Statement of Principles concerning haemophilia (Balance of Probabilities) (No. 40 of 2023)

The instrument is structured around a small set of legal and medical concepts that determine coverage, causation and temporal scope. These concepts are defined in the body and in Schedule 1. The principal concepts and how they operate are as follows.

Haemophilia: The instrument defines haemophilia as inherited disorders caused by factor VIII, IX or XI deficiencies, and explicitly excludes von Willebrand disease and acquired haemophilia (s7(2)). Although ICD‑10‑AM codes (D66, D67, D68.1) are cited as commonly associated codes, the statutory meaning is the textual definition in s7(2), with the ICD‑10‑AM reference retained as cross‑reference only (s7(3)-(4)).

Death from haemophilia: The concept extends to deaths where a terminal event or condition was contributed to by the person’s haemophilia. “Terminal event” is given examples in the Schedule (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function), but the definition uses the broader phrase “proximate or ultimate cause of death” (s7(5); Schedule definition of terminal event).

Relevant service: The instrument limits its application to claims connected with “relevant service,” which the Schedule defines as (a) eligible war service (other than operational service) under the VEA, (b) defence service (other than hazardous service and British nuclear test defence service) under the VEA, or (c) peacetime service under the MRCA. These categories determine the class of claimants to whom the Statement can apply (Schedule, relevant service).

Balance of probabilities and medical‑scientific basis: The Authority records that, on the sound medical‑scientific evidence available, it is of the view that it is “more probable than not” that haemophilia and death from haemophilia can be related to relevant service (s8). The instrument therefore articulates a standard of causal probability for decision makers to apply.

Factors and causal mechanics: The Statement contains a single enumerated factor that must exist for causal connection: inability to obtain appropriate clinical management for haemophilia (s9(1)). Section 10 imposes two limits. First, any factor must be related to the person’s relevant service (s10(1)). Second, the inability‑to‑obtain‑management factor operates only where haemophilia was suffered or contracted before or during, but did not arise out of, relevant service; it is framed as material contribution to, or aggravation of, a pre‑existing or contemporaneous condition, not as causes arising out of service (s10(2)).

Interaction with other Statements: If the factor in s9 refers to an injury or disease covered by another Statement of Principles determined under s196B(3) of the VEA, that other Statement applies according to its terms (s11). This cross‑referencing mechanism directs decision makers to consult other, potentially overlapping Statements where appropriate.

Temporal and administrative scope: The instrument applies to claims to which section 120B of the VEA or section 339 of the MRCA applies (s5). It repeals the earlier No. 24 of 2015 Statement (s4) and commences on 23 May 2023 (s2). The Authority’s seal and dating appear on the instrument (instrument heading).

These concepts combine to produce a narrowly specified causal test: a claimant must show, on the balance of probabilities, that their haemophilia (as defined) or death from haemophilia was materially contributed to or aggravated by an inability to obtain appropriate clinical management that is related to their relevant service, subject to the temporal limitation in s10(2). The instrument sets definitional boundaries and cross‑referencing rules but leaves unspecified certain terms and processes that decision makers and claimants will need to operationalise, for example the content of “appropriate clinical management.”

Directly affected parties

• Veterans and members of the Forces who lodge claims under the Veterans' Entitlements Act 1986 or the Military Rehabilitation and Compensation Act 2004 for conditions connected to haemophilia. The instrument applies specifically to claims to which section 120B of the VEA or section 339 of the MRCA applies (s5). The Schedule defines “relevant service,” so only persons whose service falls into those categories are within scope.

• Claimants whose clinical condition matches the statutory definition of haemophilia or whose death involved a terminal event contributed to by haemophilia. The instrument defines haemophilia narrowly as inherited deficiencies of clotting factors VIII, IX or XI and excludes von Willebrand disease and acquired haemophilia (s7(2)). Deaths are covered when haemophilia contributed to a terminal event, the term “terminal event” being defined in the Schedule (s7(5); Schedule definition).

Indirectly affected parties

• Health professionals and medical practitioners who prepare medical records, expert opinions and evidence for claims. The single operative factor,“inability to obtain appropriate clinical management for haemophilia” (s9(1)),will require documentation of clinical management attempts, availability of treatment, referrals, and health system interactions. Those who provide opinions will be expected to address both the medical facts and the connection to service.

• Administration and decision makers under the VEA and MRCA schemes, who will use this Statement as the causal framework when adjudicating claims that involve haemophilia. The instrument is made under subsection 196B(3) of the VEA (s3), and s11 cross‑references other Statements when factors overlap with other diseases.

• Family members or representatives pursuing death benefits. The instrument extends to “death from haemophilia” where haemophilia contributed to a terminal event (s7(5)); family claimants should anticipate that claim adjudicators will require causal linkage between haemophilia and the terminal event.

Who is excluded or limited

• Persons with von Willebrand disease and acquired haemophilia are explicitly excluded from the instrument’s definition of haemophilia (s7(2)(b)). As a result, claims based on those disorders are not covered by this Statement and will need a different Statement of Principles if one exists.

• Service categories outside the Schedule’s definition of “relevant service” are not covered. The Schedule limits “relevant service” to specific categories under the VEA and MRCA; a claimant whose service falls outside those categories will not be affected by this instrument.

• Cases where haemophilia “arose out of” service. Section 10(2) limits the operation of the s9(1) factor to material contribution to or aggravation of haemophilia where haemophilia was suffered or contracted before or during but did not arise out of the person’s relevant service. If the haemophilia genuinely arose out of service, this particular factor is not the mechanism for linkage; instead other causal pathways or Statements may be relevant, including ones referenced under s11.

Practical effect on claimants

The instrument narrows the evidentiary pathway for claimants asserting service connection for haemophilia to proving the existence of the enumerated factor(s) and their relationship to relevant service (s9-10). Because only one direct factor is listed, claimants will need to present evidence specific to “inability to obtain appropriate clinical management,” and to show how that inability was connected to the service category defined in the Schedule. The Title and s8 frame the applicable standard as balance of probabilities, indicating the threshold for success on causation.

This Statement of Principles does not create freestanding statutory duties or entitlements; instead, it prescribes the causal and medical facts that decision makers must consider when adjudicating claims under the VEA and MRCA. Key operative duties and rights, insofar as they arise from the instrument, are as follows.

Duty to apply the Statement when assessing qualifying claims: The instrument is made under subsection 196B(3) of the VEA (s3) and applies to claims to which s120B VEA or s339 MRCA applies (s5). Decision makers tasked with determining service connection must apply the Statement’s factors and definitions when assessing whether haemophilia or death from haemophilia is connected with relevant service. The instrument therefore imposes a duty on administrative decision makers to consider its content in applicable claims, in the same way other Statements of Principles are applied under the statutory framework.

Duty to establish the required causal factor: For haemophilia or death from haemophilia to be treated as connected with relevant service, at least one of the factors in s9 must exist; here, the sole factor is inability to obtain appropriate clinical management for haemophilia (s9(1)). A decision maker must be satisfied, on the balance of probabilities, that this factor existed and that it was related to the person’s relevant service (s10(1)). The statement is therefore prescriptive about what must be shown on causation.

Duty to observe temporal limits: Section 10(2) restricts the operation of s9(1) to cases where haemophilia was suffered or contracted before or during, but did not arise out of, the person’s relevant service. Decision makers must therefore determine the temporal relationship between the onset of haemophilia and the relevant service and apply the factor only where the statutory condition is met.

Right to have deaths assessed where haemophilia contributed: The Statement extends to “death from haemophilia,” defined to include deaths from terminal events or conditions that were contributed to by the person’s haemophilia (s7(5)). This grants potential claimants, or their estates, the right to have deaths considered under this causal framework when haemophilia materially contributed to the terminal event.

Right to cross‑referenced factors: Where a factor refers to another injury or disease that is the subject of a different Statement of Principles, those other Statement(s) apply in accordance with their terms (s11). This gives claimants a procedural right to have overlapping or related conditions considered under the appropriate Statements.

Absence of new duties on service providers or direct entitlements: The instrument does not impose new statutory duties on health providers to supply specific care, nor does it itself create new compensation entitlements. It provides the causal standard for claim assessment. Duties to provide care or entitlements to compensation remain governed by the substantive provisions of the VEA and MRCA and the decision‑making rules that implement them; this instrument only supplies the medical causal criteria that must be met for connection to be recognised.

Evidentiary implications for claimants: The requirement that the factor be established and linked to relevant service shifts costs of proof onto claimants and their advocates. Because the instrument specifies a single factor and requires a service relationship, claimants must provide evidence that both the clinical management gap existed and that it was related to the service categories set out in the Schedule. The instrument does not define “appropriate clinical management,” thereby leaving scope for contest about what evidence satisfies the criterion in particular cases.

The Statement itself does not create offences, penalties or an enforcement regime. It is a deliberative, evidentiary instrument made under subsection 196B(3) of the Veterans' Entitlements Act 1986 and intended to be used in the assessment of claims under other Acts (s3, s5). There are three direct implications for penalties and enforcement drawn from the instrument’s terms.

No penal sanctions in the instrument: The text contains no penalty provisions, criminal offences, administrative fines, or enforcement procedures. The instrument’s operative content is limited to definitions, causal factors, the relationship to service, and application (ss6-11, Schedule).

Use in administrative adjudication: The Statement is a tool to guide administrative decision makers applying the VEA and MRCA. Any sanctions or enforcement action (for example, decisions to grant or deny compensation, or to amend entitlements) would arise from the operative provisions of the VEA or MRCA and the decision‑making rules and review mechanisms that those Acts establish, not from this Statement. The instrument specifies it applies to claims to which s120B of the VEA or s339 of the MRCA applies (s5), but it does not set out the contents of those sections or the remedial measures available under them.

Evidential and procedural consequences: While it creates no penalties, the Statement shapes adjudicative outcomes by determining what medical facts and causal links are sufficient for a finding of service connection on the balance of probabilities. A claimant failing to establish the enumerated factor or its relationship to service, as required by ss9-10, faces the practical consequence of denial of service connection in a claim under the VEA or MRCA. Those practical consequences are administrative, not penal, and flow from the decisionmaker’s application of the VEA/MRCA with this Statement as the causal guidance.

Administrative enforcement risks and discretion: The instrument leaves substantial factual evaluation to decision makers. Because “inability to obtain appropriate clinical management” is the sole factor, adjudicators will make discretionary assessments about the sufficiency and relevance of medical and administrative evidence. The instrument does not prescribe standards of proof for what constitutes “appropriate clinical management” nor does it set procedural protections; implementation and any resulting adverse findings will therefore depend on the procedural safeguards and review avenues in the VEA and MRCA frameworks, which are outside this instrument’s text.

In short, the Statement does not itself penalise; it affects enforcement indirectly by defining the medical criteria that determine whether an administrative finding of service connection can be made under the VEA and MRCA. The instrument thereby influences entitlement outcomes within the established enforcement and review architecture of those Acts, without creating a new enforcement mechanism here.

This Statement is a specialised, instrument‑level component of the broader VEA/MRCA statutory scheme. Its interactions with other laws are set out by cross‑reference, definitions and limits within the instrument.

Primary statutory authority and application: The instrument is made under subsection 196B(3) of the Veterans' Entitlements Act 1986 (s3). It states that it applies to claims to which section 120B of the VEA or section 339 of the MRCA applies (s5). The effect is that the Statement is a statutory input to decision making under those sections; the instrument does not purport to alter other provisions of the VEA or MRCA but to provide the medical causal criteria that must be considered when adjudicating relevant claims.

Cross‑reference to other Statements of Principles: Section 11 provides a specific mechanism for interaction with other Statements determined under subsection 196B(3) of the VEA. If a factor in this Statement refers to an injury or disease covered by another Statement, then the factors in that other Statement apply in accordance with its terms as in force from time to time (s11). This rule creates a hierarchical and modular relationship among Statements: overlapping conditions will be resolved by applying the content of the other Statement(s) referenced.

Use of ICD‑10‑AM: The instrument refers to ICD‑10‑AM codes D66, D67, and D68.1 as codes that attract to haemophilia (s7(3)). It then clarifies that while those codes are informative, the statutory meaning of haemophilia is the definition in s7(2). The instrument cites the ICD‑10‑AM edition and effective date used for reference (s7(4)). This cross‑reference permits administrators to use the international classification system as an indexing and diagnostic aid but makes the statutory text determinative.

Definitions tying to VEA/MRCA categories: The Schedule defines “relevant service” by reference to categories in the VEA and MRCA: 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). The Statement therefore operates only within the service categories those Acts recognise.

Repeal and continuity: The instrument expressly repeals the earlier Statement concerning haemophilia No. 24 of 2015 (s4). This demonstrates that Statements are iteratively updated and that the current instrument displaces prior guidance for claims occurring after its commencement. Section 11’s cross‑reference to other Statements implies that continuity of treatment between Statements is maintained by reference to those instruments in force.

What the instrument does not do in relation to other laws

• It does not amend or override substantive entitlement criteria outside its narrow causal remit. It provides causal standards used in conjunction with the VEA and MRCA; it does not itself create or extinguish benefit entitlements.

• It does not set procedural rules, appeal rights, or evidence admissibility standards. Those are governed by the VEA, MRCA and their implementing instruments.

• It does not define how decision makers should reconcile competing medical opinions or address disputes over what constitutes “appropriate clinical management.” That operational detail is left to the administrative framework and the decision maker’s exercise of discretion under the primary Acts.

Consequently, the Statement functions as an evidentiary and definitional adjunct to the VEA/MRCA statutory architecture. Its practical interaction with other laws will be realised through claim evaluation, the application of other Statements (per s11), and the use of classification systems such as ICD‑10‑AM for diagnostic reference (s7(3)-(4)). Any procedural implications, enforcement or remedies arise under the VEA and MRCA rather than within the text of this instrument.

This instrument includes its own immediate amendment and temporal markers; the text records the following change history and key dates.

Repeal of prior Statement: Section 4 expressly repeals the Statement of Principles concerning haemophilia No. 24 of 2015 (Federal Register of Legislation No. F2014L01833). The repeal is unconditional in the instrument’s text, indicating that the 2015 Statement is superseded by the present instrument as from its commencement date (s4).

Date of determination and commencement: The instrument is dated 24 April 2023 (instrument heading). Section 2 states that the instrument commences on 23 May 2023. The sequence means the instrument was finalised and sealed on 24 April 2023 but took legal effect on 23 May 2023 (instrument header and s2). The Repatriation Medical Authority’s seal and the name of the Chairperson responsible for affixing it appear on the instrument.

Authority under the VEA: The instrument is made under subsection 196B(3) of the VEA (s3), which is the statutory power used to determine Statements of Principles. The instrument itself cites the statutory basis, making clear that any amendments to substance would need to be made under the same or a related statutory power.

No other amendments recorded in the text: The instrument contains no other express amendment history, transitional provisions or saving clauses relating to prior claim determinations. The only express historical act is the repeal of the 2015 Statement and the institution of the current Statement effective 23 May 2023.

Implications for claims in progress or filed before commencement: The instrument does not include transitional provisions specifying how claims lodged before commencement should be treated. The absence of such provisions in the instrument means administrators must look to the VEA, MRCA and administrative practice for guidance on whether the new Statement or the repealed Statement applies to claims lodged before 23 May 2023. The instrument itself does not resolve that question.

Ongoing updates and cross‑references: Section 11 states that if a factor refers to an injury or disease covered by another Statement determined under s196B(3), then the factors in that other Statement apply in accordance with its terms "as in force from time to time" (s11). This language anticipates future amendments to other Statements and embeds an updating mechanism by reference rather than by direct amendment.

Administrative record: The instrument records the Chairperson’s name and the use of the Authority’s common seal and thereby creates an administrative record of the Decision‑making body and date of determination. That record supports future tracking of the instrument’s provenance and amendment history.

In sum, the explicit amendment history within the instrument is limited to repeal of the 2015 Statement and the establishment of the current Statement effective 23 May 2023. Any further amendments or retrospective application issues are outside the instrument’s text and would be governed by the enabling legislation and administrative practice.

The instrument itself records no litigation history. There are no cases, appeals, tribunal decisions, or judicial pronouncements cited in the text. The body of the Statement contains no references to precedent or judicial interpretation, and the Schedule contains no legal authorities beyond internal statutory references (for example, to the VEA and MRCA) and the ICD‑10‑AM classification for diagnostic cross‑reference (s7(3)-(4), Schedule).

What the instrument states and does not state about litigation

• The instrument explicitly states the Repatriation Medical Authority’s view on the medical‑scientific evidence, using the phrase “more probable than not” to articulate the balance‑of‑probabilities threshold for causal linkage (s8). It does not purport to cite or summarise any court or tribunal decisions that have considered a haemophilia claim.

• There is no record in the instrument of legal challenges to the prior 2015 Statement or of litigation that led to the new Statement. The repeal of the 2015 Statement (s4) is stated as an administrative act without referencing any litigation.

Practical implications for litigators and reviewers

• Absence of cited jurisprudence means that, where disputed, the evidentiary issues and statutory interpretation will be adjudicated in the usual fora,administrative review bodies, courts or tribunals,using the Statement as the authoritative medical standard for causation. The Statement itself will be a primary source for legal argument about what facts satisfy the causal factor, but any litigation history will have to be developed from decisions made after or applying the Statement.

• Because the instrument uses terms that are not mechanically defined within the instrument (for example, "appropriate clinical management"), litigators should expect factual disputes about the meaning and scope of such terms. The Statement provides the legal framework that will constrain the contest, but the resolution of ambiguous or contested terms will be a matter for adjudicators and, if litigated, the courts.

• The cross‑reference mechanism in s11 means that litigation involving overlapping conditions may require attention to other Statements of Principles "as in force from time to time." Any legal challenges that concern how multiple Statements interact will engage that provision.

In short, the instrument contains no internal litigation history. It creates a framework that is likely to generate disputes about factual sufficiency and interpretation in individual cases, but any litigation history will emerge from the administrative and judicial decisions that apply this Statement in practice rather than from the instrument itself.

Several features of the Statement create practical traps and points where claimants, advisers and administrators should take care. The instrument is compact, but a small number of textual choices have outsized administrative and evidentiary consequences.

Single, narrowly framed factor: The Statement lists only one factor that must exist for a finding of service connection: inability to obtain appropriate clinical management for haemophilia (s9(1)). Because the instrument contains no other direct causal pathways, claims that cannot demonstrate that specific factor are unlikely to succeed under this Statement. Advisers should not assume a broader set of causal factors exists; the statutory test is narrow.

Exclusion of certain diagnoses: The instrument explicitly excludes von Willebrand disease and acquired haemophilia from the meaning of haemophilia (s7(2)(b)). Claims based on those conditions cannot rely on this Statement. A common misstep would be treating ICD‑10‑AM codes or colloquial diagnoses as sufficient when the statutory text excludes them.

ICD‑10‑AM codes are not determinative: The instrument notes that haemophilia attracts ICD‑10‑AM codes D66, D67 or D68.1 but then states that the statutory meaning is the textual definition in s7(2) (s7(3)). Relying solely on diagnostic coding without addressing the statutory definitional elements, or on a clinician’s coding letter alone, risks an unsuccessful claim.

Temporal limitation on the factor: Section 10(2) restricts the operation of s9(1) to situations where haemophilia was suffered or contracted before or during, but did not arise out of, the person’s relevant service. The “did not arise out of” language is crucial. If a claimant’s haemophilia arose out of service, this particular factor is not the mechanism for linkage and the claimant must either rely on a different causal basis or a different applicable Statement. Advisers should be explicit when pleading the temporal relationship between onset and service.

Undefined core terms: The instrument does not define “inability to obtain appropriate clinical management” and does not define “appropriate clinical management.” Those undefined terms will be the locus of contention. Decisions will turn on what evidence demonstrates inability and what standard of care counts as appropriate in the particular historical and service context. Expect disputes over whether lack of access was systemic, specific, due to remoteness, due to administrative denial, or otherwise. The instrument leaves the substantive content of the standard to adjudicators and medical evidence.

Service category specificity: “Relevant service” is defined in the Schedule with exclusions: for example, eligible war service and defence service are qualified by exclusions such as operational service and hazardous service (Schedule). Claims based on service not falling into the precise Schedule categories are out of scope. Advisers should map the claimant’s service record to the Schedule definitions before assuming the Statement will apply.

Death linkage mechanics: Deaths are included only where haemophilia contributed to a terminal event as defined in the Schedule (s7(5); Schedule definitions). A terminal event, as defined, includes common proximate causes of death such as pneumonia and cardiac arrest. However, linkages must be shown between the haemophilia and the terminal event. Be cautious about asserting automatic coverage of a death because a terminal event appears on a death certificate; the Statement requires causation.

Interaction with other Statements: Section 11 requires that, where a factor refers to another disease covered by another Statement, the factors in that other Statement apply “in accordance with the terms of that Statement as in force from time to time.” This creates potential complexity where multiple Statements intersect. Failure to check related Statements may result in omission of relevant factors or misapplication of causal tests.

No transitional wording: The instrument repeals the 2015 Statement but contains no transitional clauses. It is silent about claims lodged before commencement. Practitioners should not assume automatic retrospective application of the new or old Statement without checking administrative guidance or the governing statutes.

Administrative evidence burden: The instrument shifts the evidentiary burden onto the claimant to demonstrate inability to obtain appropriate clinical management and to show that this was related to relevant service (ss9-10). Because the instrument provides little procedural guidance on how to prove these facts, claimants should be prepared to marshal contemporaneous medical records, service records, and evidence of administrative decisions or systemic limitations.

In short, the principal gotchas are the narrow scope of causal factors, the explicit exclusions from the definition of haemophilia, undefined but central concepts, the temporal limits on operation, and the need to cross‑check other Statements and the Schedule’s definitions of relevant service. These features increase the importance of detailed factual pleadings and documentary evidence tailored to the instrument’s precise wording.

For claimants, medical advisers and administrators, the practical steps to align evidence and processes with the Statement are practical and targeted. The instrument sets a narrow evidentiary pathway; compliance means addressing each statutory element and its temporal and definitional constraints.

1. Confirm condition falls within the statutory definition

• Demonstrate that the person’s condition is haemophilia as defined in s7(2): deficiency of clotting factor VIII, IX or XI. Do not treat ICD‑10‑AM codes alone as determinative; the statutory definition controls (s7(3)-(4)). Exclude von Willebrand disease and acquired haemophilia from pleadings under this Statement because they are expressly excluded (s7(2)(b)).

2. Establish relevant service

• Map the claimant’s service record to the Schedule’s definition of “relevant service” before lodging a VEA or MRCA claim that relies on this Statement. The Schedule 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. If service falls outside these categories, this Statement does not apply.

3. Prove the enumerated factor

• The only statutory factor is “inability to obtain appropriate clinical management for haemophilia” (s9(1)). Gather and present contemporaneous records demonstrating attempts to obtain care, denials, delays, remoteness, lack of available treatment, administrative refusals, referral failures or other objective barriers to receiving what a treating clinician would identify as appropriate management. Expert evidence should address both the fact of inability to obtain care and what constituted appropriate management for the claimant at the relevant time.

4. Tie the factor to relevant service

• Section 10(1) requires the factor to be related to the person’s relevant service. Provide evidence linking the inability to obtain care to the service context. For example, if the claimant was stationed in a location with documented lack of access to clotting factor concentrates, that mapping should be explicit. The instrument places the relationship to service as a legal requirement; evidence must support causation on the balance of probabilities.

5. Observe temporal constraints

• Section 10(2) permits the s9(1) factor to apply only where haemophilia was suffered or contracted before or during, but did not arise out of, relevant service. Be explicit in establishing timing of onset relative to service. If onset was after service or arose out of service, this mechanism will not be appropriate.

6. Address death cases with specific linkage

• For death claims, demonstrate that haemophilia contributed to the terminal event or condition as defined in the Schedule (s7(5) and Schedule definition of terminal event). Correlate clinical deterioration, bleeding profiles and cause of death documentation to show contribution.

7. Anticipate disagreements about “appropriate clinical management”

• The instrument does not define this phrase. Obtain authoritative clinical opinions that articulate what appropriate management entailed for the individual at the relevant time, including available standards of care, likely interventions, and the anticipated outcomes if management had been available. Tie expert conclusions to factual evidence of inability to obtain that management.

8. Check for intersecting Statements

• If the factor you rely on refers to an injury or disease covered by another Statement, apply those other Statement(s) in accordance with s11. Identify any related Statements and ensure evidence also addresses their factors and definitional requirements.

9. Prepare for the balance‑of‑probabilities test

• The Authority frames the causal link as “more probable than not” (s8). Evidence should be cumulative and directed to demonstrating that, on balance, the inability to obtain appropriate clinical management related to service more likely than not materially contributed to or aggravated the haemophilia or death.

10. Document service‑side evidence

• Administrative records, orders, location postings, unit medical facility capabilities, service medical records and contemporaneous correspondence will all assist in tying inability to obtain care to the service environment. Clinical records should be obtained wherever possible and, for historical cases, affidavits from contemporaneous treating staff or colleagues can be useful.

11. For administrators: apply the Statement strictly and record reasoning

• Decision makers should document how the evidence satisfies each statutory element: (a) condition satisfies s7(2), (b) the enumerated factor exists (s9(1)), (c) the factor is related to relevant service (s10(1)), and (d) temporal limits of s10(2) are met. Where the factor refers to other Statements, decision makers should identify and apply those instruments per s11 and cite them in reasoning.

12. Consider appeal and review strategies early

• Because the Statement does not define certain key terms, anticipate grounds of contest and address potential evidentiary gaps proactively. Where interpretations of “appropriate clinical management” or “related to relevant service” are plausible in multiple ways, obtain focused expert evidence and precise factual mapping.

13. Check transitional applicability

• The instrument repeals the 2015 Statement but contains no transitional provisions (s4). If a claim straddles the commencement date, identify whether administrative practice or the governing Acts provide guidance on which Statement applies.

Compliance therefore requires a tight alignment between medical proof, service records and causal narration. Given the Statement’s narrow factor list and undefined key terms, well‑structured medical opinions that link factual inability to obtain care with the service context will be decisive. Administrative decision makers should ensure reasons address each statutory element in sequence to support coherent review and appeal paths.