption does not apply, one may provide a nexus letter when applicable linking their CFS to service through detailed medical records and expert statements. It is important to remember that a nexus can also be established in many cases at the C&P examination.

6. Underestimating the Importance of the C&P Exam

The Compensation & Pension exam may influence your VA rating, so clear and detailed communication is essential. Incomplete or vague descriptions of symptom frequency and severity can lead to underrated claims. Explain how fatigue impacts work, concentration, and self-care using real examples.

Understanding and completing the Chronic Fatigue Syndrome DBQ can prepare veterans for the C&P exam. 

7. Failing to Identify Secondary Service Connections 

CFS often coexists with other service-connected conditions such as PTSD, sleep apnea, fibromyalgia, or chronic pain. Overlooking this connection means you miss out on an increased total disability rating and monthly compensation. Always discuss secondary service connection possibilities with your healthcare provider or VA-accredited representative.

By avoiding these mistakes, veterans can present stronger, evidence-based claims that help ensure fair compensation. 

Closing Thoughts

Navigating the complexities of chronic fatigue syndrome VA disability and its connection to Gulf War exposures requires a thorough understanding of the diagnostic criteria and the disability claims process. Veterans are encouraged to stay informed, seek professional guidance, and be proactive in their pursuit of service-connected disability benefits. The key lies in excluding other conditions and establishing a clear link between CFS and military service to ensure a successful VA disability claim.

Frequently Asked Questions (FAQs)

What is the VA rating for chronic fatigue syndrome?

The VA rates Chronic Fatigue Syndrome (CFS) between 10%, 20%, 40%, 60%, and 100% under Diagnostic Code 6354, based on the severity of symptoms, functional limitations, and incapacitating episodes.

What are the top 7 symptoms of chronic fatigue syndrome?

The key symptoms of CFS include post-exertional malaise, unrefreshing sleep, impaired memory or concentration, muscle or joint pain, sore throat, and tender lymph nodes or new headaches.

How to win a VA claim for chronic fatigue syndrome?

To win a VA claim, obtain a confirmed CFS diagnosis, rule out other conditions, provide strong medical and nexus evidence linking it to service, and clearly document how symptoms impact daily life.

Can chronic fatigue be secondary to PTSD?

Yes, PTSD can cause or worsen chronic fatigue due to constant stress, anxiety, and disrupted sleep, making CFS eligible as a secondary service-connected condition.

How to get diagnosed with chronic fatigue?

CFS is diagnosed clinically after at least six months of debilitating fatigue, the presence of multiple characteristic symptoms, and the exclusion of other possible medical causes.

Is chronic fatigue covered under the PACT Act?

As a Gulf War veteran, if you served in Southwest Asia or nearby regions since August 1990, you may qualify for presumptive Chronic Fatigue Syndrome under the PACT Act, meaning the VA automatically assumes your condition is service-related. 

What is the VA rating for chronic fatigue syndrome secondary to sleep apnea?

When CFS is secondary to service-connected sleep apnea, it’s rated separately under Diagnostic Code 6354, typically between 10% and 100%, depending on symptom severity and incapacitation.

Also read: Fibromyalgia VA Rating and Benefits for Gulf War Veterans

At Prestige Veteran Medical Consulting, a veteran-owned company, we specialize in Independent Medical Opinions (IMOs) known as Nexus letters.

Our purpose is to empower YOU, the veteran, to take charge of your medical evidence and provide you with valuable educational tools and research to guide you on your journey.

Understanding the unique challenges veterans face, our commitment lies in delivering exceptional service and support.

Leveraging an extensive network of licensed independent medical professionals, all well-versed in the medical professional aspects of the VA claims process, we review the necessary medical evidence to incorporate in our reports related to your VA Disability Claim.

Prestige Veteran Medical Consulting is not a law firm, accredited claims agent, or affiliated with the Veterans Administration or Veterans Services Organizations. However, we are happy to discuss your case with your accredited VA legal professional.

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Alan Bucholz, PA-C

Board-Certified Physician Assistant | U.S. Army Combat Veteran | Co-founder & CFO, Prestige Veteran Medical Consulting

This article was medically reviewed and fact checked by Alan Bucholz, PA-C, a board-certified Physician Assistant and retired U.S. Army combat veteran with experience in emergency medicine and two combat deployments (Iraq & Afghanistan). As Co-founder of Prestige Veteran Medical Consulting, Alan provides evidence-based medical opinions to support veterans’ VA disability claims with accuracy, compliance, and ethics.

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wife, Leah Bucholz, a Physician Assistant and Army Combat Veteran.  He has devoted himself to using his
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