February 24, 2021
by Hannah Teig

Tips and Tricks for Independent Medical Exams (IMEs)

Independent medical examinations (IMEs) are a great tool for claims examiners to use in processing at the beginning, middle, and end of claim. They are also important tools for developing evidence to defend a denial or use for other disputes in litigation. The following is a list of tips and tricks to keep in mind when scheduling an IME and drafting cover letters to make sure you are getting all that you need out of the examination.

Choosing the right doctor

  • We all know there are examiners out there who always provide a favorable opinion regardless of the medicine. Don’t fall into the trap!
      • While we want favorable opinions, we also want high quality opinions.
      • A favorable opinion that is not high quality can come back to haunt you especially if the claim is in litigation and an issue turns on medical evidence. Remember, the other side can depose your doctor which can quickly expose any short comings in their opinion.
  • When selecting a doctor, carefully consider what conditions are to be evaluated and what specialty is needed to properly evaluate. If you are not sure, you can always ask the IME company you are scheduling with or an SBH attorney.
  • If you have more than one condition that needs to be evaluated by different specialists, such as a neurosurgeon and an orthopedist, consider scheduling a panel IME.
  • If you are unfamiliar with an examiner or their reports, ask around to colleagues or SBH attorneys to determine whether the examiner will be a good fit for your case.
  • Also make sure to confirm whether the examiner participates in telephone conferences and depositions, you never know when you might need to follow up with them again.

What makes a good cover letter?

  • Concise questions- don’t try to address more than one issue in the same question, the doctor may not respond to the question fully.
  • Pointed questions- if it’s a closing exam, no need to ask about compensability.
  • Request for explanation- ask the doctor to explain the how and why.
  • All necessary questions asked- don’t assume the doctor will answer a question if you don’t ask it.

Questions to Consider for Initial Compensability Examinations

  • What conditions does the examiner diagnose?
  • Are any of the diagnosed conditions compensable? Make sure to include the relevant legal standards.
    • In Oregon: is the condition caused in material part by the work injury (industrial injury) or caused in major part by occupational factors (occupational disease)?
    • In Washington: did the work injury or the worker’s occupational factors proximately cause the condition?
  • What is the recommended treatment and estimated date the work will be medically stationary (Oregon) or at maximum medical improvement (Washington)?

 Questions Required for Closing Examinations

  • Is the worker medically stationary (Oregon) or have they reached maximum medical improvement (Washington)?
  • Does the worker have any permanent impairment related to the compensable condition? Remember to ask that the examiner provider specific findings.
  • Does the worker have any permanent work restrictions?
  • Can the worker capable of returning to the job of injury?

If you have any further questions about IMEs or IME cover letters, feel free to contact me at 503-595-6115 or

Posted by Hannah Teig.