{"id":"F2024L01337","name":"Statement of Principles concerning Achilles tendinopathy (Reasonable Hypothesis) (No. 86 of 2024)","slug":"statement-of-principles-concerning-achilles-tendinopathy-reasonable-hypothesis-no-86-of-2024","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":442625,"registerId":"F2024L01337-fast-fetch-1775957589993","compilationNumber":null,"startDate":"2026-04-12","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Statement of Principles concerning Achilles tendinopathy (Reasonable Hypothesis) (No. 86 of 2024)","content":"---\nmeta-content-style-type: text/css\nmeta-content-type: application/xhtml+xml; charset=utf-8\n---\n\n?xml version=\"1.0\" encoding=\"utf-8\" standalone=\"no\"?>\n\n![RMA Australian Government Coat of Arms](image.001.jpeg)\n\n \n\nStatement of Principles\n\nconcerning\n\nACHILLES TENDINOPATHY  (Reasonable Hypothesis)\n\n(No. 86 of 2024)\n\nThe Repatriation Medical Authority determines the following Statement of Principles under subsection 196B(2) of the Veterans' Entitlements Act 1986.\n\n \n\nDated                18 October 2024.\n\n \n\n \n\n \n\n \n\n \n\n \n\n \n\n \n\n \n\n \n\nProfessor Terence Campbell AM\n\nChairperson\n\nby and on behalf of\n\nThe Repatriation Medical Authority\n\n \n\n \n\n   \n\n\nContents\n\n1 Name\n\n2 Commencement\n\n3 Authority\n\n4 Repeal\n\n5 Application\n\n6 Definitions\n\n7 Kind of injury, disease or death to which this Statement of Principles relates\n\n8 Basis for determining the factors\n\n9 Factors that must exist\n\n10 Relationship to service\n\n11 Factors referring to an injury or disease covered by another Statement of Principles\n\nSchedule 1 - Dictionary\n\n1 Definitions\n\n \n\n \n\n\n\n\n1.                Name\n\n\nThis is the Statement of Principles concerning Achilles tendinopathy (Reasonable Hypothesis) (No. 86 of 2024).\n\n1.                Commencement\n\n\n              This instrument commences on 19 November 2024.\n\n1.                Authority\n\n\nThis instrument is made under subsection 196B(2) of the Veterans' Entitlements Act 1986.\n\n1.                Repeal\n\n\nThe Statement of Principles concerning Achilles tendinopathy and bursitis (Reasonable Hypothesis) (No. 96 of 2015) (Federal Register of Legislation No. F2015L01336) made under subsection 196B(2) of the VEA is repealed.\n\n1.                Application\n\n\nThis instrument applies to a claim to which section 120A of the VEA or section 338 of the Military Rehabilitation and Compensation Act 2004 applies.\n\n1.                Definitions\n\n\nThe terms defined in the Schedule 1 - Dictionary have the meaning given when used in this instrument.\n\n1.                Kind of injury, disease or death to which this Statement of Principles relates\n  1.           This Statement of Principles is about Achilles tendinopathy and death from Achilles tendinopathy.\n\n\nMeaning of Achilles tendinopathy\n\n1.           For the purposes of this Statement of Principles, Achilles tendinopathy:\n  1.           means a symptomatic inflammatory or degenerative disease of the Achilles tendon or paratendon; and\n  2.           includes:\n    1.             insertional tendinopathy of the Achilles tendon;\n    2.          mid portion tendinopathy of the Achilles tendon;\n    3.        degenerative tears of the Achilles tendon; and\n    4.         Achilles enthesopathy or enthesitis.\n\n\nNote: Achilles tendinopathy is also known as Achilles tendonitis or paratendonitis, Achilles tendinosis or paratendinosis. Insertional Achilles tendinopathy is less than 2 cm proximal to the calcaneus and is a separate disease from Achilles enthesopathy, and mid portion Achilles tendinopathy is 2-7 cm proximal to the calcaneal insertion.  \n\nDeath from Achilles tendinopathy\n\n1.           For the purposes of this Statement of Principles, Achilles tendinopathy, in relation to a person, includes death from a terminal event or condition that was contributed to by the person's Achilles tendinopathy.\n\n\nNote: terminal event is defined in the Schedule 1 – Dictionary.\n\n1.                Basis for determining the factors\n\n\nThe Repatriation Medical Authority is of the view that there is sound medical‑scientific evidence that indicates that Achilles tendinopathy and death from Achilles tendinopathy can be related to relevant service rendered by veterans, members of Peacekeeping Forces, or members of the Forces under the VEA, or members under the MRCA.\n\nNote: MRCA, relevant service and VEA are defined in the Schedule 1 – Dictionary.\n\n1.                Factors that must exist\n\n\nAt least one of the following factors must as a minimum exist before it can be said that a reasonable hypothesis has been raised connecting Achilles tendinopathy or death from Achilles tendinopathy with the circumstances of a person's relevant service:\n\n1.           running or jogging an average of at least 30 kilometres per week for the 4 weeks before clinical onset or clinical worsening;\n2.           undertaking weight bearing exercise involving repeated activity of the ankle joint on the affected side for:\n  1.           a minimum intensity of 5 METS; and\n  2.           for at least 4 hours per week; and\n  3.           for at least the 4 weeks before clinical onset or clinical worsening;\n\n\nNote 1: Examples of weight bearing exercise involving repeated activity of the ankle joint at a minimum intensity of 5 METS include marching, playing basketball, football, volleyball, and track and field (especially those activities that involve jumping).\n\nNote 2: MET (metabolic equivalent) is a unit of measure of the level of physical capability of the cardiorespiratory system. For example, 1 MET = cardiorespiratory effort associated with a person sitting, 3-4 METs = cardiorespiratory effort associated with a person walking at average walking pace (5 km/h) or light gardening.\n\n1.           increasing the frequency, duration or intensity of activity involving the ankle joint on the affected side:\n  1.           by at least 100 percent; and\n  2.           to a minimum intensity of 5 METs; and\n  3.           for at least 2 hours per day;\n\n\nwithin the 1 week before the clinical onset or clinical worsening;\n\nNote:  MET (metabolic equivalent) is a unit of measure of the level of physical capability of the cardiorespiratory system. For example, 1 MET = cardiorespiratory effort associated with a person sitting, 3-4 METs = cardiorespiratory effort associated with a person walking at average walking pace (5 km/h) or light gardening.\n\n1.           having one or more of the following conditions involving the affected lower limb at the time of clinical onset or clinical worsening:\n  1.           pes planus;\n  2.           pes cavus;\n  3.           decreased ankle or forefoot flexibility;\n  4.           forefoot varus;\n  5.           lateral ankle joint instability;\n2.           having one of the following systemic arthritic diseases at the time of clinical onset or clinical worsening:\n  1.           ankylosing spondylitis;\n  2.           Behcet syndrome;\n  3.           enteropathic spondyloarthropathy (arthritis associated with inflammatory bowel disease);\n  4.           gout;\n  5.           pseudogout (calcium pyrophosphate dihydrate) or crystal-induced arthropathy from the deposition of calcium hydroxyapatite or calcium oxalate;\n  6.            psoriatic arthropathy\n  7.           reactive arthritis;\n  8.           rheumatoid arthritis; or\n  9.             undifferentiated spondyloarthropathy;\n3.           having chronic renal failure within the 10 years before clinical onset or clinical worsening as indicated by:\n  1.           a glomerular filtration rate of less than 15 mL/min/1.73 m2 for a period of at least 3 months; or\n  2.           undergoing chronic dialysis for renal failure;\n4.           being treated with a fluoroquinolone antibiotic within the 30 days before clinical onset or clinical worsening;\n\n\nNote: Examples of fluoroquinolone antibiotics include ciprofloxacin, moxifloxacin, norfloxacin and ofloxacin.\n\n1.           being treated with a glucocorticoid drug as specified before clinical onset or clinical worsening;\n\n\nNote: being treated with a glucocorticoid drug as specified is defined in the Schedule 1 - Dictionary.\n\n1.           having a glucocorticoid injection into the Achilles tendon, in the region of the Achilles tendon or in the retrocalcaneal bursa, before the rupture of the Achilles tendon;\n\n\nNote: rupture of the Achilles tendon can constitute clinical onset or clinical worsening of Achilles tendinopathy.\n\n1.       being treated with an aromatase inhibitor for at least 4 weeks within the 1 year before clinical onset or clinical worsening;\n\n\nNote: Examples of aromatase inhibitors include anastrozole, exemestane and letrozole.\n\n1.       having a Body Mass Index (BMI) of 30 or greater at the time of  clinical onset or clinical worsening;\n\n\nNote: BMI is defined in the Schedule 1 – Dictionary.\n\n1.       having diabetes mellitus at the time of clinical onset or clinical worsening;\n2.       inability to obtain appropriate clinical management for Achilles tendinopathy before clinical worsening.\n\n\n1.            Relationship to service\n  1.           The existence in a person of any factor referred to in section 9, must be related to the relevant service rendered by the person.\n  2.           The clinical worsening aspects of factors set out in section 9 apply only to material contribution to, or aggravation of, Achilles tendinopathy where the person's Achilles tendinopathy was suffered or contracted before or during (but did not arise out of) the person's relevant service.\n2.            Factors referring to an injury or disease covered by another Statement of Principles\n\n\nIn this Statement of Principles:\n\n1.           if a factor referred to in section 9 applies in relation to a person; and\n2.           that factor refers to an injury or disease in respect of which a Statement of Principles has been determined under subsection 196B(2) of the VEA;\n\n\nthen the factors in that Statement of Principles apply in accordance with the terms of that Statement of Principles as in force from time to time.\n\n \n\n \n\nSchedule 1 - Dictionary  \n\nNote:               See Section 6\n\n1               Definitions\n\nIn this instrument:\n\n                             achilles tendinopathy—see subsection 7(2).\n\n                               being treated with a glucocorticoid drug as specified means:\n\n(a)          being treated with prednisolone, in the combinations of mode of administration, dose, duration of treatment and proximity to the clinical onset or worsening of Achilles tendinopathy, as specified in Table 1 below; or\n\n(b)          being treated as specified in Table 1 with a glucocorticoid drug other than prednisolone in doses having an efficacy equivalent to prednisolone, that being calculated for the drugs listed in accordance with Table 2 below.\n\n \n\nTable 1\n\n- Drug or Class of Drugs Mode* Dose Minimum Duration of Treatment Duration\n- prednisolone orpharmacologically equivalent glucocorticoid IV, IM, O  0.5 grams over 6 months 6 months within the 3 years\n-  3 grams NS within the 5 years\n-  10 grams NS NS\n\n\nAbbreviations: IV = intravenous; IM = intramuscular; O = oral; NS = not specified.\n\nTable 2\n\n| Glucocorticoid | Dose ratio equivalence with respect to prednisolone |\n| --- | --- |\n| cortisone | 5 |\n| hydrocortisone | 4 |\n| prednisolone | 1 |\n| prednisone | 1 |\n| methylprednisolone | 0.8 |\n| triamcinolone | 0.8 |\n| paramethasone | 0.4 |\n| dexamethasone | 0.15 |\n| betamethasone | 0.12 |\n\n\n \n\n \n\n                               BMI means W/H2 where:\n\n(a)          W is the person's weight in kilograms; and\n\n(b)          H is the person's height in metres.\n\n                             MRCA means the Military Rehabilitation and Compensation Act 2004.\n\n                             relevant service means:\n\n(a)          operational service under the VEA;\n\n(b)          peacekeeping service under the VEA;\n\n(c)          hazardous service under the VEA;\n\n(d)          British nuclear test defence service under the VEA;\n\n(e)          warlike service under the MRCA; or\n\n(f)           non-warlike service under the MRCA.\n\nNote: MRCA and VEA are defined in the Schedule 1 - Dictionary.\n\n                             terminal event means the proximate or ultimate cause of death and includes the following:\n\n(a)           pneumonia;\n\n(b)           respiratory failure;\n\n(c)           cardiac arrest;\n\n(d)           circulatory failure; or\n\n(e)           cessation of brain function.\n\n                             VEA means the Veterans' Entitlements Act 1986.\n\n \n\n \n","sortOrder":0}],"analysis":{"flash_summary":{"complexity_score":5,"scope_assessment":{"changed":true,"description":"Yes. The instrument expressly repeals the 2015 Statement (s4) and narrows the named condition by removing bursitis from the title and coverage, focusing on Achilles tendinopathy and death from it (s7). It also updates and expands the list of qualifying factors and precise temporal/dose criteria (s9; Schedule 1 Tables 1–2), so coverage is substantively re‑scoped — narrower in disease label but broader/more prescriptive in listed medical and exposure factors."},"complexity_factors":["Technical medical thresholds and time windows to establish a ‘reasonable hypothesis’ (e.g. running ≥30 km/week for 4 weeks; METs, hours per week/day) (s9.1–s9.3)","Multiple distinct risk/causal factors with varied temporal requirements (fluoroquinolone within 30 days; aromatase inhibitor 4 weeks within 1 year; chronic renal failure within 10 years) (s9.4–s9.8)","Quantitative pharmacological dosing and equivalence rules for glucocorticoid exposure, with tables specifying dose, route, duration and prednisolone-equivalents (Schedule 1 Table 1–2)","Defined clinical concepts and precise anatomical definitions (insertional vs mid-portion) and inclusion of death from a terminal event (s7(2), Schedule 1)","Nuanced interaction between ‘clinical worsening’ and service (material contribution vs aggravation; applies only where condition pre‑existed or was suffered before/during service) (s10.1–s10.2)","Repeal of the prior instrument and consequential scope change (removal of ‘bursitis’) which affects claim coverage (s4)","Cross-reference rule applying other Statements of Principles where overlapping conditions exist, requiring coordination across instruments (s11)","Administrative application to claims under two different Acts (VEA and MRCA) and the delegated decision role of the Repatriation Medical Authority (ss3,5,8) which creates claim-assessment discretion","A residual, somewhat subjective factor — ‘inability to obtain appropriate clinical management’ — that may increase evidentiary and compliance burden (s9.12)"],"plain_english_summary":"This Statement sets the medical criteria the Repatriation Medical Authority uses to decide if Achilles tendinopathy (and death from it) can be linked to a veteran’s or service member’s relevant service for VEA/MRCA claims. It affects veterans, members of Peacekeeping Forces and serving members making entitlement or compensation claims, and, if criteria are met, establishes government liability under those Acts (see ss3–5,7,9)."},"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"},"kimi_summary":{"content_quality":"ok","complexity_score":5,"scope_assessment":{"changed":true,"description":"The original 2015 instrument covered 'Achilles tendinopathy and bursitis' together. This 2024 instrument narrows the scope to Achilles tendinopathy only, removing bursitis from coverage. This represents a significant narrowing of scope—bursitis (inflammation of the fluid-filled sac near the tendon) is now treated separately or excluded, focusing the instrument purely on tendon pathology. The detailed expansion of tendinopathy subtypes (insertional, mid-portion, degenerative tears, enthesopathy) suggests increased medical precision but reduced breadth of coverage."},"complexity_factors":["Multiple nested definitions requiring cross-referencing (e.g., 'being treated with a glucocorticoid drug as specified' refers to complex tables with dose equivalencies and timeframes)","Technical medical terminology throughout (METs, pes planus, pes cavus, forefoot varus, specific drug classes)","Mathematical calculations required for BMI and glucocorticoid dose equivalencies using Table 2 conversion ratios","Precise temporal requirements with multiple overlapping windows (4 weeks before, 1 week before, 30 days before, 10 years before, 1 year before, 3 years, 5 years)","Conditional logic with multiple conjunctive requirements ('and' conditions) in factors 9(b), 9(c), and 9(h)","Cross-reference to other Statements of Principles for conditions mentioned in factor 9(e) (systemic arthritic diseases)","Distinction between 'clinical onset' and 'clinical worsening' with different rules applying to each in section 10","Specific anatomical distinctions (insertional vs mid-portion tendinopathy, proximity to calcaneus)"],"plain_english_summary":"This instrument defines Achilles tendinopathy for compensation and replaces the 2015 rule that covered both Achilles tendinopathy and bursitis. It identifies a set of medical and service-related risk factors that, if present, create a \"reasonable hypothesis\" linking the condition to service.\n\nIt affects veterans and current/former defence members claiming under the VEA or MRCA and guides the Repatriation Medical Authority — lowering the proof threshold to make service connection and compensation easier."}},"importantCases":[],"_links":{"self":"/api/acts/statement-of-principles-concerning-achilles-tendinopathy-reasonable-hypothesis-no-86-of-2024","history":"/api/acts/statement-of-principles-concerning-achilles-tendinopathy-reasonable-hypothesis-no-86-of-2024/history","analysis":"/api/acts/statement-of-principles-concerning-achilles-tendinopathy-reasonable-hypothesis-no-86-of-2024/analysis","conflicts":"/api/acts/statement-of-principles-concerning-achilles-tendinopathy-reasonable-hypothesis-no-86-of-2024/conflicts","importantCases":"/api/acts/statement-of-principles-concerning-achilles-tendinopathy-reasonable-hypothesis-no-86-of-2024/important-cases","documents":"/api/acts/statement-of-principles-concerning-achilles-tendinopathy-reasonable-hypothesis-no-86-of-2024/documents"}}