William Record v. HHS - Hepatitis A, shoulder injury related to vaccine administration (SIRVA) (2025)

On April 29, 2021, William Record filed a petition under the National Vaccine Injury Compensation Program, alleging that he suffered a shoulder injury related to vaccine administration (SIRVA) in both shoulders as a result of receiving Hepatitis A and B vaccines on April 30, 2018. He also claimed that these injuries had residual effects lasting more than six months.

Mr. Record testified that he felt the vaccines were administered too high in his shoulders and experienced pain and limited range of motion within 48 hours.

His symptoms later spread down his arms, leading to diagnoses of carpal tunnel syndrome (CTS) and possible reactive arthritis. He underwent surgery for CTS and was treated with methotrexate.

The initial entitlement decision, issued by Chief Special Master Brian H. Corcoran on September 3, 2024, denied his claim, finding that his symptoms were not shoulder-specific, that his CTS was unrelated to SIRVA, and that the six-month severity requirement was not met.

The decision noted that while Petitioner met some elements of a Table SIRVA claim, the predominance of his symptoms in his hands and wrists, the uncharacteristic CTS surgeries, and the alternative explanation of reactive arthritis were inconsistent with a Table SIRVA. The Special Master also found that the record did not establish that any initial pain was severe enough to meet the Act's foundational severity requirement, and that SIRVA and CTS are unrelated conditions.

Petitioner appealed this decision. On March 20, 2025, Judge Stephen S.

Schwartz issued an opinion and order, finding that the Chief Special Master's decision lacked sufficient explanation for meaningful review. The court remanded the case for further proceedings, specifically noting that the decision did not adequately explain why the SIRVA Qualifications and Aids to Interpretation (QAIs) 3 and 4 were unmet, nor did it sufficiently address the six-month severity requirement, potentially conflating persistence with intensity.

Subsequently, on July 1, 2025, Chief Special Master Corcoran issued a decision awarding damages based on a stipulation between the parties. The stipulation awarded Mr.

Record a lump sum of $7,500.00, to be paid through an ACH deposit to his counsel's IOLTA account for prompt disbursement. This amount represented compensation for all damages available under Section 15(a) of the Act.