How do I respond to the IME doctor’s questions?
First, be candid and honest. IME doctors look for any reason to report that you are exaggerating.
Answer only the questions you are asked. It’s best not to volunteer information. This can be a hard rule to follow, but it’s very important.
Never guess at an answer. An approximation is as good as an exact answer. Guessing will get you in trouble. It’s okay to tell the doctor that you don’t know or are not sure of the answer to a question.
It’s good to let the doctor know if you are continuing to improve with treatment. This shows that the care you are getting from your medical providers is helping you.
If asked, tell the doctor about similar injuries or health conditions you have had in the past, even if they were minor. If you tell the doctor something that is inconsistent with your current or past medical records, the insurance company will accuse you of being dishonest.
If you had similar pain, discomfort or limitations before the collision, you will probably be asked to compare your symptoms before and after the collision.
It can help to answer that question in terms of frequency, duration and intensity. For example, before the collision your symptoms may have been occasional and mild, but after the collision they were more intense and frequent. Maybe you couldn’t (or still can’t) do things after the collision that you could do before. Think about these things before the IME.
Before you go to the IME make sure you talk with an attorney. The better prepared you are, the better you will do.