Statement of Principles concerning Merkel cell carcinoma (Reasonable Hypothesis) (No. 80 of 2024)

The instrument rests on several interlocking legal‑medical concepts. First is the statutory provenance: the RMA is exercising its statutory role in prescribing Statements of Principles under s 196B(2) VEA (Authority). That role is limited to identifying medical and exposure factors which, according to the RMA, have sound medical‑scientific support for a service link (Basis for determining the factors).

Second is the standard of proof created by the SoP: the text frames its operation around the statutory phrase “reasonable hypothesis”. The SoP spells out the minimum factual basis,at least one specified factor,that must exist before “it can be said that a reasonable hypothesis has been raised connecting Merkel cell carcinoma or death from Merkel cell carcinoma with the circumstances of a person’s relevant service” (s 9 opening). The instrument does not itself alter legal standards in the VEA/MRCA, but it operationalises the reasonable hypothesis test by enumerating the factors and their required temporal or quantitative thresholds.

Third is the disease definition and diagnostic anchoring. The SoP defines Merkel cell carcinoma as a primary cutaneous neuroendocrine carcinoma (s 7(2)(1)). It lists ICD‑10‑AM codes that “attract” to MCC but clarifies that the meaning in the SoP is given by the textual definition (s 7(2)(2)-(3)). Death from MCC includes deaths from a terminal event or condition that was contributed to by the person’s MCC; the instrument cross‑references the Schedule definition of terminal event (s 7(3); Schedule 1).

Fourth, the instrument specifies discrete exposure/medical factors and, where applicable, quantitative and temporal thresholds. Examples: sunlight exposure must equal at least 2,250 latitude equivalent hours before clinical onset (s 9(1); Schedule 1 defines how to calculate latitude equivalent hours with latitude weighting factors). PUVA therapy is defined and requires that the first treatment was at least five years before clinical onset and that at least 50 PUVA treatments were administered before clinical onset (s 9(2); Schedule 1 defines PUVA). Several immunosuppression or immunocompromise states are listed (Merkel cell polyomavirus infection, HIV infection, organ or bone marrow transplant with a 5‑year latency, non‑Hodgkin lymphoma, chronic lymphocytic leukaemia/small lymphocytic lymphoma) (s 9(3)-(7)). The SoP also includes inability to obtain appropriate clinical management prior to clinical worsening (s 9(8)), subject to the service‑relationship limitation in s 10(2).

Fifth, there is cross‑instrument interaction. If a listed factor refers to an injury or disease that itself has an SoP determined under s 196B(2) VEA, the other SoP applies in accordance with its terms as in force from time to time (s 11). This creates dependent evidence pathways where establishing a factor may require engaging with another SoP’s criteria.

Finally, the Schedule supplies technical definitions that are integral to applying the SoP: latitude equivalent hours with specific weighting by latitudinal bands (Schedule 1), what constitutes unprotected skin (Schedule 1), the definition of PUVA therapy (Schedule 1), relevant service categories (Schedule 1), and terminal event examples (Schedule 1). These definitions convert general descriptive concepts into measurable or documentable elements for adjudication.

The instrument affects claimants and decision processes under the VEA and the MRCA. It explicitly applies to claims “to which section 120A of the VEA or section 338 of the MRCA applies” (Application). Practically, that means veterans, members of Peacekeeping Forces, and members of the Forces whose claims for MCC or death from MCC are being assessed under the covered provisions of the VEA or MRCA will be affected. The RMA states its view that MCC and death from MCC can be related to relevant service rendered by veterans, members of Peacekeeping Forces, or members of the Forces under the VEA or MRCA (Basis for determining the factors). The instrument therefore defines the medical criteria that adjudicators will use to decide whether a reasonable hypothesis of service connection exists for MCC claims.

Who pays: the instrument does not in itself create financial entitlements or specify payment; rather it provides the medical rules that feed into administrative decisions about entitlements in the VEA and MRCA framework. The economic consequence is that the outcomes of claims that rely on this SoP determine access to benefits under those Acts. The SoP therefore influences which claimants will obtain favourable findings and so indirectly affects the fiscal exposure of the administering agencies, but the instrument itself contains no payment or cost provisions.

Who decides: the RMA issued the SoP (Authority). The SoP will be used by decision‑makers who process claims under the relevant VEA and MRCA sections referenced in the instrument (Application). The instrument does not name the reviewing bodies or specify their procedures; it provides the evidentiary grid that those decision processes will apply when evaluating whether a reasonable hypothesis has been raised.

Who else is affected: medical practitioners, hospitals and pathology providers who supply diagnostic evidence, and veterans’ advocates and lawyers preparing claims. The SoP sets measurable thresholds (e.g. 2,250 latitude equivalent hours, 50 PUVA treatments, five‑year latency rules) and definitional points (e.g. unprotected skin, PUVA combination therapy), so clinicians and records custodians will need to supply specific documentation. Where factors reference other SoPs (s 11), claimants and advisers must consult those instruments as well.

Administrative actors are affected because the SoP replaces a prior instrument (Repeal) and will be the operative medical statement for MCC claims from its commencement date (Commencement; Repeal). Documents, guidance, and decision‑making templates used by administrators will need to be updated to reflect the new definition, factor list and technical definitions in the Schedule.

The instrument itself does not create freestanding duties in the criminal or civil law sense; rather it establishes the evidentiary criteria that are to be used in adjudicating claims under the VEA and MRCA (Authority; Application). The operative duties and rights relevant to the SoP derive from the interplay between this instrument and the VEA/MRCA claims framework.

Primary duty for claimants: to establish that at least one of the listed factors existed for the person before clinical onset, and that the factor is related to the person’s relevant service, because the SoP specifies that at least one factor must exist “before it can be said that a reasonable hypothesis has been raised” connecting MCC or death from MCC with relevant service (s 9 opening; s 10(1)). The SoP sets the minimum evidentiary threshold for the reasonable hypothesis test; it does not itself adjudicate entitlement or set the ultimate standard of proof for deciding a claim, which remains governed by the Acts. Nevertheless, the practical effect is that claimants seeking to rely on this SoP will need to produce evidence that aligns with the quantitative or temporal thresholds embedded in the listed factors (for example, documentation of the number and timing of PUVA treatments, dates of transplantation, laboratory or clinical documentation of infections or lymphoid malignancies, or reconstructed sunlight exposure hours per Schedule 1). The duty to produce such evidence arises from the claims process that will apply the SoP.

Duty to connect factor to service: every factor relied upon must be related to the person’s relevant service (s 10(1)). This creates a secondary requirement beyond simply proving the clinical or exposure state: the claimant must show a link between that state and the service period or circumstances identified in the definition of relevant service in the Schedule (operational, peacekeeping, hazardous, British nuclear test defence service under the VEA; warlike or non‑warlike under the MRCA).

Limited application of inability to obtain appropriate clinical management: the factor in s 9(8) is constrained by s 10(2), which provides that s 9(8) applies only to material contribution or aggravation where the MCC was suffered or contracted before or during (but did not arise out of) the person’s relevant service. That restricts the circumstances where failure to obtain management can be used as the sole basis for a reasonable hypothesis connecting service to MCC.

Right to rely on cross-referenced SoPs: if a factor in s 9 refers to an injury or disease that itself has an SoP under s 196B(2) VEA, then that other SoP applies “in accordance with the terms of that Statement of Principles as in force from time to time” (s 11). Claimants may therefore exercise the right to rely on the criteria set out in other SoPs when those are invoked by a factor in this SoP.

Administrative duty of the RMA and decision makers: the RMA has issued the SoP under statutory authority (s 196B(2) VEA) and decision‑makers processing claims under the specified sections of the Acts will use the SoP as the RMA’s view of the medical evidence needed to raise a reasonable hypothesis. The instrument itself contains no enforcement or penalty provisions; its function is evidentiary.

Rights to review or appeal: the SoP does not set out review or appeal mechanisms. Rights of administrative review or judicial review that follow from the VEA, MRCA and general administrative law are not contained in the instrument and must be located in those Acts or other applicable law.

This Statement of Principles contains no criminal offences, pecuniary penalties or civil enforcement mechanisms. It is an evidentiary instrument created under subsection 196B(2) of the VEA (Authority) which is used in the administrative decision‑making processes for claims under the VEA and MRCA (Application). The instrument does not itself specify sanctions for non‑compliance or false statements, nor does it create powers to compel evidence beyond what the relevant claims administration legislation provides.

Enforcement in practice is administrative and indirect. The SoP establishes the medical criteria that decision‑makers will apply when considering whether a reasonable hypothesis has been raised linking MCC or death from MCC to relevant service (s 9; s 10). The practical consequence for claimants is that a failure to establish one of the listed factors, or to show its relationship to relevant service, will leave a decision‑maker without the RMA‑specified minimum basis for a reasonable hypothesis. That can lead to rejection of a claim or the need to rely on alternative evidence or legal arguments under the Acts. Conversely, establishing a listed factor may be determinative of the “reasonable hypothesis” threshold in administrative decision processes.

The instrument repeals an earlier SoP (Repeal). Where decision‑makers continue to rely on an outdated instrument, the legal force of the current SoP supersedes the repealed instrument from commencement (Repeal; Commencement). The administrative exposure created by determinations under the SoP is therefore concrete: accepted reasonable hypothesis findings will be inputs into statutory entitlement decisions under the VEA or MRCA, which carry financial and non‑financial consequences governed by those Acts and their administrative rules, not by the SoP itself.

Procedural enforcement measures,such as document subpoenas, medical examinations or sanctions for misleading claims,are not contained in the instrument and must be sought, if available, in the VEA, MRCA, or other procedural rules. The SoP does not expand or restrict those powers; it provides medical‑scientific criteria for adjudication.

In short, there are no direct penalties in this instrument. Its “enforcement” effect is through its role as the RMA’s medical standard in claim determinations, affecting outcomes and thereby the downstream entitlements that are administered under other statutes.

The instrument is expressly made under subsection 196B(2) of the VEA (Authority), and it applies to claims under section 120A of the VEA or section 338 of the MRCA (Application). Those references anchor the SoP within the statutory disability and compensation framework for veterans and serving members. The instrument does not itself restate or amend the substantive entitlements or procedural rules in the VEA or MRCA; it supplies the RMA’s medical findings that are to be applied within the existing legal framework.

Repeal interaction: the SoP repeals the earlier Statement of Principles concerning non‑melanotic malignant neoplasm of the skin No. 7 of 2016 (Repeal). Therefore, for the purposes of administrative decision‑making after commencement (19 November 2024), this instrument replaces that prior instrument. Any claims or decisions that relied on the prior SoP must be reconsidered in light of the new SoP where applicable, subject to any transitional or savings provisions contained in the Acts or administrative practice; the SoP itself contains no transitional provision.

Cross‑SoP references: s 11 provides an express mechanism for interaction with other SoPs. If a factor in s 9 refers to an injury or disease for which another SoP has been determined under subsection 196B(2) VEA, then the factors in that other SoP “apply in accordance with the terms of that Statement of Principles as in force from time to time.” This means (1) a factor in this SoP can trigger the application of a separate SoP, and (2) that separate SoP’s criteria and temporal provisions become applicable as set out in that instrument. Consequently, the adjudication of a given claim may require simultaneous reference to multiple SoPs and to the current versions of those SoPs.

Interaction with diagnostic coding and clinical classification: the instrument lists ICD‑10‑AM codes that are “attract[ed]” to MCC (s 7(2)(2)) but clarifies that for application of the SoP the meaning of MCC is the textual definition in s 7(2)(1). The list of ICD codes refers to 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(2)(3)). This creates a technical linkage to the classification system used in health records, but the SoP’s textual definition controls application.

Evidentiary and procedural law: the SoP is an administrative instrument meant to be used in statutory decision‑making under the VEA and MRCA. It does not specify evidentiary rules, statutory limitation periods, or procedural rights of review or appeal; those remain matters for the VEA, MRCA and general administrative law. Where a factor requires reliance on diagnoses or laboratory tests (for example, infection with Merkel cell polyomavirus, HIV, or lymphoid malignancy), claimants and decision‑makers will necessarily rely on the evidentiary regimes in those Acts, medical records law and privacy legislation to obtain and use evidence, but the SoP itself is silent on those procedural interactions.

Definitions and scope: the Schedule ties key words used in this SoP to technical concepts relevant across the legal and medical fields: relevant service types (Schedule 1), terminal event (Schedule 1), and unprotected skin (Schedule 1). The interaction with service classifications under the VEA and MRCA is direct because “relevant service” in the Schedule references categories drawn from those Acts.

In aggregate, the SoP interacts with other laws by supplying the RMA’s medical criteria that feed into statutory claims under VEA and MRCA, by cross‑referencing other SoPs, and by linking to clinical classification systems. It does not create or alter statutory entitlements, penalties or procedural rights; those remain governed by the underlying legislation.

The instrument itself records the following changes and dates that are part of its immediate amendment history. It is dated 18 October 2024 as signed by the Chairperson of the RMA (Dated; signature block). It commences on 19 November 2024 (Commencement). It expressly repeals the Statement of Principles concerning non‑melanotic malignant neoplasm of the skin No. 7 of 2016, Federal Register of Legislation No. F2016L00239, that was made under subsections 196B(2) and (8) of the VEA (Repeal). That repeal indicates that the 2016 instrument ceases to be operative from the commencement date of this 2024 instrument.

The instrument does not record any prior amendments to itself; it is presented as a discrete instrument replacing an earlier SoP. The text contains no savings, transitional or grandfathering clauses. The implication for administrative use is that, from commencement, the 2024 SoP is the RMA’s operative statement for Merkel cell carcinoma unless and until it is further amended or repealed by subsequent instruments. The instrument also provides that any factors in the 2024 SoP that refer to other injuries or diseases will be governed by those other SoPs “as in force from time to time” (s 11). That language anticipates future amendments to other SoPs: the current instrument will interact with updated versions of other SoPs as those instruments are amended.

No further historical amendment entries are included in the text. The instrument contains no provision for periodic review or scheduled amendment. The RMA’s power to issue or amend SoPs derives from the VEA, and any future changes to the RMA’s statements will appear in later instruments under that statutory regime.

Users of this SoP should therefore do two things when tracking amendment history: (1) note that this instrument replaces the 2016 SoP with effect from 19 November 2024, and (2) monitor other SoPs that are cross‑referenced in s 11, because changes to those instruments can change the evidentiary import of factors in this SoP. The instrument itself provides the dates and repeal item needed to pin down what it superseded and when.

The instrument contains no references to case law, judicial decisions or litigation involving the Statement of Principles for Merkel cell carcinoma. The text makes no mention of any judicial review, appeals, or testing of its contents in the courts. The RMA frames the instrument as being made on the basis that “there is sound medical‑scientific evidence that indicates that Merkel cell carcinoma and death from Merkel cell carcinoma can be related to relevant service” (Basis for determining the factors), but it does not cite litigation or judicial interpretation to support that view.

Because the SoP is an administrative instrument used in claims assessment under the VEA and MRCA, litigation relating to its application would typically occur in the context of disputes about claim outcomes or judicial review proceedings contesting administrative decisions that rely on the SoP. However, the instrument does not record any such proceedings. There are therefore no litigation entries to report from the instrument itself.

Practical implication for litigators and advisers: absence of recorded litigation in the instrument means that any legal testing of the 2024 SoP’s contents would be through later administrative review, merits review or judicial review processes that challenge decisions applying this SoP. Counsel preparing to litigate about claims that engage this SoP must therefore prepare for first principles arguments about the appropriate interpretation of the SoP’s textual thresholds, the application of its definitions (for example, calculation of latitude equivalent hours), and the interplay with other SoPs referenced under s 11. They should also be aware that the SoP replaces a 2016 instrument (Repeal), so historical decisions based on the 2016 SoP may be relevant as facts but not authoritative as to the RMA’s current position.

In short, the instrument itself reports no litigation history. Any case law that might be created about its application will need to be located in decisions and published reasons that post‑date its commencement.

Several practical and technical pitfalls arise when applying this SoP. These are matters the SoP itself makes consequential by virtue of its thresholds, definitions and cross‑references.

1. Latitude equivalent hours calculation. The SoP requires cumulative sunlight exposure of at least 2,250 latitude equivalent hours before clinical onset (s 9(1)). The Schedule defines latitude equivalent hours as hours multiplied by a latitude weighting factor (Schedule 1). The weighting factors vary by latitudinal bands: tropical = 1.0, subtropical = 0.75, warm temperate = 0.5, cool temperate = 0.25 (Schedule 1). The Schedule supplies a summation formula to combine exposure across latitudes. Practically, claimants must reconstruct hours spent at each latitude and show whether those hours represent “unprotected skin” exposure (Schedule 1 defines unprotected skin as skin directly exposed to the sun and not protected by sunscreen, clothing or other physical barrier). Record limitations, approximation of hours, and how to treat intermittent exposure can all materially affect whether the 2,250 threshold is reached. The SoP does not define how to treat uncertainty or estimation methods; adjudicators must apply the SoP to the available evidence.

2. PUVA thresholds are conjunctive. The PUVA factor requires two independent elements: the first PUVA treatment must have commenced at least five years before clinical onset and at least 50 PUVA treatments must have been administered before clinical onset (s 9(2)). Both conditions must be met. PUVA is defined in the Schedule as oral psoralen plus UVA exposure. Administrative records may list dermatology treatments but may not always clearly document psoralen use or count of sessions; absence of explicit session counts may defeat this pathway.

3. Timing evidence for infections and transplants. Several factors require proof that the condition or infection existed before clinical onset (s 9(3)-(5)). Demonstrating the timing of Merkel cell polyomavirus infection, HIV infection, or transplantation relative to clinical onset may be difficult because laboratory testing for Merkel cell polyomavirus is not necessarily routine and medical records may be incomplete. For transplants, corneal transplants are excluded (s 9(5)). Transplant evidence must also show the 5‑year latency where required.

4. Diagnoses of lymphoid malignancies. The SoP lists non‑Hodgkin lymphoma and mature B‑cell lymphoid leukaemia/small lymphocytic lymphoma (also identified as chronic lymphocytic leukaemia/small cell lymphoma) as qualifying factors if diagnosed before clinical onset (s 9(6)-(7)). Precise histopathology and dating of onset are essential. Ambiguous or provisional diagnoses may not satisfy the SoP.

5. Inability to obtain appropriate clinical management is constrained. The factor in s 9(8) is limited by s 10(2): it applies only to material contribution to, or aggravation of, MCC where the person’s MCC was suffered or contracted before or during (but did not arise out of) relevant service. That means s 9(8) cannot be used where MCC arose out of service. The distinction among “suffered or contracted before or during (but did not arise out of) service” and “arose out of service” will be a nuanced factual and legal question in particular cases.

6. ICD code list vs textual definition. The instrument lists ICD‑10‑AM codes that “attract” to MCC (s 7(2)(2)) but instructs that the meaning of MCC for the SoP is the textual definition in subsection 7(2)(1). Practitioners must not rely solely on coding; pathology and clinical records that establish MCC as a primary cutaneous neuroendocrine carcinoma control.

7. Cross‑SoP complexity. If a factor invokes another SoP under s 11, practitioners must consult that SoP “as in force from time to time.” That means supporting evidence may need to satisfy multiple instruments’ rules, and timing or threshold differences between instruments can complicate claims.

8. Clinical onset and dating. The SoP repeatedly uses the term “clinical onset” as the reference point for timing thresholds but does not define “clinical onset” in this instrument or the Schedule. Determining the operative date for clinical onset (first symptoms, first diagnosis, first clinical confirmation) can be contested and is likely to be material to latency thresholds (for example, the 5‑year rule for PUVA and transplant).

9. Proof burdens and record availability. The SoP creates concrete thresholds that require documentation (treatment counts, infections, transplant dates, hours at latitude). In many cases service records, civilian medical records and private practitioners’ notes may be incomplete or inaccessible, making reliance on certain pathways difficult.

10. Terminal event and death. For death claims, the SoP includes death from a terminal event or condition that was contributed to by MCC (s 7(3)). The Schedule defines terminal events (pneumonia, respiratory failure, cardiac arrest, circulatory failure, cessation of brain function) and treats these as examples of terminal events (Schedule 1). Establishing that MCC contributed to such terminal events requires a chain of causation in medical evidence; the SoP itself does not prescribe how contribution is to be demonstrated beyond the statement that such deaths are included.

These are procedural and evidentiary “gotchas” built into or implied by the SoP’s drafting. Practitioners should plan evidence collection with these specifics in mind and be prepared to address gaps, timing disputes, and technical calculation issues.

This SoP is an evidentiary instrument used when preparing or defending a claim that MCC or death from MCC is related to relevant service. Compliance, in practical terms, means assembling the evidentiary material required to establish at least one listed factor and to show that the factor is related to relevant service. The following checklist maps directly onto the SoP’s requirements and definitions.

1. Establish the diagnosis and clinical onset:

   • Obtain and collate pathology reports and clinician notes that confirm MCC as a primary cutaneous neuroendocrine carcinoma (s 7(2)(1)). Do not rely solely on ICD‑10‑AM coding lists; the SoP treats the textual definition as controlling (s 7(2)(2)-(3)).
   • Record and document the date of clinical onset to anchor latency calculations. Because “clinical onset” is the timing reference for multiple factors (s 9), explicitly state the date in submissions and support it with medical records.

2. Identify which factor(s) in s 9 you will rely on:

   • Sunlight exposure (s 9(1)): reconstruct cumulative exposure hours for “unprotected skin” before clinical onset. Use service records (postings, deployments), pay or leave logs, witness statements, personal service diaries, and civilian records to establish hours spent in specified latitudinal bands. Apply the Schedule 1 weighting factors and summation formula for latitude equivalent hours. Document whether exposure was to unprotected skin (sunscreen, clothing barriers).
   • PUVA therapy (s 9(2)): obtain dermatology treatment records that document the start date of PUVA therapy and the total number of sessions. Verify that the first PUVA treatment was at least five years before clinical onset and that at least 50 treatments were administered prior to onset. Include records demonstrating oral psoralen (methoxsalen) plus UVA exposure (Schedule 1 definition of PUVA).
   • Infectious agents (s 9(3)-(4)): obtain laboratory and clinical records confirming Merkel cell polyomavirus infection or HIV infection and the dates demonstrating the infection preceded clinical onset.
   • Transplantation history (s 9(5)): obtain surgical, hospital and transplant registry documentation for solid organ (excluding corneal) or bone marrow transplantation, confirming the procedure and date at least five years before clinical onset.
   • Lymphoid malignancies (s 9(6)-(7)): obtain haematology, pathology and oncology records to document diagnoses of non‑Hodgkin lymphoma or mature B‑cell lymphoid leukaemia/small lymphocytic lymphoma, with dates showing diagnosis before clinical onset.
   • Inability to obtain appropriate clinical management (s 9(8)): gather contemporaneous evidence showing attempts to obtain care, denials, lack of available services, or other barriers, and link that lack of management to clinical worsening. Remember the limitation in s 10(2): this factor can only be used where MCC was suffered or contracted before or during service but did not arise out of service.

3. Demonstrate relation to relevant service:

   • For whichever factor(s) you rely on, assemble service records to show the temporal and causal relationship between the factor and the person’s relevant service as defined in Schedule 1 (operational, peacekeeping, hazardous, British nuclear test defence service under the VEA; warlike or non‑warlike under the MRCA).
   • Where exposures occurred outside formal service (civilian life), show how those exposures are connected to the service period in issue if that is necessary to meet s 10(1).

4. Address cross‑SoP dependencies:

   • If a factor refers to another SoP (s 11), obtain and apply the current version of that SoP. Ensure that evidence also satisfies the requirements of the cross‑referenced SoP as then in force.

5. Prepare medical opinion evidence:

   • Commission medical expert reports that apply the SoP’s criteria to the individual facts, explicitly addressing each threshold (e.g. calculation of latitude equivalent hours, PUVA dates and counts, transplant latency). Experts should refer to the SoP’s definitions and schedule items when forming an opinion on whether a reasonable hypothesis is raised.

6. Documentary organisation:

   • Prepare a clear schedule of evidence that maps each item of evidence to the particular clause or Schedule definition it is intended to satisfy. For complex items like latitude equivalent hours, provide a worked calculation showing hours, latitudinal bands, weighting factors and the final sum.

7. Preempt likely evidentiary challenges:

   • Anticipate gaps in historical records and prepare secondary evidence such as sworn affidavits, contemporaneous personal documents, unit diaries, or witness statements to support reconstructions. Where possible, corroborate subjective accounts with objective records.

8. For death claims:

   • Obtain the death certificate, post‑mortem if any, and clinical records tracing the causal chain between MCC and the terminal event or condition listed in the Schedule (s 7(3); Schedule 1 terminal event examples). Medical opinions should explain how MCC contributed to the terminal event.

9. Administrative practice:

   • Ensure submissions reference the SoP sections relied upon and include arguments that the SoP thresholds are met and related to relevant service. Where s 10(2) limits s 9(8), make that connection explicit in submissions.

10. Keep current:

• Because s 11 ties application of some factors to other SoPs “as in force from time to time,” periodically check for updates to any cross‑referenced SoP that might affect evidence requirements.

Following these steps aligns the claim material with the RMA’s expressed evidentiary standard in this SoP and reduces the risk that a decision‑maker will find the required minimum basis for a reasonable hypothesis absent.