QME and AME process

What the Appeals Board did with this

Newest released decisions that turned on this issue. Each quotes the passage it turned on and links to the official PDF. Litigated tail — not a win rate, not a settlement value.

• ADJ13039423 · 2026-06-01 · Anaheim District OfficeQME/AME processdefendant prevailed

  Determinative passage · p.10Dr. Betancourt's reports contained thorough and detailed discussions of the issues presented. His opinions and conclusions were framed in terms of reasonable medical probability, were not speculative, and were based on pertinent facts and documents and on an adequate examination and history. Dr. Betancourt also thoroughly set forth his reasoning in support of his conclusions. Based thereon, Dr. Betancourt's opinions constitute substantial medical evidence upon which the Court can rely.

  The court found no good cause to disqualify Dr. Betancourt, as his opinions were based on reasonable medical probability and substantial evidence.

  Official decision · page 10 →
• ADJ20106865 · 2026-05-18 · Pomona District OfficeQME/AME processapplicant prevailed

  Determinative passage · p.7Not only does the letter not explicitly refer to objection, it does not contain any objection whatsoever. Applicant is entitled to retain the control of the QME process and did nothing to lose that control. Thus, defendant waived its right to an objection.

  Defendant's strike letter did not contain any objection to the QME panel specialty, so defendant waived its right to object; applicant was entitled to choose the specialty and chiropractic was appropriate.

  Official decision · page 7 →
• ADJ20938147 · 2026-04-30 · Pomona District OfficeQME/AME processapplicant prevailed

  Determinative passage · p.6Here, defendant's notice of delay was served on May 23, 2025 within California on applicant by regular mail. (Exhibit A.) The parties were therefore required to wait until fifteen (15) days after May 23, 2025, or until the after 5:00 p.m. on June 9, 2025 before requesting a panel. In their panel request, however, defendant indicated that the "date of request for comprehensive exam" was May 22, 2025. (Exhibit B, p. 3.) This is contrary to the facts of the case and contrary to the parties' stipulation to a May 23, 2025 "start date per Labor Code 4062.2." (Minutes of Hearing and Summary of Evidence (MOH & SOE), February 2, 2026, p. 2.) We therefore conclude that considering defendant's usage of an incorrect date, defendant's QME panel request was invalid. Accordingly, the issuance of panel 7823574 is similarly invalid.

  Defendant's QME panel request was premature due to incorrect date usage, making the panel invalid and entitling applicant to a replacement chiropractic panel.

  Official decision · page 6 →
• ADJ17870859 · 2026-04-23 · Lodi District OfficeQME/AME processapplicant prevailed

  Determinative passage · p.9Given the above, we find that a QME in the specialty of neurology (MPN) to address the applicant's post-concussion headaches, post-concussion syndrome and closed head injury, as well as any industrial causation of same, is appropriate.

  The WCAB found good cause for an additional neurology panel based on Dr. Chow's recommendation, applicant's symptoms, and the stipulation of treating physician Dr. Lin reporting headaches, despite defendant's objection to industrial causation.

  Official decision · page 9 →
• ADJ19984698 · 2026-04-14 · Marina del Rey District OfficeQME/AME processdefendant prevailed

  Determinative passage · p.1Defendant seeks removal of the Joint Findings of Fact and Order (F&O) issued on January 12, 2026 by the workers' compensation administrative law judge (WCJ). The F&O found, in pertinent part, that applicant validly requested a Replacement QME Panel on March 5, 2025 (to replace panel number 3593170). The WCJ ordered that replacement QME panel number 3622506 replace panel number 3593170, leaving, after the striking process previously performed by the parties, Kofi D. Agyeman, M.D., as the orthopedic surgery QME in these matters.

  The WCJ and Appeals Board found that the applicant validly requested a replacement QME panel due to Dr. Willoughby's unavailability to schedule within 120 days, and that the replacement panel and Dr. Agyeman as QME were properly appointed.

  Official decision · page 1 →
• ADJ16963666 · 2026-04-13 · San Diego District OfficeQME/AME processdefendant prevailed

  Determinative passage · p.1Defendant contends that the WCJ erred by not issuing a replacement panel in the field of orthopedic surgery and by not deeming inadmissible the medical reporting of the panel qualified evaluator (PQME), James Esch, M.D.

  The Appeals Board found no evidence that Dr. Esch's license was suspended or revoked, only that it was delinquent due to unpaid renewal fees, which was remedied before the decision date, so the replacement panel was not justified and the PQME reports were admissible.

  Official decision · page 1 →
• ADJ11426237 · 2026-03-05 · Lodi District OfficeQME/AME processdefendant prevailed

  Determinative passage · p.84:1), the evidentiary record does not establish medical limitations or other facts or circumstances that would preclude a reevaluation with the current QME. Moreover, applicant's testimony appears to support his ability, "depending on how far he has to go," to engage in air travel and navigate "getting to the airport and through security." (Id. at p. 4:11.) Thus, based on the evidence before us, we cannot conclude that the current record warrants the issuance of a replacement panel of QMEs in neurology. We will grant defendant's Petition and amend the Findings of Fact, accordingly.

  The evidentiary record does not establish medical limitations precluding travel to the QME's new office location, so replacement panel is not warranted.

  Official decision · page 8 →
• ADJ21492524 · 2026-02-17 · Anaheim District OfficeQME/AME processapplicant prevailed

  Determinative passage · p.8However, based upon an inadequate record, we cannot determine whether good cause presently exists as to the validity of the subsequent panel requests by each party, as well as the finding and order by the WCJ for a replacement panel in orthopedic surgery (MOS), and thus we must return the matter to the trial level for further proceedings.

  The WCJ found panel 7875837 was untimely requested and thus invalid, a finding not disputed by parties; however, the WCJ's findings on subsequent replacement requests lacked sufficient evidence and were rescinded, with the matter returned for further proceedings.

  Official decision · page 8 →