Statement of Principles concerning benign neoplasm of the eye and adnexa (Reasonable Hypothesis) (No. 62 of 2025)

The instrument rests on a few discrete legal and medical concepts that determine how claims will be evaluated.

Statutory scope: The central medical concept is “benign neoplasm of the eye and adnexa” as defined in subsection 7(2). That definition identifies 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 lists eleven explicit exclusions (for example, benign neoplasm of the eyelid, optic nerve, orbital bone, haemangioma, melanocytic naevi, meningioma, neurofibromatosis and retinal vasoproliferative tumours). The Schedule annotates “adnexa” to include accessory structures supporting the eye, specifically the lacrimal gland, lacrimal duct, conjunctival sac and orbit except for the eye and optic nerve (section 7(2), Note; Schedule 1 definition).

Evidence threshold and legal test: The RMA expresses the factors in terms of what “must as a minimum exist” before a reasonable hypothesis has been raised (section 9). The instrument therefore operationalises the legal threshold used in the VEA/MRCA claims process: it does not determine causation; it identifies the circumstances the RMA regards as sufficient to move an administrative decision‑maker to the point where a link to service is reasonably hypothesised.

Enumerated qualifying factors: There are only two enumerated factors (section 9). The first is persistent infection of the conjunctival epithelium with a short, specific list of human papilloma virus (HPV) strains (5b, 6, 6a, 11, 13, 16, 18, 20, 31, 33 or 45) that must have existed before clinical onset of papilloma of the conjunctiva. The second is inability to obtain appropriate clinical management for benign neoplasm of the eye and adnexa before clinical worsening. The composite effect is to focus causal linkage on either (a) a virological aetiology connected to conjunctival papillomata, or (b) an access‑to‑care or management failure where a pre‑existing condition is materially contributed to or aggravated.

Relationship to service and temporal limits: Section 10 requires that any factor relied upon must be related to the person’s relevant service. Subsection 10(2) places a further constraint on the second factor: it applies only to material contribution to, or aggravation of, the condition where the benign neoplasm was suffered or contracted before or during, but did not arise out of, the person’s relevant service. That makes clear the second factor is a mechanism for addressing aggravation or material contribution in the context of a pre‑existing condition rather than causation that first arises from service itself.

Cross‑statement interaction and coding: The instrument recognises cross‑reference effects: where a factor refers to an injury or disease covered by another Statement of Principles, the factors in that other Statement apply as in force (section 11). The instrument also notes that certain ICD‑10‑AM codes (D31.0-D31.5) normally cover benign neoplasm of the eye and adnexa, but it emphasises its own statutory definition prevails for applying the Statement (section 7(3)-(4)).

Definitions and terminological limits: The Schedule provides a concise set of definitions that the instrument uses, including “relevant service”, “terminal event” (with examples), MRCA and VEA (Schedule 1). Several terms used in the factors, such as “persistent infection”, “appropriate clinical management” and “clinical worsening”, are not defined in the instrument; that absence leaves interpretive work to decision‑makers applying the Statement to particular claims.

The instrument affects two overlapping groups: persons who lodge claims under the statutory claims pathways referenced, and the administrative and medical decision‑makers who assess those claims.

Claimants: The instrument applies to "a claim to which section 120A of the VEA or section 338 of the Military Rehabilitation and Compensation Act 2004 (MRCA) applies" (section 5). It therefore affects veterans and other persons whose claims are brought under those statutory sections for benign neoplasm of the eye and adnexa or death from that condition. For a claimant, the instrument determines which medical facts, if established, the RMA will treat as raising a reasonable hypothesis linking the condition or death to relevant service. Because the instrument narrows the list of qualifying anatomic sites and explicitly excludes several diagnoses, it affects cases at the front end by delimiting which ocular conditions are within scope and which are not (section 7(2) and exclusions in subsection 7(2)(2)).

Clinicians and evidence providers: Treating clinicians, pathologists and laboratories whose reports will be tendered in support of claims are affected in the sense that the Statement sets out what medical findings are relevant. For example, identification of persistent conjunctival HPV infection with one of the enumerated strains before clinical onset of conjunctival papilloma is a primary qualifying factor (section 9(1)). Clinicians will need to provide record evidence in forms that can demonstrate temporal sequencing (infection preceding onset) and virological strain typing where available.

Administrative decision‑makers and the RMA: The RMA determined the Statement (section 3). The instrument governs the RMA’s medico‑legal position on whether, for the purposes of the VEA/MRCA claims process, a reasonable hypothesis exists. Administrative decision‑makers who apply the VEA or MRCA will rely on this Statement when deciding entitlement, because the instrument is made under subsection 196B(2) of the VEA and is intended to be used in claim assessments (section 3 and section 8). The instrument also requires decision‑makers to give effect to other Statements when factors refer to conditions covered elsewhere (section 11).

Legal representatives and advisers: Lawyers, advocates and advocates for claimants are affected because the Statement narrows the universe of admissible medico‑legal bases for a reasonable hypothesis. Advisers will need to marshal evidence that corresponds to the precise factors and to explain how the specified factor(s) relate to “relevant service” as defined in Schedule 1.

Data and coding custodians: The instrument references specific ICD‑10‑AM codes (D31.0-D31.5) and the particular edition (Tenth Edition, effective 1 July 2017) in a note, but emphasises that for application of the Statement the statutory definition governs (section 7(3)-(4)). Those responsible for administrative coding should note the instrument’s cross‑reference but also that statutory scope is defined by the instrument itself.

Who is not covered: Persons with any of the explicitly excluded conditions listed in subsection 7(2)(2) are outside the Statement’s scope, even if their medical records carry one of the ICD codes referenced. The instrument’s exclusions make that point explicit. The second factor also applies only where the condition pre‑existed or was contracted before or during service but did not arise out of service; thus it is not an open‑ended access‑to‑care ground for new onset conditions arising from service (section 10(2)).

This Statement imposes no criminal sanction and creates no private right of action; rather, it prescribes the medical factors the RMA regards as sufficient to raise a reasonable hypothesis linking the named condition or death from it with relevant service. The immediate legal duties and rights flow from its role within the VEA/MRCA administrative framework.

Duty to apply the Statement in claims where relevant: The instrument is made under subsection 196B(2) of the VEA (section 3). That statutory context means the Statement is to be used by decision‑makers determining claims under the VEA and MRCA provisions it references (section 5). The effect is that administrative officials determining entitlement must take the Statement into account when assessing whether a reasonable hypothesis exists in a given claim. The instrument itself prescribes the minimal factors that must exist before such a hypothesis can be raised (section 9).

Claimant evidential burden and right to rely on factors: Practically, a claimant’s right is to have their claim assessed against the factors in this Statement. The Statement identifies two routes by which a reasonable hypothesis can be raised: either (1) persistent infection of the conjunctival epithelium with one of the enumerated HPV strains before clinical onset of conjunctival papilloma, or (2) inability to obtain appropriate clinical management before clinical worsening (section 9). A claimant therefore has the right to lead evidence mapped to either route.

Requirement that factors be related to relevant service: Any factor relied upon must be related to the person’s relevant service (section 10(1)). That imposes a duty on claimants to adduce material linking the qualified factor to their relevant service, and it imposes a duty on decision‑makers to assess that link. The Schedule defines “relevant service” and lists the service types that qualify (operational, peacekeeping, hazardous, British nuclear test defence service under the VEA, and warlike/non‑warlike service under the MRCA) (Schedule 1).

Temporal and causal limitation on the management factor: The second factor (inability to obtain appropriate clinical management) is limited by subsection 10(2), which provides it 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 lack of appropriate clinical management materially contributed to or aggravated the condition. That confines the second route to cases of pre‑existing conditions that were aggravated by a lack of treatment tied to service circumstances.

Cross‑Statement reliance duty: Section 11 imposes a procedural duty: where a factor refers to an injury or disease that is covered by another Statement of Principles, the factors in that other Statement apply according to their terms. Decision‑makers must therefore identify cross‑references and apply the appropriate Statements in force.

No statutory penalty provisions in the Statement: The instrument itself contains no penalties or enforcement provisions; it is a medical statement intended to guide claims assessment (sections 1-11 and Schedule 1). Any duties or penalties that attach to claims processes arise from the VEA or MRCA proper rather than from this Statement. The Schedule defines “terminal event” for death claims and gives examples such as pneumonia, respiratory failure, cardiac arrest, circulatory failure and cessation of brain function, which are matters claimants and decision‑makers will need to prove where death is asserted to have been contributed to by the named condition (Schedule 1).

The Statement of Principles is an administrative instrument that identifies medical factors the Repatriation Medical Authority considers sufficient to raise a reasonable hypothesis connecting benign neoplasm of the eye and adnexa (or death from it) to relevant service. It does not create offences, civil liabilities or monetary penalties within its text; the instrument does not specify sanctioning or enforcement mechanisms (sections 1-11 and Schedule 1).

Enforcement context and institutional role: Enforcement and any penalty regimes relevant to claims for entitlements are governed by the statutory schemes under which the Statement is used, namely the VEA and the MRCA. The Statement is an evidentiary tool within those regimes. The RMA’s role, as stated in section 3, is to determine medical‑scientific factors. The actual grant or refusal of entitlements, and any administrative consequences of false statements or fraud, fall to the procedures and sanctioning provisions that are in the VEA, MRCA or other interconnected legislation; those provisions are outside the text of this Statement.

Administrative review and decision quality: The Statement will influence administrative decisions by standardising the medical factors that raise a reasonable hypothesis. This control reduces variability in the medico‑legal foundation decision‑makers employ. However, the Statement does not set out an enforcement process; it is for decision‑makers, reviewers and courts (under the statutory appeal and review mechanisms in the VEA or MRCA, which are not included in this instrument) to assess whether a decision properly applied the Statement in an individual claim.

No criminal or civil penalty wording: Because the instrument contains no penalty clauses, no direct criminal liability, fine, or incarceration provision attaches to breaching the Statement. Similarly, the Statement does not itself confer new civil remedies. Its legal effect is evidentiary and administrative, not penal.

Practical consequences for claimants and providers: The absence of penalties in the Statement does not mean that misrepresentation or fabrication of medical evidence will be without consequence; such conduct would be addressed under the general legal and administrative frameworks that govern claims under the VEA and MRCA. The Statement does not change those frameworks but functions as the RMA’s authoritative statement of the medical‑scientific nexus required to meet the reasonable hypothesis threshold for this condition.

The instrument is enacted under subsection 196B(2) of the Veterans' Entitlements Act 1986 and is expressly framed to operate within the VEA and MRCA claims systems. The text itself contains a number of cross‑references and limits that specify how it interacts with other legal instruments and medical classifications.

Primary statutory interactions: The instrument applies to claims to which section 120A of the VEA or section 338 of the Military Rehabilitation and Compensation Act 2004 applies (section 5). It is therefore a component of the VEA/MRCA claim assessment architecture and must be applied by the administrative decision‑makers operating under those Acts. The RMA’s authority to make the Statement is expressly stated in section 3.

Interaction with other Statements of Principles: Section 11 provides for direct interaction: if a factor in this Statement refers to an injury or disease covered by another Statement determined under subsection 196B(2) of the VEA, then the factors in that other Statement apply in accordance with that Statement’s terms. That mechanism creates an internal framework of cross‑application among Statements, obliging decision‑makers to identify and follow applicable Statements rather than treating each in isolation.

Interaction with medical classification systems: The instrument notes that benign neoplasm of the eye and adnexa generally attracts ICD‑10‑AM codes D31.0 to D31.5, and it explicitly references the Tenth Edition, effective 1 July 2017 (section 7(3)-(4)). However, the instrument clarifies that for application of the Statement the statutory definition in subsection 7(2) is determinative. Thus, administrative coding and hospital data that use ICD codes are relevant for identification and record‑matching, but the Statement’s statutory definition governs entitlement assessment. The reference to a specific edition of ICD‑10‑AM may matter for administrative alignment and for historical data interpretation.

Limits where medical terms overlap with other legal definitions: The Schedule defines certain terms used in the Statement, for example “relevant service” and “terminal event” (Schedule 1). The legal interaction point to note is that while the Schedule supplies these definitions for the Statement’s purposes, other statutes or instruments may have different definitions; decision‑makers will need to reconcile those definitions when applying the VEA or MRCA overall. The Statement’s definitions are expressly for its application.

No express modification of VEA/MRCA procedural rights: The instrument does not purport to change appeal rights, review pathways, or procedural obligations set out in the VEA or MRCA. Those statutory procedural rights and obligations remain in force and govern how decisions made with reference to this Statement are reviewed or appealed. Because the Statement is silent on procedural mechanisms, its role is confined to the medical‑scientific nexus that decision‑makers should apply within existing statutory processes.

Interaction with clinical practice standards or health regulation: The Statement’s second factor hinges on “inability to obtain appropriate clinical management” before “clinical worsening” (section 9(2)). That phrase will inevitably require reference to clinical practice standards, availability of health services, and timing of management. Although the Statement does not incorporate particular clinical guidelines, decisions will have to evaluate clinical management against accepted standards of care and accessible services, and may require evidence about system availability and clinical decision‑making at the relevant time. The Statement itself does not set clinical standards.

The instrument’s own amendment history is concise and set out in the text.

Replacement and repeal: The Statement expressly repeals the prior Statement of Principles concerning benign neoplasm of the eye and adnexa (Reasonable Hypothesis) (No. 41 of 2016), Federal Register of Legislation No. F2016L00565 (section 4). That repeal is unconditional in the instrument; the 2025 Statement therefore replaces the 2016 Statement for claims to which the new Statement applies.

Dates of determination and commencement: The RMA determined this Statement on 20 June 2025, and the instrument commences on 21 July 2025 (sections 1 and 2). The two dates indicate a short lead time between determination and commencement; the instrument does not state whether claims lodged before commencement are to be assessed under the prior or new Statement, beyond the ordinary legal effect of repeal. The text does not provide transitional provisions.

No other amendments recorded in the instrument: The instrument contains no internal amendment schedule or history beyond the single repeal of the 2016 Statement and the new instrument’s commencement. There is no express saving clause preserving decisions made under the prior Statement; therefore the ordinary operation of statutory repeal and administrative practice will govern how active matters are transitioned, subject to any broader administrative guidance from the RMA or the administering agency, which are not included in this instrument.

Edition of medical classification referenced: The instrument refers to a specific edition of the ICD‑10‑AM, the Tenth Edition with effective date 1 July 2017, as the edition from which the referenced codes are drawn (section 7(4)). This is not an amendment history item per se, but it is material that could be affected by later updates to ICD coding; the instrument fixes the edition for its purposes.

No recorded subordinate instruments amending this Statement: The text presents this Statement as a single instrument and does not mention subordinate regulations or delegated legislative instruments that modify its operation.

Practical implication: Repeal of the 2016 Statement means any administrative reliance on the 2016 text should be reconsidered as of the commencement date. Parties preparing claims should use the 2025 instrument as the operative RMA Statement from 21 July 2025.

The Statement text contains no litigation history. It does not reference any judicial decisions, appeals, or legal challenges concerning benign neoplasm of the eye and adnexa or the prior Statement of Principles. The instrument is a pure administrative medical determination and the document contains no caselaw citations.

What the absence means for practitioners: Because the Statement does not identify any litigation history, practitioners cannot rely on any court‑developed jurisprudence recorded in the instrument itself to interpret its provisions. Any judicial interpretation or review of decisions that apply this Statement will arise from future litigation or from judicial decisions outside the document. Consequently, argument on ambiguous points in the Statement will need to be made on statutory and factual grounds rather than from any declared case law within the Statement.

Potential areas for future challenge: The instrument contains several imprecise terms and limits that may be the subject of judicial or administrative review when decisions are challenged. For example, the factual elements “persistent infection”, the temporal requirement that infection must have been “before clinical onset”, the standard for “appropriate clinical management”, and the phrase “clinical worsening” could be contested in appeals or judicial review if a decision‑maker’s application of those terms is alleged to be unreasonable or inconsistent with statutory obligations. The Statement does not provide interpretive glosses on these terms; it leaves their concrete application to decision‑makers and, ultimately, to courts if cases are litigated.

No recorded precedential uses in the instrument: The Statement does not include any examples, illustrative scenarios or guidance points beyond the text itself. Practitioners should therefore expect that precedential application will develop only as the Statement is applied by decision‑makers and potentially reviewed by tribunals or courts.

This instrument contains a number of specific drafting choices and limitations that can catch claimants, clinicians and advisers if not noticed. Below are concrete points to watch for when preparing or defending a claim.

Narrow statutory definition vs ICD codes: Although the instrument notes that benign neoplasm of the eye and adnexa usually attracts ICD‑10‑AM codes D31.0-D31.5 (section 7(3)), it explicitly states that, for the Statement’s purposes, the meaning is that given in subsection 7(2) (section 7(3)). That means administrative records carrying an ICD code are not determinative; practitioners must map the clinical condition to the statutory anatomical and exclusion list in subsection 7(2). If a claimant’s diagnosis is one of the listed exclusions (for example, eyelid, optic nerve, orbital bone, haemangioma, melanocytic naevi, meningioma or neurofibromatosis), the Statement does not apply even where coding might suggest otherwise (subsection 7(2)(2)).

HPV strains are tightly specified: The first qualifying factor requires persistent infection of the conjunctival epithelium with one of the listed HPV strains (5b, 6, 6a, 11, 13, 16, 18, 20, 31, 33 or 45) before clinical onset of papilloma of the conjunctiva (section 9(1)). That is a discrete, finite list. Evidence that a claimant had HPV but with a different strain, or general HPV seropositivity without strain typing and temporal sequencing, may fail to meet the factor as drafted.

Temporal sequencing requirement for HPV: The instrument requires the infection to have been present before clinical onset of conjunctival papilloma (section 9(1)). Medical records must therefore establish that the infection pre‑dated the clinical onset. Post‑onset detection of HPV, without contemporaneous or antecedent evidence, could be challenged as insufficient.

“Persistent infection” is not defined: The instrument does not define “persistent infection”, nor does the Schedule provide a definition. That absence leaves interpretive discretion to decision‑makers and requires claimants to supply clinical evidence that would ordinarily demonstrate persistence, for example serial positive virology or histopathology over an accepted period. Practitioners should anticipate argument over what constitutes persistence in the absence of a statutory definition.

Second factor is constrained and conditional: The “inability to obtain appropriate clinical management” factor (section 9(2)) does not operate as a stand‑alone causation route for new onset conditions. Subsection 10(2) makes it available only for material contribution to, or aggravation of, a benign neoplasm that was suffered or contracted before or during, but did not arise out of, the person’s relevant service. That means the access‑to‑care argument is limited to pre‑existing conditions. Claims asserting that treatment delays in service caused an initial benign neoplasm will not fall within subsection 10(2).

Undefined terms that will drive disputes: Important terms such as “appropriate clinical management” and “clinical worsening” are not defined in the instrument. These phrases will be focal points in evidence and argument. Decision‑makers will need to evaluate whether the care that was unavailable met contemporary standards and whether the condition objectively worsened because of the lack of care. Expect disputes about what constitutes “appropriate” care in different contexts and time periods.

Death claims require linking to a terminal event: For death to be within the Statement’s scope, the benign neoplasm must have contributed to the terminal event or condition (section 7(5)). The Schedule defines “terminal event” with illustrative examples (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function) (Schedule 1). Practitioners should not assume that death from an unrelated terminal event will automatically be treated as connected; they must show contribution.

Cross‑reference traps: If a factor in this Statement refers to an injury or disease covered by another Statement, the other Statement’s factors apply as in force (section 11). Claimants and advisers must check related Statements because factors and thresholds can differ. Failing to identify and apply the other Statement could lead to incorrect assessment.

Repeal timing and transitional effects: The prior 2016 Statement is repealed (section 4). The instrument contains no transitional provisions. For claims spanning the repeal/commencement dates, evidence and argument should address which Statement was operative at relevant times and whether prior decisions need to be revisited in light of the new text.

Coding edition fixed: The instrument fixes an edition of ICD‑10‑AM for its note (Tenth Edition, effective 1 July 2017) (section 7(4)). Administrative systems or datasets using later editions will need to map codes appropriately; reliance on newer ICD versions without cross‑reference may cause misalignment.

For claimants, clinicians, legal advisers and administrative decision‑makers, compliance means building an evidentiary package that aligns with the precise factors and definitions in the instrument and showing the nexus to “relevant service” as defined in the Schedule.

Step 1 , Establish statutory diagnosis: Map the claimant’s clinical diagnosis to the statutory definition in subsection 7(2). Confirm the anatomical site is one of the included sites (conjunctiva, cornea, retina, choroid, ciliary body, lacrimal gland, lacrimal duct, orbit) and that it is not one of the explicit exclusions (subsection 7(2)(2)). Do not rely solely on ICD‑10‑AM coding: the instrument states its own definition governs (section 7(3)).

Step 2 , Choose the applicable factor(s): There are only two qualifying factors (section 9). Determine whether the claim will rely on the HPV factor (section 9(1)), or on inability to obtain appropriate clinical management (section 9(2)), or both. Remember the management factor has the additional constraint in subsection 10(2) that it applies only where the benign neoplasm was suffered or contracted before or during, but did not arise out of, relevant service.

Step 3 , Gather medical and laboratory evidence tailored to the factor:

• For the HPV factor (section 9(1)): obtain virology/histopathology reports that identify HPV infection of the conjunctival epithelium and, crucially, demonstrate the strain and timing. Evidence should show one of the enumerated strains (5b, 6, 6a, 11, 13, 16, 18, 20, 31, 33 or 45) was present and that the infection existed prior to clinical onset of conjunctival papilloma. Serial test results, pathology reports with strain typing, and contemporaneous clinical records are the most direct evidence.
• For the clinical management factor (section 9(2) and section 10(2)): assemble contemporaneous clinical notes, referral letters, specialist appointment records, waitlist evidence, correspondence with health services, or policy documents showing that appropriate management was not available or was denied prior to clinical worsening. Also collect objective documentation of the clinical worsening (e.g. serial visual acuity measures, lesion progression on imaging or clinical photographs, histological progression). Because subsection 10(2) requires that the condition was suffered or contracted before or during, but did not arise out of, relevant service, show medical records establishing the pre‑existence and timing relative to service.

Step 4 , Link factor(s) to relevant service: The instrument requires the factor relied upon to be related to relevant service (section 10(1)). Use service records, deployment history, medical records during service, contemporaneous reports and any evidence showing how service circumstances caused, contributed to or aggravated the factor. For the management factor, demonstrate how service conditions or the service health system caused the inability to obtain appropriate care, and how that inability materially contributed to or aggravated the condition.

Step 5 , Address death claims: If the claim is for death from the condition, obtain cause of death documentation and show how benign neoplasm of the eye and adnexa contributed to the terminal event or condition identified in Schedule 1 as a “terminal event” (Schedule 1). Provide medical evidence linking the neoplasm to the proximate or ultimate cause of death.

Step 6 , Consider cross‑reference Statements: Review section 11. If any factor relied upon refers to another injury or disease covered by a different RMA Statement, obtain evidence that the other Statement requires and apply that Statement’s factors. Failure to identify a cross‑reference may lead to incomplete evidence.

Step 7 , Prepare legal submissions that reconcile undefined terms: Because the Statement does not define “persistent infection”, “appropriate clinical management” or “clinical worsening”, submissions should explain the medical standards relied upon and cite contemporaneous evidence showing the claimant’s situation met those clinical standards. For example, explain what “persistence” means for HPV in the conjunctiva in the claimant’s case and produce serial virology/pathology to match.

Step 8 , Use the fixed ICD edition for administrative cross‑checking: For administrative coding and record extraction, use the ICD‑10‑AM Tenth Edition referenced in the instrument (section 7(4)) to locate relevant hospital and health records. Then ensure those records are reconciled with the statutory definition in subsection 7(2).

Step 9 , Anticipate and document temporal gaps: Because causation analysis often hinges on timing, ensure that dates of infection detection, onset of clinical signs, dates of service and timing of attempted clinical management are precisely documented. Where contemporaneous testing is lacking, obtain retrospective expert opinion explaining the likely chronology and how the available tests and clinical history support the required temporal relationships.

Step 10 , Prepare for decision‑maker interpretation and potential review: Given undefined terms and discretionary assessment, clearly articulate the factual basis for each element in written submissions. If a decision goes against the claimant, document the evidentiary deficiencies and be prepared to pursue internal review or statutory avenues under the VEA/MRCA if applicable; the Statement itself does not set review procedures but will be the basis on which administrative decisions are assessed.

Following these steps aligns evidence and submissions to the instrument’s precise wording and the Schedule’s definitions, thereby reducing the risk that claims will be rejected for failing to meet the narrow factors the RMA has specified.