Record Review Sends Med-Legal Costs Soaring

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Record Review Sends Med-Legal Costs Soaring

Like a bored multi-billionaire, Medical-Legal expenses for California workers’ comp are needlessly approaching the stratosphere.

Our data point to the primary reason: attorneys regularly dumping a glut of Medical-Legal records on physician evaluators for review.

With the introduction of $3 per page record review billing code MLPRR under the newly revamped Medical-Legal Fee Schedule (MLFS), record review represents a massive slice of overall Medical-Legal expenditures. Data representing tens of thousands of bills from our Medical-Legal physician clients tell the tale.

With its debut on April 1, 2021, the new MLFS represented the first increase in reimbursement rates for physician evaluators in 15 years. Industry experts expected a commensurate rise in the amounts billed, but soon realized that Medical-Legal expenditures were handily outpacing predictions.

The data from the over 47,000 bills submitted by DaisyBill physicians between April 1st and October 18th reveals the reason for the increased Medical-legal expenditures: attorneys.

MLPRR for Med-Legal Record Review

Reimbursement for MLFS “base” codes ML200, ML201, ML202, and ML203 include payment for a reasonable amount of medical record review. For example, reimbursement for ML201 (for a 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 that exceeds the 200-page limit. Each additional page represents one billable unit of MLPRR, at $3 per unit.

The page limits after which MLPRR applies are as follows:

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

Physician evaluators often receive many, many more pages of medical records to review than the pages allowed by the evaluation codes. Frequently, attorneys on both sides dump thousands of pages on the evaluator. In fact, according to our data, the average Medical-Legal bill on which MLPRR was reported included 1,100 pages of records reviewed.

Needless to say, the charges for MLPRR add up quickly.

The result: MLPRR accounts for a stunning 29 percent of the total amount billed for Medical-Legal services by our clients, as the data show below.

As demonstrated above, MLPRR accounted for almost $32 million dollars billed since the April 1 debut of the new MLFS. That’s out of a grand total of $110,481,117 billed by all DaisyBill physician evaluators in the same time frame.

Pages of Medical Records Reviewed by DaisyBill Physician Evaluators Since April 1, 2021

The $32 million billed for MLPRR this year alone represents over 10 million pages of ADDITIONAL medical records reviewed. Crucially, that’s 10 million pages in excess of the base codes’ page limits. DaisyBill physician evaluators reviewed over 7 million pages before they could charge a dime for MLPRR, for a grand total of almost 18 million pages reviewed.

Record Review Included in MLFS Evaluation Code

7,236,501 pages

MLPRR: Additional Record Review

10,652,947 pages

Total Pages of Records Reviewed

17,889,448 pages

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

1,100 pages

Extrapolate these figures to a statewide scale, and there’s only one logical conclusion: Attorneys sending evaluators records is driving costs for Medical-Legal evaluations through the roof.

Physician evaluators, despite their first “raise” in a decade and a half, are not responsible for this — the parties’ attorneys are.

We hear complaint after complaint from physician evaluators being buried in unorganized medical records, shipped by the boxload from the parties. This sometimes includes records that are irrelevant to the dispute, or duplicates of records already reviewed from previous evaluations — and rarely in date order.

Any narrative which implies some kind of greed on the part of physician evaluators as an explanation for rising Medical-Legal costs is a Tolkien-level fantasy. Going forward, conversations about controlling Medical-Legal expenses should start with the stacks of medical records currently testing the structural integrity of physician’s desks statewide.


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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