Adhesive capsulitis
Frozen shoulder and adhesive capsulitis after a motor accident
Frozen shoulder is a capsular stiffness pattern, not simply a painful shoulder. In a CTP claim the evidence should explain whether immobilisation, surgery or the accident-related injury led to adhesive capsulitis and whether the restriction has reached a permanent plateau.
Motor accident injury
How can this injury happen?
Car or passenger collision
Direct shoulder trauma or a period of guarding after a collision may be followed by progressive capsular stiffness.
Motorcycle accident
Fracture, dislocation or cuff surgery after a motorcycle fall may require immobilisation and contribute to secondary adhesive capsulitis.
Pedestrian or cyclist impact
A painful direct impact can lead to prolonged under-use and a documented loss of capsular movement.
Injuries that can occur
- primary or secondary adhesive capsulitis
- post-fracture or post-dislocation stiffness
- post-operative capsular restriction
- coexisting cuff, biceps or AC joint pathology
Symptoms and functional problems
- progressive restriction in several directions
- difficulty reaching overhead or behind the back
- night pain, dressing and hygiene difficulty
- loss of both active and passive movement on examination
Clinical evidence
What findings matter?
A capsular pattern, serial examination and exclusion of fracture, arthritis or untreated cuff pathology matter. The WPI calculation still uses active ROM even though passive restriction helps confirm the diagnosis.
| Record or examination | What it may establish | What it cannot prove alone |
|---|---|---|
| Serial active and passive ROM | Shows the development and capsular pattern of restriction. | Only active ROM is used for the impairment calculation. |
| X-ray, ultrasound or MRI | Excludes fracture, advanced arthritis or another structural explanation. | Imaging does not quantify capsular WPI. |
| Treatment chronology | Records injections, hydrodilatation, physiotherapy, surgery and whether recovery has plateaued. | A temporary stiff phase is not permanent impairment. |
Movement in daily life
How movement affects real activities
Frozen shoulder commonly restricts elevation and rotation together, so overhead use, grooming, fastening clothing and reaching behind the back may all be affected.
Flexion
Lifting the arm forward and overhead, including reaching a shelf or putting on a shirt.
Active flexion and extension are rated through AMA4 shoulder Figures 36 to 38 when reliable.
Abduction
Lifting the arm sideways, including reaching away from the body or fastening a seat belt.
Active abduction and adduction are addressed by Figures 39 to 41.
External rotation
Washing hair, reaching behind the head and positioning the arm to put on a jacket.
Active external rotation is read with the shoulder rotation figures, not estimated from pain severity.
Internal rotation
Reaching behind the back for dressing, hygiene or fastening clothing.
Active internal rotation is addressed with Figures 42 to 44 and must be measured consistently.
Threshold injury is a separate question: adhesive capsulitis is generally a soft tissue condition and may be threshold unless the claim also proves a separate excluded injury such as fracture, nerve injury or partial/complete rupture.
Part 6 permanent impairment
How is CTP WPI assessed?
Reliable active shoulder ROM under clauses 6.50-6.52 is the primary verified method. The condition should be stable before permanent impairment is assessed.
Measurement rules that apply
- Clause 6.50 requires active, not passive, range of motion for the impairment calculation. A goniometer should be used where clinically indicated, and unreliable movement should be repeated consistently before it is accepted.
- Clauses 6.51 and 6.52 permit a contralateral baseline only where the uninjured joint is a fair estimate of pre-accident mobility. The total upper-extremity impairment for each comparable joint is subtracted before conversion to WPI.
- Clause 6.67 prohibits upper-limb strength evaluation and AMA4 Table 34. A genuine peripheral nerve or muscle-bulk injury must use another permitted method without double counting.
| Method | CTP source | When it is relevant | Important limit |
|---|---|---|---|
| Active shoulder ROM | Clause 6.50; Figures 36-44 | Permanent multi-plane capsular restriction. | Passive restriction supports diagnosis but does not set UEI. |
| Contralateral baseline | Clauses 6.51-6.52 | Where the uninjured shoulder reasonably reflects pre-accident mobility. | It is not an automatic deduction. |
| Table 3 conversion | Clause 6.56 | Converts total shoulder UEI to WPI. | Do not add a separate pain value. |
- Assessment should not occur while substantial recovery remains likely.
- Each reliable active shoulder plane is assessed under its applicable figure.
- Pain is already accommodated within the body-system method and is not added separately.
What cannot be combined?
- pain as a separate WPI allowance
- two methods rating the same capsular movement loss
- upper-limb strength Table 34
What does not establish WPI by itself?
- the diagnosis label without measured movement
- one painful examination during an acute flare
- passive ROM alone
- a history of injection or hydrodilatation
Motor accident examples
Post-fracture frozen shoulder
The fracture and the permanent shoulder movement loss must be considered without rating the same consequence twice.
Stiffness improving with treatment
If active movement is still materially improving, a permanent impairment assessment may be premature.
Claim file preparation
Evidence checklist
Assessment source
Frozen shoulder WPI assessment source
Assessment source: Motor Accident Guidelines v10.1 clauses 6.19-6.21 and 6.47-6.57; AMA4 shoulder Figures 36-44 and Table 3.
Threshold injury: Frozen shoulder may remain a threshold soft tissue injury unless a separate excluded structural injury is established.
What the assessor checks
- active ROM
- capsular diagnosis evidence
- contralateral comparison
- Table 3 conversion
What does not establish the result by itself
- pain
- diagnosis label
- passive movement
- temporary stiffness
Official sources
Related NSW CTP guides
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Frequently asked questions
- Is frozen shoulder permanent?
- It may improve substantially. WPI should be assessed only when the impairment is static or well stabilised under clause 6.19.
- Does passive stiffness count as WPI?
- It supports diagnosis, but clause 6.50 uses active ROM for the impairment calculation.
- Can frozen shoulder follow surgery?
- Yes, but the medical evidence must connect the stiffness to the accident-related injury or treatment.
- Is frozen shoulder automatically non-threshold?
- No. It is commonly a soft tissue condition unless another excluded injury is established.
- What records best show the progression?
- Serial movement measurements, treatment notes and specialist reviews showing onset, plateau and competing diagnoses.