{"id":"F2020L01376","name":"Statement of Principles concerning adhesive capsulitis of the shoulder (Reasonable Hypothesis) (No. 72 of 2020)","slug":"statement-of-principles-concerning-adhesive-capsulitis-of-the-shoulder-reasonable-hypothesis-no-72-o","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":440639,"registerId":"F2020L01376-fast-fetch-1775956208119","compilationNumber":null,"startDate":"2026-04-12","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Statement of Principles concerning adhesive capsulitis of the shoulder (Reasonable Hypothesis) (No. 72 of 2020)","content":"---\nmeta-content-style-type: text/css\nmeta-content-type: application/xhtml+xml; charset=utf-8\nmeta-generator: Aspose.Words for .NET 20.2\n---\n\n?xml version=\"1.0\" encoding=\"utf-8\" standalone=\"no\"?>\n\n![RMA-Red](image.001.jpeg)\n\n \n\nStatement of Principles\n\nconcerning\n\nADHESIVE CAPSULITIS OF THE SHOULDER   (Reasonable Hypothesis)\n\n(No. 72 of 2020)\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                                           30 October 2020\n\n \n\n \n\n \n\n \n\n \n\n| The Common Seal of the  Repatriation Medical Authority  was affixed to this instrument  at the direction of:<br> |\n| --- |\n| ![RMA Chairperson signature](image.002.png)<br> <br>Professor Nicholas Saunders AO<br>Chairperson<br> |\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\n1               Name\n\nThis is the Statement of Principles concerning adhesive capsulitis of the shoulder (Reasonable Hypothesis) (No. 72 of 2020).\n\n2               Commencement\n\n              This instrument commences on 30 November 2020.\n\n3               Authority\n\nThis instrument is made under subsection 196B(2) of the Veterans' Entitlements Act 1986.\n\n4               Repeal\n\nThe Statement of Principles concerning adhesive capsulitis of the shoulder No. 7 of 2012 (Federal Register of Legislation No. F2012L00014) made under subsection 196B(2) of the VEA is repealed.\n\n5               Application\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\n6               Definitions\n\nThe terms defined in the Schedule 1 - Dictionary have the meaning given when used in this instrument.\n\n7               Kind of injury, disease or death to which this Statement of Principles relates\n\n(1)          This Statement of Principles is about adhesive capsulitis of the shoulder and death from adhesive capsulitis of the shoulder.\n\nMeaning of adhesive capsulitis of the shoulder\n\n(2)          For the purposes of this Statement of Principles, adhesive capsulitis of the shoulder means a clinical condition characterised by shoulder pain and stiffness and severe functional restriction of both active and passive shoulder motion, lasting for at least 28 days.\n\nNote 1: Adhesive capsulitis of the shoulder is also known as frozen shoulder.\n\nNote 2: Typically, the initial phase of this condition is characterised by severe pain followed by gradually increasing stiffness.\n\n(3)          While adhesive capsulitis of the shoulder attracts ICD‑10‑AM code M75.0, in applying this Statement of Principles the meaning of adhesive capsulitis of the shoulder is that given in subsection (2).\n\n(4)          For subsection (3), a reference to an ICD-10-AM code is a reference to the code assigned to a particular kind of injury or disease in The International Statistical Classification of Diseases and Related Health Problems, Tenth Revision, Australian Modification (ICD-10-AM), Tenth Edition, effective date of 1 July 2017, copyrighted by the Independent Hospital Pricing Authority, ISBN 978-1-76007-296-4.\n\nDeath from adhesive capsulitis of the shoulder\n\n(5)          For the purposes of this Statement of Principles, adhesive capsulitis of the shoulder, in relation to a person, includes death from a terminal event or condition that was contributed to by the person's adhesive capsulitis of the shoulder.\n\nNote: terminal event is defined in the Schedule 1 - Dictionary.\n\n8               Basis for determining the factors\n\nThe Repatriation Medical Authority is of the view that there is sound medical‑scientific evidence that indicates that adhesive capsulitis of the shoulder and death from adhesive capsulitis of the shoulder 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\n9               Factors that must exist\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 adhesive capsulitis of the shoulder or death from adhesive capsulitis of the shoulder with the circumstances of a person's relevant service:\n\n(1)          having a significant injury involving the arm or shoulder of the affected side within the six months before the clinical onset of adhesive capsulitis of the shoulder;\n\nNote: significant injury involving the arm or shoulder is defined in the Schedule 1 - Dictionary.             \n\n(2)          undergoing a surgical procedure involving the shoulder, chest wall or neck of the affected side within the six months before the clinical onset of adhesive capsulitis of the shoulder;\n\n(3)          having paralysis of the affected shoulder within the one year before the clinical onset of adhesive capsulitis of the shoulder;\n\n(4)          having rotator cuff syndrome of the affected side at the time of the clinical onset of adhesive capsulitis of the shoulder;\n\n(5)          having a malignant neoplasm involving the region of the affected shoulder or the adjacent thoracic region, including the breast, within the one year before the clinical onset of adhesive capsulitis of the shoulder;\n\n(6)          having diabetes mellitus at the time of the clinical onset of adhesive capsulitis of the shoulder;\n\n(7)          having a thyroid disease from the specified list of thyroid diseases at the time of the clinical onset of adhesive capsulitis of the shoulder;\n\nNote: specified list of thyroid diseases is defined in the Schedule 1 - Dictionary.\n\n(8)          having Parkinson's disease at the time of the clinical onset of adhesive capsulitis of the shoulder;\n\n(9)          having dyslipidaemia before the clinical onset of adhesive capsulitis of the shoulder;\n\nNote: dyslipidaemia is defined in the Schedule 1 - Dictionary.\n\n(10)      taking highly active antiretroviral therapy for human immunodeficiency virus infection at the time of the clinical onset of adhesive capsulitis of the shoulder;\n\n(11)      taking phenobarbital or primidone within the six weeks before the clinical onset of adhesive capsulitis of the shoulder;\n\nNote: Phenobarbital is also known as phenobarbitone.\n\n(12)      having a significant injury involving the arm or shoulder of the affected side within the six months before the clinical worsening of adhesive capsulitis of the shoulder;\n\nNote: significant injury involving the arm or shoulder is defined in the Schedule 1 - Dictionary.             \n\n(13)      undergoing a surgical procedure involving the shoulder, chest wall or neck of the affected side within the six months before the clinical worsening of adhesive capsulitis of the shoulder;\n\n(14)      having paralysis of the affected shoulder within the one year before the clinical worsening of adhesive capsulitis of the shoulder;\n\n(15)      having rotator cuff syndrome of the affected side at the time of the clinical worsening of adhesive capsulitis of the shoulder;\n\n(16)      having a malignant neoplasm involving the region of the affected shoulder or the adjacent thoracic region, including the breast, within the one year before the clinical worsening of adhesive capsulitis of the shoulder;\n\n(17)      having diabetes mellitus at the time of the clinical worsening of adhesive capsulitis of the shoulder;\n\n(18)      having a thyroid disease from the specified list of thyroid diseases at the time of the clinical worsening of adhesive capsulitis of the shoulder;\n\nNote: specified list of thyroid diseases is defined in the Schedule 1 - Dictionary.\n\n(19)      having Parkinson's disease at the time of the clinical worsening of adhesive capsulitis of the shoulder;\n\n(20)      having dyslipidaemia before the clinical worsening of adhesive capsulitis of the shoulder;\n\nNote: dyslipidaemia is defined in the Schedule 1 - Dictionary.\n\n(21)      taking highly active antiretroviral therapy for human immunodeficiency virus infection at the time of the clinical worsening of adhesive capsulitis of the shoulder;\n\n(22)      taking phenobarbital or primidone within the six weeks before the clinical worsening of adhesive capsulitis of the shoulder;\n\nNote: Phenobarbital is also known as phenobarbitone.\n\n(23)      inability to obtain appropriate clinical management for adhesive capsulitis of the shoulder.\n\n10           Relationship to service\n\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\n(2)          The factors set out in subsections 9(12) to 9(23) apply only to material contribution to, or aggravation of, adhesive capsulitis of the shoulder where the person's adhesive capsulitis of the shoulder was suffered or contracted before or during (but did not arise out of) the person's relevant service.\n\n11           Factors referring to an injury or disease covered by another Statement of Principles\n\nIn this Statement of Principles:\n\n(1)          if a factor referred to in section 9 applies in relation to a person; and\n\n(2)          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\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                               adhesive capsulitis of the shoulder—see subsection 7(2).\n\n                               dyslipidaemia means persistently abnormal blood lipid levels, diagnosed by a medical practitioner and evidenced by:\n\n(a)          a serum high density lipoprotein cholesterol level less than 1.0 mmol/L; or\n\n(b)          a serum low density lipoprotein level greater than 4.0 mmol/L; or\n\n(c)          a serum triglyceride level greater than or equal to 2.0 mmol/L; or\n\n(d)          total serum cholesterol level greater than 5.5 mmol/L; or\n\n(e)          the regular administration of drug therapy to normalise blood lipid levels.\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 also defined in the Schedule 1 - Dictionary.\n\n                               significant injury involving the arm or shoulder means an injury that results in substantial pain, swelling, tenderness and immobilisation of the arm or shoulder.\n\nNote: Examples of injuries that result in substantial pain, swelling, tenderness and immobilisation of               the arm or shoulder include fracture of a bone of the shoulder (humerus, scapula or clavicle), fracture of a bone of the arm, penetrating injury to the shoulder joint, dislocation of the shoulder or a joint of the arm, and significant injuries to the soft tissues of the arm or shoulder.\n\n                               specified list of thyroid diseases means:\n\n(a)          Graves' disease;\n\n(b)          Hashimoto's thyroiditis;\n\n(c)          hyperthyroidism and thyrotoxicosis; or\n\n(d)          hypothyroidism.\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_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":4,"scope_assessment":{"changed":false,"description":"This is a standard replacement instrument maintaining the established scope of Repatriation Medical Authority Statements of Principles. It updates the 2012 version with current medical evidence but does not expand beyond the traditional function of defining service-connection factors for a specific medical condition. The structure mirrors other SOPs with the typical onset/worsening bifurcation and dictionary-based definitions."},"complexity_factors":["23 enumerated factors with parallel structure (factors 1-11 for onset, 12-22 for worsening, 23 for both)","Multiple defined terms in Schedule 1 (7 explicit definitions including nested definitions for MRCA and VEA)","Cross-referencing mechanism in section 11 linking to other Statements of Principles","Specific quantitative medical thresholds in definitions (e.g., serum cholesterol >5.5 mmol/L, triglycerides ≥2.0 mmol/L)","Temporal requirements requiring precise date calculations (6 months, 1 year, 6 weeks, 28 days)","Dual application framework — distinguishes between clinical onset and clinical worsening with different factor sets","Incorporation by reference to ICD-10-AM Tenth Edition (external classification system)"],"plain_english_summary":"This Statement of Principles sets the medical rules for deciding whether adhesive capsulitis (\"frozen shoulder\") is linked to Australian defence service, replacing the 2012 version with updated evidence. It affects veterans, peacekeepers, and current or former defence members claiming under the Veterans' Entitlements Act 1986 or the Military Rehabilitation and Compensation Act 2004.\n\nThe instrument lists 23 medical factors that, if shown, create a \"reasonable hypothesis\" of service connection — acting as the evidence gatekeeper for compensation."},"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":true,"description":"Section 4 expressly repeals the prior Statement of Principles (No. 7 of 2012), and this instrument establishes the current criteria (s7–s11) for linking adhesive capsulitis to relevant service. It applies to claims under section 120A of the VEA or section 338 of the MRCA (s5). The repeal in s4 indicates the earlier instrument has been replaced; the new instrument therefore supersedes the prior scope and sets updated factors and definitions (see Schedule 1)."},"complexity_factors":["Legal test: use of the “reasonable hypothesis” standard (s8–9) introduces a low‑threshold evidentiary legal concept.","Multiple timing windows and distinctions: different look‑back periods (six months, one year) for onset versus worsening (s9, s10).","Medical specificity: detailed medical conditions and treatments listed as qualifying factors (s9; Schedule 1 definitions such as dyslipidaemia).","Cross‑references to other Statements of Principles: factors that refer to other instruments import their terms (s11).","Repeal and replacement of prior instrument: repeals the 2012 Statement (s4), so assessors must apply the new terms.","Defined terms and thresholds in the Dictionary (Schedule 1) create precise diagnostic and evidentiary requirements (e.g. lipid thresholds).","Conditional application rules: subsections 9(12)–9(23) apply only to material contribution or aggravation where the condition pre‑existed or was suffered before/during service (s10)."],"plain_english_summary":"This instrument is a Statement of Principles by the Repatriation Medical Authority that sets the medical conditions and timing rules used to decide whether adhesive capsulitis of the shoulder (frozen shoulder) can be connected to a person’s military service for VEA or MRCA claims. It affects veterans, serving members and claimants whose entitlement to Commonwealth compensation or rehabilitation depends on a “reasonable hypothesis” linking the condition to service. The Authority lists specific injuries, surgeries, illnesses, medications and diagnostic thresholds and requires those factors be related to the person’s relevant service."}},"importantCases":[],"_links":{"self":"/api/acts/statement-of-principles-concerning-adhesive-capsulitis-of-the-shoulder-reasonable-hypothesis-no-72-o","history":"/api/acts/statement-of-principles-concerning-adhesive-capsulitis-of-the-shoulder-reasonable-hypothesis-no-72-o/history","analysis":"/api/acts/statement-of-principles-concerning-adhesive-capsulitis-of-the-shoulder-reasonable-hypothesis-no-72-o/analysis","conflicts":"/api/acts/statement-of-principles-concerning-adhesive-capsulitis-of-the-shoulder-reasonable-hypothesis-no-72-o/conflicts","importantCases":"/api/acts/statement-of-principles-concerning-adhesive-capsulitis-of-the-shoulder-reasonable-hypothesis-no-72-o/important-cases","documents":"/api/acts/statement-of-principles-concerning-adhesive-capsulitis-of-the-shoulder-reasonable-hypothesis-no-72-o/documents"}}