Med-Legal Data: MLPRR Charges Continue to Climb

Med-Legal Data: MLPRR Charges Continue to Climb

California Medical-Legal record review expenses soared into the wide blue yonder after the Division of Workers’ Compensation (DWC) updated the Medical Legal Fee Schedule (MLFS) effective April 1, 2021.

In November, daisyBill published a post on the apparent correlation between climbing MLFS costs and the introduction of MLPRR which reimburses California evaluators $3 per page of record review.

Surprisingly, as a percentage of the total medical-legal expenses owed to daisyBill clients, MLPRR expenses remain the same as reported in November 2021, even though the number of medical-legal bills doubled.

Attorney Requests = Higher Med-Legal Bills

The official purpose of the MLPRR billing code is to provide physicians a way to receive reimbursement for review of records beyond the number of pages included in “base” Medical-Legal numerical billing codes ML200, ML201, ML202, and ML203.

As we noted in our prior post, the reimbursement for each of these numerical billing codes includes payment for record review up to the following page limits:

MLFS Evaluation Code

Record Review Reimbursement Included in MLFS Evaluation Code

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

However, attorneys regularly dump documents far in excess of 200 pages on physician evaluators for review. MLPRR ensures Medical-Legal physicians are compensated for the extra time required to sift through the additional pages of records.

Moreover, MLPRR offers a tangible way to track precisely the count of pages lawyers are shipping to doctors’ doorsteps for review. (Hint: It’s way more than the DWC originally expected.)

Medical-Legal Fee Schedule Bills Data: April 1, 2021 - January 13, 2022

In the nine plus months since the new MLFS became effective, daisyBill data for medical-legal bills submitted by our clients demonstrate the following:

  • 80,490 medical-legal bills submitted using the new MLFS billing codes
  • Per the MLFS, $187,626,725 is due for the 80,490 medical-legal bills
  • $54,719,750 reimbursement is due for physician review of additional records (MLPRR)
  • MLPRR represents approximately 29% of the total reimbursement due for all 80,490 bills

Remember, as noted above, the reimbursement for each of these numerical billing codes includes payment for record review up to an established page limit. The $54.7 million in MLPRR expenses demonstrates the following:

  • Physicians reviewed 12 million pages of records as allowed by the numerical billing codes
  • Physicians also reviewed an additional 18 million pages of medical records as reported by MLPRR
  • Total pages of records reviewed by physician evaluators reporting MLPRR: 30 million pages

MLPRR Comparison: October 2021 vs January 2022

Surprisingly, a comparison of the MLPRR data published by daisyBill in November to the current data displayed above demonstrates that MLPRR’s outsized impact on total Medical-Legal expenses remains precisely the same.

As shown below, this trend has continued unchecked since MLPRR was first implemented.

Date of Service (new MLFS, only)

April 1, 2021 - Oct. 12, 2021

April 1, 2021 - Jan. 13, 2022

Total MLFS Expenses



MLPRR: Total Record Review Expense



Percent of MLPRR Expense to Total MLFS Expense



For years, our Medical-Legal physician clients have expressed frustration over being inundated by all parties’ attorneys with piles of irrelevant, disorganized, and duplicated medical records. Now, the cost of this obnoxious practice can be easily tracked in terms of page numbers and cold hard cash.

With the numbers laid out plainly, the question remains: Who’s going to
do something about it (other than blame physician evaluators for the high cost of medical-legal evaluations)?

Make workers’ comp a better investment. From fee schedule calculators to billing software to complete managed billing, daisyBill has your back. Contact us to learn more.


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