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Medical record review prompts for defense firms

Medical record review prompts for defense firms test what the record actually supports: which claimed injuries rest only on subjective report, whether treatment intensity matches objective findings, and where pre-existing conditions can and cannot be apportioned. One prompt builds the IME referral from what you found.

The job

Test whether the claimed injuries were caused by the incident, whether the treatment matches the documented findings, and what the realistic exposure is.

Produces

Exposure memo, IME referral, motion practice, cross-examination preparation.

Spine priority

S4, S6, S7, S14, S15, S16, S17, S18, S19, S20, S21, S22. This lane runs the integrity section hardest.

Run order

Spine with emphasis on integrity, then D1 through D4 to build the analysis, then D5 to convert it into an IME referral, then D6 and D7 as the file develops.

The prompts

Run these after the spine prompts marked priority above. Placeholders in angle brackets need filling in.

D1

Treatment intensity analysis

Compare documented treatment frequency and duration against the objective findings supporting it. Identify encounters or courses of treatment where the intensity is not matched by documented objective findings. Report as observation with citations, not conclusion.

The neutral-report clause is not politeness. An output phrased as a conclusion is one you have to re-verify before using, and it reads badly if it surfaces in discovery.

D2

Objective findings audit

For each claimed injury, list the objective findings supporting it separately from subjective reports. Identify claimed injuries supported only by subjective report.

The cleanest prompt in this lane. It runs the three-state doctrine directly at the central question.

D3

Apportionment

For each body region, separate findings attributable to documented pre-existing conditions from findings first documented after the incident. Quote the pre-incident baseline. Identify where the record does not permit apportionment.

The closing clause is the honest one and it will fire often. Records frequently do not permit apportionment, and saying so early is better than discovering it through an expert.

D4

Alternative causation

Identify records supporting causes other than the incident: pre-existing conditions, intervening events, degenerative findings, unrelated diagnoses, occupational or recreational activity. Cite each.
D5

IME referral construction

Based on gaps, contradictions, and unresolved causation questions in these records, draft the questions an independent medical examiner should be asked to address. For each question, cite the record basis that makes it necessary.

This is the highest-leverage prompt in the lane. A referral built from identified record problems produces a far more useful examination than a generic question set, and it gives the examiner the record basis rather than a framing.

D6

Provider relationship indicators

Identify any documented referral relationships, letters of protection, liens, or billing arrangements appearing in the records. Report only what is documented, with citations.

Documented only. Inference here is both unreliable and, if it surfaces, damaging.

D7

Testimony-record conflicts

Compare deposition or recorded statement testimony against the medical records. Identify every conflict, with the testimony quoted, the contradicting record quoted, and both citations.

Lane failure mode: anchoring, mirrored. Ask for weaknesses and you will receive them, including some that are artifacts of an incomplete production. Cross-check every gap and every missing record against S4 before it becomes an argument. A gap that is really an unproduced file is a bad argument that gets corrected in front of the mediator.

Professional responsibility. Same competence and supervision frame as Lane 1. Additionally, findings that drive a coverage or claims decision may carry unfair claims practice exposure if they rest on unverified output, which is a Tier 1 verification question rather than a technology question.

Lane failure mode: anchoring, mirrored

Ask for weaknesses and you will receive them, including some that are artifacts of an incomplete production. Cross-check every gap and every missing record against S4 before it becomes an argument. A gap that is really an unproduced file is a bad argument that gets corrected in front of the mediator.

Professional responsibility

Same competence and supervision frame as Lane 1. Additionally, findings that drive a coverage or claims decision may carry unfair claims practice exposure if they rest on unverified output, which is a Tier 1 verification question rather than a technology question.

Issues to raise, not answers. Requirements vary by jurisdiction, and none of this is legal advice.

Run these on a file you already have

Send one real record set. You get back a cited chronology, and you review it, you revise it, you sign it.

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Last verified: 2026-09-08 · ← All 71 prompts