Statement of Principles concerning rotator cuff syndrome (Balance of Probabilities) (No. 110 of 2022)

The SoP centres on three core legal-medical concepts: the defined medical condition (rotator cuff syndrome), a set of factual or clinical factors which, if established, satisfy the RMA’s view of service connection on the balance of probabilities, and the relationship of those factors to the person’s relevant service. Each of these concepts is defined and confined by text in this instrument.

1. Definition of the condition (s 7(2)-(4), Schedule 1): Rotator cuff syndrome is defined as a clinically symptomatic inflammatory or degenerative disorder of the rotator cuff or the long head of biceps and their associated bursae. The SoP lists included diagnoses (for example calcifying tendonitis, rotator cuff tear, impingement syndrome, tendinopathy) and explicitly excludes adhesive capsulitis. The instrument notes typical clinical characteristics (persistent shoulder pain and tenderness, worse with overhead abduction) and links the textual definition to ICD‑10‑AM codes M75.1, M75.2, M75.3, M74.4 or M74.5 for administrative classification (s 7(2)-(4)).

2. Factors that must exist (s 9): The RMA requires at least one of the listed factors to be present to say, on the balance of probabilities, that rotator cuff syndrome or death from it is connected with the circumstances of relevant service. The factors include: recent injury to the affected shoulder (within 30 days before clinical onset) (s 9(1)); prior surgery on the affected shoulder (s 9(2)); combinations of repetitive/sustained or forceful activities with quantified minimum exposure thresholds (s 9(3)-(5)); long-term exposures such as 4,000 hours of overhead activity in 10 years (s 9(4)); medical conditions associated with tendon disease (dialysis‑related amyloidosis, diabetes mellitus, dyslipidaemia, gout) (s 9(6), (13)-(15), (22), (28)-(30)); specified autoimmune diseases involving the shoulder (s 9(11), (27)); use of specific drugs (glucocorticoids according to Table 1 and equivalences in Table 2, and fluoroquinolones within 60 days) (s 9(15), (16), (31), (32)); anatomical narrowing of the subacromial space and joint instability or prior dislocation/subluxation (s 9(8)-(9)); infection of the subacromial/subdeltoid bursa (s 9(10), (26)); regular weight-bearing use of upper limbs for at least one year (s 9(7), (23)); and inability to obtain appropriate clinical management (s 9(33)). The identical factors for “clinical worsening” are repeated in subsections 9(17)-9(33) with equivalent wording.

3. Relationship to service (s 10): Section 10(1) requires that the existence of any factor in s 9 must be related to the person’s relevant service. Section 10(2) imposes a narrower application for the factors in subsections 9(17)-9(33): those factors apply only to material contribution to, or aggravation of, rotator cuff syndrome where the person’s syndrome was suffered or contracted before or during the relevant service but did not arise out of the relevant service. In short, the SoP distinguishes between factors that may establish service connection for onset and those that operate only as aggravating or contributing causes where the condition pre‑existed service.

4. Cross‑reference mechanism (s 11): If a factor listed in s 9 refers to an injury or disease that itself is covered by a separate SoP, then the factors in that other SoP apply in accordance with its terms. That ties this SoP into the RMA’s broader suite of Statements of Principles and allows the specialised treatment of other injuries/diseases to be invoked where relevant.

5. Dictionary/definitions (Schedule 1): Several technical terms are defined and set quantitative thresholds. Examples include “forceful activities” (lifting/carrying >3 kg or >1 kg more than 10 times per hour), “injury to the affected shoulder” (symptoms within 24 hours and lasting at least 7 days unless promptly and specifically-treated), “dyslipidaemia” (specific laboratory thresholds or regular lipid-lowering therapy), and the glucocorticoid dosing equivalence tables (Tables 1 and 2 in Schedule 1). The Schedule also defines “terminal event” for death claims and sets out the list of specified autoimmune diseases.

The SoP therefore functions as a specialised, prescriptive evidentiary tool: it converts a range of clinical findings, quantified exposures and prior diagnoses into discrete factors that may, if related to relevant service, establish service connection on the balance of probabilities (s 8, s 9, s 10).

The instrument applies to persons making claims to which section 120B of the Veterans’ Entitlements Act 1986 (VEA) or section 339 of the Military Rehabilitation and Compensation Act 2004 (MRCA) applies (s 5). It is intended to be used in the assessment of service connection for rotator cuff syndrome and death from rotator cuff syndrome for individuals falling within those statutory schemes.

Who decides and uses the instrument

• The RMA is the decision-maker that determined and issued the Statement (s 3 and front matter). The SoP is therefore an instrument produced by the RMA to guide determinations under the VEA and MRCA frameworks.
• The instrument’s explicit linkage to s 120B VEA and s 339 MRCA (s 5) means that decision-makers applying those provisions will use the SoP to assess whether rotator cuff syndrome is connected with relevant service. The text of the SoP itself does not name administrative agencies beyond the RMA or specify case management arrangements.

Categories of affected persons

• Veterans and former or current members of the Forces who allege rotator cuff syndrome arising in connection with their service, or who seek to establish that the condition was materially contributed to or aggravated by service, will be directly affected because the SoP specifies the factors that can establish a connection (s 7-10).
• Persons seeking compensation for death where rotator cuff syndrome contributed to a terminal event are covered, because the SoP explicitly includes death from rotator cuff syndrome as within its scope (s 7(5) and Schedule 1 terminal event definitions).
• Medical practitioners, occupational health assessors and medico-legal experts preparing evidence for claims will be affected because the SoP sets the clinical definitions, temporal windows and quantitative thresholds that evidence should address (s 7, s 9, Schedule 1).

Geographic and temporal limits

• The SoP itself is an Australian instrument. It commenced on 21 November 2022 (s 2) and repealed the earlier SoP No. 101 of 2014 (s 4). It applies when the claim falls within the specified sections of the VEA or MRCA (s 5).

Practical consequences for claimants

• Claimants seeking to establish a connection will need to adduce evidence that at least one of the listed factors existed and was related to their relevant service (s 9, s 10(1)). For contribution or aggravation where the condition pre-existed service, the narrower application and the requirement that the condition “did not arise out of” service will influence which factors are relevant (s 10(2), s 9(17)-(33)).
• Because several factors require quantitative proof (for example, 160 hours within 210 days; 4,000 hours within 10 years; 400 hours at 20 kg within 10 years) or clinical time windows (for example, injury within 30 days of onset; fluoroquinolone within 60 days), both claimants and medical advisers must assemble documentary evidence that maps to those thresholds (s 9; Schedule 1).

Excluded persons or conditions

• The SoP excludes adhesive capsulitis of the shoulder from the definition of rotator cuff syndrome (s 7(2)(c)), so claims based solely on adhesive capsulitis would not fall under this SoP’s factors.
• The SoP’s factors have specified applicability limits (for example, some factors apply only to aggravation or material contribution where the condition pre-existed), so not all listed factors are available for every factual matrix (s 10(2)).

This instrument does not create new duties in a regulatory sense such as criminal offences or administrative penalties. Instead, it prescribes evidentiary criteria that must be considered and satisfied for a finding that rotator cuff syndrome (or death from it) is connected with relevant service. The practical duties and rights that the SoP establishes arise from its use in the VEA and MRCA decision-making frameworks.

Duties and obligations implied for decision-makers and medical assessors

• Use the SoP as the authoritative list of factors which, if established and related to relevant service, satisfy the RMA’s view that service connection exists on the balance of probabilities (s 8, s 9). The instrument is made under the RMA’s statutory authority (s 3) and is intended to be applied in determinations under the referenced statutory provisions (s 5).
• When a factor listed in s 9 refers to an injury or disease that itself has an SoP, apply that other SoP in accordance with its terms (s 11). This imposes a duty to consult and apply cross-referenced SoPs rather than treating the factor in isolation.

Duties that fall on claimants (practical evidentiary duties)

• Establish that at least one of the enumerated factors in s 9 existed and was related to their relevant service (s 9, s 10(1)). The SoP requires linkage of the factor to the person’s service; the instrument itself does not establish automatic connection without evidence of relation to service.
• For factors imposing quantification (for example hours of activity), provide evidence that satisfies the stated thresholds (s 9(3)-(5), (19)-(21)). Evidence might include employment records, task logs, duty statements, sporting histories or other contemporaneous documentation that can be aligned with the temporal windows stated in the SoP.
• For drug-related factors, supply clinical records or pharmacy dispensing records that document the prescribed drugs and timing relative to onset or worsening; the Schedule sets out dose and duration criteria for glucocorticoids and equivalence conversions for alternative steroids (Schedule 1, Tables 1-2).

Rights implicit in the SoP’s procedural role

• Persons subject to an adverse decision that employs this SoP have the right to have the decision-maker consider the SoP’s listed factors, and, where a listed factor refers to another SoP, to have that other SoP applied (s 11). The SoP therefore informs the correct legal-medical yardstick to be applied.
• The SoP provides claimants with a transparent statement of the factual and clinical criteria that will be taken into account in assessing service connection. This is a right to predictability: the thresholds and temporal windows are published (s 9; Schedule 1).

Limits and non-rights

• The SoP does not itself authorise payment of benefits, create entitlements, nor set review or appeal rights. Those procedural rights and relief mechanisms are governed by the VEA and MRCA provisions to which the SoP applies; the instrument merely supplies the medical-evidentiary yardstick (s 5).
• The SoP does not impose positive duties on third parties (for example employers or medical practitioners) to produce records; it sets out what must be shown in a claim context.

Practical interpretive duties

• Decision-makers must determine whether the person’s clinical onset or worsening of rotator cuff syndrome is established and, if so, whether any listed factor existed in the required time before that onset or worsening (ss 7 and 9). Several definitions in Schedule 1 require precise clinical timing (for example, “injury to the affected shoulder” requires symptoms within 24 hours and persistence for at least 7 days unless certain treatments occurred; Schedule 1).
• For cases that involve pre-existing conditions where the condition did not arise out of service, the decision-maker must apply the narrower aggravation/material contribution rules for subsections 9(17)-9(33) (s 10(2)).

In short, the SoP creates an obligation on tribunal/administrative decision-makers to use its listed factors as the basis for medical causation assessments under the linked statutory provisions, and places a practical duty on claimants to produce evidence that aligns with the SoP’s defined factors, quantitative thresholds and timing requirements.

The Statement of Principles instrument itself does not create criminal offences, pecuniary penalties or an enforcement regime. Its purpose is evidentiary and administrative: to set out factors that the Repatriation Medical Authority considers, on the balance of probabilities, relate rotator cuff syndrome or death from it to relevant service (s 8). There are no provisions in the text of the SoP that prescribe sanctions, fines or enforcement actions for non‑compliance, nor does the instrument delegate enforcement functions to agencies.

How the SoP operates in administrative decision-making

• The SoP functions as an evidentiary framework that decision-makers exercising powers under the VEA and MRCA will apply when determining service connection for rotator cuff syndrome (s 5). The text tells users which factors the RMA accepts as capable of establishing connection, and sets thresholds and time windows; it does not, however, specify enforcement mechanisms or penalties for actors who fail to produce evidence.
• The RMA’s finding (s 8) , that on the sound medical‑scientific evidence available it is more probable than not that rotator cuff syndrome can be related to relevant service , is a normative evidentiary conclusion, not an enforcement direction. The SoP supplies criteria but leaves substantive determinations, procedural steps and any subsequent remedies to the statutory decision-making processes under the VEA and MRCA.

Absence of sanctioning provisions

• Given the absence of penal provisions, failure to meet a listed factor will not itself attract a statutory penalty under this instrument; the consequence is administrative , inability to establish service connection under the RMA’s SoP and hence potential adverse outcome in a claim. The instrument does not establish review rights, appeal pathways, or time limits; those are matters for the VEA and MRCA and associated regulations and procedures.

Potential enforcement by implication

• While the SoP does not create penalties, its use by decision-makers can have practical material consequences for claimants: an inability to show a listed factor will likely affect entitlement outcomes in claim determinations. Therefore the “enforcement” effect is indirect: adherence to the SoP’s criteria is essential to successful claims, and administrative decision-makers will apply the SoP when adjudicating claims brought under the specified statutory provisions (s 5).

Summary

• The instrument is an evidentiary tool rather than a penal instrument. It prescribes what must be shown for service connection determinations but contains no independent enforcement or penalty provisions. Any enforcement or remedial consequences follow from the VEA and MRCA administrative processes that use this SoP, not from the SoP itself.

The SoP is expressly linked to specific statutory provisions and to other Statements of Principles. Its interaction with other legal instruments and the administrative system is governed by its own cross-references and by the fact that it is made under the VEA.

Statutory linkage (s 5)

• The instrument applies to claims to which section 120B of the VEA or section 339 of the MRCA applies (s 5). That is the primary statutory interaction: the SoP is a tool to be used when adjudicating claims under those provisions. The SoP does not itself restate or modify the substantive eligibility, remedy or procedural provisions of those Acts; it supplies medical causation criteria to be used within those statutory frameworks.

Authority under the VEA (s 3)

• The SoP is made under subsection 196B(3) of the VEA (s 3). This shows that the RMA’s power to determine Statements of Principles is a function provided by the VEA; the SoP must therefore be read as an exercise of that delegated statutory power. The instrument does not amend the VEA or the MRCA; it operates within their decision-making processes.

Cross-reference to other Statements of Principles (s 11)

• Section 11 provides a direct interface: if a factor in this SoP refers to an injury or disease that is itself covered by another SoP made under subsection 196B(3) of the VEA, then the factors in that other SoP apply according to its own terms. This means that the RMA anticipates overlap between SoPs and provides that a separate, potentially more specialised SoP will govern the details where there is direct reference. Practically, decision-makers must identify whether any listed factor invokes another SoP and then apply that other SoP’s factors "as in force from time to time" (s 11).

Classification systems and coding (s 7(3)-(4))

• The SoP recognises ICD‑10‑AM coding (s 7(3)-(4)): while the textual definition is definitive for the SoP’s application, the instrument refers to specific ICD‑10‑AM codes (M75.1, M75.2, M75.3, M74.4, M74.5) and specifies the edition and effective date of the Australian modification. This creates an administrative link with the medical classification system used in the Australian health system for coding diagnoses and ensures compatibility with clinical records that carry these codes.

Relevance to death claims and broader medical causation (s 7(5), Schedule 1)

• For death claims, the SoP links rotator cuff syndrome to terminal events and provides a defined list of terminal events (Schedule 1), such as pneumonia, respiratory failure, cardiac arrest, circulatory failure or cessation of brain function. Where death is alleged to have been contributed to by rotator cuff syndrome, the SoP expects decision-makers to consider the defined terminal events as part of the causation chain.

No express interactions with criminal law, workers compensation or private insurance

• The instrument contains no provisions that refer to workers compensation regimes, criminal law, or private health/insurance entitlements. It stands as a statutory instrument for the VEA/MRCA purposes. Where overlap occurs in practice (for example, a veteran also making a workers compensation claim), the SoP does not provide rules for primacy or coordination; those matters would be resolved under the other statutory regimes and administrative processes, which are not addressed in this text.

Temporal and amendment interactions (s 4)

• The SoP repeals the earlier SoP No. 101 of 2014 (s 4). That establishes a temporal interaction: the current SoP supersedes the older instrument for applicable claims from its commencement date. Section 11’s reference to other SoPs “as in force from time to time” indicates that SoPs are dynamic and that decision-makers should apply the current version of any referenced SoP.

Summary

• The SoP interacts directly with the VEA and MRCA through its statutory basis (s 3) and applicability (s 5), cross-references other RMA SoPs where factors overlap (s 11), and aligns administratively with ICD-10-AM coding (s 7(3)-(4)). It is an administrative-evidentiary instrument intended for use within the compensatory/rehabilitation decision-making frameworks of those Acts, not a freestanding statute with broad legal effects beyond those schemes.

This Statement of Principles document itself contains limited internal history. The instrument identifies its own name, date and commencement, and specifies the repeal of the prior SoP for the same condition.

Key amendment and issuance events recorded in the instrument

• Date of determination: The front matter records that the RMA determined this Statement of Principles on 21 October 2022 (front matter).
• Commencement: The instrument commences on 21 November 2022 (s 2).
• Repeal: It expressly repeals “The Statement of Principles concerning rotator cuff syndrome No. 101 of 2014 (Federal Register of Legislation No. F2014L01379), made under subsections 196B(3) and (8) of the VEA” (s 4). That is the only explicit repeal or amendment action recorded.

Implications of the repeal

• The repeal of the 2014 SoP is absolute in the terms used: the current instrument replaces the previous SoP for rotator cuff syndrome. The instrument does not include transitional provisions addressing claims that were lodged or determined under the earlier SoP before the repeal date; any transitional application would be governed by the VEA, MRCA and administrative practice but is not set out in this text.

Tables and definitional updates

• The Schedule’s Tables (Table 1 and Table 2) supply detailed dosage, route, duration and proximity parameters for glucocorticoid exposure, and equivalence conversions for various glucocorticoid drugs. The Schedule therefore contains specific substantive content that may constitute the principal area likely to be amended in future updates should medical evidence or pharmacology guidance change. The instrument itself does not record any prior versions of those Tables.

Reference to “as in force from time to time” (s 11)

• Section 11’s use of the language “apply in accordance with the terms of that Statement of Principles as in force from time to time” indicates the RMA expects SoPs to be dynamic documents that may be updated. The current instrument does not itself list prior amendments or subsequent changes beyond the 2014 repeal, but signals that cross-referenced SoPs could change over time and that users should consult the current versions.

No recorded schedule of revisions within the document

• The instrument does not contain a revision history table, nor does it record incremental amendments between 2014 and 2022 other than the repeal. For authoritative tracking of future amendments, users will need to consult the Federal Register of Legislation or the RMA’s published instruments (the document itself references the Federal Register number of the repealed 2014 SoP).

Practical note for practitioners

• Given that the SoP replaces an earlier instrument, practitioners should ensure that the dates of onset, clinical worsening, and the date of lodgement/decision are aligned with the appropriate SoP version in force at the time of determination. Because the instrument does not set out transitional provisions, administrative practice and the governing Acts will determine whether a claim initiated under the earlier SoP should be re-assessed under this instrument; the practitioner should verify the applicable SoP at the time of decision-making.

The instrument contains no discussion of case law, judicial review decisions, or litigation concerning the Statement of Principles itself. It does not cite any judicial decisions, nor does it identify any precedent‑setting determinations or disputes relating to No. 110 of 2022. The document therefore provides no internal litigation history.

Implications of the silence

• Absence of litigation references in the SoP does not mean there has been no litigation in practice concerning rotator cuff syndrome claims under the VEA or MRCA; it only means that this instrument does not record such matters. The SoP is a primary RMA instrument and its legal application and interpretation can be the subject of administrative review, merits review or judicial review under the relevant Acts, but the instrument contains no textual record of such proceedings.

What the instrument does provide for adjudicators and reviewers

• The SoP supplies the RMA’s contemporaneous view of the medical-scientific evidence and the specific factors that the RMA accepts as capable of establishing service connection (s 8 and s 9). Where disputes arise about the application or interpretation of those factors, tribunals or courts (outside the instrument) will need to apply the SoP as an administrative instrument in their review of decision‑maker reasoning. The SoP itself does not anticipate or prespecify the scope of judicial or administrative review.

Practical guidance for litigators and reviewers encountering disputes

• In the absence of a litigation history in the text, lawyers and reviewers should: (a) identify the exact version of the SoP applicable to the decision under review (the instrument commenced 21 November 2022, s 2); (b) map the claimant’s evidence to the specific factors and defined terms in s 9 and Schedule 1; and (c) ascertain whether any cross-referenced SoP applies under s 11. Because the SoP contains definitional thresholds, disputes will often turn on whether evidence establishes those thresholds (for example, the timing requirements in the definition of “injury to the affected shoulder” in Schedule 1).

Limitations for research or case law review

• Because the instrument does not include litigation history, researchers must consult external sources (for example, administrative tribunal records, Federal Court judgments, or internal agency decisions) to identify how courts and tribunals have interpreted or applied the SoP in contested claims. The SoP itself should be treated as the RMA’s policy/medical statement, not as a compendium of judicial responses.

This SoP contains numerous technical requirements and defined thresholds that create potential pitfalls for claimants, clinicians and decision-makers. The following practical issues are grounded in the instrument’s text and should be considered when preparing or assessing claims.

1. Onset versus worsening: two separate factor lists (s 9(1)-(16) and s 9(17)-(33)) are used. Subsections 9(1)-(16) operate in relation to clinical onset; subsections 9(17)-(33) are the corresponding list for clinical worsening. Section 10(2) further limits the latter list to material contribution or aggravation where the person’s rotator cuff syndrome was suffered or contracted before or during relevant service but did not arise out of service. Practitioners must therefore be precise in establishing whether the claimant is asserting onset during/relevant to service, or aggravation during service of a pre‑existing condition (ss 9, 10).

2. Temporal proximity windows: certain factors require short proximity to onset or worsening. For example, an injury to the affected shoulder must occur within 30 days before clinical onset or worsening (s 9(1), 9(17); Schedule 1 definition of “injury to the affected shoulder”). Fluoroquinolone use must be within 60 days prior to onset or worsening (s 9(16), 9(32)). Failure to document these proximity windows precisely will be fatal to reliance on the factor.

3. Quantified exposure thresholds: several factors set precise quantitative thresholds that must be proved. Examples include:

   • 160 hours within 210 consecutive days of repetitive/sustained or forceful activities that have not ceased more than 30 days before onset/worsening (s 9(3), 9(19)).
   • 4,000 hours within 10 years of repetitive/sustained overhead activity (s 9(4), 9(20)).
   • 400 hours within 10 years of lifting or carrying loads of at least 20 kilograms with the affected upper limb (s 9(5), 9(21)). Evidence must be marshalled to match these thresholds; vague statements of “frequent lifting” or “regular overhead work” will not match the numerical requirements.

4. Definition of “forceful activities” and small thresholds: Schedule 1 defines forceful activities as equivalent to lifting/carrying more than 3 kilograms, or lifting/carrying >1 kg in excess of 10 times per hour. That is a low threshold and may bring many everyday tasks within “forceful activities,” but the claimant still must prove duration and frequency requirements in the SoP (Schedule 1; ss 9(3), 9(19)).

5. Injury definition requirements: “Injury to the affected shoulder” requires onset of specific symptoms within 24 hours of the injury and persistence for at least 7 days, unless particular medical interventions occurred (Schedule 1). The definition includes rules for masking by analgesia or unconsciousness. Practitioners should ensure contemporaneous records document the immediate symptom onset and duration.

6. Ambiguity in Table 1 “NS” entries: Table 1 for glucocorticoid dosing contains “NS” (not specified) entries for some duration or proximity cells and uses abbreviations (IV, IM, O, NS). The Schedule lists abbreviations and the presence of NS indicates the RMA did not specify a duration or proximity in that cell. This creates interpretive risk: where a cell is NS, decision-makers will need to consider whether the lack of specification permits broader interpretation or requires additional supporting evidence. Practitioners must be ready to justify why a particular steroid exposure meets the SoP despite “NS” entries (Schedule 1, Table 1; Table abbreviations).

7. Equivalence conversions for steroids: Table 2 lists dose efficacy equivalence values for different glucocorticoid drugs. Accurate pharmacological conversion is therefore required to determine whether a non‑prednisolone drug meets the prednisolone-equivalent thresholds in Table 1. Evidence should include dose, route and timing (Schedule 1, Tables 1-2).

8. “Inability to obtain appropriate clinical management” as a factor (s 9(33)): this is broad and may be difficult to establish. The SoP does not define the scope or required evidentiary threshold for this factor, so claimants must document attempts to access care, barriers encountered and the clinical consequences. Absence of a definition increases potential for disputes about what evidence suffices.

9. Cross-referenced SoPs (s 11): where a factor refers to another injury/disease that has its own SoP, that other SoP’s factors apply “as in force from time to time.” Practitioners must check the current version of any cross-referenced SoP and ensure evidence satisfies that SoP’s criteria. Failure to do so can lead to overlooked relevant factors or misapplication of criteria.

10. Side-specific requirements: the SoP repeatedly uses “affected shoulder” and “affected side.” Evidence needs to identify laterality. Aggregated or non‑side-specific evidence may not meet the SoP’s requirements.

11. Death claims and terminal events: when death is alleged to have been contributed to by rotator cuff syndrome, the SoP includes it as part of “death from rotator cuff syndrome” if death resulted from a terminal event or condition which rotator cuff syndrome contributed to (s 7(5)). Schedule 1 lists examples of terminal events. Demonstrating causal contribution to a terminal event requires mapping clinical pathways , this may be challenging where rotator cuff syndrome is remote from the proximate cause of death.

12. Repeal of the 2014 SoP (s 4): practitioners dealing with claims spanning the repeal date must be alert to which SoP applied at the time of the decision. The instrument contains no transitional rules in the text itself.

13. “Relevant service” linkage (s 10(1)): every listed factor must be related to relevant service. The SoP does not define “related to relevant service” beyond the statutory context; practitioners should ensure they present evidence of the relationship between the factor and the period/location of relevant service.

In sum, the SoP’s granular thresholds, definitional detail and proximity windows create a risk profile where documentary precision, contemporaneous clinical records, quantified exposure evidence and attention to definitional language are decisive. Failure to match the SoP’s technical requirements is a common “gotcha.”

This section outlines practical steps and documentary evidence that follow directly from the SoP’s text and Schedule. The aim is to translate the SoP’s technical criteria into an evidence checklist and an approach to presenting a claim where rotator cuff syndrome or death from rotator cuff syndrome is alleged to be connected with relevant service.

1. Establish the correct SoP and applicability

   • Confirm the SoP in force when the decision will be made (this instrument commences 21 November 2022 and repeals the 2014 SoP, s 2, s 4). Ensure the claim is one to which s 120B VEA or s 339 MRCA applies (s 5).

2. Map the clinical condition to the SoP’s definition

   • Ensure the diagnosis fits the textual definition in s 7(2). If the condition is adhesive capsulitis only, the SoP excludes it (s 7(2)(c)). Note ICD‑10‑AM codes that correspond to the SoP (M75.1, M75.2, M75.3, M74.4, M74.5) but rely on the textual definition for substantive application (s 7(3)-(4)).

3. Identify whether the claim is for onset or for clinical worsening

   • Determine whether the claim alleges clinical onset during or after service, or material contribution/aggravation of a pre‑existing condition. Apply the correct list of factors (s 9(1)-(16) for onset; s 9(17)-(33) for worsening) and note s 10(2)’s restriction on the latter where the condition “did not arise out of” relevant service.

4. Demonstrate at least one listed factor and relate it to relevant service

   • Select the most readily provable factor(s) from s 9. Provide documentary proof that the factor existed and that it was related to relevant service (s 10(1)). For each factor chosen, collect the following evidence types as applicable.

5. Evidence checklist mapped to factors (examples grounded in Schedule and s 9)

   Exposure and activity factors

   • Repetitive/sustained/forceful activity (s 9(3), 9(4), 9(19), 9(20)): obtain duty statements, rosters, task logs, employer records, statements from supervisors/colleagues, or sporting participation records. Quantify hours: for 160 hours in 210 days show task duration and frequency; for 4,000 hours in 10 years show cumulative exposure calculations.
   • Lifting/carrying >=20 kg for 400 hours in 10 years (s 9(5), 9(21)): provide evidence of loads handled and time spent, including weights lifted in training, operational tasks or employment duties.
   • Forceful activities definition (Schedule 1): where relying on force, document that tasks exceeded >3 kg or involved lifting >1 kg more than 10 times per hour. Evidence can include task descriptions and frequency measures.

   Trauma and surgical factors

   • Injury to the affected shoulder within 30 days before onset/worsening (s 9(1), 9(17); Schedule 1): secure emergency department notes, GP summaries, imaging, treatment records that show symptom onset within 24 hours of injury and persistence for at least 7 continuous days or records of specified interventions (immobilisation, injection, surgery). If analgesia masked pain, obtain hospital notes documenting return of symptoms on regaining consciousness or cessation of analgesia.
   • Surgical procedure on the affected shoulder before onset/worsening (s 9(2), 9(18)): obtain operation notes, discharge summaries, anaesthetic records and dates.

   Medical comorbidities and lab evidence

   • Dialysis-related amyloidosis (s 9(6), 9(22)): provide dialysis history showing long‑term haemodialysis or peritoneal dialysis and any relevant imaging or biopsy evidence.
   • Diabetes mellitus, gout (s 9(13), 9(28)): supply diagnostic records, laboratory tests (e.g. HbA1c), pharmacist records, and specialist letters.
   • Dyslipidaemia (s 9(14), 9(30); Schedule 1): produce lipid panel results that meet the specified thresholds (for example LDL >4.0 mmol/L; HDL <1.0 mmol/L; triglycerides ≥2.0 mmol/L; total cholesterol >5.5 mmol/L) or evidence of regular lipid‑lowering drug administration.
   • Specified autoimmune diseases (s 9(11), 9(27); Schedule 1): supply rheumatology diagnoses and clinical notes confirming involvement of the shoulder joint or associated bursae.

   Drug exposure

   • Glucocorticoid use (s 9(15), 9(31); Schedule 1, Tables 1-2): obtain prescription records, pharmacy dispensing records, hospital drug charts showing route (IV/IM/oral/injection into tendon region), dose and duration. Where a drug other than prednisolone was used, perform equivalence conversion per Table 2 and show that the equivalent prednisolone dose meets Table 1 thresholds. Note proximity requirements in Table 1 (for example injection into tendon region requires ≥1 injection within 2 weeks of onset/worsening).
   • Fluoroquinolone antibiotic use (s 9(16), 9(32)): provide prescription or dispensing records showing specific fluoroquinolone exposure within 60 days before clinical onset/worsening.

   Imaging and anatomical evidence

   • Anatomical narrowing of the subacromial space (s 9(8), 9(24); Schedule 1): supply imaging reports (x‑ray, MRI) demonstrating acquired reduction of the subacromial space, and if possible evidence of causes such as osteophytes, malunited fractures, foreign materials from prior surgery.

   Infection and local disease

   • Infection of the subacromial/subdeltoid bursa (s 9(10), 9(26)): obtain microbiology, operative notes, imaging and specialist letters documenting bursal infection at the time of onset/worsening.

   Weight-bearing upper limb use

   • Regular use of upper limbs for weight‑bearing for at least 1 continuous year (s 9(7), 9(23)): collect clinican statements, care records (for transfers from wheelchair), mobility aid usage logs, or occupational records showing prolonged upper limb weight‑bearing.

   Inability to obtain appropriate clinical management

   • Document attempts to access care: records of referrals, appointment cancellations, denial of services, geographic or service barriers, and evidence of resulting clinical deterioration (s 9(33)).

   Death claims

   • Terminal event causation (s 7(5); Schedule 1 terminal event list): assemble death certificate, hospital records, clinical notes showing causal contribution of rotator cuff syndrome to a terminal event (for example where rotator cuff syndrome led to immobility and subsequent pneumonia).

6. Address linkage to relevant service

   • For each factor, document how and when it related to the person’s relevant service (s 10(1)). This may include service medical records, deployment/task records, training logs, and statements linking the activity or exposure to the service period.

7. Check cross-referenced SoPs

   • If any factor refers to an injury/disease covered by another SoP (s 11), identify that SoP, obtain the current version “as in force from time to time,” and ensure supporting evidence also meets that SoP’s factors.

8. Prepare clinical and medico-legal reports that map evidence to SoP language

   • Request that treating practitioners or medico-legal experts explicitly address the SoP’s factors, giving opinions that link timing, dosage, frequency and side-specific findings to the relevant SoP paragraphs and Schedule definitions.

9. Quantify exposures carefully

   • Where the SoP requires numerical thresholds (hours, weights), prepare calculations and supportive documentation to show how the thresholds are met. Where hours are estimated, provide a clear methodology and corroborative evidence (for example rosters, timesheets, or affidavits).

10. Account for “NS” entries in Table 1

• When relying on steroid exposure where Table 1 includes “NS” (not specified), ensure contemporaneous prescribing records and clinician explanations are available to address any interpretive gaps. Provide a clear statement of the exact doses, route and timing and why they meet the SoP’s intent.

11. Ensure side-specific clinical detail

• Always identify the affected shoulder and side. Imaging and examination findings should be side-specific to match the SoP’s repeated references to the “affected shoulder” or “affected side.”

12. Record contemporaneous symptom onset and persistence

• For injuries, ensure records state symptom onset within 24 hours and persistence for at least 7 days, or record the relevant specified medical interventions that replace the 7‑day requirement (Schedule 1).

13. Anticipate disputes and prepare for alternative factors

• If one factor is borderline or lacks documentation, prepare alternative factors or a combination of factors. The SoP requires only at least one factor to exist (s 9), but having multiple supportive pieces of evidence strengthens the claim.

14. Keep versions and dates aligned

• Given the repeal of the 2014 SoP (s 4), ensure that the version of the SoP presented with the claim is the one in force at the time of decision-making. Document the dates when exposures occurred relative to service and relative to the SoP commencement date.

By following this approach, practitioners and claimants will ensure that evidence is specifically oriented to the SoP’s expressed criteria and thresholds, improving the ability of adjudicators to apply the instrument’s factors under the VEA and MRCA statutory frameworks.