SoP LibraryNon-melanoma malignant neoplasm of the skin

Statement of Principles

Non-melanoma malignant neoplasm of the skin — DVA SoP factors

Every factor in the Repatriation Medical Authority Statements of Principles for Non-melanoma malignant neoplasm of the skin. DVA can only accept a claim for Non-melanoma malignant neoplasm of the skin if at least one of these factors is met and connected to your service. Reasonable Hypothesis (RH) applies to operational service; Balance of Probabilities (BoP) applies to peacetime service.

Source: Repatriation Medical Authority Statements of Principles as held by the Veterans Health Centre. SoPs are amended and replaced regularly; always confirm the current instrument at rma.gov.au before relying on it.

Non-melanoma malignant neoplasm of the skin

RH No. 78 of 2024 · BoP No. 79 of 202464 factors

Meaning of non-melanoma malignant neoplasm of the skin: For the purposes of this Statement of Principles, non-melanoma malignant neoplasm of the skin: (a) means a primary malignant neoplasm arising from the non- melanotic cells of the epidermis of the skin; and (b) includes: (i) basal cell carcinoma; (ii) squamous cell carcinoma; (iii) squamous cell carcinoma in situ (Bowen disease) or basal cell carcinoma in situ; and (iv) non-melanoma malignant neoplasm of the external aspect of the lip, subungual skin, external auditory canal skin, and anogenital skin; and (c) excludes: (i) non-melanoma malignant neoplasm mucosa lining the oral (inner) aspects of the lips, conjunctiva, and anogential mucosa; (ii) malignant melanoma of the skin; (iii) keratoacanthoma; (iv) Merkel cell carcinoma; (v) mammary and extramammary Paget disease; (vi) Kaposi sarcoma; (vii) soft tissue sarcoma; (viii) carcinoid tumour; (ix) non-Hodgkin lymphoma; and (x) Hodgkin lymphoma. (3) While non-melanoma malignant neoplasm of the skin attracts ICD-10-AM codes: C00.0, C00.1, C00.2, C00.6, C00.8, C00.9, C44, C51.0, C51.1, C51.2, C51.8, C51.9, C60.0, C60.1, C60.2, C60.8, C60.9, C63.2, D04, D07.1, D07.4, in applying this Statement of Principles the meaning of non-melanoma ma

Reasonable Hypothesis (RH) — Statement of Principles No. 78 of 2024

At least one of the following factors must as a minimum exist before it can be said that a reasonable hypothesis has been raised connecting non- melanoma malignant neoplasm of the skin or death from non-melanoma malignant neoplasm of the skin with the circumstances of a person's relevant service:

  1. (1)
    being a prisoner of war of Japan before clinical onset;
  2. (2)
    having sunlight exposure to unprotected skin for a cumulative period of at least 2,250 latitude equivalent hours before clinical onset;

    Note: latitude equivalent hours and unprotected skin are defined in the Schedule 1 - Dictionary.

  3. (3)
    having at least 5 sunburns at the affected site at least 2 years before clinical onset;

    Note: sunburn is defined in the Schedule 1 - Dictionary.

  4. (4)
    having ultraviolet radiation exposure from an ultraviolet-emitting tanning device (excluding sunlamps) on at least 10 occasions at the affected site before clinical onset, at least 2 years before clinical onset;
  5. (5)
    having received a burn from an electric welding device on at least 10 occasions at the affected site, at least 10 years before clinical onset;
  6. (6)
    having PUVA therapy, where: (a) the first PUVA treatment commenced at least 5 years before clinical onset; and (b) at least 50 PUVA treatments were administered before clinical onset;

    Note: PUVA therapy is defined in the Schedule 1 - Dictionary.

  7. (7)
    having received a cumulative equivalent dose of at least 0.1 sievert of ionising radiation to the affected site at least 10 years before clinical onset;

    Note: cumulative equivalent dose is defined in the Schedule 1 - Dictionary.

  8. (8)
    undergoing a course of radiotherapy for cancer at the affected site, at least 5 years before clinical onset;
  9. (9)
    undergoing a course of radiotherapy for acne at the affected site, at least 5 years before clinical onset;
  10. (10)
    being infected by the same human papillomavirus type 16, 18 or 33 for at least 2 consecutive years before clinical onset of squamous cell carcinoma of the penis, vulva or perianal skin;
  11. (11)
    being infected with human immunodeficiency virus before clinical onset;
  12. (12)
    undergoing solid organ (excluding corneal transplant) or bone marrow transplantation at least 5 years before clinical onset;
  13. (13)
    taking one of the following medications within the 10 years before clinical onset: (a) acalabrutinib; (b) azathioprine; (c) ciclosporin; (d) elotuzumab; (e) fingolimod (f) hydroxycarbimide (hydroxyurea); (g) ibrutinib; (h) methotrexate; (i) mycophenolate; (j) ruxolitinib; (k) siponimod (l) sirolimus; (m) tacrolimus; (n) tofacitinib; (o) upadacitinib; (p) ustekinumab; (q) zanubrutinib; (r) tumour necrosis factor-α inhibitors adalimumab, certolizumab, etanercept, golimumab, or infliximab; or (s) BRAF kinase inhibitors dabrafenib, encorafenib, vemurafenib;
  14. (14)
    taking ripretinib within the 10 years before clinical onset of squamous cell carcinoma of the skin;
  15. (15)
    taking ozanimod or ponesimod within the 10 years before clinical onset of basal cell carcinoma of the skin;
  16. (16)
    taking voriconazole continuously for at least 3 months, at least 6 months before clinical onset of squamous cell carcinoma of the skin;
  17. (17)
    taking a cumulative dose of at least 25 g of hydrochlorothiazide, at least 6 months before clinical onset of squamous cell carcinoma of the skin;
  18. (18)
    taking a cumulative dose of at least 50 g of hydrochlorothiazide, at least 6 months before clinical onset of basal cell carcinoma of the skin;
  19. (19)
    having autoimmune hepatitis at the time of clinical onset;
  20. (20)
    having inflammatory bowel disease at the time of clinical onset;
  21. (21)
    having psoriasis at the time of clinical onset;
  22. (22)
    having rheumatoid arthritis at the time of clinical onset;
  23. (23)
    having sarcoidosis at the time of clinical onset;
  24. (24)
    having chronic osteomyelitis with a sinus tract draining to the affected skin site at least 2 years before clinical onset;

    Note: sinus tract is defined in the Schedule 1 - Dictionary.

  25. (25)
    having non-Hodgkin lymphoma before clinical onset;
  26. (26)
    having mature B-cell lymphoid leukaemia and small lymphocytic lymphoma before clinical onset;

    Note: Mature B-cell lymphoid leukaemia and small lymphocytic lymphoma is also known as chronic lymphocytic leukaemia/small cell lymphoma.

  27. (27)
    having phimosis for a continuous period of at least 2 years before clinical onset of squamous cell carcinoma of the glans penis or prepuce of the penis;

    Note: phimosis is defined in the Schedule 1 - Dictionary.

  28. (28)
    having a scar at the affected site at least 5 years before clinical onset;
  29. (29)
    having ulceration at the affected site for a cumulative period of at least 6 months, at least 5 years before clinical onset;
  30. (30)
    having lichen sclerosus at the affected site, at least 5 years before clinical onset of squamous cell carcinoma of the penis, vulva or perianal skin;
  31. (31)
    having hidradenitis suppurativa at the affected site, at least 5 years before clinical onset of squamous cell carcinoma of the skin;

    Note: hidradenitis suppurativa is defined in the Schedule 1 - Dictionary.

  32. (32)
    having chronic lymphoedema at the affected site, at least 5 years before clinical onset of squamous cell carcinoma of the skin;
  33. (33)
    smoking at least 15 cigarettes per day for at least 5 years, or the equivalent thereof in other tobacco products, at least 5 years before clinical onset of squamous cell carcinoma of the skin, and where smoking has ceased, clinical onset occurred within 20 years of cessation;

    Note: One gram of tobacco is considered to be equivalent to one cigarette.

  34. (34)
    being exposed to arsenic as detailed below, at least 10 years before clinical onset; (a) consuming arsenic containing compounds (for example, Fowler's solution) for a cumulative period of at least 3 months; or (b) consuming drinking water with an average arsenic concentration of at least 50 micrograms per litre for a cumulative period of at least 2 years; or (c) inhaling, ingesting or having cutaneous contact with a pesticide containing arsenic, or arsenic in copper smelting operations, for a cumulative period of at least 1,000 hours; or (d) having clinical evidence of chronic arsenic toxicity;
  35. (35)
    having cutaneous contact at the affected site with coal-tar distillate, for a cumulative period of at least 1,500 hours, at least 5 years before clinical onset;
  36. (36)
    having cutaneous contact at the affected site with one of the following polycyclic aromatic hydrocarbons, for a cumulative period of at least 1,500 hours, at least 5 years before clinical onset of non-melanoma malignant neoplasm of the scrotal skin; (a) creosote; (b) shale oil; (c) soot; (d) mineral oil;
  37. (37)
    inability to obtain appropriate clinical management for non-melanoma malignant neoplasm of the skin before clinical worsening;

Aggravation-only factors: the factors in subsection 9(37) apply only to material contribution to, or aggravation of, the condition where it was suffered or contracted before or during (but did not arise out of) the person’s relevant service.

Balance of Probabilities (BoP) — Statement of Principles No. 79 of 2024

27 factors

At least one of the following factors must exist before it can be said that, on the balance of probabilities, non-melanoma malignant neoplasm of the skin or death from non-melanoma malignant neoplasm of the skin is connected with the circumstances of a person's relevant service:

  1. (1)
    having sunlight exposure to unprotected skin for a cumulative period of at least 4,500 latitude equivalent hours before clinical onset;

    Note: latitude equivalent hours and unprotected skin are defined in the Schedule 1 - Dictionary.

  2. (2)
    having at least 10 sunburns at the affected site at least 5 years before clinical onset;

    Note: sunburn is defined in the Schedule 1 - Dictionary.

  3. (3)
    having ultraviolet radiation exposure from an ultraviolet-emitting tanning device (excluding sunlamps) on at least 20 occasions at the affected site before clinical onset, at least 5 years before clinical onset;
  4. (4)
    having PUVA therapy, where: (a) the first PUVA treatment commenced at least 5 years before clinical onset; and (b) at least 100 PUVA treatments were administered before clinical onset;

    Note: PUVA therapy is defined in the Schedule 1 - Dictionary.

  5. (5)
    having received a cumulative equivalent dose of at least 0.5 sievert of ionising radiation to the affected site at least 10 years before clinical onset of basal cell carcinoma;

    Note: cumulative equivalent dose is defined in the Schedule 1 - Dictionary.

  6. (6)
    undergoing a course of radiotherapy for cancer at the affected site, at least 10 years before clinical onset;
  7. (7)
    being infected by the same human papillomavirus type 16, 18 or 33 for at least 2 consecutive years before clinical onset of squamous cell carcinoma of the penis, vulva or perianal skin;
  8. (8)
    being infected with human immunodeficiency virus before clinical onset;
  9. (9)
    undergoing solid organ (excluding corneal transplant) or bone marrow transplantation at least 10 years before clinical onset;
  10. (10)
    taking one of the following medications within the 5 years before clinical onset: (a) acalabrutinib; (b) azathioprine; (c) ciclosporin; (d) elotuzumab; (e) fingolimod (f) hydroxycarbimide (hydroxyurea); (g) ibrutinib; (h) methotrexate; (i) mycophenolate; (j) ruxolitinib; (k) siponimod (l) sirolimus; (m) tacrolimus; (n) tofacitinib; (o) upadacitinib; (p) ustekinumab; (q) zanubrutinib; (r) tumour necrosis factor-α inhibitors adalimumab, certolizumab, etanercept, golimumab, or infliximab; or (s) BRAF kinase inhibitors dabrafenib, encorafenib, vemurafenib;
  11. (11)
    taking ripretinib within the 5 years before clinical onset of squamous cell carcinoma of the skin;
  12. (12)
    taking ozanimod or ponesimod within the 5 years before clinical onset of basal cell carcinoma of the skin;
  13. (13)
    taking voriconazole continuously for at least 3 months, at least 1 year before clinical onset of squamous cell carcinoma of the skin;
  14. (14)
    taking a cumulative dose of at least 25 g of hydrochlorothiazide, at least 1 year before clinical onset of squamous cell carcinoma of the skin;
  15. (15)
    having autoimmune hepatitis at the time of clinical onset;
  16. (16)
    having inflammatory bowel disease at the time of clinical onset;
  17. (17)
    having chronic osteomyelitis with a sinus tract draining to the affected skin site at least 5 years before clinical onset of squamous cell carcinoma;

    Note: sinus tract is defined in the Schedule 1 - Dictionary.

  18. (18)
    having non-Hodgkin lymphoma before clinical onset;
  19. (19)
    having mature B-cell lymphoid leukaemia and small lymphocytic lymphoma before clinical onset;

    Note: Mature B-cell lymphoid leukaemia and small lymphocytic lymphoma is also known as chronic lymphocytic leukaemia/small cell lymphoma.

  20. (20)
    having phimosis for a continuous period of at least 2 years before clinical onset of squamous cell carcinoma of the glans penis or prepuce of the penis;

    Note: phimosis is defined in the Schedule 1 - Dictionary.

  21. (21)
    having a scar at the affected site at least 10 years before clinical onset;
  22. (22)
    having ulceration at the affected site for a cumulative period of at least 1 year, at least 10 years before clinical onset;
  23. (23)
    having lichen sclerosus at the affected site, at least 10 years before clinical onset of squamous cell carcinoma of the penis, vulva or perianal skin;
  24. (24)
    having hidradenitis suppurativa at the affected site, at least 10 years before clinical onset of squamous cell carcinoma of the skin;

    Note: hidradenitis suppurativa is defined in the Schedule 1 - Dictionary.

  25. (25)
    being exposed to arsenic as detailed below, at least 10 years before clinical onset; (a) consuming arsenic containing compounds (for example, Fowler's solution) for a cumulative period of at least 3 months; or (b) consuming drinking water with an average arsenic concentration of at least 50 micrograms per litre for a cumulative period of at least 5 years; or (c) inhaling, ingesting or having cutaneous contact with a pesticide containing arsenic, or arsenic in copper smelting operations, for a cumulative period of at least 1,000 hours; or (d) having clinical evidence of chronic arsenic toxicity;
  26. (26)
    having cutaneous contact at the affected site with coal-tar distillate, for a cumulative period of at least 3,000 hours, at least 10 years before clinical onset;
  27. (27)
    inability to obtain appropriate clinical management for non-melanoma malignant neoplasm of the skin before clinical worsening;

Aggravation-only factors: the factors in subsection 9(27) apply only to material contribution to, or aggravation of, the condition where it was suffered or contracted before or during (but did not arise out of) the person’s relevant service.

A VHC Diagnostic Assessment addresses each of these factors one by one against your service record and clinical history. See how a VHC DVA claim works, see all fees ($600 + GST per stage) or book an appointment.

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Dr Perkins has spent more than thirteen years working exclusively with current and former ADF members — treating their conditions, writing their reports and navigating the DVA system alongside them. With over 100,000 claims submitted and 2,000 Permanent Impairment Assessments completed, he has seen precisely what separates an accepted claim from a rejected one at every level, from initial liability to the Veterans' Review Board.

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