Statement of Principles concerning haemophilia (Reasonable Hypothesis) (No. 39 of 2023)

This Statement of Principles employs a small number of interlocking legal and medical concepts to tie a clinical condition to relevant service for the purposes of VEA/MRCA claims. The core concepts are: the statutory meaning of "haemophilia", the limited set of qualifying factors that raise a reasonable hypothesis, the required nexus between those factors and "relevant service", and the cross-reference mechanism with other Statements of Principles.

Haemophilia , The instrument defines haemophilia as the genetic clotting disorders due to deficiencies in clotting factors VIII (haemophilia A), IX (haemophilia B) or XI (haemophilia C). It expressly excludes von Willebrand disease and acquired haemophilia (s 7(2)). Although it records the ICD‑10‑AM codes associated with haemophilia (s 7(3)), it clarifies that the statutory definition in subsection 7(2) is the operative meaning. The Schedule reiterates that haemophilia is as described in s 7(2) (Schedule 1, definition "haemophilia").

Death from haemophilia , The Statement covers death "from haemophilia" where death results from a terminal event or condition that the person’s haemophilia contributed to (s 7(5)). The Schedule gives examples of terminal events (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function), but does not exhaustively define terminal event (Schedule 1).

Factors that raise a reasonable hypothesis , The Authority sets the causation threshold by specifying the factor(s) that must exist to move from possibility to a "reasonable hypothesis" connecting the condition to relevant service (s 9). Only one factor is listed: inability to obtain appropriate clinical management for haemophilia (s 9(1)). The structure implies that proof of this single factor, properly related to relevant service, suffices to raise the reasonable hypothesis.

Relationship to relevant service , Section 10 links the factors to service. Subsection 10(1) requires that any factor in s 9 be related to the person’s relevant service. Subsection 10(2) further confines the single factor to situations of material contribution or aggravation where the person’s haemophilia was suffered or contracted before the relevant service or during it but did not arise out of the relevant service. The instrument therefore distinguishes between haemophilia that arose out of service and haemophilia that existed before or during service but was not caused by service; the stated factor applies only to the latter group (see s 10(2)).

Interaction with other Statements of Principles , Section 11 provides for cross-reference application: where a factor in this Statement refers to an injury or disease covered by another Statement, the factors in that other Statement apply according to its terms as in force. That creates a mechanism for layered causation analysis where comorbidities or linked conditions are governed by separate medical statements.

Statutory context and scope , The Statement is made under s 196B(2) of the VEA (s 3) and is intended to be applied in deciding claims for entitlements for conditions connected to service where either s 120A VEA or s 338 MRCA is the relevant claims gateway (s 5). The Schedule defines "relevant service" in the statutory categories used in the VEA and MRCA (Schedule 1).

Precision and limits , The Statement is concise, with a narrow list of factors and a tight service-relationship rule. It accompanies a statutory process that requires decision-makers to determine whether the required factor exists and is linked to relevant service. The clearest exclusions are von Willebrand disease and acquired haemophilia (s 7(2)(b)) and the limitation in s 10(2) that the single listed factor does not apply where haemophilia "arose out of" relevant service.

The instrument affects particular categories of claimants, decision-makers and, indirectly, medical practitioners and record-keepers whose documentation will be relied upon in claims. The instrument identifies who the Statement applies to: a "claim to which section 120A of the VEA or section 338 of the MRCA applies" (s 5). It does not create entitlements itself; rather, it provides the medical causation criteria to be applied in evaluating those statutory claims.

Primary affected persons

• Veterans, former members of the Forces, and members of Peacekeeping Forces who lodge claims under the gateways identified in s 5. The Schedule defines "relevant service" to include operational, peacekeeping, hazardous and British nuclear test defence service under the VEA, and warlike and non‑warlike service under the MRCA (Schedule 1). The Statement therefore affects service personnel and ex‑personnel whose haemophilia or death from haemophilia is alleged to be connected to those forms of service.
• Dependants and representatives who submit death claims where death is alleged to be from haemophilia, because s 7(5) and the Schedule include death from haemophilia where a terminal event was contributed to by the person’s haemophilia.

Administrative decision-makers

• The Repatriation Medical Authority is the instrument-maker and sets the medical criteria (s 3). Tribunals, decision-makers in the Department or other statutory bodies that apply Statements of Principles in deciding entitlements will be required to apply this Statement when assessing whether a reasonable hypothesis exists for claims falling under s 120A VEA or s 338 MRCA (s 5).
• Where a factor in this Statement refers to an injury or disease covered by another Statement, decision-makers must apply that other Statement’s factors according to its terms (s 11).

Medical practitioners and record-keepers

• Clinicians who treat service members or veterans and the custodians of medical and service records are indirectly affected because the single determinative factor is "inability to obtain appropriate clinical management for haemophilia" (s 9(1)). Evidence about access to, provision of, and gaps in clinical management will be central to whether a reasonable hypothesis is raised.
• Service health system administrators and private practitioners who provided or failed to provide treatment during service will find their records become material evidence in claims where inability to obtain appropriate clinical management is alleged.

Who is not covered or is specifically excluded

• Persons with von Willebrand disease or acquired haemophilia are excluded from the statutory meaning of "haemophilia" for the purposes of this Statement (s 7(2)(b)). Claims based on those conditions will not be captured by this Statement, although they could fall under other Statements if covered.
• The instrument, by its own terms, does not apply to claims outside the two specified statutory gateways (s 5). It does not alter eligibility criteria in primary legislation; it only supplies medical factors for the reasonable hypothesis test within the claim processes to which it applies.

Distribution of decision-making power and practical effect

• The Repatriation Medical Authority determines the Statement’s content (s 3); the ultimate factual application,whether a particular claimant’s evidence meets the factor and relationship-to-service conditions,will be made by claim adjudicators and, if disputed, by tribunals or courts applying the Statement as part of statutory claims processes. The instrument concentrates an evidentiary focus on access to appropriate clinical management rather than on a broader set of possible causal factors.

This Statement of Principles imposes no freestanding duties or criminal sanctions. Rather, it establishes the medical causation criteria that decision-makers must apply in claims under the specified statutory gateways (s 5). The obligations and rights it creates are therefore indirect and procedural: it shapes what claimants must establish and what decision-makers must consider when determining whether a reasonable hypothesis connects haemophilia or death from haemophilia to relevant service.

Claims‑related duties and evidentiary posture

• Claimants seeking to raise a reasonable hypothesis have the burden of adducing material that establishes at least one of the factors in s 9. There is only one factor listed: inability to obtain appropriate clinical management for haemophilia (s 9(1)). The claimant must therefore produce evidence relevant to that factor.
• Section 10 requires that any factor relied upon be related to the person’s relevant service (s 10(1)). Claimants must show the relationship between the inability to obtain appropriate clinical management and the relevant service categories defined in the Schedule (Schedule 1). In addition, where the haemophilia was suffered or contracted before or during service (but did not arise out of it), s 10(2) states that the factor applies only to material contribution or aggravation of the haemophilia. This narrows the claimant’s evidentiary task when haemophilia pre‑existed or was present during service.

Decision‑maker duties

• Decision-makers applying the reasonable hypothesis test in the context of s 120A VEA or s 338 MRCA must apply the Statement’s textual content. That includes: recognising the statutory meaning of haemophilia (s 7(2)), limiting application to the listed factor(s) (s 9), ensuring the factor is related to relevant service (s 10), and cross‑checking with other Statements of Principles where the factor refers to another injury or disease (s 11).
• Where a factor in this Statement refers to a condition covered by another Statement, decision-makers must apply the factors of that other Statement "in accordance with the terms of that Statement of Principles as in force from time to time" (s 11). That imposes a duty to identify and apply applicable external Statements.

Rights created or affected

• The Statement affects veterans’ and claimants’ procedural right to have their medical causation assessed using the criteria the Authority has determined. It does not itself confer entitlements under the VEA or MRCA; rather, it defines the conditions under which a reasonable hypothesis can be said to exist for the statutory claim process.
• Applicants have the implicit right to have decision-makers consider evidence that addresses the listed factor and its relationship to relevant service. The Statement channels evidentiary focus to clinical management availability and the service linkage.

Limitations and exclusions affecting duties and rights

• Exclusion of von Willebrand disease and acquired haemophilia (s 7(2)(b)) means claimants with those diagnoses cannot rely on this Statement to establish a reasonable hypothesis; they must rely on other Statements or legal arguments.
• The textual limitation in s 10(2) confines the operation of the single factor to cases where haemophilia was suffered or contracted before or during service but did not arise out of service, and where the inability to obtain appropriate clinical management materially contributed to or aggravated the condition. That restricts claimants’ ability to invoke the factor where the haemophilia arose out of service.

Practical evidential duties

• While the Statement does not prescribe documentary forms, its focus on "inability to obtain appropriate clinical management" places practical duties on claimants and their representatives to gather evidence of clinical management history, service medical records, contemporaneous requests for treatment, and any contemporaneous barriers to access. Decision-makers will be required to consider such material in applying the Statement’s factor and relationship elements.

The Statement of Principles instrument contains no criminal sanctions, civil penalties or administrative fines. It is not an enforcement instrument in the sense of prescribing penalties. Its legal effect is confined to shaping the medical causation inquiry within statutory claims processes under the VEA and MRCA. The instrument therefore creates no direct enforcement machinery of its own; instead, its operation is enforced indirectly through the adjudicative processes that apply Statements of Principles when deciding entitlement claims.

What enforcement looks like in practice

• Adjudication and entitlement decisions. The practical enforcement mechanism is administration of claims under section 120A of the VEA and section 338 of the MRCA (s 5). Decision-makers in those statutory processes will apply this Statement when determining whether a reasonable hypothesis exists that connects haemophilia or death from haemophilia to relevant service. Acceptance or rejection of a claimant’s case under those statutory provisions is the practical outcome of the Statement’s application.
• Repeal and currency. Compliance with the current Statement is enforced by requiring decision-makers to apply the instrument as in force. The instrument repeals the earlier Statement No. 23 of 2015 (s 4), so decision-makers must apply the 2023 Statement to claims within its scope from its commencement date (s 2). Failure to apply the current Statement when it governs a claim would be a process error for the decision-maker, remediable through internal review or appeal processes available under the statute (those processes are not detailed in the instrument).

No direct inspection, reporting or licensing powers

• The instrument does not create powers to inspect medical providers, compel records, or license clinicians. It also does not impose reporting obligations on third parties. The factual record will nevertheless be central to the decision, and decision-makers already possess, under the broader statutory framework, powers to seek medical examinations and records as part of claims processing; those powers are not created or modified by this Statement and are outside this instrument’s text.

Administrative discretion and review pathways

• The Repatriation Medical Authority exercised its statutory rule‑making power under s 196B(2) VEA to set the Statement (s 3). Subsequent enforcement of the Statement occurs through administrative decisions applying it. Where there is dispute about application, the usual avenues for administrative review and judicial review of statutory decision-making apply in practice, although the instrument does not itself refer to those processes.

Consequences of incorrect application

• The instrument itself does not spell out remedies for incorrect application, but the operative consequence is that an incorrect application may lead to erroneous acceptance or rejection of a claim under the VEA or MRCA gateways. Any remedial pathways would be those provided by the underlying legislation and administrative law, which are not amended or specified by this Statement.

This instrument is an administrative medical‑evidentiary rule made under the Veterans' Entitlements Act 1986 (VEA) (s 3) and is intended to operate within the claims processes of that Act and the Military Rehabilitation and Compensation Act 2004 (MRCA) by reference (s 5). Its interaction with other laws is functional and interpretive: it instructs decision-makers about the medical factors that satisfy the "reasonable hypothesis" test under the statutory claims gateways it references. The instrument also expressly contemplates interaction with other Statements of Principles.

Primacy and application within the VEA/MRCA claims processes

• The Statement is made under s 196B(2) of the VEA (s 3). It applies to claims to which s 120A of the VEA or s 338 of the MRCA applies (s 5). It therefore functions as a specialised evidentiary aid within the statutory framework of those Acts. The instrument does not alter primary law in the VEA or MRCA; it specifies the medical factors the Repatriation Medical Authority regards as raising a reasonable hypothesis relevant to the statutory tests adjudicators must apply.

Cross‑Statement interaction

• Section 11 creates a formal rule for cross-Statement application. If a factor in this Statement refers to an injury or disease governed by another Statement of Principles, the factors in that other Statement apply "in accordance with the terms of that Statement of Principles as in force from time to time" (s 11). That requires decision-makers to engage with other Statements as part of a composite causation analysis where comorbidities or overlapping conditions are at issue. The effect is to ensure consistency across Statements and to avoid duplicative or conflicting causation rules where multiple Statements overlap.

Interpretive anchors and coding

• The Statement records ICD‑10‑AM codes conventionally associated with haemophilia but insists that the statutory meaning of haemophilia is that given in s 7(2) (s 7(3)). The reference to the ICD‑10‑AM (s 7(4)) is explicit about which edition and source is being referenced (Tenth Edition, effective date 1 July 2017, copyrighted by the Independent Hospital Pricing Authority, ISBN provided). That ties the Statement to an internationally recognised diagnostic coding system while preserving the primacy of the textual definition. Decision-makers may therefore use coding as an aid but must interpret haemophilia according to the instrument’s definition.

Relationship to other statutes and rights of review

• The Statement makes no express changes to the substantive eligibility rules in the VEA or the MRCA; it is procedural and evidentiary. Any interaction with administrative law remedies (internal review, merits review, judicial review) will arise through the decision‑making processes under the VEA and MRCA and applicable administrative law. The Statement does not specify or alter those review rights.

Limitations where other laws govern clinical regulation

• The Statement does not purport to regulate clinical practice, licensing or standards outside its evidentiary function. Regulatory regimes for medical practitioners, hospital standards, or public health obligations remain governed by other statutes and professional codes. Where inability to obtain appropriate clinical management is alleged, the Statement requires that fact be established for causation purposes; it does not itself set clinical standards or impose obligations on providers.

Repeal of prior instrument

• The Statement repeals the 2015 haemophilia Statement (s 4). That repeal affects the body of Statements decision-makers must consult. Any claims falling within the instrument’s operative date must be assessed against No. 39 of 2023 rather than No. 23 of 2015.

The instrument itself contains limited amendment history information. It records its own name, commencement and repeal of the previous Statement concerning haemophilia No. 23 of 2015 (s 4), and it is dated 24 April 2023 with commencement on 23 May 2023 (s 2). The Authority’s Common Seal was affixed at the direction of the Chairperson as recorded in the instrument.

Concrete chronological items in the instrument

• Date of Authority endorsement: the text bears the date 24 April 2023 as the date the Repatriation Medical Authority determined the Statement (instrument header).
• Commencement: the instrument commences on 23 May 2023 (s 2).
• Repeal: the Statement repeals the prior Statement No. 23 of 2015 (s 4), identified by its Federal Register of Legislation number (F2014L01831).

What this instrument does not record

• The instrument does not list prior amendments to earlier Statements other than the express repeal of No. 23 of 2015. It does not provide a legislative history of why particular textual changes were made relative to the repealed instrument. The document therefore provides only the immediate amendment step (repeal) and the new Statement as the current instrument.
• There is no schedule of transitional arrangements or grandfathering clauses in the text. The instrument does not state whether claims lodged before commencement are to be assessed under the old or new Statement. The absence of transitional provision means decision-makers must apply the text in force on the decision date; practical application and transitional handling will be governed by the administrative practice and statutory framework rather than by this instrument’s text.

Seal and authority

• The instrument records the Common Seal of the Repatriation Medical Authority affixed at the direction of the Chairperson (instrument header). That documents the Authority’s formal adoption of the Statement.

Implication for users tracking changes

• Practitioners and claimants must note that No. 39 of 2023 replaced No. 23 of 2015 as of 23 May 2023. Any analysis of medical causation in claims should therefore reference the 2023 Statement for decisions made on or after that date. The instrument contains no further amending events or subsequent changes; any later amendments would be recorded in subsequent instruments and are not part of this text.

The Statement of Principles document provided contains no litigation history, no citations to tribunal or court decisions, and does not name any cases. It is an administrative instrument issued by the Repatriation Medical Authority under s 196B(2) of the VEA (s 3) and therefore sits as evidence‑guidance in the statutory claims regime. The text does not record any challenges to its content or application, nor does it summarise any decisions interpreting the Statement.

Consequences of absent litigation record in the instrument

• Because the instrument does not mention any judicial or tribunal consideration, there is no internal textual record of how courts or tribunals have construed its provisions. Any case law that addresses the Statement’s interpretation, or the application of its factor(s) to particular factual matrices, is external to this text and would need to be sought in judicial and tribunal databases. This instrument should be treated as the authoritative source of the Authority’s medical view; however, its legal application and interpretive boundaries may be clarified or adjusted by subsequent administrative or judicial decisions, which are not referenced here.

What to expect in practice

• In practice, disputes about the application of the Statement typically arise in merits review forums or judicial review proceedings when claimants or decision-makers disagree about whether the listed factor exists and is related to relevant service. The instrument itself prescribes the test and definitions; litigation would concern whether the evidence meets that test and how key phrases (for example "inability to obtain appropriate clinical management") are to be interpreted in specific fact patterns. The Statement does not itself provide interpretive guidance beyond its textual provisions.

No cases named or relied upon

• The Statement contains no case law citations, no references to administrative decisions, and no explanatory notes that summarise adjudicative treatment. The only external reference is to the ICD‑10‑AM coding standard and its edition (s 7(4)).

The instrument is compact and aimed at a narrow evidentiary point. Several practical pitfalls and interpretive tight spots arise from its wording; practitioners should note these carefully because they affect the scope of claims and the evidentiary strategy.

1. Single-factor causation list

• The Authority lists only one factor as sufficient to raise a reasonable hypothesis: "inability to obtain appropriate clinical management for haemophilia" (s 9(1)). That narrow list channels all claims that rely on the Statement’s medical test into a single factual enquiry. If a claimant cannot demonstrate this element, the Statement affords no alternative medical factor for causation under its own terms.

2. Relationship-to-service constraint

• Every factor must be "related to the relevant service rendered by the person" (s 10(1)). That raises the evidentiary requirement beyond mere existence of inability to obtain care; claimants must show a nexus to one of the statutory service categories defined in the Schedule (operational, peacekeeping, hazardous, British nuclear test defence under the VEA; warlike or non‑warlike under the MRCA).
• Section 10(2) further restricts the operation of s 9(1): it applies only where the haemophilia was suffered or contracted before or during (but did not arise out of) the relevant service, and the inability to obtain appropriate management materially contributed to or aggravated the haemophilia. The wording means that the factor does not apply where the haemophilia "arose out of" service; practitioners must be careful to classify the temporal and causal origin of the haemophilia in each case.

3. Exclusions in the definition of haemophilia

• The statutory meaning excludes von Willebrand disease and acquired haemophilia (s 7(2)(b)). Claims that are coded as haemostatic disorders but that fall within those excluded diagnoses cannot rely on this Statement. Reliance on ICD codes alone can mislead, since s 7(3) affirms that despite ICD‑10‑AM codes being associated, the statutory meaning is the definition in s 7(2).

4. Death claims require contribution to a terminal event

• The Statement covers "death from haemophilia" only where the death was from a terminal event or condition that was contributed to by the person's haemophilia (s 7(5)). Practitioners should note the Schedule’s examples of terminal events and build evidence to show haemophilia’s contribution to the terminal event rather than merely showing the existence of haemophilia.

5. Cross-statement interaction can impose other requirements

• If the factor in s 9 refers to an injury or disease governed by another Statement, s 11 requires application of that other Statement’s factors "in accordance with the terms" of the other Statement. That can import additional or different medical tests into the causation analysis and may create complexity where multiple Statements overlap.

6. No express transitional arrangements or guidance on retrospective claims

• The instrument repeals the prior Statement but does not state how to treat claims lodged before commencement. Decision-makers must therefore determine which Statement applies according to the governing administrative rules and the timing of decisions; practitioners should not assume automatic retrospective application of the new Statement without checking claim timing and decision practice.

7. Vagueness of "appropriate clinical management"

• The text does not define "inability to obtain appropriate clinical management" or "appropriate" itself. That leaves an interpretive task for decision-makers and reviewers. Evidence will need to address not only absence of care but why available care was not "appropriate" by relevant standards; the Statement offers no clinical benchmark within its text.

8. Potential for narrow evidentiary focus to exclude broader causal arguments

• Because the Statement establishes a single factor, claimants who wish to advance other medical causal pathways (for example, immunological complications, infections from treatment, or other service-linked exposures) may not be able to rely on this Statement unless those matters are captured by other Statements or fall within the cross‑reference in s 11.

9. Practical documentary burden

• The Statement’s operation places emphasis on documents and records that establish both the unavailability (or inappropriateness) of clinical management and the service nexus. Lack of contemporaneous service or medical records could materially weaken a claim that otherwise meets the clinical threshold.

10. Coding should not be determinative

• The instrument records ICD‑10‑AM codes (s 7(3)-(4)) but makes clear the statutory meaning is the textual one in s 7(2). Relying solely on diagnostic codes without satisfying the textual definition and the s 9/s 10 requirements risks misdirecting the causation argument.

Compliance with this Statement of Principles for the purpose of raising a reasonable hypothesis in a claim under s 120A VEA or s 338 MRCA requires a deliberate, evidence‑focused approach. The Statement’s text narrows the medical question to whether the claimant can establish the listed factor and its relationship to relevant service (s 9-10). The practical steps below align with the document’s requirements and the concrete interpretive points the instrument raises.

1. Confirm the statutory gateway

• Verify the claim is one "to which section 120A of the VEA or section 338 of the MRCA applies" (s 5). The Statement is only applicable within those gateways. If a claim sits outside them, this Statement is not the evidentiary instrument to rely upon.

2. Establish the correct diagnostic category

• Ensure the claimed condition fits the Statement’s statutory definition of haemophilia (s 7(2)). Demonstrate that the condition is a genetic deficiency in clotting factor VIII, IX or XI (haemophilia A, B or C). Exclude von Willebrand disease and acquired haemophilia from the causal narrative, as they are excluded in s 7(2)(b).

3. Where diagnostic codes are used, anchor them to the textual definition

• If ICD‑10‑AM codes are referenced (s 7(3)-(4)), explain that the code is an aid to diagnosis but the claim rests on the statutory meaning in s 7(2). Cite the relevant edition if using the code (the Statement identifies the Tenth Edition, effective 1 July 2017).

4. Focus on the single listed factor

• The claimant must adduce evidence relevant to the factor in s 9(1): inability to obtain appropriate clinical management for haemophilia. Evidence should show an absence, insufficiency, or inappropriateness of clinical management and link that shortfall to a material contribution to or aggravation of the haemophilia.

5. Link the factor to relevant service

• Demonstrate how the inability to obtain appropriate clinical management was related to the claimant’s relevant service (s 10(1)). Use the Schedule’s service categories to identify the relevant service relied upon (Schedule 1). If the haemophilia was suffered or contracted before or during service but did not arise out of service, evidence must show material contribution or aggravation by the lack of appropriate management (s 10(2)).

6. For death claims, show contribution to a terminal event

• If the claim concerns death, produce evidence that the death resulted from a terminal event or condition to which haemophilia made a contribution (s 7(5); Schedule 1). The Schedule lists exemplar terminal events, but practitioners should ensure medical evidence connects haemophilia causally to the proximate or ultimate cause of death.

7. Anticipate cross‑Statement issues

• If any aspect of the inability to obtain appropriate clinical management refers to another injury or disease covered by a different Statement, identify that Statement and prepare to address its factors as well (s 11). That may require gathering additional medical opinions or records relevant to the other Statement’s criteria.

8. Assemble contemporaneous medical and service records

• The Statement places evidentiary emphasis on access to and appropriateness of clinical management. To satisfy that, compile:
  • service medical records listing diagnoses and treatment provided during service;
  • hospital and outpatient records post‑service showing management attempts and gaps;
  • evidence of requests for care, referrals, denials or logistical barriers to accessing care during the relevant service period;
  • expert medical opinion addressing why available care was not "appropriate" and how the lack of appropriate care materially contributed to or aggravated the haemophilia. The Statement does not mandate particular documents; these categories reflect the type of material that aligns directly with the textual requirements (s 9-10).

9. Use targeted expert evidence

• Given the textual ambiguity in "appropriate clinical management," obtain medical opinion that addresses: standards of appropriate clinical management for the specific haemophilia genotype or severity; whether the claimant received those standards during the relevant period; and the causal linkage between lack of appropriate management and material contribution or aggravation. The instrument itself does not define these standards, so expert evidence will need to articulate them in terms decision-makers can apply to the statutory text (s 9(1); s 10(2)).

10. Prepare for narrow causation arguments

• Because the Statement gives a single factor, be ready to explain why other causal narratives either fall within another Statement (invoking s 11) or do not bear on this claim. If other medical causal routes are to be advanced, identify whether corresponding Statements exist and, if so, address their factors.

11. Account for exclusions and coding issues in submissions

• Explicitly address and disambiguate any diagnostic codes that might suggest von Willebrand disease or acquired haemophilia, explaining why the claimant’s condition falls within the statutory definition of haemophilia (s 7(2)). If death is being claimed, explain how haemophilia contributed to the terminal event rather than simply being a comorbidity.

12. Consider timing and the repeal of the prior Statement

• The present Statement commenced on 23 May 2023 and repealed the earlier 2015 Statement (s 2-4). For claims spanning the changeover, clarify which instrument governs the claim based on the timing of the decision and administrative practice, and address any issues of transitional application with the decision-maker.

13. For administrators: maintain consistent application and cross-reference checks

• Decision-makers should ensure that the s 9(1) factor is applied only where it is related to "relevant service" (s 10), check whether other Statements apply under s 11, and not conflate ICD coding with the statutory definition in s 7(2). The instrument contains no operational guidance for decision-makers beyond its text; consistent internal practice notes should be drafted to apply the Statement fully and uniformly.

14. Address evidentiary gaps proactively

• Where contemporaneous records are missing, secure corroborative material: witness statements, unit logs, appointment schedules, and medical correspondence. Demonstrate why the absence of formal records does not negate the inability to obtain appropriate clinical management when that is the central causal claim.

Following these steps will align a claimant’s or decision‑maker’s approach with the textual requirements of this Statement of Principles. The instrument is concise and legal compliance therefore depends on a tight fit between the available evidence and the precise statutory wording in sections 7-11 and the Schedule.