Australia’s DVA impairment assessment system: A maze with a method

The Australian Department of Veterans’ Affairs (DVA) permanent impairment assessment process follows a structured yet complex framework designed to evaluate service-related injuries for compensation. The system operates under two distinct legislative schemes—the Safety, Rehabilitation and Compensation (Defence-related Claims) Act 1988 (DRCA) for pre-July 2004 injuries and the Military Rehabilitation and Compensation Act 2004 (MRCA) for later injuries—each with different assessment methodologies, thresholds, and compensation calculations. Recent reforms are addressing long-standing inefficiencies, with simplified medical forms, digital transformation initiatives, and proposed legislative harmonization aimed at creating a more veteran-centric process.

Who makes the call: Medical assessment hierarchy

The DVA assessment system follows a clear preference order for medical opinions, prioritizing treating specialists’ expertise. The medical assessment hierarchy operates as follows:

1. Treating medical specialists hold the highest authority, with their opinions given greatest weight due to their ongoing relationship with the veteran and specialized expertise.
2. Treating general practitioners (GPs) are next in the hierarchy, consulted when specialists aren’t available, though their opinions are superseded by relevant specialists when conflicts arise.
3. Contracted Medical Advisors (CMAs) employed by DVA analyze existing evidence and recommend when further specialist assessment is needed.
4. Independent Medical Examiners (IMEs) are engaged for specific expertise when treating doctors aren’t available, medical evidence conflicts, or additional expertise is required. Since January 2023, MedHealth has been DVA’s sole provider of IMEs.
5. Occupational physicians are often preferred specifically for work capacity assessments.

The selection process emphasizes quality of advice over cost. DVA delegates have authority to select practitioners and must prioritize specialists in the relevant field for diagnosing conditions. When independent assessments are needed, practitioners are selected based on qualifications, experience, expertise, report quality, and absence of conflicts.

Doctor qualifications: Not just any medical degree

Medical practitioners conducting DVA assessments must meet rigorous qualification standards:

All assessors must hold current registration with the Australian Health Practitioners Regulation Agency (AHPRA), meet the definition of a “legally qualified medical practitioner,” and have a Medicare provider number.

Specialists require relevant specialty registration aligned with the condition being assessed and sufficient experience evaluating specific impairment types. For psychiatric conditions, only psychiatrists (not psychologists) can provide medical opinions.

All practitioners must demonstrate understanding of the relevant assessment framework—either the DRCA PI Guide or GARP M—and be familiar with “whole person impairment” concepts and DVA reporting requirements. This technical knowledge is crucial for accurate assessments as the guides contain complex evaluation tables and methodologies.

Rehabilitation providers involved in assessments must be Comcare-approved, demonstrating they meet specific performance standards. In unusual circumstances, non-Comcare approved providers with appropriate expertise may be approved.

Different practitioners, different roles

Each type of medical practitioner plays a distinct role in the permanent impairment assessment process:

Treating GPs provide initial medical evidence, coordinate care, issue incapacity certificates, monitor condition progress, and conduct veteran health checks. Their assessments may be limited by their generalist knowledge and are typically superseded by specialist opinions.

Medical specialists deliver authoritative diagnoses within their specialty, conduct detailed impairment assessments, provide expert evidence on causation, determine impairment ratings according to relevant guides, and recommend treatment plans. Their opinion carries significant weight in the assessment hierarchy.

Independent Medical Examiners provide objective, unbiased assessments when requested by DVA, help resolve conflicting evidence, offer specialized expertise for complex cases, prepare detailed reports addressing specific questions, and clarify evidence when existing information is insufficient. They must avoid conflicts of interest and follow professional standards.

This tiered approach ensures veterans receive appropriate specialist evaluation while maintaining access to their regular treating doctors for ongoing care.

The examination process: Detailed and documented

The permanent impairment examination follows a structured pathway from initial claim to final determination:

1. Initial claim processing: The veteran must have an accepted service-related condition with liability confirmed by DVA before impairment assessment proceeds.
2. Referral to medical practitioner: DVA issues a specific request with a Transaction Reference Number (TRN) to the appropriate medical specialist.
3. Pre-examination review: The medical practitioner reviews the veteran’s complete medical history, treatment records, service history, and previous diagnostic results.
4. Comprehensive examination: The assessment includes detailed history-taking, physical examination with standardized measurements, and specific testing relevant to the condition (hearing tests, respiratory function tests, psychological examination).
5. Documentation: The practitioner must prepare a detailed report including examination findings, functional loss assessment, range of motion measurements, pain assessment, test results, and opinions on permanence and stability.
6. Assessment calculation: Impairment ratings are calculated using the appropriate guide—GARP M for MRCA claims (0-100 point scale) or DRCA PI Guide for DRCA claims (percentage of whole person impairment).
7. Lifestyle assessment: Veterans complete a Lifestyle Rating form assessing how their condition affects personal relationships, mobility, community activities, and employment.
8. Final determination: DVA combines medical and lifestyle ratings using the relevant guide to calculate compensation.

Documentation requirements are stringent and specific, with practitioners needing to follow precise protocols for measuring and recording impairments according to the relevant assessment guide.

Evaluation standards: By the book

Medical practitioners must adhere to strict evaluation standards when conducting permanent impairment assessments:

Assessments must follow the specific methodology outlined in either GARP M (for MRCA claims) or the DRCA PI Guide (for DRCA claims). These guides contain detailed tables and instructions for evaluating different body systems and conditions.

Medical assessment must be objective and evidence-based, with opinions supported by clinical findings rather than solely on the veteran’s self-report. Range of motion should be assessed actively rather than passively.

Practitioners must document comprehensive examination findings with specific measurements and test results, providing clear rationale for impairment ratings assigned.

For conditions that are permanent but not yet stable, assessors must specify the current impairment level, expected timeframe for stabilization, and projected final impairment rating.

When assessing multiple conditions, each is evaluated separately according to relevant tables, then combined using a specific formula (not simple addition) via the Combined Values Chart in the relevant guide.

Quality assurance measures include Medical Adviser-Consultant (MA-C) reviews for unclear or complex cases, with procedural fairness maintained throughout the process.

When doctors disagree: Managing conflicts

DVA has established protocols for handling disagreements or conflicting medical opinions:

When treating doctors disagree with independent assessors, DVA delegates follow a hierarchical approach. Treating specialists’ opinions generally take precedence over GPs’, and specialist opinions carry more weight in their area of expertise.

For complex cases or when medical evidence conflicts, DVA may commission Independent Medical Examinations through MedHealth (sole provider since January 2023) to provide additional expert opinion.

If a DVA Contracted Medical Adviser’s opinion potentially contradicts the veteran’s claim, the delegate must give the veteran opportunity to provide counter-evidence before making a decision.

Veterans who disagree with assessment results can appeal through a multi-stage process, either:

• For MRCA decisions: Apply for review to the Veterans’ Review Board (VRB) within 12 months
• For DRCA decisions: Request reconsideration by DVA within 30 days (pre-April 21, 2025) or apply for VRB review within 12 months (post-April 21, 2025)

If still dissatisfied, veterans can appeal to the Administrative Review Tribunal (ART, which replaced the Administrative Appeals Tribunal on October 14, 2024), with further appeals to the Federal Court possible on points of law.

Veterans’ rights: Protections in the process

Veterans have extensive rights throughout the permanent impairment assessment process:

Information rights include accessing documents through Freedom of Information requests, reviewing documentation used in decisions, knowing how information will be used, and understanding decision rationales.

Support rights allow veterans to have a support person present during assessments, engage free advocates from Ex-Service Organisations, and seek assistance from trained Veterans’ Advocates. No legal representation is permitted at VRB hearings, though it’s allowed at other stages.

Appeal rights provide multiple avenues for challenging decisions, with specific timeframes for each pathway. MRCA appeals must go to the VRB within 12 months, while DRCA reconsiderations must be requested within 30 days. Appeals to the ART have varying deadlines depending on the decision type.

Medical and support rights include using DVA health cards for treatment, receiving care for certain conditions while claims are processed, and claiming reimbursement for costs related to obtaining medical evidence for reviews.

Privacy rights are protected under the Privacy Act 1988 and Australian Privacy Principles, with DVA required to follow strict protocols for handling personal information.

DRCA versus MRCA: Different approaches, different outcomes

The DRCA and MRCA frameworks use significantly different approaches to assess permanent impairment:

Assessment methodology: DRCA requires separate evaluation of each condition, while MRCA uses a “whole of person” approach combining all injuries. This fundamental difference means veterans with multiple conditions often fare better under MRCA.

Compensation calculation: DRCA pays compensation as a lump sum based on whole person impairment percentage, while MRCA offers more flexibility with options for periodic payment, lump sum, or a combination.

Thresholds and proof standards: DRCA requires each condition to independently meet minimum thresholds with a “beyond reasonable doubt” standard, making approvals harder to obtain. MRCA generally requires 10 impairment points (5 for specific conditions) with a more favorable “beneficial standard of proof” for warlike service.

Lifestyle assessment: DRCA uses a weighted formula for Non-Economic Loss assessment, while MRCA employs a numerical lifestyle rating from 0-7 based on daily living impacts.

Superannuation implications: DRCA deducts a 5% superannuation contribution from fortnightly payments, while MRCA does not and includes compensation for lost non-salary benefits.

These differences have significant implications for veterans’ compensation outcomes, with the Royal Commission into Defence and Veteran Suicide recommending harmonization of these systems.

Specialized providers: Med For Men and others

Several specialized providers have emerged to assist veterans with permanent impairment assessments:

Med For Men employs ex-service members as GPs who understand veterans’ unique needs, assists with completing DVA-issued assessments, typically offers appointments within 10-15 business days, and provides guidance on navigating the MyService Portal.

Australian Veteran Health Services (AVHS) offers services run by veterans for veterans with comprehensive DVA system knowledge, provides permanent impairment assessments as a core service, and offers telehealth throughout Australia with outreach clinics in Townsville and Canberra.

Veterans Health Centre (VHC) is a 100% ADF veteran-owned facility founded in 2019 by Dr. Thomas Perkins with over 25 years of ADF experience, providing comprehensive chart reviews, assistance with Initial Liability Claims, and completion of Diagnostic and Permanent Impairment Assessments.

Medilinks specializes in mental health assessments for veterans, reducing wait times from 8 months to 4 weeks, completing and submitting reports to DVA within 2-3 weeks, and employing former DVA staff including from the DRCA Permanent Impairment team.

These providers address a critical need by offering veterans specialized assistance from practitioners who understand both the medical aspects and the complex DVA assessment system.

Recent developments: Streamlining the system

Significant changes have been implemented to improve the DVA permanent impairment assessment process:

The new DRCA PI Guide implemented in April 2023 replaced the previous Edition 2.1 guide with improvements to style and format while maintaining continuity in compensation outcomes.

A major medical forms simplification project has reduced 210 forms to 84, cutting total page count from 658 to 183 pages. User-friendly checkbox functionality has been added to improve ease of use, with the project continuing through mid-2024.

COVID-19 adaptations led to permanent telehealth arrangements from January 1, 2022, enabling flexible healthcare access and reducing in-person visit requirements.

Digital transformation through the MyService platform has simplified the claims process from a 16-page form to 3-7 online questions, with some common conditions approved in under eight seconds. All claims must now be lodged through this system.

The Royal Commission into Defence and Veteran Suicide’s 2022 Interim Report recommended legislative simplification, leading to the Veterans’ Entitlements, Treatment and Support (Simplification and Harmonisation) Bill 2024, which would use MRCA as the single act for all future claims.

Claims backlog clearance has been a priority, with 99% of the 41,799 backlogged claims completed by March 2025. DVA now aims to allocate new claims within two weeks of receipt.

These changes collectively represent a significant effort to modernize and streamline a system that has historically been criticized for its complexity and inefficiency.

Conclusion

The DVA permanent impairment assessment system balances the need for thoroughness with growing pressure for efficiency and simplification. The distinct approaches under DRCA and MRCA create complexity but ensure comprehensive evaluation of service-related injuries. Recent reforms addressing form complexity, digital transformation, and legislative harmonization show a system evolving toward greater veteran-centricity, though navigating the assessment process remains challenging enough that specialized providers have emerged to bridge the gap. For veterans, understanding these complexities—and their rights within the system—remains essential to securing appropriate compensation for permanent impairments resulting from their service.