For attorneys 5 min read
Anatomy of a defensible narrative report
A narrative report that survives cross-examination reads the same way whether it helps or hurts the retaining party. These are the structural elements we build into every report.
1. A complete records inventory
Every document reviewed is listed with source and date range, and gaps are stated explicitly. An opinion built on an undisclosed subset of records is the easiest thing in the world to impeach.
2. History taken from the claimant, not the file
The report distinguishes what the examinee reported, what the records show, and where the two diverge — without editorializing about credibility.
3. Objective findings separated from subjective report
Measured range of motion, strength grades, reflexes, and provocative test results are recorded as data. Pain reports are recorded as reports. Blurring the two is the most common reason an opinion gets discounted.
4. Causation reasoning that is actually shown
Mechanism of injury, temporal relationship, biological plausibility, pre-existing conditions, and alternative explanations are each addressed. A bare conclusion of 'causally related' with no reasoning behind it carries no weight.
5. Clear statements on MMI, impairment, and restrictions
Whether maximum medical improvement has been reached, any impairment rating with the edition and tables used, functional restrictions, and the basis for future care recommendations.
What to ask before you retain
A short diligence checklist saves months.
- Turnaround time from records receipt to draft
- Whether the examiner performs both plaintiff- and defense-side work
- Deposition and trial testimony availability
- Whether addenda are issued when new records arrive
Key takeaway
Look for a stated records inventory, a clean split between objective and subjective findings, and causation reasoning that is written out rather than asserted.
Have questions about your own case?
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