Lawyers PI Program
“Building a PI Practice”


 From the Desk of:


“Getting the Referral Without Asking

Plaintiff IME Part 1 of 3”



WARNING: If you have not read all previous consultations, then you stand the chance of being a "one-and-done" with the lawyers. You have to learn to speak their language of admissibility.


This is what appears to have eluded the majority of the profession as we ask over and over, “why aren’t they referring?” You now know the answer; you haven’t spoken the language of the lawyer and they don’t know that you now do.


If you haven’t read, understood and put into narrative format all of the previous consultations, then do not read another word because without that knowledge, you will be a one-and-done! The lawyers will refer one to you and be done with you, perhaps forever because you don’t have what they need. It’s not enough to speak their language; you must be able to clinically correlate the history, functional loss, structural loss and functional limitations with causality and permanency on paper in narrative format.


It is unacceptable to send to attorney’s paperwork in evaluation format as a final narrative. There should be no rationale for care on a narrative and no necessity for tests on a narrative. Those are the needs of the doctor and not the lawyer. You need results and know how they clinically correlate to the accident.


If you haven’t been able to figure it out, there is a narrative template on the Web site you can purchase to make it easy. If you want to e-mail me a copy of your narrative, I will take a look at it and let you know if it meets the standards required. Do not send me an evaluation; I will only look at final narratives. My response will be that you meet the standards, or you don’t. If not, you will need to go back and re-read the consultations to incorporate the requirements explained and then re-send the corrected copy to me, or purchase a template. When you have understood everything and you have a narrative, take a sample of your narrative and laminate it, three-hole punch the pages and put it in a leather binder.


Go through all of your patient records over the last year and see what personal injury patients you have cared for. Every patient within a year is an active patient, perhaps not to you, but to their lawyer as the case hasn’t been settled yet. In this relationship, who is more important, you or the lawyer? The answer is simple. You already have the patient and the lawyer needs your work to prevail. Therefore, you are the key to success. Now is when you reach out to the lawyer to solidify the relationship.


Call the lawyer and request a breakfast meeting (no McGriddle’s and Slurpee’s, find an upscale restaurant). Request that you sit down with them to review their client’s findings. ½ will agree right away to meet you and the other ½ will request that you just send over the paperwork. For those only wanting the paperwork, tell them that you have significant findings and want to sit and explain it to them. You also want direction from them on how they want the findings articulated on paper. With that request the majority will agree to a breakfast meeting.


First and foremost, we never change any findings…ever! And…I strongly suggest that you follow the instructions on building a narrative within the consults or the template you can get on the Web site. However, many attorneys have their own style and want findings articulated in a precise way. As long as you don’t change the results, it is permissible to articulate the findings in a number of ways.


When you meet with the attorney, make sure you have acquired the functional loss information from your patient, the radiographic and MRI findings and you understand their relationship to the accident as far as causality. It will also be impressive to them if the patient has seen a medical specialist, such as a neurologist and/or an orthopedist, and you have the specialist’s report to show them and can explain how it correlates with your findings. This makes you the quarterback of the case, which is the goal. Everything flows through you, as you have taken the time and steps to gather everything a lawyer would have a paralegal do. This saves them significant amounts of time, which equates to money.


During your breakfast meeting, review your patient’s findings with them. Make sure to highlight the persistent functional loss in all 3 categories; personal, social and work. Then take out your sample narrative and show the lawyer the format. Ask for suggestions on how to make it better. This accomplishes 2 things. First, it shows the lawyer the quality of work that you do and second, it empowers them in your practice. This will help foster a more meaningful relationship.


In the beginning, when I went through this process, the lawyers were impressed that I understood their needs of functional loss correlated to the accident and all other findings, and they always had suggestions as to how to articulate the findings. After a few meetings, my confidence level increased regarding my paperwork and the lawyers were so impressed with the sample narrative, that every single lawyer that I met with requested a copy of the narrative. The answer to their question was always met with a resounding “NO.” That is the reason I laminate it and put it in a binder, so they can’t take it with them. They will be so impressed that they will want a copy for all of their other referral sources (your competition) as a template. Kindly explain to them that they get a copy when you send in your patient’s results.


Once you get to this point, the relationship will have been made, as the lawyer will understand that you now speak their language. From the lawyer’s perspective, you will be adding value to their cases in an ethical fashion because you will have taken the extra steps. You will not only understand what is wrong with their client, but will document it so that they can utilize it in an admissible fashion.


The next consult will be to explain how to take the next step with the lawyer during this meeting. A concept I created that is changing the industry. The plaintiff IME. You will be the on the cutting edge. I have done this on Long Island, Buffalo and Deerfield Beach Florida, and in every region, it has been met with instant, overwhelming success, because the narrative delivered worked.