January 30, 2026 | Sacramento, CA — MedLegalNews.com — MLPRR is emerging as a major medical-legal cost driver in California, quietly reshaping workers’ compensation expense profiles for employers and insurers through record review charges billed by Qualified Medical Evaluators and Agreed Medical Evaluators.
In 2023, QMEs and AMEs billed more than $93 million statewide for medical-legal record review services exceeding standard page limits, according to billing analytics published by daisyBill. The charges were submitted under billing code MLPRR, which allows additional reimbursement when medical-legal reviewers assess voluminous records beyond base thresholds.
The data points to a significant escalation in both utilization and total spend—raising concerns about medical-legal inflation, claim complexity incentives, and downstream exposure for payers.
How MLPRR Became a Material Cost Driver
Medical-legal record review charges apply when evaluators exceed the standard number of pages allowed for review as part of a comprehensive medical-legal evaluation. While originally designed to compensate for genuinely complex cases, MLPRR billing has expanded alongside increasingly large claim files.
According to daisyBill’s analysis, the growth is not driven by higher per-page rates, but by volume—more pages submitted, more frequent billing of add-on review time, and broader use across disputed claims.
As claim files now routinely include years of treatment records, utilization review decisions, imaging reports, and prior evaluations, MLPRR has evolved from a marginal fee into a recurring expense category.
Why QMEs and AMEs Drive the Spend
QMEs and AMEs occupy a pivotal role in California’s dispute resolution system. Their evaluations often determine compensability, apportionment, and permanent disability ratings—making their record review workload central to claim outcomes.
However, payer advocates note that the incentive structure is misaligned. The more records submitted, the more billable review time becomes available, regardless of whether the additional materials meaningfully affect the evaluator’s conclusions.
For employers and carriers, this translates into higher medical-legal spend without corresponding predictability or measurable value.
What the Data Signals for Employers and Insurers
The $93 million figure underscores a broader trend: medical-legal costs are no longer confined to evaluation fees alone. Ancillary charges—record reviews, supplemental reports, and follow-up analysis—now represent a growing share of total exposure.
Claims professionals warn that unchecked growth in MLPRR utilization could:
- Inflate litigation-driven claim costs
- Increase friction in settlement negotiations
- Mask inefficiencies behind technical billing compliance
Absent clearer utilization controls, MLPRR may continue expanding regardless of claim merit.
Why Oversight and Reform Discussions Are Emerging
The timing of the data is notable. California regulators are already weighing reforms tied to medical-legal accountability, fraud detection, and cost containment across the workers’ compensation system.
While MLPRR billing itself is lawful, employer groups argue that rising utilization mirrors patterns seen in other areas where billing rules are permissive but oversight is limited.
As fraud enforcement actions and audits increase elsewhere in the system, medical-legal billing practices are drawing closer scrutiny.
What Comes Next
Industry observers expect greater emphasis on:
- Standardizing record submission limits
- Enhancing audit protocols for medical-legal invoices
- Aligning reimbursement with demonstrated analytical necessity
Without intervention, MLPRR charges are likely to remain a persistent and growing cost line for California payers.
For additional data and billing insights, readers can review daisyBill’s medical-legal analytics here.
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FAQs: Medical-Legal Record Review Costs
What is MLPRR in California workers’ compensation?
MLPRR is a billing code used by QMEs and AMEs to charge for medical-legal record review time that exceeds standard page limits.
Why are record review costs increasing?
Growth is driven primarily by larger claim files and increased utilization of add-on review time, not higher reimbursement rates.
Who pays MLPRR charges?
Employers and workers’ compensation insurers are responsible for paying approved medical-legal record review charges.
Are MLPRR charges regulated?
Yes, but critics argue current rules allow broad discretion, contributing to cost escalation.