Statement of Principles concerning hypertension (Balance of Probabilities) (No. 22 of 2022)

The core legal‑technical concepts in this instrument are: the SoP as an evidentiary schema for causation on the balance of probabilities; the clinical definition of hypertension to be used for claims under the SoP; the enumerated factors that, when present and related to relevant service, permit a finding of connection to service; temporal rules distinguishing onset and clinical worsening; and the incorporation of detailed biomedical thresholds and drug lists in the Schedule.

Definition of hypertension: The SoP defines hypertension for its purposes as persistent elevated blood pressure diagnosed by a medical practitioner and evidenced by clinic, ambulatory or home readings at specified thresholds, or by the regular administration of antihypertensive therapy (s 7(2)). It excludes temporary elevations from specified causes such as acute renal failure, eclampsia, pre‑eclampsia, gestational hypertension, neurogenic hypertension, and medication‑induced transient increases (s 7(2)(b)). The SoP explicitly notes that although hypertension attracts ICD‑10‑AM codes I10 or I15, for the purposes of this instrument the meaning is the one given in the subsection (s 7(3)-(4)).

Factors and timing: Section 9 lists 37 discrete factors. Factors 1-18 relate to establishing that hypertension (or death from hypertension) is connected with relevant service. These include long‑term overweight/obesity (5 years before clinical onset) (s 9(1)); heavy alcohol consumption (an average of at least 400 g alcohol per week continuously for at least 6 months) (s 9(2)); high salt intake (an average of at least 12 g salt per day for at least 1 year) (s 9(3)); renal artery stenosis; solid organ/stem cell/bone marrow transplant pre‑onset; diabetes mellitus for at least 5 years pre‑onset; chronic kidney disease at the time of clinical onset; specified endocrine disorders; sleep apnoea; structural kidney vascular lesions; clinically significant mental health disorders as listed; relevant drugs from Specified Lists 1 or 2; glucocorticoid therapy meeting defined thresholds; medroxyprogesterone or megestrol acetate use in specified contexts; long‑term physical inactivity measured by METs; arsenic exposure as specified (s 9(1)-(18)).

Factors 19-37 mirror many of the earlier factors but are framed to support material contribution to, or aggravation of, pre‑existing hypertension. The SoP makes clear that these factors only apply where a person’s hypertension was suffered or contracted before or during relevant service, but did not arise out of service (s 10(2)).

Evidentiary thresholds and equivalences: The Schedule supplies many operational measures. Examples: ambulatory blood pressure equivalents (average 24‑hour ≥130/80 mmHg, daytime ≥135/85 mmHg, nighttime ≥120/70 mmHg) (Schedule 1); BMI and waist circumference cut‑offs for overweight/obesity; chronic kidney disease criteria (GFR <60 mL/min/1.73 m2 for ≥3 months, albuminuria ≥3 mg/mmol for ≥3 months, biopsy/imaging/urinary sediment evidence or prior transplant) (Schedule 1); detailed tables for equivalent glucocorticoid dosing and inhaled glucocorticoid thresholds; extensive Specified Lists 1-3 naming drug classes and agents (Schedule 1).

Service relationship and cross‑references: The SoP requires that any factor asserted under s 9 be “related to the relevant service rendered by the person” (s 10(1)). It also instructs that where a factor refers to an injury or disease covered by another Statement of Principles, the factors in that other SoP apply as in force (s 11), thereby creating a mechanism for cross‑application across overlapping SoPs.

Death from hypertension: The SoP treats “death from hypertension” as death from a terminal event or condition that was contributed to by the person’s hypertension, and provides an explicit list of terminal events (pneumonia, respiratory failure, cardiac arrest, circulatory failure or cessation of brain function) as examples (s 7(5); Schedule 1).

Primary subjects: The instrument applies to veterans and members of the Forces whose claims under the VEA or MRCA involve hypertension or death from hypertension (s 5). The Schedule defines “relevant service” to include eligible war service (other than operational service) under the VEA, defence service (other than hazardous service and British nuclear test defence service) under the VEA, and peacetime service under the MRCA (Schedule 1). This means the SoP is directly invoked in administrative compensation, pension or rehabilitation claims where a claimant seeks a finding that hypertension is connected with their relevant service.

Decision‑makers and medical assessors: The SoP is made by the Repatriation Medical Authority (RMA) (s 3) and supplies the medical‑scientific framework that administrative decision‑makers apply in adjudicating claims where s 120B VEA or s 339 MRCA govern the causation test (s 5). The instrument does not itself name the adjudicative or claims processing bodies, but its function is to guide those determining service connection under the listed statutory provisions; in practice decision‑makers exercising functions under the VEA or MRCA will rely on the SoP when applying the statutory tests referenced.

Medical practitioners and veterans’ treating clinicians: The SoP’s thresholds and lists create concrete evidentiary tasks for treating clinicians who must supply the medical evidence on which decision‑makers rely. Evidence types that will be material under the SoP include recorded clinic, ambulatory and home blood pressure readings per the thresholds in s 7(2) and Schedule 1; medication charts and dispensing records for drugs listed in Specified Lists 1-3; cumulative glucocorticoid dosing records; laboratory results (GFR, albumin:creatinine ratio) to meet chronic kidney disease criteria; diagnostic imaging and biopsy reports for kidney pathology; sleep study reports for sleep apnoea; and documented histories of alcohol and salt intake.

Claimants with overlapping conditions: If an asserted factor in s 9 refers to an injury or disease that has its own Statement of Principles, the corresponding SoP applies in accordance with its own terms (s 11). This affects claimants whose hypertension may be linked to another defined disease (for example, chronic kidney disease, endocrine disorders) because decision‑makers must apply the relevant SoP(s) in combination.

Third parties and evidence providers: Employers, military medical record repositories, pathology laboratories, pathology laboratories, and water testing bodies may be asked to produce records relevant to the specific exposure definitions in the Schedule (for example, documented arsenic concentrations in drinking water for defined periods).

Population effects and prevalence considerations: The SoP treats many common risk factors (overweight/obesity, alcohol, salt intake, diabetes, sleep apnoea) as possible connecting factors. That makes a broad set of claimants potentially affected, but each factor requires specific durational or dosing thresholds and demonstrable relation to relevant service (ss 9, Schedule 1, s 10(1)). The instrument’s detailed thresholds will make many claims hinge on documentary historical evidence rather than generalised clinical opinion.

Nature of duties and rights under the instrument: The SoP itself does not create direct statutory rights to compensation or prescribe the full administrative entitlement framework; rather, it creates a determinative medical schema that decision‑makers must apply when deciding whether hypertension or death from hypertension is connected with relevant service for the purposes of claims that fall under s 120B VEA or s 339 MRCA (s 5). It imposes no standalone statutory duties on claimants, clinicians, employers or regulators, but it does require that decision‑makers consider whether at least one of the enumerated factors in s 9 existed and was related to relevant service in order to reach the balance of probabilities causal finding (s 9; s 10(1)).

Obligation to relate factors to service: Section 10(1) requires the existence of any factor in s 9 to be related to the relevant service rendered by the person. That creates an evidential burden: evidence must be tendered to show a causal nexus between the identified factor (for example, an exposure or medical treatment during or as a result of service) and the person’s service. The SoP does not prescribe the form of that evidence; it prescribes the substantive conditions that must be met for a finding on causation.

Differentiated roles for onset vs aggravation: The SoP supplies different tests depending on whether the claim is for onset (s 9(1)-(18)) or material contribution/ aggravation of pre‑existing disease (s 9(19)-(37) and s 10(2)). For example, being overweight or obese for at least 5 years pre‑onset is a factor for onset (s 9(1)); the same being overweight or obese for at least 5 years pre‑worsening is a factor for aggravation (s 9(19)). Decision‑makers must therefore identify whether a claim asserts onset or aggravation to choose the applicable factors.

Medical evidence thresholds and clinician certification: The SoP prescribes objective thresholds for hypertension diagnosis (s 7(2)) and for many factors (e.g. specific alcohol/salt thresholds, cumulative glucocorticoid doses, and BMI/waist circumference cut‑offs in the Schedule). That creates a duty on claimants to obtain clinical records and on clinicians to report measured values and dosing histories with dates. Statements that merely assert general risk or clinical opinion without reference to the SoP thresholds will be of limited utility.

Right to cross‑application of other SoPs: Section 11 creates a right, in effect, for a factor that refers to another disease to be governed by the applicable SoP for that disease. When a factor in s 9 references an injury or disease covered by another SoP, the other SoP’s factors apply “in accordance with the terms of that Statement of Principles as in force from time to time” (s 11). That requires decision‑makers and claimants to locate and apply multiple SoPs where overlaps occur.

No penal sanctions or procedural prescriptions within the instrument: The SoP contains no criminal offences or administrative penalties. It does not set out appeal routes, time limits for claims, or procedures for evidentiary disputes. Those procedural rights and duties will be derived from the underlying statutes (VEA and MRCA) and related administrative law and tribunal processes rather than from this instrument. The SoP therefore functions as a substantive evidentiary test rather than a procedural code.

The instrument contains no penal provisions, fines, or criminal offences and does not itself create enforcement mechanisms. It is an administrative medical determination document made under s 196B(3) of the Veterans' Entitlements Act 1986 (s 3), intended to be applied by decision‑makers in determining whether hypertension or death from hypertension is connected with relevant service for claim purposes (s 5). The text does not prescribe enforcement actions, compliance penalties, or sanctioning powers against claimants, clinicians, service providers or others.

How findings made under this SoP are used in enforcement and decisions: The SoP is intended to be used as the medical‑scientific basis for deciding claims under s 120B VEA or s 339 MRCA (s 5). Enforcement in the sense of administrative outcomes therefore occurs when decision‑makers apply the SoP to accept or reject a claim for service connection; the instrument itself does not set the remedies (for example, pension, rehabilitation or compensation rates). Any adverse decision taken using the SoP will be subject to the rights of review and appeal set out in the underlying statutes and administrative law, but those procedural routes are not described in this instrument.

Potential administrative enforcement implications not stated in the instrument: Because the SoP provides bright‑line numerical thresholds and named drug lists, administrative decision‑makers will enforce those thresholds when accepting or rejecting causal links. For example, failure to document the specified cumulative glucocorticoid dose, or to prove the defined duration of alcohol or salt consumption, will likely result in a negative causal finding if no alternative qualifying factor in s 9 is established. The instrument itself does not set standards of proof beyond “balance of probabilities”; that standard is asserted in s 8 as the RMA’s view based on the available evidence. Any disputes about the correct application of the SoP would proceed through the administrative decision review mechanisms of the VEA or MRCA and judicial review channels (not set out in the SoP).

No direct investigatory or compliance powers: The SoP does not confer investigatory powers on the RMA or other entities to compel production of medical records or service documents. It relies on existing administrative processes and records production rules under the underlying statutes and general administrative law. Any coercive powers to obtain records would therefore derive from other statutes or tribunal processes, not from this instrument.

Primary statutory interfaces: The SoP is made under s 196B(3) of the Veterans' Entitlements Act 1986 (s 3) and is expressly linked to claims under s 120B of the VEA and s 339 of the MRCA (s 5). It therefore operates as a medical determinative instrument within the statutory framework of the VEA and MRCA. The SoP by itself does not alter the substantive provisions of those Acts; it supplies the medical causation framework that decision‑makers apply when those statutory causation provisions are invoked.

Cross‑application with other Statements of Principles: Section 11 provides that if a s 9 factor refers to an injury or disease for which a separate SoP exists, then the factors in that other SoP apply in accordance with its terms “as in force from time to time” (s 11). This creates a mechanism for integration across the RMA’s body of SoPs where conditions overlap. Practically, decision‑makers will need to consult multiple SoPs to resolve claims where a single factor references a separately defined disease (for example, chronic kidney disease or a listed endocrine disorder).

Reference to ICD‑10‑AM and other external technical sources: Section 7(3)-(4) acknowledges ICD‑10‑AM codes (I10 and I15) but makes clear that the definition of hypertension for the SoP is the definition in s 7(2). The SoP also explicitly references the International Statistical Classification of Diseases and Related Health Problems, Tenth Revision, Australian Modification (ICD‑10‑AM), Tenth Edition, effective 1 July 2017 (s 7(4)). That means decision‑makers may use ICD coding as supporting material but must apply the SoP’s definition for entitlement determinations.

Interaction with clinical and pharmaceutical regulation: The Schedule lists Specified Lists 1-3 of drugs (Schedule 1). Those lists refer to drug classes and named agents whose use is a factor in causation (ss 9(13), 9(14), 9(31), 9(32), and Schedule 1). These references create a point of contact with pharmaceutical practice and therapeutic guidelines: evidence of prescription, administration, indication, duration and cessation dates will be material. The SoP also provides equivalency tables for glucocorticoid dosing and inhaled glucocorticoids (Schedule 1), which require clinicians to map prescribed medicines to the specified thresholds.

Administrative law and procedural rights: The SoP does not specify appeal, review, or procedural mechanisms. Those are governed by the VEA/MRCA and administrative law. The instrument therefore interacts with the broader legal framework for review and merits appeals under the relevant statutes, but does not alter those rights within its own text.

Interaction with occupational, public health and environmental law: Certain causative factors involve environmental exposures or occupational histories, most notably “being exposed to arsenic as specified” (Schedule 1). Establishing such exposure will require evidence that may be held by environmental regulators, water suppliers or employers. The SoP does not modify the responsibilities of those bodies, but it creates an evidentiary standard for claims that may draw on records from other regulatory regimes.

No conflict‑resolution mechanism within the instrument: The instrument does not provide mechanisms for resolving conflicts between medical opinion and the SoP’s thresholds (for example, where a claimant’s treating clinician records a diagnosis but fails to document the SoP thresholds). Decision‑makers are expected to apply the SoP; how they handle incomplete evidence or contested clinical judgment will be governed by the general decision‑making and review provisions of the VEA/MRCA and administrative law principles, not by the SoP.

This Statement of Principles is No. 22 of 2022 and commences on 4 April 2022 (s 2). It expressly repeals the prior Statement of Principles concerning hypertension No. 64 of 2013, Federal Register of Legislation No. F2013L01651, that was also made under subsection 196B(3) of the VEA (s 4). The instrument is dated 4 March 2022 and bears the Common Seal of the Repatriation Medical Authority (front matter).

The instrument itself contains no further amendment schedule, transitional provisions, or savings clauses beyond the repeal of the 2013 SoP. It does not record any prior amending instruments, nor does it set a sunset clause or periodic review obligation within its text. The Schedule and list‑based definitions are contained within the instrument and are effective as of commencement.

Because the SoP is made under subsection 196B(3) of the VEA, further amendments would be effected by subsequent RMA determinations under that same statutory head of power. The instrument’s s 11 language that cross‑applies other SoPs “as in force from time to time” anticipates future amendments to other SoPs might change how some factors interact; however, the instrument itself does not record a mechanism or timetable for amendment beyond the RMA’s ongoing power to make and revoke SoPs under the VEA.

In practical terms, claimants and decision‑makers must treat this 2022 SoP as the operative RMA determination replacing the 2013 instrument. Any prior claims decided under the 2013 SoP will have been governed by its terms until repeal; after 4 April 2022, the 2022 SoP’s thresholds and lists apply. The instrument does not specify transitional application to claims in progress; therefore, application to particular claims will be determined by the relevant statutory provisions and administrative practices (the SoP simply states its commencement date and its repeal of the earlier instrument).

No amendment or variant history beyond the repeal is recorded in the instrument as provided. To identify later amendments to this SoP or related SoPs, practitioners must consult the Federal Register of Legislation and the RMA’s public records for any subsequent determinations or revocations.

The instrument text contains no references to judicial decisions, tribunal determinations or litigation involving this Statement of Principles. It does not cite any case law, nor does it record any appeals, reviews or judicial scrutiny of the 2022 instrument itself. The RMA’s Statement records only its medical‑scientific view that, on the balance of probabilities, hypertension and death from hypertension can be related to relevant service (s 8).

Because the SoP functions as an evidentiary and medical standard used by decision‑makers under the VEA and MRCA, disputes about its application in particular claims would be litigable issues in the administrative and tribunal systems established by those statutes. The SoP does not set out appeal rights; those remain in the VEA/MRCA and associated merits and judicial review processes. The instrument therefore provides no record of litigation history in its text.

For practitioners preparing for potential litigation or review, the absence of litigation history in the instrument means that arguments over the correct interpretation and application of specific threshold provisions (for example, how to measure and prove a minimum 400 g/week alcohol consumption for six months, or whether glucocorticoid use meets the cumulative dose thresholds) will likely be developed in claim‑specific decision records and subsequent review or court proceedings rather than in the instrument itself. Any judicial interpretations of similar or prior SoPs (for example, the repealed 2013 hypertension SoP) are not referenced and should not be assumed to exist unless located in external legal research sources.

Because the SoP cross‑references other SoPs and uses medical and technical measures (ICD‑10‑AM reference, dosing tables, specified drug lists), litigation or review may focus on: admissible evidence to meet the numerical thresholds; the correct application of “related to the relevant service” (s 10(1)); whether the condition “did not arise out of” service when applying the aggravation/material contribution factors (s 10(2)); and the scope and applicability of s 11 cross‑references. None of these litigation vectors are addressed in the instrument; they remain possible avenues for administrative or judicial contest in individual cases.

The SoP’s detailed thresholds and lists create multiple potential pitfalls for claimants, clinicians and decision‑makers. The instrument is technical; small errors in evidence, timing, units or documentation can determine whether a factor meets the SoP’s tests.

1. Diagnosis must meet the instrument’s definition, not merely an ICD code. The SoP requires diagnosis by a medical practitioner with specified clinic, ambulatory or home readings at defined thresholds, or the regular administration of antihypertensive therapy (s 7(2)). The instrument notes that while hypertension uses ICD‑10‑AM codes I10 or I15, the SoP’s meaning is the subsection definition (s 7(3)-(4)). A claim supported only by an ICD code without objective readings or documented antihypertensive therapy may be deficient.

2. Measurement modality matters. Clinic, home and ambulatory thresholds differ (s 7(2) and Schedule 1). Ambulatory blood pressure equivalents use average 24‑hour, daytime or nighttime measures (Schedule 1). Practitioners must ensure the reading type is stated and compared to the correct numerical threshold.

3. Exclusions for temporary elevations. The SoP excludes temporary elevations from particular medical causes and medications (s 7(2)(b)). Claims that rely on transient blood pressure spikes (for example, peri‑operative rises or pregnancy‑related hypertension) will not satisfy the hypertension definition.

4. Timing and continuous period requirements are strict. Many factors require defined durations before clinical onset or worsening: being overweight/obese for at least 5 years; alcohol consumption of ≥400 g per week continuously for at least 6 months; salt intake of ≥12 g per day for at least 1 year; glucocorticoid thresholds, etc. Evidence must support both the duration and the timing relative to clinical onset/worsening (s 9 and Schedule 1).

5. Units and conversions are non‑intuitive. Alcohol is expressed in grams, using the Australian standard 10 g per standard drink (notes in ss 9(2), 9(20)). Salt is expressed both in grams and millimoles (12 g = 200 mmol). Arsenic exposure is defined in micrograms per litre for cumulative periods. Inaccurate conversions or failure to apply the specified standards will undermine a claim.

6. Drug list mapping and indication. The Specified Lists 1-3 include classes and named agents (Schedule 1). Practitioners must map prescribed medicines to the lists and prove duration, indication and whether cessation or substitution was possible (see s 9(13) for Specified List 1 where the drug “cannot be ceased or substituted”). Evidence such as dispensing records, hospital charts and clinical notes recording therapeutic necessity will be necessary.

7. Cessation windows for some therapies are tight. For example, glucocorticoid therapy that has ceased or decreased must show the clinical onset or worsening occurred within 30 days of cessation or reduction for the factor to apply (s 9(15), s 9(33)). Medroxyprogesterone or megestrol acetate similarly have a 30‑day window after cessation (s 9(16), s 9(34)). Missing the date window by days can be dispositive.

8. Distinction between onset and aggravation rules matters. The factors in ss 9(19)-(37) apply only where the hypertension pre‑exists and was suffered or contracted before or during relevant service but did not arise out of service (s 10(2)). Claimants and advisers must be precise about whether they assert that service caused hypertension to arise, or that service materially contributed to or aggravated pre‑existing hypertension.

9. “Related to the relevant service” is required for each factor. Section 10(1) requires that the existence of any factor be related to the relevant service. This means it is not sufficient to establish a factor occurred; the claimant must link that factor to their service. The SoP does not specify the nature of evidence required to prove the relation, so decision‑makers may rely on contemporaneous service records, medical records from service, deployment logs, or other documentation.

10. “Inability to obtain appropriate clinical management” is an open‑ended factor. Section 9(37) lists inability to obtain appropriate clinical management for hypertension as a factor for clinical worsening. This phrase is potentially broad; claimants should provide detailed evidence of attempts to obtain care, barriers encountered, and contemporaneous clinical outcomes. The SoP does not define “appropriate” in that context beyond the plain meaning.

11. Cross‑SoP dependencies. Where a factor refers to an injury or disease covered by another SoP (s 11), the other SoP’s factors apply “as in force from time to time.” This can introduce complexity and raise issues if the other SoP has different or updated thresholds. Practitioners must identify and apply the correct version and provisions of all involved SoPs.

12. Death from hypertension requires contribution to a terminal event. For claims that assert death from hypertension, the SoP requires that the hypertension contributed to the terminal event (s 7(5)); the Schedule lists examples of terminal events. Mere presence of hypertension at death is insufficient without evidence of contribution.

13. Repeal and commencement timing. This SoP replaced the 2013 hypertension SoP from 4 April 2022 (s 2, s 4). Claims straddling the repeal date may engage questions of which SoP applies; the instrument does not set out transitional rules. Practitioners should check the underlying statutes and decision makers’ policies for transitional application.

14. No penal or procedural instructions. The SoP does not prescribe how evidence is to be admitted, how disputes of fact are resolved, or how to obtain records. Those practical steps depend on the VEA/MRCA administrative frameworks and general administrative law.

To present a robust claim or to advise a claimant under this SoP, practitioners should organise evidence to match the SoP’s substantive structural requirements: diagnosis of hypertension per s 7(2), demonstration of at least one qualifying factor in s 9, and proof that the factor(s) are related to the person’s relevant service (s 10(1)). Below is a practical evidence checklist and steps for compliance.

1. Establish the diagnosis under the SoP definition (s 7(2)).

   • Obtain the treating medical practitioner’s statement confirming diagnosis and describing the clinical onset date.
   • Supply clinic blood pressure records showing usual clinic readings ≥140/90 mmHg, or home readings ≥135/85 mmHg, or ambulatory readings meeting the ambulatory equivalents in Schedule 1 (average 24‑hour ≥130/80, daytime ≥135/85, nighttime ≥120/70).
   • If the diagnosis is by regular antihypertensive therapy alone, provide medication initiation dates and prescribing notes indicating therapy commenced to control high blood pressure.
   • Exclude transient causes by providing contemporaneous clinical notes showing chronicity and exclusion of the listed temporary conditions (for example, pregnancy‑related hypertension).

2. Identify and document at least one s 9 factor (onset or aggravation as applicable).

   • Overweight/obese (s 9(1), s 9(19)): provide serial BMI records and waist circumference measures; if BMI ≥25 or waist above thresholds, demonstrate continuity for the required 5‑year period (Schedule 1 definitions).
   • Alcohol (s 9(2), s 9(20)): document intake in grams/week over the required continuous 6‑month period. Use the Australian standard conversion (10 g per standard drink). Where contemporaneous records are absent, corroborate with partner statements, service records, drink diary evidence, or treatment records.
   • Salt intake (s 9(3), s 9(21)): provide dietary history, nutritionist reports, or medical records estimating salt intake at ≥12 g/day for ≥1 year. Account for sodium‑containing medications as noted in the SoP.
   • Renal artery stenosis, CKD, diabetes, endocrine disorders, sleep apnoea (ss 9(4), 9(6), 9(7), 9(8), 9(9)): supply imaging, biopsy, sleep study reports, laboratory results (GFR, albumin:creatinine), and specialist letters confirming diagnoses and relevant timing.
   • Solid organ/stem cell/bone marrow transplant (ss 9(5), 9(23)): surgical and hospital records documenting transplantation date(s).
   • Drug exposures (ss 9(13), 9(14), 9(31), 9(32)): obtain full medication histories, dispensing records, hospital charts and notes proving use, indication, dose, start and stop dates. Map each agent to the Specified Lists in Schedule 1 to confirm applicability.
   • Glucocorticoid therapy (ss 9(15), 9(33)): compile cumulative dose calculations per the equivalent glucocorticoid therapy table in Schedule 1. Where inhaled or topical steroids are relied upon, map doses to the “equivalent inhaled glucocorticoid” and “high or very high potency topical glucocorticoid” definitions.
   • Physical inactivity (ss 9(17), 9(35)): provide functional assessments, exercise testing results, clinician statements quantifying inability to undertake activities >3 METs for the required period.
   • Arsenic exposure (ss 9(18), 9(36)): obtain water testing reports, environmental exposure assessments, or clinical evidence of chronic arsenic toxicity that meet the Schedule 1 definitions.
   • Inability to obtain appropriate clinical management (s 9(37)): document attempts to seek care, service medical records, civilian GP correspondence, waiting lists, transfer limitations, or barriers during service that prevented appropriate management.

3. Relate each factor to relevant service (s 10(1)).

   • Provide service medical records, deployment logs, treatment records from military hospitals/clinics, orders showing where a person served, and contemporaneous incident reports that link the factor to service conditions (for example, documented exposures during service, service‑period medication use).
   • Where factors are environmental (for example, arsenic in water), supply credible linkage between the service location and the exposure (water supplier data, engineering reports or environmental assessments).

4. Address onset vs aggravation distinction (s 10(2)).

   • If claiming material contribution or aggravation of pre‑existing hypertension, demonstrate that the hypertension was suffered or contracted before or during relevant service and that service did not cause it to arise (provide medical history before service).
   • Then prove the aggravating factor(s) occurred after that pre‑existing state and during or related to service, with dates and durability matching the SoP thresholds.

5. For death from hypertension claims (s 7(5), Schedule 1)

   • Obtain the death certificate, autopsy or coronial findings, and clinical records showing hypertension contributed to a terminal event listed in the Schedule (for example, cardiac arrest or circulatory failure). Provide clear causal nexus evidence between hypertension and the terminal event.

6. Cross‑reference other SoPs where factors refer to separate diseases (s 11).

   • Identify any factor that references another SoP (for example, chronic kidney disease). Retrieve and apply the current text of that SoP and ensure the evidence meets the other SoP’s tests as applied “as in force from time to time” (s 11).

7. Practical evidence format and chronology.

   • Provide a clear chronology: dates for service periods, dates of onset or clinical worsening, dates for exposures, drug start/stop dates, and dates of diagnostic tests. Because numerous factors require continuous periods, the chronology should show continuity.
   • Use unit conversions and cumulative dosing calculations consistent with Schedule 1. For glucocorticoids, produce cumulative dose tables and indicate equivalent doses for other glucocorticoids where necessary.

8. Anticipate common evidential challenges.

   • If contemporaneous records are lacking, gather secondary corroboration: statutory declarations, witness statements, family accounts, unit diaries, or hospital discharge summaries.
   • Where dosing or intake estimates are necessary (alcohol, salt), obtain expert nutritional assessments or clinical reconstructions that explain estimation methodology and its reasonableness.

9. Present medical expert opinion tied to the SoP.

   • Where medical opinion is used, ensure expert clinicians explicitly address the SoP criteria: state which s 9 factor(s) are relied upon, explain how the evidence meets the specific thresholds, and state whether the factor(s) were related to relevant service in the expert’s view. Generalised statements that do not reference the SoP thresholds will be less persuasive.

10. Keep the SoP and its Schedule to hand; check for updates.

• The instrument states that where another SoP is involved, it applies “as in force from time to time” (s 11). Practitioners should confirm the operative version of any cross‑referenced SoP and ensure that the current SoP (No. 22 of 2022) remains the governing instrument for hypertension, noting its repeal of the 2013 SoP (s 4).

11. Administrative follow‑through.

• Lodge complete documentary evidence with the claim file to avoid delays. Where records are located on multiple systems (military health records, civilian GP, hospital pharmacy), obtain consent and authorisations early to avoid retrieval delays.

12. Anticipate questions about missing or partial data.

• Decision‑makers applying the SoP will weigh probability. If specific numerical evidence is missing but there is persuasive circumstantial evidence that a threshold was met, prepare supporting affidavits and corroborating materials and an expert report explaining inferential reasoning in SoP terms.

Following these steps will align claim preparation with the instrument’s structure: establishing a SoP‑compliant diagnosis (s 7), demonstrating at least one qualifying factor with required durational or dosing thresholds (s 9 and Schedule 1), and showing the factor is related to relevant service (s 10). The SoP’s precise numerical criteria mean that attention to units, cumulative dosing calculations, dates and continuous period requirements is essential.