{"id":"F2024L00216","name":"Statement of Principles concerning seborrhoeic keratosis (Balance of Probabilities) (No. 20 of 2024)","slug":"statement-of-principles-concerning-seborrhoeic-keratosis-balance-of-probabilities-no-20-of-2024","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":442290,"registerId":"F2024L00216-fast-fetch-1775957340134","compilationNumber":null,"startDate":"2026-04-12","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Statement of Principles concerning seborrhoeic keratosis (Balance of Probabilities) (No. 20 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\n\n \n\nStatement of Principles\n\nconcerning\n\nSEBORRHOEIC KERATOSIS (Balance of Probabilities)\n\n(No. 20 of 2024)\n\nThe Repatriation Medical Authority determines the following Statement of Principles under subsection 196B(3) of the Veterans' Entitlements Act 1986.\n\n \n\nDated 22 February 2024.\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:
|\n| --- |\n|
Professor Terence Campbell AM
Chairperson
|\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 seborrhoeic keratosis (Balance of Probabilities) (No. 20 of 2024).\n\n2 Commencement\n\n This instrument commences on 26 March 2024.\n\n3 Authority\n\nThis instrument is made under subsection 196B(3) of the Veterans' Entitlements Act 1986.\n\n4 Repeal\n\nThe Statement of Principles concerning seborrhoeic keratosis No. 56 of 2015 (Federal Register of Legislation No. F2015L00251) made under subsection 196B(3) of the VEA is repealed.\n\n5 Application\n\nThis instrument applies to a claim to which section 120B of the VEA or section 339 of the Military Rehabilitation and Compensation Act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 seborrhoeic keratosis and death from seborrhoeic keratosis.\n\nMeaning of seborrhoeic keratosis\n\n(2) For the purposes of this Statement of Principles, seborrhoeic keratosis:\n\n(a) means a benign intra-epidermal skin tumour arising from the proliferation of basaloid keratinocytes with histopathological architecture of a papilloma with a flat base and a hyperkeratotic crown; and\n\n(b) includes:\n\n(i) basal cell papilloma;\n\n(ii) dermatosis papulosa nigra;\n\n(iii) pigmented seborrhoeic keratosis;\n\n(iv) seborrhoeic wart;\n\n(v) stucco keratosis; and\n\n(vi) Leser-Trélat sign/disease; and\n\n(c) excludes:\n\n(i) seborrhoeic dermatitis; \n\n(ii) seborrhoeic psoriasis; and\n\n(iii) solar keratosis.\n\n(3) While seborrhoeic keratosis attracts ICD‑10‑AM code L82, in applying this Statement of Principles the meaning of seborrhoeic keratosis 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 seborrhoeic keratosis\n\n(5) For the purposes of this Statement of Principles, seborrhoeic keratosis, in relation to a person, includes death from a terminal event or condition that was contributed to by the person's seborrhoeic keratosis.\n\nNote: terminal event is defined in the Schedule 1 – Dictionary.\n\n8 Basis for determining the factors\n\nOn the sound medical‑scientific evidence available, the Repatriation Medical Authority is of the view that it is more probable than not that seborrhoeic keratosis and death from seborrhoeic keratosis can be related to relevant service rendered by veterans 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 exist before it can be said that, on the balance of probabilities, seborrhoeic keratosis or death from seborrhoeic keratosis is connected with the circumstances of a person's relevant service:\n\n(1) inability to obtain appropriate clinical management for seborrhoeic keratosis before clinical worsening.\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 factor set out in subsection 9(1) applies only to material contribution to, or aggravation of, seborrhoeic keratosis where the person's seborrhoeic keratosis 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(3) 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 MRCA means the Military Rehabilitation and Compensation Act 2004.\n\n relevant service means:\n\n(a) eligible war service (other than operational service) under the VEA;\n\n(b) defence service (other than hazardous service and British nuclear test defence service) under the VEA; or\n\n(c) peacetime service under the MRCA.\n\nNote: MRCA and VEA are also defined in the Schedule 1 - Dictionary.\n\n seborrhoeic keratosis—see subsection 7(2).\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":{"kimi_summary":{"content_quality":"ok","complexity_score":3,"scope_assessment":{"changed":false,"description":"This Statement of Principles maintains the same narrow scope as its 2015 predecessor. It addresses a single, specific benign skin condition and establishes minimal connection factors for veterans' compensation purposes. The 2024 revision updates medical definitions and coding references but does not expand the substantive scope beyond determining service-relatedness for seborrhoeic keratosis claims."},"complexity_factors":["Short document (approximately 1,500 words across 11 sections plus a brief dictionary)","Only 7 defined terms in Schedule 1, with minimal cross-referencing","Single operative factor in section 9 (inability to obtain appropriate clinical management), with straightforward application in section 10","Medical terminology is technical but clearly defined in section 7(2) with explicit inclusions and exclusions","Simple conditional structure: one factor OR nothing; no nested exceptions or complex logical operators","References to external legislation (VEA, MRCA) are limited and clearly defined","No temporal complexity or transitional provisions beyond basic commencement and repeal clauses"],"plain_english_summary":"This rulebook tells decision-makers whether Australian veterans and current/former defence members can get compensation for seborrhoeic keratosis. It provides one service-connection pathway: the condition (which must have existed before or during service) is compensable if the person couldn’t access proper medical treatment because of their service. It tightens the condition’s definition (naming included and excluded subtypes), allows death from related complications to count, and applies the usual “balance of probabilities” test."},"flash_summary":{"complexity_score":3,"scope_assessment":{"changed":true,"description":"This instrument repeals the prior Statement of Principles (s4) and restates the condition's legal definition and scope (s7). It sets a single qualifying factor for service connection (s9) and clarifies that that factor must be related to 'relevant service' (s10). Those definitional clarifications and the move to a sole listed factor represent a change in scope and the mechanics of proving connection to service compared with the repealed 2015 instrument (s4, s7–s10)."},"complexity_factors":["Technical medical definition and explicit inclusions/exclusions for seborrhoeic keratosis (s7(2)–(4)) — requires clinical interpretation.","Standard of proof and evidentiary framing: reliance on 'balance of probabilities' and 'sound medical‑scientific evidence' (s8).","Single qualifying factor approach: only 'inability to obtain appropriate clinical management before clinical worsening' qualifies (s9(1)), with a service‑relationship constraint (s10).","Cross‑references to other Statements of Principles where factors refer to other conditions (s11) — creates interdependence and potential complexity in claims involving multiple conditions.","Replaces earlier instrument (repeal of No.56 of 2015) and sets a clear commencement date (s4, s2) — administrative transition implications (s4).","Reference to but override of ICD‑10‑AM coding by the instrument's own definition (s7(3)–(4)) — affects clinical coding versus legal meaning.","Applicability to distinct statutory schemes (VEA and MRCA) and defined categories of 'relevant service' (s5, Schedule 1) — determines the population and payor/decision framework.","Definition of 'terminal event' for death claims (Schedule 1) — narrows what is treated as death from the condition for entitlement purposes."],"plain_english_summary":"This Statement of Principles by the Repatriation Medical Authority defines seborrhoeic keratosis (what is included and excluded), treats death partly caused by it as within scope, repeals the 2015 statement, and applies to claims under the Veterans' Entitlements Act and the Military Rehabilitation and Compensation Act. Mechanically, it makes a veteran’s claim more likely to succeed on the balance of probabilities if at least one listed factor exists — presently only ‘inability to obtain appropriate clinical management before clinical worsening’ — and that factor must be related to relevant service."},"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"}},"importantCases":[],"_links":{"self":"/api/acts/statement-of-principles-concerning-seborrhoeic-keratosis-balance-of-probabilities-no-20-of-2024","history":"/api/acts/statement-of-principles-concerning-seborrhoeic-keratosis-balance-of-probabilities-no-20-of-2024/history","analysis":"/api/acts/statement-of-principles-concerning-seborrhoeic-keratosis-balance-of-probabilities-no-20-of-2024/analysis","conflicts":"/api/acts/statement-of-principles-concerning-seborrhoeic-keratosis-balance-of-probabilities-no-20-of-2024/conflicts","importantCases":"/api/acts/statement-of-principles-concerning-seborrhoeic-keratosis-balance-of-probabilities-no-20-of-2024/important-cases","documents":"/api/acts/statement-of-principles-concerning-seborrhoeic-keratosis-balance-of-probabilities-no-20-of-2024/documents"}}