Statement of Principles concerning autosomal dominant polycystic kidney disease (Reasonable Hypothesis) (No. 35 of 2023)

The instrument contains a small number of tightly defined legal and medical concepts that govern its application.

• Scope and legal basis. The instrument is a Statement of Principles under s196B(2) VEA (s3) and applies to claims to which s120A VEA or s338 MRCA applies (s5). It therefore functions as the RMA’s determination of the medical-scientific basis for causation in statutory claims, rather than as primary legislation on entitlements.

• Definition of the disease. ADPKD is defined textually as "an autosomal dominant genetic disorder, which involves the development of multiple bilateral renal cysts and enlarged kidneys, associated with gradual deterioration of renal function, and may involve cysts in other organs such as the liver" (s7(2)(a)). The instrument excludes certain other cystic kidney diseases and acquired cystic disease from the meaning of ADPKD (s7(2)(b)). Although the ICD‑10‑AM code Q61.2 is noted (s7(3)), subsection 7(3) instructs that for application of this Statement the meaning is the textual definition in s7(2), and s7(4) identifies the specific ICD‑10‑AM edition referenced.

• Death from ADPKD. The instrument embraces not only the diagnosed disease but also death from a terminal event or condition that was contributed to by the person's ADPKD (s7(5)). The Schedule lists particular forms of terminal events (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function).

• Threshold for a "reasonable hypothesis". Section 9 prescribes the factors that must exist before a reasonable hypothesis connecting ADPKD (or death from it) to relevant service can be said to be raised. The instrument specifies a single minimum factor: inability to obtain appropriate clinical management for ADPKD (s9(1)). That is the statutory minimum; a claim must establish at least one of the factors listed.

• Relationship to service. Section 10 links the enumerated factor(s) to relevant service. All factors in s9 must be related to relevant service (s10(1)). Subsection 10(2) restricts the operation of the s9(1) factor where the disease was suffered or contracted before or during (but did not arise out of) the relevant service: in those circumstances s9(1) may only apply to material contribution to, or aggravation of, the disease.

• Interaction with other Statements. Section 11 provides that where an s9 factor refers to an injury or disease covered by another Statement of Principles determined under s196B(2) VEA, the factors in that other Statement apply in accordance with its terms as in force from time to time. That creates cross-referential application where conditions overlap.

• Definitions and categories. Schedule 1 supplies definitions essential to interpretation , in particular, a non-exhaustive list of what counts as "relevant service" under the instrument (operational, peacekeeping, hazardous, British nuclear test defence service under the VEA, warlike and non-warlike service under the MRCA) and the definition of "terminal event" for death cases (Schedule 1, definitions).

These concepts form the mechanical criteria that decision-makers must apply when assessing whether a reasonable hypothesis exists tying ADPKD or death from ADPKD to relevant service under the specified provisions of the VEA and MRCA.

Directly affected persons

• Claimants. The instrument applies to persons making claims to which section 120A of the VEA or section 338 of the MRCA applies (s5). That means individuals whose claims raise an issue whether ADPKD, or death from ADPKD, can be connected to their relevant service under the statutory framework to which those sections relate. The Statement therefore limits and structures the medical criteria such claimants must meet to establish a reasonable hypothesis linking the condition to their service.

• Next of kin and estates in death claims. Because s7(5) includes death from a terminal event or condition contributed to by ADPKD, families, representatives and estates pursuing death-related entitlements under the VEA or MRCA will be affected where ADPKD is alleged to have contributed to the terminal event.

Indirectly affected persons and bodies

• Decision-makers under the VEA and MRCA. While the instrument itself is a determination by the Repatriation Medical Authority (s3), decision-makers who adjudicate claims under the VEA/MRCA will apply this Statement of Principles as the RMA’s medical-scientific guidance on causation. The instrument sets the criteria those decision-makers must consider when deciding whether a reasonable hypothesis exists.

• Medical and legal practitioners preparing and advising on claims. The single enumerated factor (inability to obtain appropriate clinical management) frames the evidentiary case practitioners will need to develop and present. Practitioners preparing dossiers must be attentive to the textual disease definition in s7(2), the exclusions in s7(2)(b), and the terminal event concept in Schedule 1.

• Agencies administering entitlements. Administrative units that process claims will need to apply the Statement when screening and assessing medical causation issues, and must account for the repeal of the previous 2015 Statement (s4) where comparative assessment arises for claims spanning the repeal date.

Who bears costs or consequences

• Claimants bear the primary evidentiary burden of raising the factors in s9 and establishing the required relationship to relevant service under s10. The instrument establishes the legal criteria; it does not set procedural rules for proof, but meeting the criteria will require evidence of the disease, evidence that the enumerated factor existed, and evidence linking that factor to relevant service.

• Administrative bodies and decision-makers bear the implementation costs of applying the new wording, and may need to revise assessment templates, training material and internal guidance to reflect the new Statement and its commencement and repeal dates.

Categories of service captured

• The Schedule defines "relevant service" widely to include operational, peacekeeping, hazardous, British nuclear test defence service (all under the VEA) as well as warlike and non-warlike service under the MRCA (Schedule 1, relevant service). The instrument therefore reaches claims arising from a range of service types identified in the Schedule.

Temporal coverage

• The instrument commenced on 23 May 2023 (s2). It repeals the 2015 Statement (s4). The instrument does not contain explicit transitional provisions; practitioners and administrators will need to determine how the repeal interacts with claims lodged before and after commencement, consistent with the governing statutes and administrative practice.

In short, the instrument primarily affects claimants seeking to connect ADPKD or death from ADPKD to service for entitlement purposes, and the practitioners and decision-makers who prepare and adjudicate those claims. It sets a single, focused factor that must be proved and prescribes how that factor must relate to recognised categories of relevant service.

Duties created by the instrument

• Duty to apply the Statement when relevant. The Repatriation Medical Authority has determined this Statement under s196B(2) VEA (s3), and it applies to claims within s120A VEA or s338 MRCA (s5). Decision-makers assessing such claims must take the Statement into account as the RMA’s determination of the medical-scientific criteria for raising a reasonable hypothesis; the instrument creates the duty to assess causation against its criteria where relevant.

• Duty to relate factors to service. Any factor relied upon from s9 must be related to the person's relevant service (s10(1)). Where the s9(1) factor is relied upon in relation to disease suffered or contracted before or during (but not arising out of) relevant service, that factor is only applicable to material contribution to, or aggravation of, the disease (s10(2)). This imposes a specific duty on claimants and decision-makers to demonstrate the causal nexus between the factor and the relevant service category.

• Duty to consult cross-referenced Statements. If a factor in s9 refers to an injury or disease covered by another Statement of Principles made under s196B(2) VEA, then the factors in that other Statement apply in accordance with its terms as varied from time to time (s11). This creates a duty on decision-makers and practitioners to identify and apply cross-referenced Statements in appropriate cases.

Rights and entitlements implicated

• Right to have causation assessed under this Statement. Persons with relevant claims have the right to have ADPKD or death from ADPKD assessed against the RMA’s Statement of Principles as it stands for the purposes of raising a reasonable hypothesis. The instrument sets the evidential yardstick for that assessment.

• Inclusion of death caused via terminal events. The instrument expressly includes death from a terminal event or condition that was contributed to by ADPKD (s7(5)), which confers the right for death-related claims to be considered when ADPKD has materially contributed to the terminal event listed in the Schedule.

Limits and clarifications

• Textual definition takes precedence over ICD code for the Statement’s application. Although the ICD-10-AM code Q61.2 is noted (s7(3)), the instrument instructs that the meaning of ADPKD for this Statement is the textual definition in s7(2). The instrument also specifies the edition of ICD-10-AM referenced (s7(4)). Practitioners should note that the statutory meaning is the descriptive definition rather than reliance solely on the ICD code.

• Exclusions. The instrument excludes certain other cystic and acquired kidney diseases from the meaning of ADPKD (s7(2)(b)). That limits claims that might otherwise be framed by reference to broader cystic kidney pathology.

Procedural duties not contained

• The instrument does not set procedural proof rules, evidence thresholds beyond the factors, or the administrative process for lodging or deciding claims. Those procedural duties remain located in the VEA, MRCA and associated regulations or administrative practice. The Statement supplies the medical criteria that must be considered in that existing procedural context.

In sum, the instrument establishes duties to apply its definitions and causal-factor tests in relevant claims, limits the disease concept and death inclusions, imposes the requirement that factors be related to relevant service under specified constraints, and requires cross-referencing to other Statements where applicable.

Nature of enforcement

• The instrument is a Statement of Principles under subsection 196B(2) of the VEA (s3). It is not itself an enforcement provision or a penal regime. It sets out the Repatriation Medical Authority’s determinations about medical-scientific causation for the purposes of assessing claims under specified provisions of the VEA and MRCA (s5). Enforcement in the conventional criminal or regulatory sense (fines, criminal sanctions) is not created by this instrument.

How the instrument is used in claims adjudication

• Adjudicative effect. The primary enforcement effect of the Statement is administrative: it provides the RMA's medical-scientific criteria which decision-makers apply when determining whether a "reasonable hypothesis" has been raised linking ADPKD or related death to relevant service. Decisions under the VEA/MRCA about benefit entitlements, rehabilitation or related administrative outcomes will be informed by whether claimants meet the criteria set out in this Statement. The instrument, therefore, functions as a binding or authoritative medical guide in the administrative decision-making process, though it does not itself prescribe sanctions.

Remedies and review

• The Statement does not specify remedies, appeal or review mechanisms. Those procedural avenues for challenge, review or appeal of decisions that apply the Statement are governed by the VEA, MRCA and their associated judicial and administrative review processes, which are outside the text of this instrument. The instrument does not alter or create penalty clauses or civil remedies; rather, it operates as the medical-scientific standard applied in the existing statutory framework.

Compliance consequences

• Administrative consequences of non-compliance with the instrument per se are indirect: if a claimant cannot demonstrate the requisite factors and the required relationship to relevant service as set in the Statement, decision-makers may find that a reasonable hypothesis has not been raised and consequently decline to accept the claimed connection for entitlement purposes. Conversely, a finding that the Statement’s criteria are met may lead to administrative acceptance of causation and the consequent entitlements under the governing statutes. The instrument itself does not stipulate the downstream entitlements or sanctions.

Transparency and certainty risks

• The Statement contains terms that are not defined in the instrument, notably "inability to obtain appropriate clinical management" (s9(1)) and "material contribution" or "aggravation" as they are used in s10(2). The lack of statutory definition introduces interpretive space for adjudicators, which in practice may lead to disputes about application. That interpretive uncertainty may manifest as contested decisions or administrative review, but the instrument itself does not prescribe penalties for divergent views.

In short, the instrument does not create penalties; it creates an authoritative medical framework that is enforced through administrative application in claims under the VEA and MRCA. Enforcement consequences flow through the statutory decision processes that use this Statement as the medical basis for causation findings.

Interaction with the Veterans' Entitlements Act 1986 and MRCA

• Source and application. The instrument is made under subsection 196B(2) of the VEA (s3) and expressly states that it applies to claims to which section 120A of the VEA or section 338 of the MRCA applies (s5). That means the Statement must be read and applied in the context of those statutory claim provisions; it provides the medical-scientific foundation for establishing a reasonable hypothesis of causation within those statutory frameworks. The instrument itself does not amend the VEA or the MRCA , it operates as an RMA determination under the VEA framework.

Cross-references to other Statements of Principles

• Section 11 creates explicit cross-Statement interaction: if an s9 factor refers to an injury or disease covered by another Statement of Principles made under s196B(2) VEA, then the factors in that other Statement apply in accordance with its terms as in force from time to time (s11). That establishes an automated method to import the content of other Statements where overlap exists. Practically, this requires decision-makers and practitioners to identify overlapping Statements and apply their provisions consistently with the terms of those Statements in force at the time of assessment.

Relationship to ICD-10-AM and coding systems

• The instrument notes that ADPKD attracts ICD‑10‑AM code Q61.2 (s7(3)) and identifies the precise edition and effective date of the ICD-10-AM referenced (s7(4)). However, s7(3) clarifies that, for the purposes of applying this Statement, the meaning of ADPKD is the textual definition in s7(2). This creates a relationship where the coding system is acknowledged for classification but the statutory definition governs legal application.

Interaction with administrative and procedural law (implicit)

• The Statement sets medical criteria to be applied within the procedural rules of the VEA and MRCA. The instrument itself does not set appeals, review, evidence admissibility, or procedural deadlines; those procedural elements are left to the governing statutes and their administrative systems. Therefore, in practice, claimants and administrators will apply this Statement through the existing decision-making and review channels established by the VEA and MRCA, which govern rights to review, merits appeal and judicial review outside the Statement text.

Statutory exclusions and overlap with other medical conditions

• The instrument excludes certain kidney diseases from the definition of ADPKD (s7(2)(b)). Where a claim involves those excluded conditions, the Statement will not assist in establishing a reasonable hypothesis for ADPKD; instead, other Statements (if any) for the excluded diseases or other statutory provisions would need to be considered. Section 11 governs situations where s9 points to an injury or disease already covered elsewhere.

Temporal interaction: repeal of prior Statement

• The instrument repeals the 2015 Statement (s4). That repeal changes the authoritative Statement to be applied from the commencement date (s2). How that temporal change interacts with claims lodged before the commencement date is not addressed in the instrument, so practitioners must apply the new Statement in the context of relevant statutory and administrative transitional rules.

In summary, the Statement interacts with other laws primarily by supplying the RMA’s medical-scientific criteria to be applied within the statutory framework of the VEA and the MRCA, by cross-referencing and importing other Statements where relevant, by acknowledging but subordinating ICD coding to the textual definition, and by replacing the prior 2015 Statement as of its commencement.

Instrument provenance and dates

• This Statement of Principles is recorded as No. 35 of 2023. The document is dated 24 April 2023 and it commences on 23 May 2023 (see the front matter, s2 and the date entry). The Repatriation Medical Authority affixed its Common Seal at the direction of Professor Terence Campbell AM, Chairperson.

Repeal of prior Statement

• Section 4 expressly repeals the earlier Statement of Principles concerning autosomal dominant polycystic kidney disease No. 39 of 2015 (Federal Register of Legislation No. F2015L00004). The repeal is absolute in form; the instrument does not include transitional provisions within its text describing how pending or decided claims are to be treated.

Changes in definitional content versus the repealed instrument

• The instrument contains a single enumerated factor (s9(1)) , inability to obtain appropriate clinical management , as the minimum factor required to raise a reasonable hypothesis. Without the prior Statement text in this instrument, one can only note that the 2015 Statement is repealed and replaced; the current instrument’s text is authoritative as of commencement.

Absence of later amendments in the instrument

• No amendments to the 2023 instrument are recorded within the text provided. The instrument refers to the applicability of other Statements as they stand "from time to time" (s11), which means cross-referenced Statements may be amended subsequently, and such amendments would interact with this Statement under s11.

Publication and citation

• The instrument references the ICD‑10‑AM, Tenth Edition, effective date 1 July 2017, and provides the ISBN and copyright owner for that classification system (s7(4)). This indicates the RMA’s reliance on a particular edition of an external clinical classification system when noting the coding of ADPKD (even though the textual definition controls application per s7(3)).

Practical significance of repeal and commencement timing

• The timing of repeal and commencement creates an implementation milestone: after 23 May 2023 this instrument governs the RMA’s Statement of Principles for ADPKD claims in place of the 2015 Statement. The instrument itself does not spell out transitional arrangements for claims spanning the repeal date; therefore, administrators and practitioners must apply the new Statement from its commencement date and must consult the VEA, MRCA and administrative practice for transitional handling.

In short, the amendment history recorded within the instrument is limited: it replaces the 2015 Statement, it is dated 24 April 2023 and commences 23 May 2023, and it contains no subsequent amendments within the provided text.

No litigation record included in the instrument

• The instrument contains no statements, footnotes or appendices recording judicial decisions, litigation, or disputes related to its content. It does not list any cases, treatment of precedent, or outcomes of appeals. The text is confined to the RMA’s determinations and the Statement itself.

Implications of an absence of litigation history

• Because the instrument contains no litigation history, readers should treat the Statement as an administrative determination not annotated with case law or interpretive precedent in the document itself. Any interpretive disputes about undefined phrases such as "inability to obtain appropriate clinical management" or the application of s10(2)’s limitation on material contribution/aggravation would have to be resolved in administrative decision-making and, if contested, through the statutory review and appeal mechanisms provided by the VEA and MRCA frameworks. Those potential disputes and any outcomes would not be recorded in this instrument.

Potential loci for future litigation (based on the instrument’s language)

• The instrument contains terms that are open to interpretation and may generate contested decisions: the meaning and evidentiary threshold for "inability to obtain appropriate clinical management" (s9(1)) is not defined; the statutory application of "material contribution" and "aggravation" in s10(2) may be contested; and the correct application of s11 where an s9 factor refers to a disease covered by another Statement may raise questions of precedence and timing. The instrument includes the textual definition of ADPKD and explicit exclusions (s7(2)), which could also be a focus of disputes where diagnostic labels overlap.

No recorded judicial construction of this instrument in the text

• The Statement itself does not record any judicial construction or settled interpretive approach. Those seeking to rely on or challenge a decision that applies this Statement must search or litigate in the appropriate judicial or administrative review forums outside the text of the instrument, relying on the procedural and review rights in the VEA and MRCA.

In summary, the instrument contains no internal litigation history. The document’s language leaves interpretive issues for administrative practice and potential judicial or review processes under the governing statutes, none of which are documented in the instrument itself.

Terms left undefined in the instrument

• "Inability to obtain appropriate clinical management" (s9(1)). The Statement identifies this as the sole minimum factor that can raise a reasonable hypothesis, but the phrase is not defined, qualified, or exemplified. The absence of a statutory definition leaves open critical questions: what quality and duration of lack of access suffice, whether inability must be caused by service conditions, and whether inability means absolute impossibility or a failure to receive timely or guideline-standard care. Practitioners cannot find a clarifying definition in the instrument.

• "Material contribution" and "aggravation" (s10(2)). Those legal causation concepts are invoked but not elaborated in the instrument. The instrument restricts s9(1)’s application to material contribution or aggravation where the disease pre-existed or was contracted before/during service but did not arise out of it; however, the instrument does not supply threshold tests or examples for material contribution or aggravation.

Scope and single-factor structure

• Single enumerated factor. Section 9 lists only one factor , inability to obtain appropriate clinical management , as the minimum that must exist. That concentrated focus means that claims alleging other service-related causal mechanisms not captured by that specific wording will not satisfy the Statement’s enumerated minimum unless they fall under another Statement invoked via s11. Practitioners should not assume that a wider range of occupational or environmental exposures is automatically covered by this Statement in the absence of incorporation elsewhere.

Exclusions to the disease definition

• The instrument expressly excludes autosomal recessive polycystic kidney disease, medullary sponge kidney disease, medullary cystic kidney disease and acquired cystic disease of kidney from the meaning of ADPKD (s7(2)(b)). Claims that rely on those conditions will not be advanced under this Statement and require consideration of other Statements or legal avenues. Misdiagnosis or mislabelling can therefore be critical to claim success.

Reliance on textual definition over ICD code

• Although the instrument notes the ICD‑10‑AM code Q61.2 applies to ADPKD (s7(3)) and specifies the edition referenced (s7(4)), it instructs that the meaning of ADPKD for applying the Statement is the textual definition in s7(2). Relying solely on coding can be inadequate; decision-makers must apply the textual definition and exclusions.

Relevance and timing issues due to repeal

• Repeal of the 2015 Statement (s4) and commencement date (s2) expose practitioners to timing issues: the instrument contains no transitional rules addressing claims commenced before the 23 May 2023 commencement but decided afterwards. Parties should be alert to how administrative practice and the governing statutes handle the temporal application of Statements.

Cross-Statement application complexity

• Section 11 requires cross-application of other Statements where an s9 factor refers to an injury or disease covered by another Statement. That creates potential complexity: to determine which Statement controls, practitioners must identify referenced cross-Statements and their current terms. The instrument requires application "in accordance with the terms of that Statement as in force from time to time", which makes up-to-date checking of other Statements essential.

Textual anomalies

• The Schedule contains the dictionary entry "autosomal dominant polysystic kidney disease,see subsection 7(2)". That spelling "polysystic" appears inconsistent with the spelling used elsewhere in the instrument. While minor, textual inconsistencies can complicate precise drafting queries or automated searches.

Limited procedural guidance

• The instrument sets the medical criteria but does not provide procedural guidance about the kinds of evidence, form of proof or administrative process. Practitioners must therefore rely on the governing statutes and administrative policy for evidential and procedural expectations.

Narrow death definition reliance

• The instrument includes death caused by a "terminal event or condition that was contributed to by the person's ADPKD" (s7(5)), and the Schedule lists examples of terminal events. However, the causal link required between ADPKD and the terminal event is not elaborated in the instrument; determining whether ADPKD contributed to a listed terminal event will require medical evidence and interpretive judgement.

In sum, the instrument is concise and narrowly focused; its lack of definitional detail on central terms and absence of procedural guidance are likely the principal practical pitfalls for claim preparation and adjudication.

For claimants and advisers

• Identify the statutory basis of the claim. Confirm the claim is within the scope of section 120A of the VEA or section 338 of the MRCA, as this Statement applies only to claims to which those sections apply (s5). The Statement itself does not specify procedural steps for lodging; follow statutory procedures under the relevant Act for submission.

• Establish the disease as defined in the Statement. Demonstrate that the condition meets the textual definition in s7(2): an autosomal dominant genetic disorder involving multiple bilateral renal cysts and enlarged kidneys, associated with gradual deterioration of renal function, and possibly involving cysts in other organs such as the liver. Ensure diagnoses distinguish ADPKD from excluded conditions listed in s7(2)(b). For death claims, demonstrate that death was from a terminal event or condition contributed to by ADPKD (s7(5)) and relate it to items in the Schedule’s terminal event list where applicable.

• Prove the minimum factor(s). The Statement requires that at least one of the factors in s9 exist; the instrument lists a single minimal factor: inability to obtain appropriate clinical management for ADPKD (s9(1)). Compile contemporaneous medical records, appointment records, referral histories, correspondence, and other documentation to evidence inability to obtain appropriate clinical management. Because the instrument does not define that phrase, include contextual details: dates, locations, reasons for inability to access care, attempts to obtain care, clinical consequences of missed or delayed management, and any service-related causes of the inability.

• Demonstrate the relationship to relevant service. Under s10(1), any s9 factor relied upon must be related to the person's relevant service. Use service records to establish the timing and nature of the relevant service as defined in Schedule 1 (operational, peacekeeping, hazardous, British nuclear test defence service under the VEA; warlike or non-warlike under the MRCA). Where the disease pre-existed or was contracted before/during service but did not arise out of service, s10(2) requires showing that inability to obtain appropriate clinical management materially contributed to, or aggravated, the disease. Evidence should therefore link the inability to obtain management to measurable deterioration or aggravation of renal function or clinical progression.

• Address exclusions and overlaps. If a factor in s9 refers to a condition already covered in another Statement, identify that Statement and apply its factors as required by s11. Check the current terms of any cross-referenced Statement, as s11 imports those terms "as in force from time to time".

• Prepare for definitional challenges. Because key terms are undefined, prepare expert medical evidence that explains how the facts meet the instrument’s criteria, including the medical standard of "appropriate clinical management" and clinical causation linking missed or unavailable management to disease progression or terminal event. Where death is claimed, obtain and supply a cause-of-death certificate and expert opinion tying the terminal event to ADPKD per s7(5).

For decision-makers and administrators

• Apply the textual definition. When assessing claims, apply the textual definition in s7(2) rather than relying solely on ICD coding. Section 7(3) makes clear that the textual definition is the operative meaning for the Statement.

• Check for cross-Statement coverage. If an s9 factor refers to another disease or injury covered by a different Statement under s196B(2), apply the factors in that other Statement per s11. Maintain an up-to-date register of Statements and their effective terms to ensure cross-application is current.

• Focus on the service nexus. Ensure that any s9 factor is assessed for its relationship to the claimant’s relevant service as required by s10(1). Where the disease pre-dates service, apply s10(2) to determine whether the factor materially contributed to or aggravated the pre-existing disease.

• Document interpretive approaches. Given the lack of statutory definitions for important terms, develop and document internal guidance and precedents on interpreting "inability to obtain appropriate clinical management", "material contribution" and "aggravation" to promote consistent decision-making. Such guidance should be grounded in accepted medical standards and consistent with statutory obligations.

• Manage transition from prior Statement. Because the instrument repeals the 2015 Statement (s4) and commences on a fixed date (s2), ensure administrative systems and staff are instructed to apply the 2023 Statement from its commencement and to consider any necessary transitional handling consistent with the VEA and MRCA.

Evidence and expert input

• Use medical expert evidence to tie facts to the Statement’s criteria. Experts should be asked to address directly whether the claimant’s condition fits the textual ADPKD definition, whether inability to obtain appropriate clinical management existed and, if so, whether and how that inability related to service and materially contributed to or aggravated the disease or death.

• Corroborate service-related claims with records. Service records establishing the nature and timing of relevant service are crucial to linking the s9 factor to relevant service per s10. Administrative evidence of service conditions that caused or produced inability to obtain management will support the statutory relationship requirement.

Administrative housekeeping

• Update claim lodgement materials and checklists to align with the 2023 Statement. Because the Statement specifies a narrow minimum factor, ensure application forms and instructions prompt claimants to provide evidence relevant to inability to obtain appropriate clinical management and the service nexus.

• Monitor and record outcomes. Decision-makers should record the evidential bases used when accepting or rejecting causation under this Statement to build an administrative record that supports consistent future application and assists in resolving disputes.

In summary, compliance requires demonstrable evidence that the condition falls within the instrument’s textual definition, that the s9 factor of inability to obtain appropriate clinical management existed, and that there is a clear connection between that factor and the person’s relevant service as defined in the Schedule. Given definitional gaps in the Statement, high-quality medical and service evidence will be decisive.