Building a chronology for a WorkCover Queensland IME brief.

WorkCover Queensland publishes, in one document, both what an independent medical examination report must contain and what the fee for it covers: the examination, the written report and a review of up to 150 pages of referral documentation.¹ Read together, those two lists set the brief for the chronology. It has to gather the history the report must state, and it has to make a brief that often runs well past 150 pages quick to read and easy to check.

This piece works through the Queensland rules in the order an examiner meets them: the report list, the definition of injury in the Act, the page count, and the extra requirements of a permanent impairment assessment. It covers procedure only. What the records mean, and what weight each one carries, stays with the examiner who signs the report.

The report list doubles as the chronology's contents page

The Table of Costs sets out what every IME report must include: the history of the reported event or injury, the treatment history including medication, the worker's background (relevant medical history, social and personal history, and educational and employment history), the clinical examination findings, the results of investigations, a work-related diagnosis, a prognosis and a response to the insurer's specific questions. A psychiatric report must also cover developmental and substance use history.¹

The examination findings come from the room, and the diagnosis, prognosis and answers come from the examiner. Everything else on the list is drawn from the records, which makes the list a sensible set of headings for the chronology itself:

The Table of Costs also expects the examiner to review all material the insurer provides or approves, and where relevant medical information is missing, to ask the insurer for it and, if it cannot be obtained, to say so in the report.¹ A chronology that lists what it found under each heading also shows, by an empty or thin heading, what the brief lacks, which is the point at which that request is worth making.

Section 32 decides where the timeline needs the most detail

Under section 32(1) of the Workers' Compensation and Rehabilitation Act 2003, an injury is a personal injury arising out of, or in the course of, employment if the employment is a significant contributing factor to it. Section 32(3)(b) includes an aggravation of an existing injury, disease or medical condition, and section 32(4) declares that an aggravation is an injury only to the extent of its effects.² When a referral asks for causation, the Table of Costs describes the work as analysing competing causes, pre-existing conditions and differential diagnoses, and treats it as a complex IME.¹

For the chronology, that puts weight on the months and years before the date of injury. Earlier presentations to the same body part, imaging taken before the claim, a previous claim or a period off work all belong in date order with their pages, alongside the first records after the event. A timeline that starts on the date of injury leaves the examiner to find the earlier history in the brief unaided, which is exactly the reading a causation question depends on.

Psychiatric claims bring two further points. Since 30 October 2019, the section 32(1) test, a significant contributing factor, has applied to a psychiatric or psychological disorder as it does to any other injury. For a disorder relating to an injury sustained before then, section 731 keeps the former section 32, under which employment had to be the major significant contributing factor (former section 32(1)(b)).²³ The date of injury in the chronology therefore decides which test the examiner is asked to apply.

Section 32(5) then excludes a psychiatric or psychological disorder arising out of reasonable management action taken in a reasonable way by the employer, the worker's expectation or perception of such action, or action by the Regulator or an insurer in connection with the worker's application for compensation.²

Whether an action was reasonable management action is a question for the insurer, and the chronology does not answer it. What the chronology can do is place the workplace events the records describe, such as a performance meeting, a transfer or a disciplinary letter, in the same timeline as the first record of symptoms, each with its source, so the sequence is visible when a referral asks about it.

The 150-page line arrives early

The IME fee includes a review of up to 150 pages of referral documentation. Beyond that, additional reading time is a separate item that needs the insurer's prior approval.¹ The insurer is to provide the referral documentation 10 days before the appointment, and the provider is told to contact the insurer when documents have not arrived, when the reason for referral or the questions are unclear, or when the volume or nature of the documentation appears excessive or unnecessary for the purpose of the referral.¹

Each of those conversations is easier with an index in hand. A list of the documents in the brief, each with its author, date and page range, gives the page count on the day the brief arrives, shows duplicates and material from outside the claim, and supports a request for approval before the reading is done rather than after. The Table of Costs also treats a first IME more than 12 months after the date of injury as complex, because it requires review of a prolonged medical, diagnostic and treatment history,¹ and those are the briefs where an index pays for itself first.

A workable order for a Queensland brief is therefore:

• index every document and count the pages as soon as the brief arrives;
• check the index against the referral questions and ask the insurer early about anything missing or excessive;
• build the chronology under the report headings, starting before the date of injury;
• mark undated material and unreadable pages as such, so the gaps are recorded rather than filled.

A permanent impairment brief follows the Queensland Guide

A permanent impairment assessment for an injury on or after 15 October 2013 is made under the Queensland Guidelines for Evaluation of Permanent Impairment, second edition, together with the fifth edition of the AMA Guides. For an earlier injury, the fourth edition of the AMA Guides and the Table of injuries apply.¹ The date of injury in the chronology therefore decides which instrument the examiner works from, and it is worth confirming against the claim documents before anything else.

The Guide states what the report must cover. Alongside the medical history, the clinical findings, the methodology and the conclusions, it asks whether the injury is stable and stationary (well stabilised and unlikely to change substantially in the next year, with or without further treatment), whether the findings are medically consistent with the injury's stated mechanism, and any pre-existing impairment considerations. It also says assessors should not comment on whether the claim should have been accepted.⁴ The approved report template follows the same order, with sections for consistency of presentation, stabilisation of injuries, pre-existing impairments and their apportionment.⁵

Three parts of the chronology carry most of that load. The treatment course, with the date of the most recent change and any treatment still proposed, is what the stable and stationary question is read against. Each recorded account of the mechanism, from the first certificate onwards, lets the examiner compare the history given at examination with what earlier reports recorded. The pre-injury history supplies the material for the pre-existing and apportionment sections. The Guide asks for the report within ten working days of the assessment being completed, unless the referrer and the assessor agree otherwise,⁴ so these sections need to be ready before the examination, not assembled after it.

Build to the report headings, and leave the weighing to the examiner

A Queensland chronology earns its place by following the list the report will be checked against, starting before the date of injury, and showing its gaps instead of smoothing them over. It records what each document says and where, including the places where two records disagree, and it stops there. Whether employment was a significant contributing factor, whether an injury is stable and stationary and what share of an impairment was there before are the examiner's findings, and a chronology that keeps to facts with their pages is one the examiner can rely on when stating them.