Statement of Principles concerning rheumatic heart disease (Reasonable Hypothesis) (No. 51 of 2019)

The Statement establishes several primary legal and medical concepts that determine whether rheumatic heart disease (RHD) or death from RHD can be connected to relevant service under the veteran compensation and rehabilitation statutes.

Rheumatic heart disease, for the instrument’s purposes, is defined tightly in subsection 7(2). It requires clinical or echocardiographic documentation of cardiac disease, typically involving the mitral or aortic valve, that follows acute rheumatic fever. The definition explicitly includes pathological stenosis or regurgitation accompanied by scarring, deformity or morphological change of at least one heart valve, chronic rheumatic myocarditis and chronic rheumatic pericarditis, and it excludes acute carditis of acute rheumatic fever. The RMA also records that RHD can be diagnosed in the absence of previously documented acute rheumatic fever. The instrument notes that while ICD‑10‑AM codes I05-I09 typically correspond to RHD, the statutory meaning is the subsection 7(2) definition rather than the ICD codes alone (subsections 7(2)-(4)).

“Death from rheumatic heart disease” is treated to include deaths from terminal events or conditions that were contributed to by the person’s RHD; “terminal event” is defined in the Schedule to include causes such as pneumonia, respiratory failure, cardiac arrest, circulatory failure or cessation of brain function (subsection 7(5); Schedule 1).

The causal test employed is the “reasonable hypothesis” standard. Section 9 lists discrete factors, any one of which must exist as a minimum before a reasonable hypothesis is said to connect RHD (or death from it) with the circumstances of relevant service. Those factors encompass prior acute rheumatic fever, prior group A beta‑haemolytic streptococcal infection (skin or pharynx), crowded living or working conditions, events related to clinical worsening (including pregnancy within 30 days prior, inability to obtain appropriate clinical management), and time‑linked requirements such as “at least three months before the clinical onset” or within ten years prior to clinical worsening (section 9).

The instrument differentiates between factors that establish initial connection (subsections 9(1)-(3) require factors at least three months before clinical onset) and factors that can establish material contribution or aggravation of an existing condition (subsections 9(4)-(8)). Section 10(2) constrains the latter group to circumstances where the person’s RHD was suffered or contracted before or during, but did not arise out of, their relevant service. The Schedule’s definition of “relevant service” lists the discrete categories of service under the VEA and MRCA to which the Statement applies (Schedule 1).

Finally, section 11 provides an interactional concept: where a section 9 factor refers to another injury or disease that itself has a Statement of Principles, the terms of that other Statement apply. This creates a mechanism for importing specialised causation criteria from other Statements when factors cross‑refer to other diagnosable conditions.

Each of these concepts is intended to be applied by the decision‑maker handling a claim under s 120A of the VEA or s 338 of the MRCA, using the RMA’s specified medical‑causal framework as the threshold evidence that a “reasonable hypothesis” is established (s 5). The RMA’s reliance on “sound medical‑scientific evidence” is recorded in s 8 as the basis for the Statement.

The instrument affects persons making claims under two statutory schemes: claims to which section 120A of the Veterans’ Entitlements Act 1986 (VEA) applies, and claims to which section 338 of the Military Rehabilitation and Compensation Act 2004 (MRCA) applies (s 5). The Schedule defines “relevant service” to include operational service, peacekeeping service, hazardous service and British nuclear test defence service under the VEA, and warlike or non‑warlike service under the MRCA (Schedule 1). Accordingly, the population directly affected is serving or former members of the Forces, veterans, and members of Peacekeeping Forces whose claims raise rheumatic heart disease or death from it in the statutory compensation and rehabilitation contexts governed by the VEA and MRCA.

The immediate operational effect is on claimants seeking to establish a causal link between their RHD (or death attributable to RHD) and their service. The Statement prescribes the minimal medical and situational factors that must be present for a “reasonable hypothesis” to be raised (s 9). That means claimants will need to present evidence corresponding to one or more of the specified factors (for example, clinical or echocardiographic documentation, proof of prior acute rheumatic fever, microbiological or clinical records of group A streptococcal infection, records showing crowded living or working conditions, pregnancy records if relevant, and documentation of inability to obtain appropriate clinical management).

Decision‑makers charged with assessing entitlements under the VEA and MRCA will be the bodies that apply this Statement. The instrument itself is made by the RMA (s 3), and it frames the medical issues for application under the statutory claims provisions. While the Statement establishes presumptive links and required factors, it is an input into the administrative determination process rather than a direct grant of benefit.

Health practitioners and medical experts preparing reports for claims will be affected by the instrument’s definition of RHD and the required evidentiary elements. The instrument privileges clinical and echocardiographic documentation in the definition of RHD (subsection 7(2)(a)), which focuses the type of medical evidence that supports a claim.

Other affected parties include administrators who adjudicate claims and those who collect and manage medical records, because the Statement’s temporal and diagnostic requirements (for example, “at least three months before the clinical onset”, and the exclusion of acute carditis of acute rheumatic fever) will influence how claims are investigated and how medical histories are interpreted.

Finally, because section 11 imports other Statements where a factor refers to an injury or disease covered by another Statement, claimants and advisors must monitor and obtain the other applicable Statements of Principles. The instrument’s repeal of the earlier 2011 Statement (s 4) means that claims falling after the commencement date will be assessed against this 2019 Statement rather than the 2011 instrument.

This Statement itself sets out evidentiary and causal criteria rather than prescriptive duties with penalties. It is, however, functionally a mandatory framework that decision‑makers use when deciding whether a “reasonable hypothesis” connects rheumatic heart disease (or death from it) with relevant service. The primary operative duties and rights that follow from the instrument can be characterised as obligations on claimants to establish one of the specified factors and rights to have a claim assessed under the RMA‑determined criteria.

Duties and evidentiary expectations for claimants

• Establish one or more of the factors in section 9. The instrument is explicit that at least one of the listed factors must exist “as a minimum” before a reasonable hypothesis is raised (s 9). The factors are expressed in terms that map to discrete evidence types and temporal relationships: documented acute rheumatic fever or documented group A beta‑haemolytic streptococcal infection occurring at least three months before clinical onset (subsections 9(1)-(2)); evidence of crowded living or working conditions at least three months before onset (subsection 9(3)); and other temporal and causal relationships for clinical worsening (subsections 9(4)-(8)). Claimants therefore bear the practical duty of adducing evidence corresponding to these factors when seeking to raise the reasonable hypothesis.
• Provide medical documentation consistent with the definition of RHD in subsection 7(2). The instrument requires RHD to be clinically or echocardiographically documented (subsection 7(2)(a)); the presence of pathological valvular change, chronic myocarditis or pericarditis support the diagnosis (subsection 7(2)(b)). The claimant therefore has the de facto duty to supply or rely on medical records that meet these clinical thresholds.

Rights of claimants

• Right to have their claim assessed against the RMA’s identified factors. Section 5 makes the Statement applicable to claims under s 120A of the VEA and s 338 of the MRCA, thereby entitling eligible claimants to have the RMA’s criteria considered in the claims process.
• Right to have death assessed as “death from rheumatic heart disease” if the death resulted from a terminal event that was contributed to by RHD. Subsection 7(5) extends the disease to include deaths where a terminal event (as defined in the Schedule) was contributed to by the person’s RHD.

Duties of decision‑makers (implicit from application clauses)

• Apply the Statement as the medical framework for determining whether a reasonable hypothesis exists in claims under the specified statutory sections (s 5). The instrument itself does not lay out adjudicative procedures; it supplies the medical causal criteria decision‑makers must apply.
• Where a factor refers to another disease with its own Statement, apply that other Statement’s factors per section 11. This places an obligation on decision‑makers to cross‑reference other Statements in their determinations when the factual basis so requires.

Limitations and constraining clauses

• The instrument distinguishes between causation for onset and material contribution/aggravation. Subsection 10(2) constrains how subsections 9(4)-(8) can be used: they apply only where RHD was suffered or contracted before or during (but did not arise out of) relevant service. This is a built‑in legal limitation on how certain factors may be used to establish a connection to service.

The instrument does not create criminal offences or pecuniary penalties. It does not itself pay benefits or impose express investigatory or disclosure obligations. Instead, it sets the medical foundation that structures duties and rights in the claims process under the VEA and MRCA.

The Statement of Principles instrument contains no offences, fines, or direct penal sanctions. It is an evidentiary and causal framework rather than an enforcement instrument. The text does not create administrative penalties nor prescribe enforcement powers; instead it operates as the RMA’s determination of the medical factors that constitute a reasonable hypothesis connecting rheumatic heart disease to relevant service.

Enforcement in practice will occur through the statutory claim assessment processes under the Veterans’ Entitlements Act 1986 and the Military Rehabilitation and Compensation Act 2004, because the Statement is made under subsection 196B(2) of the VEA and is declared to apply to claims to which s 120A of the VEA or s 338 of the MRCA apply (ss 3 and 5). The instrument therefore functions as binding medical guidance to the decision‑makers who administer claims under those Acts. Any administrative consequences , acceptance, rejection, or partial acceptance of a claim, and any subsequent entitlement decision , flow from how decision‑makers apply this Statement when exercising the powers available to them under the VEA and MRCA (the Statement itself does not specify those powers).

The instrument imposes no express monitoring, compliance auditing, or sanctioning regime. It does not authorise coercive powers to obtain medical records or to compel testimony. Nor does it specify review, appeal, or merits review procedures; those procedural rights, if they exist, derive from the VEA and MRCA rather than from this instrument. The Statement also does not direct any executive agency to take specific enforcement actions beyond applying the Statement’s criteria when assessing claims.

Because the Statement prescribes the factors that will be treated as sufficient to raise a reasonable hypothesis, its practical enforcement role is that decision‑makers will accept claims meeting the minimum criteria set out in section 9 as having met the threshold for a reasonable hypothesis. Conversely, where none of the listed factors is established, decision‑makers will be entitled to find that no reasonable hypothesis has been raised. The instrument therefore has significant practical effect on entitlement outcomes, but those outcomes are realised through existing administrative decision‑making mechanisms under the VEA and MRCA rather than by penalties embedded in the Statement itself.

If a factor in section 9 refers to an injury or disease covered by another Statement of Principles, the other Statement applies in accordance with its terms (section 11). This creates an enforcement mechanism by reference: when cross‑referenced criteria are relevant, decision‑makers must apply the other Statement’s terms, which may affect the ultimate determination in a claim.

In summary, there are no direct penalties or sanctions in the instrument; its “enforcement” is administrative, realised through how statutory decision‑makers apply the Statement to claims under the VEA and MRCA, and through the cross‑referencing mechanism in section 11 and the statutory links in section 5.

The Statement is integrated into the statutory compensation and rehabilitation framework through express references and application clauses. It is made under subsection 196B(2) of the Veterans’ Entitlements Act 1986 (s 3), and it is declared to apply to claims to which s 120A of the VEA or s 338 of the Military Rehabilitation and Compensation Act 2004 (MRCA) applies (s 5). Those statutory sections (not reproduced within this instrument) set the procedural and substantive pathways by which claims under the VEA and MRCA are lodged and assessed. The Statement therefore functions as an RMA‑determined evidentiary and causation input into that pre‑existing statutory decision framework.

The Schedule defines “relevant service” in terms that map to categories under both the VEA and MRCA, listing operational service, peacekeeping, hazardous service, British nuclear test defence service (VEA categories), and warlike or non‑warlike service under the MRCA (Schedule 1). This definition determines the universe of claims to which the factors in section 9 can be applied. Practically, the Statement will be applied by the decision‑maker charged with adjudication under the relevant statutory provisions; the instrument does not itself change those statutes, but it modifies the medical causation input that decision‑makers must consider under them.

Section 11 creates an explicit cross‑instrument interaction rule: if a factor in section 9 refers in relation to a person to an injury or disease that is the subject of another Statement of Principles (made under subsection 196B(2) of the VEA), then the factors in that other Statement apply according to its terms. This imports a mechanism for inter‑Statement consistency and for chaining causation criteria across defined diseases. Decision‑makers must therefore be attentive to the text of other Statements when a given section 9 factor concerns a different injury or disease. The instrument does not define the procedure for identifying or obtaining the other Statement, but it makes clear that cross‑application is required where relevant.

The instrument’s reference to ICD‑10‑AM codes (subsection 7(3)-(4)) clarifies the relationship between diagnostic coding systems and the statutory definition. It records that while RHD attracts particular ICD‑10‑AM codes (I05-I09), the statutory meaning is subsection 7(2). The ICD reference thereby functions as an interpretive aid rather than as a determinative legal test, but it also ties the Statement to Australia’s recognised diagnostic coding regime and specifies the edition and effective date of the ICD‑10‑AM being referenced (Tenth Edition, effective 1 July 2017). This reduces ambiguity where clinical records use ICD coding, while affirming the primary importance of the subsection 7(2) definition.

The instrument effects a repeal of the earlier Statement of Principles concerning RHD No. 19 of 2011 (s 4). That repeal means assessments for claims after the commencement date must use this 2019 Statement, not the 2011 instrument, and any interaction between the new Statement and earlier instruments will be governed by the new text.

Because the Statement is expressly confined to its role within the VEA/MRCA statutory architecture, it does not purport to displace other legal regimes outside that framework (for example, workers’ compensation or general civil litigation). The text contains no provision for direct use in other compensation schemes; any use outside the VEA/MRCA context would be a matter for decision‑makers in other regimes or courts to determine, but the Statement itself is crafted for the VEA/MRCA claims environment.

The instrument records one explicit change to the legal instrument set for rheumatic heart disease: it repeals the earlier Statement of Principles concerning rheumatic heart disease No. 19 of 2011 (Federal Register of Legislation No. F2011L00493) (s 4). The instrument’s own commencement date is specified as 27 May 2019 (s 2). The Statement was dated 26 April 2019 and bears the Common Seal of the Repatriation Medical Authority, affixed at the direction of the Chairperson (prefatory material).

Beyond the explicit repeal of the 2011 Statement, the text does not record any prior amendments or indicate that it is an amendment to another in‑force instrument; it is framed as a fresh Statement (No. 51 of 2019) that takes effect on the commencement date and replaces the 2011 instrument. The instrument includes a Schedule of definitions and sets out its operative sections (1-11) and Schedule 1, but there are no transitional provisions, savings clauses, or express grandfathering arrangements in the text. Practitioners should therefore assume that from the commencement date this 2019 Statement is the authoritative RMA Statement of Principles for rheumatic heart disease within the VEA/MRCA framework.

The instrument also specifies which ICD‑10‑AM edition and effective date it references (Tenth Edition, effective 1 July 2017) when referring to ICD codes (subsection 7(4)). If medical classification systems are updated after that date, the instrument does not itself update or adopt later ICD editions; any such change would require an amendment to the Statement or a new Statement specifying a revised ICD reference.

No further amendment history is recorded in the instrument’s text. It contains no provision authorising delegated amendment or automatic updating. If the RMA or the responsible Minister wished to change the factors, definitions, or the ICD edition referenced, a subsequent instrument under the same statutory power (subsection 196B(2) of the VEA) would be required.

Because the instrument cross‑references other Statements of Principles (section 11), amendment of other Statements may have practical effect on how this Statement operates in particular claims where factors refer to other diseases. Practitioners must therefore monitor amendment activity for any Statements of Principles that are referenced, as those changes will flow through to assessments under section 11.

The text of this Statement of Principles contains no account of judicial decisions, litigation outcomes, or examples of case law. It does not name any cases, nor does it summarise litigation that has interpreted the earlier 2011 Statement or the medical questions set out. The instrument records the RMA’s own view , that there is sound medical‑scientific evidence linking RHD to relevant service , but it does not present or cite any court findings or adversarial determinations (s 8).

Because the instrument is an administrative determination made under subsection 196B(2) of the VEA, litigation that challenges the application of this Statement to a particular claim would arise under the statutory claims and review processes of the VEA and the MRCA. Those processes and any associated judicial review or merits review pathways are not reproduced in the instrument, and no litigation history is recorded here.

Practical implications for litigators and advisers from the absence of recorded litigation in the instrument:

• There is no RMA‑published case law within this instrument to indicate how courts have interpreted the listed factors, the temporal phrases (for example “at least three months”), or the undefined terms (for example “crowded living or working conditions” and “inability to obtain appropriate clinical management”).
• Any litigant or adviser who wishes to challenge an administrative decision that applies this Statement will need to rely on the statutory appeal and review mechanisms available under the VEA/MRCA and on external jurisprudence rather than precedents recorded in this instrument.
• Because section 11 imports other Statements where relevant, litigation risks and interpretive authority may be distributed across multiple Statements of Principles. The instrument does not consolidate or summarise the litigation histories of other Statements; practitioners must check each Statement that becomes relevant in a particular claim.

In short, the Statement itself provides no litigation history; it is a fresh RMA articulation of factors as at April/May 2019 and must be treated as the administrative evidentiary baseline in the absence of any judicial gloss contained in the instrument. Any case law that touches on interpretation, standards of proof, or the application of these specific factors will be found in external sources and is not recited here.

This instrument contains a number of interpretive and procedural features that can be traps for claimants and advisers if overlooked. The following points derive directly from the wording and structure of the Statement.

1. Diagnosis requirement and exclusion

• The statutory meaning of rheumatic heart disease is clinical or echocardiographic documentation that follows acute rheumatic fever (subsection 7(2)(a)). The instrument excludes acute carditis of acute rheumatic fever (subsection 7(2)(c)). Practically, an isolated episode of acute carditis labeled as part of acute rheumatic fever is not the same thing as the chronic rheumatic heart disease contemplated here. A claimant whose records only show acute carditis may fail to meet the definition.

2. ICD codes are not determinative

• Although RHD attracts ICD‑10‑AM codes I05-I09, subsection 7(3) instructs that the meaning is the subsection 7(2) definition. Reliance on ICD coding alone (for example, a hospital discharge code) is not sufficient; the clinical/echocardiographic elements required by 7(2) are the operative legal test. The instrument references a specific ICD edition (subsection 7(4)), so the mere presence of a code is informative but not dispositive.

3. Temporal precision in section 9

• Several factors require specific timing: “at least three months before the clinical onset” for subsections 9(1)-(3); “within the ten years before the clinical worsening” for crowded conditions (subsection 9(6)); “pregnant within the 30 days before the clinical worsening” (subsection 9(7)). These precise timeframes can defeat a claim if documentary evidence does not align. For example, a streptococcal infection recorded two months before onset does not satisfy subsections 9(1)-(2).

4. Broad but undefined social factors

• “Crowded living or working conditions” (subsections 9(3) and 9(6)) is not defined in the instrument. Decision‑makers will need to make an evaluative finding about what constitutes crowding. The lack of a statutory definition introduces interpretive discretion and potential inconsistency. Claimants should compile contextual evidence (accommodation records, service records about billets or barracks, testimonies) to substantiate crowding, because the instrument itself provides no metric.

5. Material contribution and the pre‑existing disease limitation

• Subsections 9(4)-(8) are limited in application by section 10(2): they “apply only to material contribution to, or aggravation of, rheumatic heart disease where the person's rheumatic heart disease was suffered or contracted before or during (but did not arise out of) the person's relevant service.” If the RHD arose out of service, these particular factors are not the appropriate path to establishing material contribution. That distinction matters in claims where onset occurs during service; advisers must categorise claims as arising out of service versus suffered/contracted before/during service.

6. “Inability to obtain appropriate clinical management” is not defined

• Subsection 9(8) admits that inability to obtain appropriate management is a factor, but the instrument does not state what qualifies as “appropriate” or how inability must be demonstrated. Records of referrals, appointment logs, service health clinic notes, correspondence showing denial or lack of access will be critical. The vagueness creates potential for dispute about what standard of care was available and whether the inability was causally material.

7. Death provisions require causal contribution

• Subsection 7(5) extends RHD to include death from a terminal event that was “contributed to by” the person’s RHD. This is a contribution standard: the terminal event must have been contributed to by RHD, not merely coincident with it. The Schedule defines “terminal event” narrowly, listing examples. Proof will require clear medical evidence linking RHD to the proximate or ultimate cause of death.

8. Cross‑referencing to other Statements

• Section 11 requires application of other Statements where a section 9 factor refers to another injury or disease with its own Statement. Failure to identify and apply the referenced Statement could result in incomplete evidence or misapplication of standards. Practitioners must check for and obtain those other Statements.

9. Repeal of the 2011 Statement

• The 2011 RHD Statement has been repealed (s 4). Claims arising after commencement must rely on the 2019 Statement. Advisers accustomed to the 2011 criteria should not assume continuity without checking the new text.

10. RMA’s “view” is recorded but not substantiated in the text

• Section 8 records the RMA’s view that there is sound medical‑scientific evidence for the connection, but the Statement does not reproduce that evidence. Where a decision‑maker or tribunal requires the underlying science, parties may need to supply the medical literature or expert reports; the Statement itself will not supply it.

These features demonstrate that the instrument is a tightly framed legal tool with several underlying factual and temporal thresholds. Claim preparation must anticipate precise documentary and evidentiary requirements, and advisers should not rely solely on diagnostic coding or generic medical summaries.

Complying with the Statement means ensuring that a claim under s 120A of the VEA or s 338 of the MRCA is supported by evidence that establishes at least one of the factors in section 9 and that the person’s rheumatic heart disease meets the instrument’s definitional requirements (subsection 7(2)). The following practical steps, tied to the instrument’s text, will assist claimants and advisers.

1. Establish the clinical/echocardiographic diagnosis

• Produce clinical notes and echocardiogram reports that document cardiac disease consistent with subsection 7(2)(a). Ensure reports describe valvular stenosis or regurgitation, and where appropriate note scarring, deformity or morphological change, chronic rheumatic myocarditis, or chronic rheumatic pericarditis (subsection 7(2)(b)). If the diagnosis relies on a label in hospital records, corroborate it with the actual imaging or clinician’s report because ICD codes alone will not substitute for clinical documentation (subsections 7(2) and 7(3)).

2. Match evidence to one or more section 9 factors

• For subsection 9(1): provide documentation of acute rheumatic fever occuring at least three months before the clinical onset of RHD. This may include hospital discharge summaries, diagnostic records, or clinician letters with dates.
• For subsection 9(2): provide microbiological, clinical, or laboratory evidence of group A beta‑haemolytic streptococcal infection of the skin or pharynx at least three months before clinical onset, including throat swabs, GP records, or specialist notes.
• For subsection 9(3): assemble contemporaneous evidence of crowded living or working conditions at least three months before onset. Service accommodation records, barracks layouts, orders, or witness statements that describe numbers and density of occupants will be relevant.
• For subsections 9(4)-(8) (material contribution/aggravation): show the timing and nature of prior RHD and then document the specified events before clinical worsening (acute rheumatic fever, streptococcal infection, crowded conditions within ten years, pregnancy within 30 days, inability to obtain appropriate clinical management). In particular, for subsection 9(7) produce pregnancy records and correlate the dates with the clinical worsening of RHD.

3. Attend to timing precision

• Strictly align documentary evidence with the time windows the instrument specifies: “at least three months” (subsections 9(1)-(3)), “within ten years” (subsection 9(6)), and “within the 30 days” (subsection 9(7)). Where dates are approximate, provide ancillary evidence (e.g. employment or deployment records) to narrow timing.

4. Deal with undefined concepts proactively

• For “crowded living or working conditions” and “inability to obtain appropriate clinical management”, provide contextual and documentary evidence: photographs, accommodation rosters, orders assigning billets, medical clinic logs, referral documentation, correspondence about access to care, notes showing cancelled or unavailable appointments, or correspondence demonstrating inability to obtain specialist or surgical care.

5. Where factors refer to other diseases, obtain and apply the other Statements

• If a factor points to an injury or disease covered by another Statement of Principles, obtain that Statement and ensure the evidence satisfies its factors, because section 11 requires application of the other Statement’s terms.

6. Address death claims carefully

• For death claims, compile medical records and the death certificate; ensure expert medical opinion links RHD to the terminal event (as defined in the Schedule). Subsection 7(5) requires that the terminal event was “contributed to by” RHD, so an opinion explaining causal contribution is necessary.

7. Prepare medical expert reports that map explicitly to the Statement

• Instruct medical experts to address each relevant subsection in their reports. Experts should state whether the clinical or echocardiographic criteria are met, whether any of the section 9 factors are present, and how those factors temporally and causally relate to the person’s service. Experts should also address whether the RHD contributed to any terminal event in the case of a death claim.

8. Cross‑check against the effective ICD edition if relying on coded records

• If hospital or administrative records rely on ICD‑10‑AM coding, note that the instrument references the Tenth Edition effective 1 July 2017 (subsection 7(4)). Use the coding as supplementary evidence but not as a substitute for the clinical/echocardiographic documentation required by subsection 7(2).

9. Record the relation to “relevant service”

• Ensure evidence links the identified factor(s) to the person’s relevant service as defined in Schedule 1. For example, if relying on crowded conditions during a deployment, provide service records showing deployment dates and locations that match the timeframe required by the applicable subsection (see Schedule 1 and s 10).

10. Anticipate cross‑claims and overlapping pathologies

• If there is an overlapping condition that itself has a Statement of Principles, gather and present evidence relevant to that Statement as well. Section 11 requires that the other Statement’s factors be applied where a section 9 factor refers to that disease.

Advisers should prepare evidence packages that map facts and records to each element the Statement requires. Because the Statement does not itself provide procedures for claim submission or appeal, comply also with the procedural requirements of the VEA and MRCA when lodging claims. The RMA’s statement of basis in section 8 does not substitute for expert evidence; where clinical issues are complex, obtain specialist cardiology and infectious disease reports that explicitly address the Statement’s factors and timeframes.