Catching IME Contradictions Before the Hearing

The most expensive surprises in a workers' comp case are the ones hiding in the medical record. A treating physician and an AME disagree on apportionment. Two reports put maximum medical improvement eight weeks apart. Buried across thousands of pages, that conflict does not announce itself — until opposing counsel raises it at the worst possible moment.

Put every doctor on the same axes

The fix is structural. Instead of reading each report in isolation, line them up side by side on the axes that drive the claim — whole-person impairment, causation, apportionment, work status, and the MMI date — with each value cited to its source.

• Impairment (WPI): where the ratings agree and where they diverge.
• Causation: industrial versus non-industrial framing across examiners.
• Apportionment: the percentages that move settlement value the most.
• MMI and work status: dates that quietly control deadlines and exposure.

Surface the disagreement, cite the source

When the comparison flags a conflict — say, an AME apportioning seventy percent non-industrial against a treating physician who does not — it is not enough to say so. Each side of the disagreement links to the exact page it came from, so the attorney evaluates the actual reports, not a summary's claim about them.

Why timing is the whole game

A conflict found early is a strategy: you can develop rebuttal, schedule a supplemental exam, or adjust a settlement posture on your timeline. The same conflict found late is a scramble. The value is not that a machine noticed the disagreement — it is that a licensed attorney saw it in time to do something about it.