{"id":"F2016L01675","name":"Statement of Principles concerning complex regional pain syndrome (Reasonable Hypothesis) (No. 97 of 2016)","slug":"statement-of-principles-concerning-complex-regional-pain-syndrome-reasonable-hypothesis-no-97-of-201","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":438999,"registerId":"F2016L01675-fast-fetch-1775955190588","compilationNumber":null,"startDate":"2026-04-12","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Statement of Principles concerning complex regional pain syndrome (Reasonable Hypothesis) (No. 97 of 2016)","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\nCOMPLEX REGIONAL PAIN SYNDROME  (Reasonable Hypothesis)\n\n(No. 97 of 2016)\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               28 October 2016\n\n \n\n \n\n \n\n \n\n \n\nThe Common Seal of the  Repatriation Medical Authority  was affixed to this instrument  at the direction of:\n\n![](image.002.png)\n\n \n\n \n\n \n\n \n\nProfessor Nicholas Saunders AO\n\nChairperson\n\n \n\n   \n\n\nContents\n\n1 Name\n\n2 Commencement\n\n3 Authority\n\n4 Application\n\n5 Definitions\n\n6 Kind of injury, disease or death to which this Statement of Principles relates\n\n7 Basis for determining the factors\n\n8 Factors that must exist\n\n9 Relationship to service\n\n10 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 complex regional pain syndrome (Reasonable Hypothesis) (No. 97 of 2016).\n\n2               Commencement\n\n              This instrument commences on 28 November 2016.\n\n3               Authority\n\nThis instrument is made under subsection 196B(2) of the Veterans' Entitlements Act 1986.\n\n4               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\n5               Definitions\n\nThe terms defined in the Schedule 1 - Dictionary have the meaning given when used in this instrument.\n\n6               Kind of injury, disease or death to which this Statement of Principles relates\n\n(1)          This Statement of Principles is about complex regional pain syndrome and death from complex regional pain syndrome.\n\nMeaning of complex regional pain syndrome\n\n(2)          For the purposes of this Statement of Principles, complex regional pain syndrome means a disorder of a body region or regions which meets the following criteria:\n\n(a)          continuing pain, which is disproportionate to any inciting event; and\n\n(b)          at least one symptom in two of the four following categories:\n\n(i)            sensory: hyperalgesia or allodynia;\n\n(ii)         vasomotor: temperature asymmetry or skin colour changes or skin colour asymmetry;\n\n(iii)       sudomotor/oedema: oedema or sweating changes or sweating asymmetry; or\n\n(iv)        motor/trophic: decreased range of motion or motor dysfunction (weakness, tremor, dystonia) or trophic changes (hair, nails, skin); and\n\n(c)          at least one sign at the time of evaluation in two or more of the following categories:\n\n(i)            sensory: evidence of hyperalgesia (to pinprick) or allodynia (to light touch and/or deep somatic pressure or joint movement);\n\n(ii)         vasomotor: evidence of temperature asymmetry or skin colour changes or asymmetry;\n\n(iii)       sudomotor/oedema: evidence of oedema or sweating changes or sweating asymmetry; or\n\n(iv)        motor/trophic: evidence of decreased range of motion or motor dysfunction (weakness, tremor, dystonia) or trophic changes (hair, nails, skin).\n\nDeath from complex regional pain syndrome\n\n(3)          For the purposes of this Statement of Principles, complex regional pain syndrome, in relation to a person, includes death from a terminal event or condition that was contributed to by the person's complex regional pain syndrome.\n\nNote: terminal event is defined in the Schedule 1 – Dictionary.\n\n7               Basis for determining the factors\n\nThe Repatriation Medical Authority is of the view that there is sound medical‑scientific evidence that indicates that complex regional pain syndrome and death from complex regional pain syndrome 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: relevant service is defined in the Schedule 1 – Dictionary.\n\n8               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 complex regional pain syndrome or death from complex regional pain syndrome with the circumstances of a person's relevant service:\n\n(1)          having an injury or a disease involving a major peripheral nerve in the six months before the clinical onset of complex regional pain syndrome, where the pain originates in the region of the affected peripheral nerve;\n\n(2)          having an injury or a disease from the specified list of injuries or diseases in the six months before the clinical onset of complex regional pain syndrome, where the pain originates in the region of the body affected by the injury or disease;\n\nNote: specified list of injuries or diseases is defined in the Schedule 1 - Dictionary.               \n\n(3)          having surgery in the six months before the clinical onset of complex regional pain syndrome, where the pain originates in the region of the surgical procedure;\n\n(4)          being treated with phenobarbital at the time of the clinical onset of complex regional pain syndrome;\n\n(5)          inability to obtain appropriate clinical management for complex regional pain syndrome.\n\n9               Relationship to service\n\n(1)          The existence in a person of any factor referred to in section 8, must be related to the relevant service rendered by the person.\n\n(2)          The factor set out in subsection 8(5) applies only to material contribution to, or aggravation of, complex regional pain syndrome where the person's complex regional pain syndrome was suffered or contracted before or during (but did not arise out of) the person's relevant service.\n\n10           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 8 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 5\n\n1               Definitions\n\nIn this instrument:\n\n                             complex regional pain syndrome—see subsection 6(2).\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                               specified list of injuries or diseases means:\n\n(a)          acute myocardial infarction;\n\n(b)          crush injury;\n\n(c)          cut, stab, abrasion or laceration;\n\n(d)          electrical injury;\n\n(e)          external bruise;\n\n(f)           fracture;\n\n(g)          hemiplegia of the limb due to cerebrovascular accident;\n\n(h)          herpes zoster;\n\n(i)            intramuscular injection;\n\n(j)            intravenous injection or cannulation;\n\n(k)          joint dislocation;\n\n(l)            leprosy;\n\n(m)        physical injury due to munitions discharge;\n\n(n)          snakebite;\n\n(o)          spinal cord injury;\n\n(p)          sprain or strain;\n\n(q)          venepuncture; or\n\n(r)           any other injury or disease which causes acute tissue damage.\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","sortOrder":0}],"analysis":{"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":false,"description":"This instrument stays within the expected scope of a Repatriation Medical Authority Statement of Principles: it defines CRPS for claims purposes, lists the medical/time factors that raise a reasonable hypothesis of service connection, and sets how those factors relate to service and to other SOPs. It does not add issues beyond that mandate (for example, it does not create new eligibility categories, extend benefits, or alter non‑medical claim procedures)."},"complexity_factors":["Short instrument (10 substantive clauses plus a Schedule) — compact structure","Several defined terms in the Schedule: complex regional pain syndrome, relevant service, specified list of injuries or diseases, terminal event, MRCA, VEA","Conditional timing rules (six‑month window) for multiple factors (s.8(1)–(3))","Multi‑element diagnostic definition requiring both symptoms and clinical signs across specified categories (s.6(2))","Cross‑reference to other Statements of Principles where an underlying injury/disease is already covered (s.10) — creates interdependence","Discretionary/ambiguous criterion: 'inability to obtain appropriate clinical management' (s.8(5)) — increases interpretive complexity","Interplay between causation, contribution and aggravation rules (s.9 and s.8(5))","References to two different statutes (VEA and MRCA) and to specific claim sections (s.4) — procedural cross‑linking"],"plain_english_summary":"**What this instrument does (mechanics)\n\n- This is a Statement of Principles (SOP) issued by the Repatriation Medical Authority that sets out the medical criteria used to decide whether a veteran’s complex regional pain syndrome (CRPS) — or death from CRPS — can be reasonably hypothesised to be connected with their military service for the purposes of veterans’ compensation law (see sections 4 and 6).\n\n- It: (a) defines what is meant by CRPS for these claims (s.6(2)); (b) lists the medical and circumstantial factors that, if present, are sufficient to raise a \"reasonable hypothesis\" linking CRPS to relevant service (s.8); (c) requires that any such factor be related to the person’s relevant service (s.9); and (d) imports, where relevant, the factors from other SOPs when an identified factor is an injury/disease already covered by another SOP (s.10).\n\n- The RMA states it relies on \"sound medical‑scientific evidence\" that CRPS and death from CRPS can be related to relevant service (s.7).\n\n\nWho this affects\n\n- Veterans and members of the Australian Defence Force (and related categories under the VEA/MRCA) who lodge claims under the Veterans' Entitlements Act 1986 or the Military Rehabilitation and Compensation Act 2004 (s.4 and Schedule definitions).\n\n- Medical practitioners who assess and document signs, symptoms and the timing of injury/disease for claimants.\n\n- The Department that administers entitlements: if a reasonable hypothesis is found under this SOP, the claimant proceeds to the next evidentiary/legal stage for benefits.\n\n\nKey medical test and timing rules (practical summary)\n\n- Definition of CRPS (s.6(2)): continuing pain disproportionate to any inciting event; at least one reported symptom in two of four categories (sensory; vasomotor; sudomotor/oedema; motor/trophic); and at least one clinical sign in two or more of those categories at evaluation.\n\n- Factors that are sufficient to raise a reasonable hypothesis (any one of the following) (s.8):\n  - An injury or disease involving a major peripheral nerve in the six months before CRPS onset, with pain in the nerve’s region (s.8(1)).\n  - An injury or disease from the specified list (see Schedule) in the six months before CRPS onset, with pain in the injured region (s.8(2)).\n  - Surgery in the six months before CRPS onset, with pain originating in the surgical region (s.8(3)).\n  - Being treated with phenobarbital at the time CRPS begins (s.8(4)).\n  - Inability to obtain appropriate clinical management for CRPS (s.8(5)).\n\n- The six‑month timing window is a repeated requirement for the nerve injury, specified injuries, and surgery factors (s.8(1)–(3)).\n\n- Death from CRPS is included where CRPS contributed to the terminal event (s.6(3) and Schedule definition of \"terminal event\").\n\n\nHow the SOP links to service and other SOPs\n\n- Any listed factor must be connected to the person’s \"relevant service\" (operational, peacekeeping, hazardous, British nuclear test defence service under the VEA, or warlike/non‑warlike service under the MRCA) (s.9 and Schedule).\n\n- If a factor refers to an injury or disease that is already the subject of another SOP, the criteria in that other SOP apply (s.10).\n\n\nPurpose‑claim and practical implications\n\n- The RMA asserts (s.7) that medical evidence supports connecting CRPS to service in some cases. Mechanically, the SOP provides a structured, evidence‑based shortcut for claims decision‑makers: if the claimant meets the SOP criteria, a \"reasonable hypothesis\" of service connection is raised and the claim advances under the statutory test.\n\n- Who pays and who decides: entitlement payments or compensation remain payable under the VEA/MRCA administrative processes if the claim succeeds. The RMA (through this SOP) supplies the medical threshold; the government (through its claims/agencies) makes the entitlement decision and pays any benefits.\n\n\nCosts, incentives and trade‑offs (implementation risks and behavioural effects)\n\n- Cost incidence: claims that meet the SOP make it more likely veterans will obtain benefits paid by the government; the fiscal cost is borne by the State/taxpayers. The direct private‑sector effect is limited.\n\n- Incentives for claimants and doctors: the SOP encourages claimants (and their treating clinicians) to document timing, the anatomical origin of pain, the presence of specified injuries/surgery/nerve damage, and medication history (e.g. phenobarbital). That documentation influences claim outcomes.\n\n- Administrative discretion and medical uncertainty: some criteria are concrete (six‑month windows, listed injuries). Others are less precise — notably \"inability to obtain appropriate clinical management\" (s.8(5)) — which admits administrative and medical judgement and may produce inconsistent decisions or increased evidentiary disputes.\n\n- Substitution and evidentiary burden: because the SOP imports other SOPs when an underlying injury is covered elsewhere (s.10), claimants may need to navigate multiple SOPs and produce records that satisfy more than one standard.\n\n- Concentrated benefits, diffuse costs: those veterans who meet the listed factors obtain a procedurally easier path; costs are spread across the broader public budget.\n\n- Implementation risk: the diagnostic definition of CRPS requires assessment of both subjective symptoms and objective signs at evaluation (s.6(2)), which can be clinically challenging and may lead to disputes over whether the sign/symptom thresholds are met at the time of assessment.\n\n\nPractical compliance burden\n\n- Claimants must provide medical records showing: the inciting injury/surgery/nerve disease within six months of CRPS onset (where relevant), documentation of symptoms and clinical signs meeting the definition (s.6), medication history (phenobarbital), or evidence that appropriate clinical care was unavailable.\n\n- Treating clinicians may need to record specific categories of symptoms and signs to satisfy the SOP’s checklist‑style requirements.\n\n\nNet effect on private enterprise and markets\n\n- Direct effects on competition, prices, productivity or ownership are minimal. The SOP primarily affects administrative eligibility for government benefits rather than market regulation.\n\n- Indirect effects may include higher demand for medical documentation and medico‑legal assessments from private providers, and administrative workload for the agencies handling claims.\n\n\nSource statements vs. tested implications\n\n- The instrument itself states the evidentiary basis (s.7). The practical implications above describe the likely administrative, fiscal and behavioural consequences that follow from using a condition‑based SOP as the statutory threshold for a reasonable hypothesis.\n\n\nBottom line (plain):\n\n- This SOP tells decision‑makers: here is how to recognise CRPS for claims, and here are the specific, mainly time‑limited medical or service‑related factors that will — if linked to a person’s relevant service — be enough to raise a reasonable hypothesis that the CRPS is related to service. That makes it procedurally easier for qualifying veterans to proceed with an entitlement claim, while imposing a documentary and clinical evidence burden on claimants and their clinicians."},"kimi_summary":{"content_quality":"ok","complexity_score":4,"scope_assessment":{"changed":false,"description":"This instrument appears to maintain its original scope as a specific medical determination for CRPS under the veterans' compensation framework. It follows the standard template for Repatriation Medical Authority Statements of Principles without significant scope creep."},"complexity_factors":["Moderate cross-referencing between the main sections and Schedule 1 (Dictionary)","Medical diagnostic criteria in section 6(2) with four categories and sub-categories requiring specific combinations (symptoms from 2 of 4 categories, signs from 2 of 4 categories)","Conditional logic in section 8 with five alternative factors (disjunctive requirements)","Nested limitation in section 9(2) restricting the application of factor 8(5) to aggravation cases only","Incorporation by reference mechanism in section 10 linking to other Statements of Principles","18 defined terms in the Dictionary including a detailed list of 18 specific injuries/diseases plus a catch-all category"],"plain_english_summary":"This Statement of Principles sets the medical test for CRPS compensation claims by defining the condition and identifying five service‑related factors (major nerve injury, certain traumatic injuries, recent surgery, phenobarbital use, or inability to obtain treatment) that can create a “reasonable hypothesis” linking CRPS to service. It applies to veterans and defence members under the VEA 1986 and MRCA 2004 and is the legal gateway to entitlement — note the treatment‑access factor only aids claims for worsening pre‑existing CRPS."}},"importantCases":[],"_links":{"self":"/api/acts/statement-of-principles-concerning-complex-regional-pain-syndrome-reasonable-hypothesis-no-97-of-201","history":"/api/acts/statement-of-principles-concerning-complex-regional-pain-syndrome-reasonable-hypothesis-no-97-of-201/history","analysis":"/api/acts/statement-of-principles-concerning-complex-regional-pain-syndrome-reasonable-hypothesis-no-97-of-201/analysis","conflicts":"/api/acts/statement-of-principles-concerning-complex-regional-pain-syndrome-reasonable-hypothesis-no-97-of-201/conflicts","importantCases":"/api/acts/statement-of-principles-concerning-complex-regional-pain-syndrome-reasonable-hypothesis-no-97-of-201/important-cases","documents":"/api/acts/statement-of-principles-concerning-complex-regional-pain-syndrome-reasonable-hypothesis-no-97-of-201/documents"}}