CA Med-Legal: $76 Million Owed For Record Review in First Year

CA Med-Legal: $76 Million Owed For Record Review in First Year

It’s been just over a year since California adopted the new Medical-Legal Fee Schedule (MLFS). Effective April 1, 2021, the new MLFS represented the first increase in fees for Medical-Legal services in 15 years. This MLFS change also revealed the genuinely bonkers amount of medical records attorneys ask physician evaluators to review.

Below, we share data from our 996 physician evaluator clients, and break down code-by-code exactly the Medical-Legal services these physicians provided in the first year of the new MLFS.

Spoiler alert: at $3 per page, those dump trucks full of medical records continue to cost California payers a pretty penny — through no fault of physician evaluators.

MLPRR Data: Record Review Costs Climb

With higher reimbursements for all Medical-Legal services for dates of service starting April 1, 2021, California workers’ comp experts expected a significant increase in overall Medical-Legal expenses. But thanks to billing code MLPRR for medical record review, expenses quickly blew past predictions.

This new MLPRR method of tracking pages of records reviewed by physician evaluators revealed that physicians routinely receive tons more pages of records to review than the amount included in the ‘base’ MLFS evaluation codes. In fact, according to our data, the average Medical-Legal bill on which MLPRR was reported included 1,079 pages of records reviewed.

The result: MLPRR accounted for a whopping 29 percent of the reimbursement owed for 112,178 Medical-Legal bills submitted between April 1, 2021 and March 31, 2022. As shown below, daisyBill Medical-Legal evaluators billed a grand total of $76,523,198 for MLPRR, in the first year under the current MLFS.

Count of Pages Reviewed by Evaluators Since April 1, 2021

From April 1, 2021 to March 31, 2022, daisyBill physician evaluators reviewed 42,421,745 pages of records.

Reimbursement for MLFS evaluation codes ML200, ML201, ML202, and ML203 include payment for what the Division of Workers’ Compensation (DWC) presumably believes are reasonable amounts of records to review for these evaluation codes.

For example, the reimbursement for ML201 (Comprehensive Medical-Legal Evaluation) includes payment for up to 200 pages of record review. Starting with the 201st page, the physician may bill for every page reviewed that exceeds the 200-page limit. Each additional page represents one billable unit of MLPRR, at $3 per unit.

The table below lists the page limits for each Med-Legal evaluation code. For records reviewed in excess of the listed page count, the doctor may bill MLPRR for each additional page.

MLFS Evaluation Code

Record Review Included

ML200 - Missed Appointment

200 Pages

ML201 - Comprehensive Medical-Legal Evaluation

200 Pages

ML202 - Follow-up Medical-Legal Evaluation

200 Pages

ML203 - Supplemental Medical-Legal Evaluation

50 Pages

As noted above, daisyBill clients billed over $76 million for MLPRR between April 1, 2021 and March 31, 2022. This represents over 25 million pages of additional medical records reviewed. Crucially, that’s 25 million+ pages in excess of the allowed records for each evaluation code, for a total of over 42 million pages reviewed.

Below are the staggering numbers of pages reviewed by daisyBill physician evaluators in year one under the current MLFS:

Record Review Included in MLFS Evaluation Code

16,891,650 pages

MLPRR: Additional Record Review

25,530,095 pages

Total Pages of Records Reviewed

42,421,745 pages

Average Pages of Records Reviewed per Evaluation (when MLPRR reported)

1,079 pages

Extrapolate these figures to a statewide scale, and the rate at which medical record review is driving costs becomes mind-boggling.

To be absolutely clear: physician evaluators review the records sent to them by the parties; physicians are not responsible for MLPRR costs. 

We hear regular complaints from physician evaluators being buried under heaps of unorganized medical records. This sometimes includes records that are irrelevant to the dispute at hand, or duplicates of records already reviewed for previous evaluations. If payers have a gripe about Medical-Legal expenses, those gripes should be addressed to the parties’ attorneys.


Make RFAs, billing, and appeals easier than ever — and get paid faster. daisyBill empowers providers to collect what’s owed in record time. Contact us to learn how we can help your practice.

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DaisyBill provides content as an insightful service to its readers and clients. It does not offer legal advice and cannot guarantee the accuracy or suitability of its content for a particular purpose.