Lawyers PI Program
“Building a PI Practice”


 From the Desk of:


“Plaintiff IME Part 3 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.


Plaintiff IME’s are a powerful tool in helping to level the playing field when dealing with the insurance IME’s, who often render a very inaccurate report of the true condition of the patient. In the previous consultation, I shared with you the purpose, the coding and how they should be presented. In this consultation, I want to share with you another way to implement the “Plaintiff IME” program. This is the system that I developed over many years of treating the traumatically injured and can be instituted in a very short amount of time.

I created a relationship with another doctor in my community that I felt was clinically excellent and would provide a very thorough evaluation of my patients. I also explained to that doctor the concept of “Plaintiff IME’s,” or the second opinion. We then began cross-referring to each other for a second opinion on the condition of our patients. We did this relatively early in care and we each sent to the other requests for consultations.

This served many purposes. First and foremost, it ensured that our diagnosis was accurate and the treatment plan recommended was also appropriate for the condition of the patient. This created many conversations with each other regarding the care of the patient and the patient always was the victor as a result of their doctor being more thorough. The doctor and I always wrote a very thorough report, utilizing the standards taught in consultations 1-14, and we exchanged reports.

If the patient had an attorney representing them, we always forwarded the doctor’s report along with my information. This second opinion was the “Plaintiff IME.” Now the attorney had both the treating doctor’s report and the independent doctor’s report, that spent the necessary time and energy to perform an evaluation of the true nature of the patient’s condition. This was beneficial to the attorney as they now had 2 reports to counteract the usually negative insurance IME report. Please understand that many times, our reports were negative as well. That was because there were no findings vs. ignoring the findings.


Create a relationship with a doctor whose abilities you feel confident in, and start requesting a second opinion for your patients; the real winners…the patients.