Statement of Principles concerning benign neoplasm of the eye and adnexa (Balance of Probabilities) (No. 63 of 2025)

Principal legal form and source: The Statement is an instrument under subsection 196B(3) of the VEA (Authority). Its legal effect is to articulate the medical factors the Repatriation Medical Authority regards as satisfying the causal connection between a condition and relevant service on the balance of probabilities, subject to the application rules in the VEA and MRCA (s 8).

Balance of probabilities standard: The instrument explicitly frames its factual standard as “more probable than not” and ties that position to the Authority’s view of “sound medical‑scientific evidence” (s 8). That is a statement about the Authority’s evidentiary threshold used to recommend or determine causal links; it does not itself recite the full decision‑making process under s 120B of the VEA or s 339 of the MRCA (s 5).

Operative definition of the condition: The instrument defines benign neoplasm of the eye and adnexa as a non‑malignant neoplastic proliferation of cells of the eye classified by site,conjunctiva, cornea, retina, choroid, ciliary body, lacrimal gland, lacrimal duct and orbit,and then provides an eighteen‑point exclusions list (s 7(2)(a)-(b)). The instrument also clarifies that while certain ICD‑10‑AM codes (D31.0-D31.5) map to the condition, the textual definition in s 7(2) is the operative meaning for application of the Statement (s 7(3)). The Schedule provides a dictionary cross‑reference to this definition (Schedule 1).

Causal factors: Section 9 sets the determinative factors. At least one of two discrete factors must be present before a causal connection on the balance of probabilities is found: (1) persistent infection of the conjunctival epithelium with specified human papilloma virus (HPV) strains before clinical onset of conjunctival papilloma (s 9(1)); or (2) inability to obtain appropriate clinical management for the benign neoplasm before clinical worsening (s 9(2)). The HPV factor lists particular strains by reference (5b, 6, 6a, 11, 13, 16, 18, 20, 31, 33, 45).

Relationship to relevant service and temporal rules: Section 10 requires that any factor established must be related to the person’s relevant service as defined in the Schedule. Importantly, the inability to obtain appropriate clinical management factor (s 9(2)) is expressly limited to cases of material contribution to or aggravation of the condition where the condition was suffered or contracted before or during, but did not arise out of, the person’s relevant service (s 10(2)). The Schedule defines “relevant service” in three categories (eligible war service other than operational service; defence service other than hazardous service and British nuclear test defence service; peacetime service under MRCA).

Interaction with other Statements of Principles: Section 11 provides that if a factor in section 9 refers to an injury or disease that is itself the subject of another Statement of Principles made under s 196B(3) of the VEA, then the factors in that other Statement apply according to its terms as in force from time to time (s 11).

Death from the condition: The Statement treats death caused or contributed to by benign neoplasm of the eye and adnexa as included. The Schedule defines “terminal event” and gives non‑exhaustive examples such as pneumonia, respiratory failure, cardiac arrest, circulatory failure and cessation of brain function (Schedule 1 definition of terminal event). That connects fatal end events with the underlying condition for claim purposes where contribution is established (s 7(4)).

Administrative basics: The instrument gives administrative particulars,instrument title, date (20 June 2025), repeal of the prior instrument, commencement date (21 July 2025) and the copyright and edition of the ICD‑10‑AM referenced (Tenth Edition, effective 1 July 2017) (cover page; ss 1-4; s 7(3)(b)). These items influence which historical records and diagnostic codes may be cited but do not expand the textual definition of the condition.

Primary persons: The Statement directly affects veterans and members of the Forces who lodge claims governed by section 120B of the VEA or section 339 of the MRCA (s 5). Those individuals are the claimants whose diagnoses of benign neoplasm of the eye and adnexa, or deaths contributed to by such conditions, will be assessed against the factors in this Statement.

Decision makers: The Repatriation Medical Authority made the Statement and so provides the medical/scientific framework decision makers use. While the instrument itself does not restate the decision‑making provisions of the VEA or MRCA, the Statement is intended to be applied by officers deciding entitlement under those Acts (s 1; s 5). Relevant decision makers include those exercising powers under s 120B VEA and s 339 MRCA, although the instrument does not enumerate them.

Medical evidence providers: Ophthalmologists, pathologists, infectious disease specialists, general practitioners and other clinicians who diagnose eye conditions and provide certificates, reports or test results will be affected because their clinical records, HPV testing results and treatment histories are the factual materials that bear on the two listed factors (s 9). Medical practitioners must be aware that the Statement requires specific factual findings,persistent conjunctival epithelial infection with listed HPV strains before clinical onset, or an inability to obtain appropriate clinical management before clinical worsening,which implicates clinical testing, serial observation and contemporaneous treatment records.

Agencies administering benefits: Agencies or tribunals that administer VEA and MRCA claims must apply the Statement when the condition and claim fall within the Acts’ scope (s 5). The instrument’s repeal of the 2016 Statement (s 4) means agencies must substitute the new Statement’s definitions and factors in assessments from the commencement date.

Other Statement framers and cross‑referenced instruments: If a factor in s 9 refers to another disease or injury that itself has a Statement of Principles, the persons preparing evidence or deciding claims must consult that other Statement as it applies (s 11). This creates an interdependence for claimants and decision makers where co‑morbid or antecedent conditions are specified.

Third parties and insurers: Although the instrument is framed in the veterans’ entitlements context, its definitions and ICD‑10‑AM cross‑references may be relied upon in other administrative or medico‑legal settings where the same clinical categories are relevant. The instrument’s narrow exclusions list (s 7(2)(b)) changes which ocular neoplasms are covered for the purposes of claims under the specified statutes and therefore affects any third party assessing liability, benefits or clinical coverage that defers to the statutory Statements.

Those not covered: The instrument explicitly excludes a list of site‑specific and disease entity conditions, for example benign neoplasm of the eyelid, optic nerve, orbital bone, haemangioma, lipoma of the eye, lymphangioma, melanocytic naevi, meningioma, neurofibromatosis, ocular surface squamous dysplasia and retinal vasoproliferative tumours (s 7(2)(b)). Practitioners handling claims for those conditions must not treat this Statement as applicable.

Geographic and temporal scope: The Statement applies to claims subject to the VEA and MRCA categories defined as relevant service in the Schedule. The Schedule’s definition of relevant service lists eligible war service (other than operational service), defence service (other than hazardous service and British nuclear test defence service) under the VEA, and peacetime service under the MRCA. That framing means only persons whose service fits those definitions are within the SoP’s ambit (Schedule 1).

What the instrument requires claimants to prove: The Statement does not itself create a novel statutory benefit; rather it specifies the medical factors that, if proved on the balance of probabilities and tied to relevant service, permit a decision maker under the VEA or MRCA to conclude the condition is related to service (ss 5, 8-10). Concretely, a claimant must establish at least one of the factors in s 9 and that the factor is related to the claimant’s relevant service as defined in the Schedule (ss 9, 10(1)).

Temporal duty for factor (s 9(2)): For claims relying on the inability to obtain appropriate clinical management factor (s 9(2)), the instrument imposes a temporal condition,this factor applies only where the benign neoplasm was suffered or contracted before or during, but did not arise out of, the person’s relevant service, and where the failure to obtain treatment materially contributed to or aggravated the condition (s 10(2)). Practitioners must therefore establish that the condition pre‑existed service or was present during service but not caused by service, and that lack of treatment materially altered the disease course.

Duty to relate factor to service: The Statement requires that an established factor be related to relevant service. That is, evidence must link either the HPV infection or the inability to obtain appropriate clinical management to the claimant’s relevant service (s 10(1)). The instrument leaves the precise legal test for that nexus to the VEA and MRCA processes but makes relation to service a gatekeeping condition.

Duty to consult cross‑referenced Statements: If a factor in s 9 refers to a disease or injury covered by another Statement of Principles, the claimant and decision maker must consult that other Statement and apply its factors according to its terms as in force (s 11). That creates an operational duty to cross‑reference and integrate multiple Statements where relevant.

Rights of claimants under the Acts: The instrument states it “applies to a claim to which section 120B of the VEA or section 339 of the MRCA applies” (s 5). That framing operates as a procedural right for claimants to have this Statement considered when those statutory provisions govern their claims. The Statement does not itself adjudicate benefits, but claimants have the right to rely on it in support of service connection under the Acts.

Authority’s duty: Implicit in the instrument is the Repatriation Medical Authority’s role in articulating medical‑scientific views to be applied under the Acts (s 8). The Authority states that its view is based on “sound medical‑scientific evidence” and that the condition can be related to relevant service on the balance of probabilities (s 8). The instrument operationalises that duty by setting out the factors and definitions.

Administrative duties not stated: The Statement does not specify procedural duties such as timelines, evidence formats, testing standards, or medical examination protocols. Those procedural obligations remain governed by the VEA, MRCA and the administrative practice of the agencies and decision makers applying those Acts; the Statement supplies the substantive medical criteria to be considered (s 5).

No penal regime or new prohibitions: The instrument does not create criminal offences, civil penalties, or regulatory prohibitions. It sets medical criteria used in determining service connection under existing Acts (see generally the instrument).

No penal provisions in the instrument: The Statement of Principles contains no express enforcement mechanisms, penalty provisions, or disciplinary sanctions. It is a medical‑scientific statement intended for use in adjudication of claims under the VEA and MRCA; it does not itself create offences or civil penalties (covering provisions; ss 1-11; Schedule 1).

Enforcement by application in claims processes: Enforcement in practical terms comes through application by decision makers under the VEA and MRCA. The Statement will be applied when determining whether, on the balance of probabilities, the condition or death is connected with relevant service, in accordance with those Acts (s 5). Any consequences,such as changes to entitlement to pensions, rehabilitation, compensation or medical benefits,follow from the decision made under the governing Act, not from the Statement itself.

No administrative sanctions for non‑compliance with the Statement: Because the instrument is a descriptive and determinative list of factors rather than a regulatory code imposing duties with sanctions, there are no administrative fines, prohibitions or criminal sanctions that attach to failing to meet the factors. The “penalty” is factual: failure to establish a listed factor or relation to relevant service will, in ordinary application, result in the claimant not establishing service connection under the relevant statutory scheme.

Evidence standards and decision risk: The Statement sets out the Authority’s position that, on the medical‑scientific evidence available, it is more probable than not that the condition can be related to relevant service (s 8). That statement is a guidance tool; it does not, in itself, formalise evidentiary rules or appellate remedies. Enforcement thus depends on how decision makers weigh and require evidence in particular claims under s 120B VEA or s 339 MRCA.

Relevance to procedural review and appeal: The instrument does not specify administrative review or judicial appeal routes. Any challenge to a decision that applies this Statement would proceed under the review and appeals mechanisms provided in the VEA or MRCA or general administrative law, as applicable. The instrument’s role in such litigation would be as substantive medical guidance; the instrument does not itself provide remedies or enforcement processes.

Record‑keeping and evidentiary implications: Because the Statement’s factors require medical proof (for example, persistent infection with specified HPV strains before clinical onset, or proof of inability to obtain appropriate clinical management), parties should anticipate that the available medical records, test results and contemporaneous treatment notes will be decisive. The Statement does not impose record‑keeping sanctions but its practical effect enforces evidentiary standards through the claims process.

Statutory nexus: This Statement is made under the VEA (subsection 196B(3)) and expressly applies to claims falling under s 120B of the VEA and s 339 of the MRCA (ss 3, 5). It does not operate in isolation; its legal force comes from being the medical‑scientific Statement that decision makers must consider when applying the substantive and procedural provisions of those Acts.

Replacement of prior Statement: The instrument repeals the earlier Statement of Principles concerning the same condition (No. 42 of 2016) (s 4). Therefore, for claims decided on or after the commencement date, decision makers must apply the 2025 Statement rather than the 2016 instrument (s 2). The repeal is an express legislative substitution, with the consequence that any prior determinations relying on the 2016 Statement may be treated differently under the 2025 instrument where factors, definitions or exclusions differ.

Interaction with other Statements of Principles: Section 11 creates a positive cross‑instrument interaction. If a factor in s 9 refers to an injury or disease for which there is another Statement of Principles determined under s 196B(3) of the VEA, “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” (s 11). That requires claimants and decision makers to harmonise multiple Statements where conditions overlap or where a factor points to another covered disease.

ICD‑10‑AM coding and clinical classification: The instrument notes specific ICD‑10‑AM codes (D31.0-D31.5) that correspond to benign neoplasm of the eye and adnexa, and specifies the edition and effective date of the Australian Modification that it references (Tenth Edition, effective date 1 July 2017) (s 7(3)). It also stresses that the textual definition in subsection 7(2) controls application. The interaction here is practical,coding may aid identification and record retrieval,but legal interpretation depends on the instrument’s text rather than ICD codes (s 7(3)).

Relationship with MRCA and VEA definitions: The Schedule imports definitions for MRCA, relevant service and VEA. The instrument’s reach is therefore shaped by those statutory definitions; for example, “relevant service” is defined to include eligible war service (other than operational service), defence service (other than hazardous service and British nuclear test defence service) under the VEA, and peacetime service under the MRCA (Schedule 1). That definition will interact with the distinct eligibility and causation rules in each parent Act when a tribunal or decision maker applies the Statement.

No conflict clause or supremacy provision: The instrument contains no express clause resolving conflicts with other statutory rules. Its legal operation is contingent upon existing VEA and MRCA processes and administrative practice. If another statutory instrument or judicial precedent were to prescribe a different test for service connection, resolution would be determined under the hierarchy of laws and the decision-making framework in the VEA and MRCA, not by this Statement itself.

Evidence and procedural law interplay: The Statement prescribes substantive medical factors but leaves procedural evidentiary questions,how evidence is adduced, what tests satisfy persistence of infection, what constitutes inability to obtain appropriate clinical management,to the governing Acts and administrative practices. The instrument therefore interacts with procedural law by shaping the substantive thresholds that evidence must meet within existing evidentiary and administrative frameworks.

Instrument identity and dates: The Statement is titled “Statement of Principles concerning benign neoplasm of the eye and adnexa (Balance of Probabilities) (No. 63 of 2025)” and is dated 20 June 2025. It commences on 21 July 2025 (cover page; ss 1-2).

Repeal of prior instrument: Section 4 expressly repeals the Statement of Principles concerning benign neoplasm of the eye and adnexa (Balance of Probabilities) (No. 42 of 2016) (Federal Register of Legislation No. F2016L00569). The 2016 instrument is therefore superseded by No. 63 of 2025 from the commencement date (s 4). No other prior amendments or versions are referenced in the text.

Authority and statutory basis unchanged: The instrument is made under subsection 196B(3) of the VEA, the same statutory provision under which such Statements are typically made. The instrument reproduces the usual administrative scaffold for Statements of Principles: title, authority, commencement, repeal, application and definitions (s 3).

ICD edition specified: The instrument references the ICD‑10‑AM, Tenth Edition, effective date 1 July 2017, as the edition for code references (s 7(3)(b)). That edition specification is an element of the instrument’s drafting history, clarifying which coding set is intended to correspond with the textual definition.

No internal amendments listed: The Statement contains no schedules of amendment, transitional provisions, or dates for staged implementation beyond its single commencement date. It does not provide for retrospective application or specify savings for decisions made under the 2016 instrument prior to repeal. Practitioners should therefore note the plain repeal and replacement model,new claims and decisions from the commencement date are to be governed by the new Statement.

Signature and authorship: The instrument is signed by Professor Terence Campbell AM, Chairperson, on behalf of the Repatriation Medical Authority, indicating the administrative provenance of the change (cover page). That signature is the formal attestation required for such statutory instruments.

No stated future review or expiry: The instrument contains no provision requiring periodic review, sunset, or scheduled amendment. Any future amendment or repeal would be effected by the Authority under the relevant provisions of the VEA.

No litigation recorded in instrument: The Statement itself contains no record of judicial or tribunal decisions, appeals, or litigation history concerning its contents. The instrument’s text does not reference any cases, precedents or adjudicative rulings (entire instrument). It is a fresh Statement replacing the 2016 instrument.

Implications for disputes: Because the instrument provides substantive medical factors used in statutory determinations, it is likely to be relied upon in administrative decisions under the VEA and MRCA and could be material to any review or appeal of those decisions. The Statement does not contain case law or litigation commentary itself; any litigation that cites or challenges the Statement must be found in the VEA/MRCA adjudicative record outside this instrument.

No internal examples of contested application: The Statement does not include hypothetical applications, illustrative examples, or summaries of contested cases. Absent judicial interpretation within the instrument, the text alone governs how decision makers should apply the listed factors.

Relevance of prior Statement litigation unknown: The instrument repeals the 2016 Statement, but it does not provide information about whether that prior instrument was the subject of litigation or appeal. The new Statement’s repeal of the older instrument does not alter any extant judicial determinations, but the instrument does not supply transitional litigation guidance.

Where to look for litigation history: Any review of litigation involving application of these factors must be conducted outside this instrument, by searching decisions under the VEA and MRCA where benign neoplasm of the eye and adnexa was at issue. The instrument itself offers no litigation docket or references.

Narrow textual definition controls over ICD coding: The Statement includes ICD‑10‑AM codes that map to the condition (D31.0-D31.5) but explicitly states that the operative meaning for application of the Statement is the textual definition in subsection 7(2) (s 7(3)(a)). Practitioners relying on ICD codes alone risk misclassification; the textual site‑by‑site definition and exclusions list govern entitlement analyses.

Extensive exclusions list: The instrument excludes multiple site‑specific conditions and disease entities (s 7(2)(b)). Common ocular lesions such as benign neoplasm of the eyelid, optic nerve, orbital bone, haemangioma, lipoma, lymphangioma, melanocytic naevi, meningioma, neurofibromatosis, ocular surface squamous dysplasia and retinal vasoproliferative tumours are outside the Statement’s scope. Failure to notice these exclusions can lead to misdirected claims or lost appeal opportunities.

Limited causal factors,two narrow pathways: Only two factors are nominated in s 9. The first is persistent conjunctival epithelial infection with specific HPV strains prior to clinical onset of conjunctival papilloma (s 9(1)). The second is inability to obtain appropriate clinical management before clinical worsening (s 9(2)). No broader occupational or environmental exposures are listed. Claims relying on other plausible causal pathways will not be assisted by this Statement.

HPV strain specificity: The HPV factor lists discrete strains (5b, 6, 6a, 11, 13, 16, 18, 20, 31, 33, 45) (s 9(1)). Proof of infection with an unlisted strain does not meet the specific factor in the Statement. Testing protocols, laboratory reports and specimen retention matters become critical because the factor requires not only proof of HPV infection but infection by one of the listed strains and timing evidence that the infection preceded clinical onset.

Temporal restriction on inability to obtain management: The inability to obtain appropriate clinical management factor (s 9(2)) applies only where the benign neoplasm was suffered or contracted before or during, but did not arise out of, relevant service, and where the failure to obtain treatment materially contributed to or aggravated the condition (s 10(2)). This is a multi‑element test: (a) establishing the condition pre‑existed or existed during service; (b) showing it was not caused by service; and (c) demonstrating material contribution or aggravation due to lack of appropriate management. Evidence gaps on any element can defeat a claim relying on this factor.

Burden of relating the factor to relevant service: Section 10(1) requires the factor to be related to the person’s relevant service. The instrument does not prescribe how relation is proved; practitioners must therefore marshal clinical timelines, service records, access to health care evidence during or following service, and any contemporaneous complaints or referrals to demonstrate nexus.

Death definition and terminal event examples: The instrument includes death from the condition where the condition contributed to a “terminal event,” and the Schedule lists five examples (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function) (s 7(4); Schedule 1). Practitioners should bear in mind that the Schedule’s list is illustrative: the instrument’s phrasing indicates inclusion of such terminal events, but the text of the Schedule frames them as examples rather than an exhaustive catalogue.

Cross‑reference requirement: If a factor refers to an injury or disease covered by another Statement, the other Statement’s factors apply “as in force from time to time” (s 11). Practically, that means practitioners must check the current text of other Statements. Failing to update cross‑referenced materials can produce errors if intervening amendments have altered those other Statements.

No procedural detail: The Statement supplies substantive criteria but no procedural guidance such as what constitutes “appropriate clinical management,” the requisite duration or method for proving “persistent infection,” or acceptable test methodologies. These gaps increase the evidentiary burden on claimants and create discretionary space for decision makers.

Commencement and repeal timing: The instrument commences on 21 July 2025 and repeals the 2016 Statement (ss 2, 4). Practitioners dealing with claims spanning the repeal date must be careful about which Statement applied at the time of the decision and whether any transitional issues might arise. The instrument contains no transitional provisions, so administrative practice will determine handling of cases in progress.

No enforcement or penalty guidance: Because the Statement contains no sanctions or enforcement mechanisms, practitioners should not look for procedural penalties in this instrument. The practical consequences of non‑compliance are evidentiary and administrative, not punitive under the instrument itself.

Establish the listed factor and relation to service: To use this Statement in a claim, a claimant must establish, on the balance of probabilities, at least one of the two factors listed in s 9 and show that the established factor is related to the claimant’s relevant service as defined in the Schedule (ss 9, 10(1)). In practice that means assembling medical records and service records that prove timing, diagnosis, laboratory findings and, where relevant, treatment access during or after service.

For HPV factor claims (s 9(1)): Obtain and document testing that demonstrates persistent infection of the conjunctival epithelium with one of the listed HPV strains (5b, 6, 6a, 11, 13, 16, 18, 20, 31, 33, 45) prior to clinical onset of conjunctival papilloma. Clinical notes should record onset dates, serial examinations showing persistence rather than a single transient finding, and laboratory reports specifying HPV strain typing. Because the instrument is precise about strain and timing, contemporaneous laboratory documentation and clinician commentary on persistence and chronology are important.

For inability to obtain appropriate clinical management claims (s 9(2); s 10(2)): Demonstrate that the benign neoplasm was suffered or contracted before or during relevant service and that it did not arise out of the person’s relevant service; then show that inability to obtain appropriate clinical management occurred before clinical worsening and that this inability materially contributed to or aggravated the condition. Evidence can include service medical records showing referral and treatment attempts, records of civilian medical consultations, correspondence documenting lack of access, wait times, or denial of care, as well as clinical progression notes correlating the timing of management failure with worsening pathology. The Statement does not define “appropriate clinical management”; therefore practitioners should explain the standard of care applicable at the time and provide contemporaneous evidence showing the absence of that care and a plausible causal chain to aggravation.

Address exclusions explicitly: If a claimant’s diagnosis falls within an excluded category listed in s 7(2)(b), do not rely on this Statement. Instead, identify the correct site or disease entity and, if necessary, locate the relevant Statement of Principles or alternative legal avenue. In other words, check the instrument’s exclusions first; the textual definition controls over ICD code matches (s 7(3)(a)).

Use ICD cross‑references cautiously: The instrument lists ICD‑10‑AM codes D31.0-D31.5 as corresponding codes (s 7(3)(a)-(b)). Use those codes for record retrieval and indexing but rely on the textual definition to determine applicability. Confirm that code assignments in historical records correspond to the textual sites and are not miscoded labels that fall into exclusion categories.

Cross‑reference other Statements where indicated: If a factor refers to an injury or disease covered by another Statement, obtain and apply that other Statement’s factors “as in force from time to time” (s 11). Practically, this means checking the current authoritative version of any cross‑referenced Statement and integrating its criteria and timing requirements into the claim evidence dossier.

Prepare for adjudicator discretion: The Statement provides substantive factors but leaves procedural determinations and evidentiary weighting to the decision maker under the VEA or MRCA. Present evidence in a way that anticipates adjudicator discretion: provide clear timelines, certified copies of laboratory reports, contemporaneous medical notes, and service records that show access or denial of treatment during relevant service.

Document terminal events for death claims: For claims where death is alleged to have been contributed to by the benign neoplasm, obtain the death certificate, clinical notes documenting the terminal event and causal chain, and any post‑mortem or hospital documentation. Use the Schedule’s definition of terminal event and the illustrative examples (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function) to frame how the neoplasm contributed to the fatal outcome (s 7(4); Schedule 1).

Time the claim to commencement date: For claims straddling the repeal and commencement dates, verify which Statement applied when the decision is made. The instrument commences on 21 July 2025 and repeals the earlier Statement (ss 2, 4); ensure that submissions after the commencement date apply the 2025 Statement.

Record retention and testing: Because the Statement requires proof of persistent infection and delineated strain typing, retain and, where possible, obtain confirmatory laboratory evidence. If historical specimens are unavailable, explain the absence and provide contemporaneous clinical evidence that supports the presence of persistent infection and timing relative to clinical onset.

Integrate medico‑legal and clinical narratives: Given the Statement’s narrow factors, craft medico‑legal reports that tie clinical findings to the statutory factor precisely. For the inability to obtain appropriate management factor, include expert opinion linking absent or delayed care to material contribution or aggravation, with references to accepted clinical standards contemporaneous with the treatment dates.

Be ready to consult other Statements: If a factor references another disease or injury subject to a different Statement, obtain that Statement and apply its factors. Make sure submissions address any cumulative or sequential causal arguments by mapping each factor to the correct Statement and showing how the combined facts meet the relevant tests.

Finally, remember the Statement’s evidentiary role: It is a tool used by decision makers under the VEA and MRCA. Prepare evidence to satisfy the listed factors and the relation to relevant service. The Statement provides the substantive thresholds; compliance is achieved by meeting those thresholds with clear, contemporaneous, and strain‑ or treatment‑specific evidence as required by ss 9-10 and the Schedule.