Tuesday, December 31, 2013

In Arizona, You Can Tape-Record Your Independent Medical Examination ("IME")





On Nov. 20, 2012, an Arizona court decided whether a workers’ compensation insurance carrier could suspend an injured worker’s benefits for obstructing an independent medical examination (“IME”) because the injured worker stated she was going to tape-record (audio) the examination.

An independent medical examination is simply when a medical professional (usually selected by the insurance carrier) who has not previously seen the injured worker as a patient examines the injured worker.

The issue was brought before the court because Arizona law states that “[i]f the employee refuses to submit to the medical examination or obstructs the examination, his right to compensation shall be suspended until the examination has been made, and no compensation shall be payable during or for such period.”[1]

 The court concluded that a “claimant, who expressed an intention at [the] beginning of [an] independent medical examination (IME) to tape-record the IME, without having made any prior communication about recording it, did not commit a “wrongful act” constituting obstruction of IME”[2]

What does this mean?

 As an injured worker who is seeking to receive workers’ compensation and who is asked to see a doctor to have an IME performed, you can tape record the independent medical examination using an audio recorder.

Why is this important?

The Kwietkauski holding specifies that when you express “an intention at the beginning” of your IME to tape-record the examination, that recording cannot be said to be a “wrongful act” constituting an obstruction.[3] Many cases in Arizona have further stated that “benefits may not be suspended in the absence of a wrongful act by the employee.”[4] You as the injured worker “must ‘volitionally’ (consciously) refuse to attend or obstruct the IME.

What if the IME physician does not allow the tape recording?

Under Arizona law, you have a legal right to audio record your independent medical examination. If the IME physician refuses to allow you to record the examination, he may, “[b]ut a doctor’s policy or preferences [do] not trump [your] right to record [your] IME.”[5] Just remember that the doctor does have the right to say no to the recording or refer you to another physician.

When do I seek counsel from a licensed and competent attorney in good standing with the state of Arizona?

A medical examination can sometimes be an overwhelming experience and not knowing what you can and cannot do only adds to the pressure. As an injured worker you want to be sure that you take all the right steps to ensure your rights are secured so that you can receive the medical care you deserve. The counsel of a competent attorney certified by the State Bar of Arizona as a workers’ compensation specialist is a great way to ensure that you get all your questions answered so that you are able to boldly move forward toward achieving your desired legal goal.

Meet Benjamin F. Manion, a Certified Specialist in Workers’ Compensation by the State Bar of Arizona at Taylor and Associates, PLLP



Benjamin F. Manion is a certified specialist in workers’ compensation by the state bar of Arizona with over 10 years’ experience as a licensed attorney. Mr. Manion is fluent in Spanish and a graduate of Arizona State University.

Contact Mr. Manion on the web at www.TaylorandAssociates.net or by phone at 1-888-650-4798 for your free consultation.

Attorney Advertising. This web site is designed for general information only. The information presented at this site should not be construed to be formal legal advice nor the formation of a lawyer/client relationship.


[3] Id.
[4]Edmunds v. Indus. Comm’n, 126 Ariz. 486, 487, 616 P. 2d 946, 947 (App. 1980); Garza v. Indus. Comm’n, 17 Ariz. App. 525, 530, 498 P. 2d 599, 604 (1972).  

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