How to Prepare for An Independent Medical Examination

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Jeffrey Johnson is a legal writer with a focus on personal injury. He has worked on personal injury and sovereign immunity litigation in addition to experience in family, estate, and criminal law. He earned a J.D. from the University of Baltimore and has worked in legal offices and non-profits in Maryland, Texas, and North Carolina. He has also earned an MFA in screenwriting from Chapman Univer...

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Written by Jeffrey Johnson
Insurance Lawyer Jeffrey Johnson

UPDATED: Jul 16, 2021

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If you are pursuing a personal injury claim, you will likely need to undergo an independent medical exam (IME) by a physician assigned by the defendant or the insurance company.  How you prepare for an independent medical exam can have a significant impact on your case, so you should take some time beforehand to get ready.

Preparing for an Independent Medical Examination

TIP:  Remember that a personal injury independent medical exam is performed by a doctor chosen by the defendant.  The examining physician will report everything you say or do during the IME to the defendant, so it is important that you are careful not to make a statement that diminishes your injury. 

How you prepare for an independent medical exam will help set the tone for your visit.  During the IME you will be asked a series of questions about your injury – how you feel, what activities cause pain, what type of medical treatment you have had, etc.  The treating doctor may not have enough time for you to go into sufficient detail, so you can prepare a written statement to give to the doctor.  Write down:

  • Your current complaints about your injury
  • What types of activities that aggravate the injury
  • What types of activities you can no longer do because of the injury
  • What treatment you have received so far – include what medications you are taking and any physical therapy you are working through

Your statement does not need to be long, and should not get into the details of the accident.  The purpose is to describe your injury and what impact your injury has on your day-to-day life, so keep it focused.  You will still need to answer questions to the IME, so make sure what you say is consistent with your written statement.  If you involve a personal injury attorney in your case, give her a copy of your statement so she is aware of what you said to the IME physician.

Surviving an Independent Medical Examination

What you say and how you behave during the IME will have significant influence on your personal injury claim.  Regardless of what preparations you have made before the exam, what happens during the IME will dictate how the doctor views your injuries.  Keep a few simple tips in mind:

  • Be polite:  The IME physician is selected by the defendant, and may have significant experience disproving plaintiff’s injury claims.  However, you do not need to enter the exam with an adversarial attitude.  Maintain a positive demeanor, regardless of how the IME physician acts.
  • Bring a friend:  In many states, you have the right to invite a witness with you during a personal injury independent medical examination.  Having a witness to the IME can help verify what was said and done should questions later arise.  Do not bring a witness who will confront the doctor or attempt to answer questions on your behalf.  The best witness to an IME is one who doesn’t say a word.
  • Tell the truth:  Although you should avoid making statements that diminish your pain, you should never lie during an IME.  Describe your pain accurately and completely, but do not exaggerate.
  • Relate your pain to daily activities:  Pain is subjective and difficult to adequately describe, so you it may be easier to describe daily activities that worsen your pain.  If you prepared a written statement, you can work from that list.
  • Focus on the relevant facts:  Listen closely to what the IME physician is asking for, and provide answers that address his questions directly.  You do not need to get chatty and go into a detailed account of how your accident occurred or what you have done since.  If the IME doctor asks about the accident, give short and direct answers.  If the doctor asks about the quality of treatment you have received since, stick to the facts about what your previous physicians have done – saying too much will never help and can only hurt your personal injury claim.

Surviving an independent medical exam is not difficult if you prepare yourself before hand, and conduct yourself professionally during the process.  Maintain a calm and polite demeanor, avoid giving more information than the doctor asks for, and clearly describe the pain you are feeling. 

After a Personal Injury Independent Medical Examination

Immediately after leaving the IME, it is a good idea to take some time to write down as much as you can remember about the process, including:

  • What the doctor said
  • What you answered
  • What the doctor did / what tests were performed
  • What time you arrived at the office
  • What time you went into the examination room
  • When the doctor entered and left the room
  • What statements, if any, were recorded

It is not uncommon for plaintiffs to dispute the results of an IME, and having an accurate reflection taken immediately following the exam will help an attorney prepare a response to the doctor’s assessment.  You can ask the doctor’s office if you are permitted to record the IME, however, do not be surprised if your request is denied. 

An IME can be intimidating, but taking time to prepare for one, knowing what to do during one, and recording what happened after the exam can help your personal injury claim.  If you have any questions or concerns about your IME, consult a personal injury attorney

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