Table 1. Common elements of vaccine-injury compensation schemes for six selected countries.

Common elements	Finland	Germany	New Zealand	Sweden	United Kingdom of Great Britain and Northern Ireland	United States of America
Administration and funding	Manufacturers, distributors, suppliers tax	General revenue of the Lander (state governments)	ACC earner’s account (funded by personal income tax) and ACC non-earner’s account (funded by government)	Percentage levy of member manufacturers’ annual sales	National treasury	Flat-rate tax paid by manufacturers for every childhood vaccine sold
Eligibility/vaccines covered	All	All recommended vaccines (child and adult)	All	All	Recommended childhood vaccines, adult influenza, armed forces	Recommended childhood vaccines, adult influenza, armed forces
Process and decision-making	Finnish Pharmaceutical Insurance Pool claims officer	Internal Lander office of social recompensation (medical expert consultation)	Review by ACC Treatment Injury Advisory Committee	Claims manager with Zurich insurance	Evaluation by appointed medical officer	Vaccine injury table or proving “causation in fact”a
Standard of proof	Balance of probabilitiesb	Probable cause	Balance of probabilitiesb	“Preponderant probability”	Balance of probabilitiesb	Balance of probabilitiesb
Elements of compensation	Unreimbursed medical costs, disability pension, noneconomic loss, death benefits	Medical costs, disability pension, funeral costs	Medical costs, disability pension, death benefits	Unreimbursed medical costs, disability pension, death benefits	Lump sum payment	Non-reimbursed medical expenses, lost wages, noneconomic loss, future care costs, death, legal fees
Litigation rights	No	Limited	No	No	Yes	If compensation accepted, no further civil claim allowed
Claims compensated	2004–2008: 45 vaccine claims	1961–2001: ~4000 claims	1992–2000: 77/293	Vaccine-specific data not available	2005: 4/106	2008: 145/226 (non-autism claims)c

ACC, Accident Compensation Corporation.

^a “Causation in fact” considers an injury to be proven if these 3 criteria are met: (i) a medical theory causally connecting the vaccination and the injury; (ii) a logical sequence of cause and effect showing that the vaccination was the reason for the injury; and (iii) a showing of a proximate temporal relationship between vaccination and injury.

^b Balance of probabilities mean that there is a “preponderance of evidence” or more evidence than not to suggest the vaccine caused the injury. This is a lower burden of proof than “beyond reasonable doubt".

^c Between 2001 and 2010 more than 5600 claims were made for autism or autism spectrum disorder caused by measles–mumps–rubella vaccine and thimerosal-containing vaccines. These cases were consolidated into the Omnibus Autism Proceedings. After several test cases, no causal link has been found between autism and the vaccines, however a large number of cases have not yet been formally dismissed or withdrawn from the courts. Given the separate process that has been established for this large number of claims, this data is listed separately in the claims data published by the National Vaccine Injury Compensation Programme in the United States of America.³⁸