Why some IME reports land and others don't. A view from the other side.
By Greg Freeman · 14 May 2026 · 8 min read
You open the report expecting something useful. Three pages in, you realise it doesn't answer the question you needed answered. The matter stalls. Back to the provider. More delay. Everyone loses time.
It happens more than it should. And it's usually not the doctor's fault.
The brief sets the ceiling
A report can only be as good as what the expert was given. The brief sets the ceiling. No examiner gets above it.
I've spent years on the provider side, tens of thousands of IMEs across workers comp, motor vehicle, insurance, abuse and negligence, and a lot of time on the phone with the doctors who write these reports. They tell me the same things, over and over, about what they need and what they don't get.
Questions that are too broad to answer
The most common issue, and the most fixable. A brief that asks for "an opinion on the claimant's condition" gives the expert almost nothing. Condition compared to what? In what context? For what purpose? You get a report that's technically responsive and practically useless.
A test one senior partner shared with me. Before the brief goes out, read the questions and ask: if this expert answered exactly what I've asked and nothing more, would I have what I need to move this matter forward? If the answer's no, the questions aren't done.
Not "assess the claimant's psychological state" but "does the claimant have a diagnosable psychological condition causally related to the incident of [date], and if so what treatment is reasonably necessary and what's the prognosis?" One version gets you an essay. The other gets you a report you can use.
Incomplete clinical history
The examining doctor forms an independent opinion off a single appointment and whatever you've sent. They're not the treating practitioner. What's in the brief is largely what they've got. When the history's missing, they either qualify their opinion to death or work around the gaps and reach conclusions that get challenged later. The best briefs include:
- All treating practitioner records relevant to the injury or condition
- Imaging results and specialist reports
- Any prior IME reports on the same matter
- A clear chronology of the injury, treatment and current status
- Relevant pre-existing conditions, including ones that seem unrelated
That last one matters more than people realise. A pre-existing condition that looks irrelevant can reshape causation once the expert sees it. Better the expert factors it in than the other side raises it later.
How the brief is built matters as much as what's in it
The brief arrived, the content was there, but finding anything took an hour. A thousand-page brief with no index is a problem for everyone. The briefs examiners like working with are indexed (table of contents, page references), chronological (not bundled by source), tabbed or bookmarked, volume-controlled (relevant records, not everything), and have a one-page summary up front.
This isn't admin polish. An examiner who can move through the brief quickly spends their time on the clinical work, not file management. Experts talk to each other, the referrers who send well-built briefs get better engagement, faster turnaround, and first pick of slots.
Specialist fit matters more than availability
Mismatch happens when the booking defaults to who's available, or who you've used before, rather than who fits the matter. The orthopaedic surgeon briefed on a chronic pain claim that needed a pain medicine specialist. The report comes back and doesn't carry the clinical authority the matter required.
Another IME. Another six to ten weeks. Another fee. And now two reports on the file that don't always agree, the first doesn't quietly disappear, and the other side will find it. The fix is upstream: before booking, get clear on what the matter actually needs. A good provider should help you choose the specialist based on matter type and the questions you need answered. If they can't, or won't, that tells you something too.
Five things the best briefs get right
- The purpose of the examination. What the report's for and the context it'll be used in.
- The specific questions. Precise, tied to the matter, framed around what needs to be established.
- Complete clinical history. Treating records, imaging, prior reports, injury chronology.
- Relevant background. Pre-existing conditions, work history, functional demands of the role.
- Well-built mechanics. Indexed, chronological, tabbed, volume-controlled, with a one-page summary at the front.
Most briefs cover two or three of these well. The gap between the ones that work first time and the ones that don't is usually half an hour at the front end.
Want this on your desk? Download the one-page IME brief checklist, the five things the best briefs get right.
Greg Freeman is Head of Growth at MEDirect. Without Prejudice is an independent newsletter for legal and claims professionals, published fortnightly. Views expressed are the author's own and do not represent the views of any other organisation. This newsletter is general information only and does not constitute legal, medical, or professional advice.