The medical section of a demand package tells the adjuster what happened to the client, in the order it happened, with the records attached to prove it. Adjusters read hundreds of these, and they read them the same way: story first, then the records, then the two against each other. A summary that the records support gets evaluated on the merits. A summary the records contradict, even in small ways, gets evaluated as advocacy, and every number in it is discounted. The habits below are about being in the first category.
The summary should be written from a timeline built from every page produced, not from the specialist records and the client's account. Two reasons. The first is accuracy: the dates, providers, diagnoses, and findings in the summary have to match the records, and the only way to be sure is to have them all in front of you. The second is that the adjuster will have the whole record, or will get it, and whatever the summary leaves out is what the adjuster will find. A prior complaint in the primary care chart, a gap the summary skipped, a note where the client reported feeling better. Better to know those before drafting and to address them than to have them raised in the response.
Open with the incident as the first treating provider recorded it. The emergency department triage note or the first office visit is the contemporaneous account, and quoting it puts the mechanism on the record in a clinician's words rather than the drafter's. If the client did not seek care for several days, say so and say why, because the adjuster will notice the date either way.
Describe the care chronologically, provider by provider: the diagnosis each made, the treatment each gave, the objective findings each recorded, the referrals, and the imaging with its results. Use the providers' language for diagnoses and findings and cite the page. Report the course as it ran, including the visits where the client improved; a trend that shows improvement and then a plateau or a recurrence is credible, and a summary that omits the improvement is not. Where there was a gap in treatment, address it in a sentence with the reason from the record.
If the record contains prior complaints, prior imaging, or a prior claim involving the same body part, the summary should say so and say what the record shows about resolution and the client's condition before the incident. This is the part drafters most want to leave out and the part that most damages a demand when it surfaces in the response. A prior episode that resolved, followed by a documented symptom-free period, followed by the incident, supports an aggravation claim; the same prior episode discovered by the adjuster in a record the demand did not mention supports nothing.
State where the client is now, from the most recent records: current symptoms, restrictions, the treating provider's statement about maximum medical improvement or future care if there is one. Prognosis and future treatment need a source; a treating physician's note or a retained expert's report, cited, rather than the drafter's estimate.
The itemized medical bills are the number the demand is built on, and the adjuster's first check is whether each billed encounter appears in the treatment records. Billing for a visit with no corresponding note, a therapy course with more billed sessions than attendance entries, or a procedure the records do not mention gets the entire specials figure treated as unreliable. Build the specials from the same chronology as the summary, so every line has a date of service that matches a record entry, and resolve the mismatches before sending rather than after.
Attach the records organized by provider and in date order, with a page index. Attach the imaging reports and, where the finding matters, the images. Include the chronology itself as an exhibit if it is clean and factual; an adjuster who can follow the case on one timeline evaluates it faster and with less suspicion than one who has to build the timeline from a binder. A chronology that argues is not an exhibit, so keep the argument in the letter and the facts in the timeline.
Characterizations of the medicine that no provider made. Causation opinions with no source. Adjectives attached to findings. Anything about the client's suffering that the records do not support and the client cannot testify to. The medical summary is the factual foundation of the demand; the persuasion goes elsewhere in the letter, where it belongs.
A factual chronology attached as an exhibit helps, because the adjuster can evaluate the case on one timeline instead of rebuilding it from the records. Keep the argument in the letter and the chronology neutral; a chronology that argues loses its value as an exhibit.
Yes, where the record contains them. Address the prior episode, what the record shows about its resolution, and the client's condition before the incident. A prior injury the adjuster discovers in a record the demand omitted damages the demand more than the injury itself.
Itemized by provider and date of service, with each billed encounter matching an entry in the treatment records. Reconcile the bills to the notes before sending; unmatched charges are the first thing an adjuster looks for.
No. NaviCase provides the chronology and, in the Summary + Analysis tier, the flagged patterns in the record. The demand and its arguments are counsel's work. The chronology comes back in Word so it can be cut into the letter directly.
A cited chronology in Word, ready to cut into the medical summary and the specials.
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