California Code of Regulations
Title 8 - Industrial Relations
Division 1 - Department of Industrial Relations
Chapter 1 - Division of Workers' Compensation - Qualified Medical Evaluator Regulations
Article 6 - QME Discipline
Section 65 - Sanction Guidelines for Qualified Medical Evaluators
Current through Register 2024 Notice Reg. No. 38, September 20, 2024
The guidelines for determining appropriate sanctions for physicians licensed as Qualified Medical Evaluators shall be set forth in the Sanction Guidelines for Qualified Medical Evaluators as adopted by the Industrial Medical Council on October 21, 1999, and re-adopted and enforced by the Administrative Director.Sanction Guidelines for Qualified Medical Evaluators
I. PART ONE--OVERVIEW
The purpose of these guidelines is to provide the framework of the Administrative Director's (AD) disciplinary process for those affected by it -- Qualified Medical Evaluators, the Administrative Director, administrative law judges with the Office of Administrative Hearings, licensing boards and other interested parties. These guidelines are not intended to be an exhaustive list of violations or disciplinary actions that the Administrative Director may consider against any QME. Any violation of statutory or administrative duties may constitute grounds for discipline under these guidelines.
The Administrative Director believes that education is the most effective course of action in resolving less serious regulatory violations. These guidelines also set out the parameters for discipline for misconduct considered serious.
The Administrative Director recognizes the need to promulgate uniform guidelines for particular violations in order to establish consistency in imposing disciplinary sanctions for similar offenses. The Administrative Director also recognizes that mitigating or aggravating circumstances in a specific case may necessitate variance from these guidelines.
In the event of a hearing, if an administrative law judge finds that the circumstances of a particular case are not adequately addressed in these guidelines, the Administrative Director may request that the administrative law judge include in the proposed decision an explanation of the recommended sanction and/or terms of probation, so those circumstances are better understood by the Administrative Director during its review of the case for ultimate action.
In cases of violations of Labor Code sections 139.2(k) and 139.2(m) and/or section of Title 860 of Title 8 of the California Code of Regulations, the Administrative Director may impose discipline, up to and including suspension or termination, upon any physician certified by the Administrative Director as a Qualified Medical Evaluator.
In determining the level of the penalty to be imposed in a given case pursuant to section of Title 861 of Title 8 of the California Code of Regulations, the following factors shall be considered:
A respondent may present evidence at a hearing or in the settlement process and shall have the burden of demonstrating mitigating circumstances and/or any rehabilitative or corrective measures he or she has taken. The Administrative Director does not intend, by the following references to written statements, letters, and reports, to waive any evidentiary objections to the form of such evidence. The following are examples of appropriate evidence a respondent may submit to demonstrate his/her rehabilitative efforts and competency:
In the above examples, the mitigating circumstances and/or rehabilitative efforts shall be detailed in any proposed decision or any transmittal memorandum accompanying a proposed stipulation.
If probation is imposed as part of a disciplinary action, the probation shall include:
The number in parenthesis refers to the paragraph number found in the sample Model Disciplinary Order, found in Part Two of these guidelines.
Range of Optional Conditions:
The Administrative Director may also impose other conditions appropriate to the case which are not contrary to public policy or existing law.
II. Part Two -- Violations and Sanctions
The Administrative Director may impose disciplinary sanctions for violations by a Qualified Medical Evaluator of any material statutory or administrative duty (Labor Code § 139.2(k)(1)).
Actions by a Qualified Medical Evaluator for which disciplinary action is appropriate are specified in the California Labor Code, the California Business and Professions Code, the California Penal Code, and Titles 8 and 16 of the California Code of Regulations.
Accordingly, the following, disciplinary sanctions shall be applied by the Administrative Director when a QME is found to be in violation of a material statutory and/or administrative duty.
Minimum sanction: Stayed revocation, 7 years probation and:
If warranted, any or all of the following:
Minimum sanction: Stayed revocation, five (5) years probation and:
If warranted:
Minimum sanction: Stayed revocation and 5 years probation, and:
If warranted, any or all of the following:
Ex.: False statement on QME exam application, appointment application or reappointment application regarding:
- probationary professional license status;
- past criminal conviction related to professional practice;
- completion of minimum continuing education, teaching or practice criteria for appointment or reappointment;
- time spent in direct patient treatment;
- number of QME or AME evaluations done in prior year(s) for purpose of annual fee or for reappointment;
- extent of AME work in lieu of direct patient treatment;
(Representing self as QME with active status when status lapsed).
Minimum sanction: Stayed revocation and 5 years probation, and:
If warranted, any or all of the following:
- misleading or deceptive advertising -- Bus. & Prof. Code § 2271, 651
- failure to include required fraud warning -- Labor Code §§ 5432, 5433
- anonymous advertising - Bus. & Prof. Code § 2272
- misuse of title 'M.D.', 'D.O.', 'doctor', etc. Bus. & Prof. Code §§ 2275, 2276
- use of fictitious name without permit (Bus. & Prof. Code § 2285)
Minimum sanction: Educational material to be provided by the Administrative Director, and:
If warranted, any or all of the following:
Minimum sanctions: Educational material to be provided by the Administrative Director, and:
If warranted, any or all of the following:
Minimum sanction: Educational materials to be provided by Administrative Director, and:
If warranted, any or all of the following:
Minimum sanction: Educational material to be provided by the Administrative Director, and:
If warranted, any or all of the following:
Conduct including but not limited to:
- refusing to schedule unrepresented cases (8 Cal. Code Regs. § 41(a)(2))
- routinely requiring IWs to wait over one hour (8 Cal. Code Regs. § 41(f))
- rescheduling panel QME exam 3 or more times per case (8 Cal. Code Regs. § 41(a)(7))
- switching location of QME exam to address not on QME panel letter (8 Cal. Code Regs. § 34(b))
- failing to serve QME appointment notification form/3 or more instances (8 Cal. Code Regs. § 34(a))
- failure to submit evaluations upon request by the Medical Director
- failure to timely notify the parties of a disqualifying conflict of interest (8 Cal. Code Regs. § 41.5)
- failure to report specified financial interests (8 Cal. Code Regs. §§ 1(ee) and 29)
Minimum sanction: Educational material to be provided by the Administrative Director, and
If warranted, any or all of the following:
- Involving a reckless disregard for available information or facts known to the physician.
Minimum sanction: Stayed revocation and five (5) years probation, with:
If warranted, any or all of the following:
- minimum face-to-face time in evaluation (Labor Code § 139.2(k); Labor Code § 4628; 8 Cal. Code Regs. § 49 et seq.)
- in billing for medical/legal report (Labor Code § 139.2(k); Labor Code § 4628; 8 Cal. Code Regs. § 9795).
Minimum sanction: Educational materials to be provided by the Administrative Director.
If warranted, any or all of the following:
Minimum sanction: Stayed revocation, one (1) year probation, and:
If warranted, any or all of the following:
Minimum sanction: Educational material to be provided by the Administrative Director, and:
If warranted, any or all of the following:
Minimum sanction: Educational material to be provided by the Administrative Director, and:
If warranted, any or all of the following:
- Involving 3 or more instances
Minimum sanction: Educational material to be provided by the Administrative Director, and:
If warranted, any or all of the following:
- Defective declaration(s) required by Labor Code § 4628;
- Serving an unsigned report;
- Omitting discussion in a report of relevant information provided to QME;
- Inadequate or incorrect discussion of factors of disability;
- Other report deficiencies identified by Administrative Director quality review panel;
- Other report deficiencies that affect the substantial rights of a party and are in violation of the regulations governing QMEs;
- Determinations by DEU that a report is not ratable;
- Decisions of Administrative Director granting rating reconsideration;
- Omitting declaration(s) required by Labor Code § 4628.
Minimum sanction: Educational material to be provided by the Administrative Director, and:
If warranted, any or all of the following:
- Three Finding(s) by WCJ under Labor Code § 4628(e) or Labor Code § 139.2(d)(2)
Minimum sanction: Stayed revocation, one (1) year probation, and:
If warranted, any or all of the following:
Minimum sanction: Impose an actual period of suspension (Refer to #3, #4, or #5)
III. PART THREE - SAMPLE MODEL DISCIPLINARY ORDERS
QME certificate number(s) ____________________ issued to Respondent ____________________ is/are revoked.
QME certificate number(s) ____________________ issued to Respondent ____________________ is/are revoked, pursuant to the Determination of Issues (Ex. I, II, and III separately and for all of them.)
QME certificate number(s) ____________________ issued to Respondent is/are suspended for (state time period). Actual suspension starts on the 16th day after the effective date of this decision.
QME certificate number(s) ____________________ issued to Respondent ____________________ is/are suspended for (state time period), pursuant to Determination of Issues (enter ¶ numbers), separately and for all of them. All suspensions shall run concurrently. Actual suspension starts on the 16th day after the effective date of this decision.
QME certificate number(s) ____________________ issued to Respondent ____________________ is/are suspended for (state time period), pursuant to Determination of Issues (enter ¶ number(s)); and (state time period), pursuant to Determination of Issues (enter ¶ number(s)). These suspension shall run consecutively, for a total period of (enter total time period). Actual suspension starts on the 16th day after the effective date of this decision.
However, (revocation/suspension) is stayed and Respondent __________ is placed on probation for (enter time period) upon the following terms and conditions. Within 15 days after the effective date of this decision, the Respondent shall provide the Administrative Director (AD), or his/her designee, proof that Respondent has served a true copy of this decision on:
In the event Respondent's probation was imposed by the Administrative Director pursuant to Labor Code § 139.2(m), due to an order by Respondent's professional licensing board which suspended or imposed probationary status on Respondent's professional license, or due to a misdemeanor or felony conviction related to Respondent's practice or for a crime of moral turpitude, Respondent shall also provide the Administrative Director proof that a true copy of this decision was served on every party for whom Respondent wrote a medical/legal report from the date of the licensing board action or the date of the criminal conviction until the effective date of this decision.
Respondent shall obey all federal, state and local laws and regulations, all rules governing practice as a Qualified Medical Evaluator, all rules in California governing Respondent's professional area of practice, and remain in full compliance with any court ordered criminal probation, payments and other orders.
Respondent shall submit quarterly declarations under penalty of perjury on forms provided by the Administrative Director, stating whether there has been compliance with all the conditions of probation.
Respondent shall comply with the Administrative Director's probation surveillance program. Respondent shall, at all times, keep the Administrative Director informed of his or her addresses of business and residence which shall both serve as addresses of record. Changes of such addresses shall be immediately communicated in writing to the assigned Administrative Director probation monitor. Under no circumstances shall a post office box serve as an address of record.
Respondent shall also immediately inform the Administrative Director, in writing, of any travel to any areas outside the jurisdiction of California which lasts, or is contemplated to last, more than thirty (30) days.
Respondent shall appear in person for interviews with the Administrative Director, his/her designee or his/her designated physician(s) or medical consultant(s), upon request at various intervals and with reasonable notice.
In the event Respondent should leave California to reside or to practice outside the State, or for any reason should Respondent's QME status become inactive in California, Respondent shall notify the Administrative Director probation monitor in writing within ten (10) days of the dates of departure and return, or the dates of inactive QME status in California. Non practice is defined as any period of time exceeding thirty (30) days in which Respondent is not engaging in any activities defined in sections 2051 and 2052 of the Business and Professions Code. All time spent in an intensive training program approved by the Administrative Director or its designee shall be considered as time spent in practice.
Periods of temporary permanent residence or practice outside California or periods of non-practice within California, as defined in this condition, will not apply to the reduction of the probationary period.
Upon successful completion of probation, Respondent's QME certificate(s) shall be fully restored.
If Respondent violates probation in any respect, the Administrative Director, after giving Respondent notice and the opportunity to be heard, may revoke probation and carry out the disciplinary order that was stayed. If an accusation or petition to revoke probation is filed against Respondent during probation, the Administrative Director shall have continuing jurisdiction until the matter is final and the period of probation shall be extended until the matter of the new accusation or petition to revoke is final.
Following the effective date of this decision, if Respondent ceases practicing as a Qualified Medical Evaluator, due to retirement, health reasons or is otherwise unable to satisfy the terms and conditions of probation, Respondent may voluntarily tender his/her QME certificate(s) to the Administrative Director. The Administrative Director reserves the right to evaluate Respondent's request and to exercise its discretion whether to grant the request, or to take any other action deemed appropriate and reasonable under the circumstances. Upon formal acceptance of the tendered QME certificate(s), Respondent will no longer be subject to the terms and conditions of probation.
Upon the effective date of this decision, the Administrative Director shall make a notation on each letter sent to an unrepresented injured worker, which lists Respondent's name on a panel of QMEs, indicating that Respondent is currently on probation as a QME. Administrative Director also shall make a notation next to Respondent's name wherever it appears in each QME roster issued during the period in which Respondent is on probation on the date the roster is issued. Respondent shall answer truthfully any questions from injured workers or other parties about Respondent's probationary QME status.
As part of probation, Respondent is suspended from performing any function as a Qualified Medical Evaluator or an Agreed Medical Evaluator for (enter total time period for suspension), beginning on the sixteenth (16th) day after the effective date of this decision.
Within thirty (30) days of the effective date of this decision, Respondent shall submit to the Administrative Director or his/her designee for his/her prior approval an educational course on forensic evaluator ethics, or on matters related to the violation(s) charged in the accusation, or both. Said course(s) shall be successfully completed by Respondent (enter time for completion), and in any event no later than during the first year of probation. Respondent shall provide theAdministrative Director or its designee with proof of attendance at such course(s).
Completion of any such course required as a term of probation shall be in addition to the continuing medical education requirements for reappointment as a Qualified Medical Evaluator.
Following completion of each course ordered as a term of probation, the Administrative Director or his/her designee may administer an examination to test Respondent's knowledge of the course(s).
Within sixty (60) days of the effective date of this decision, Respondent shall submit to the Administrative Director for its prior approval a clinical training or educational program. The exact number of hours and the specific content of the program shall be determined by the Administrative Director or his/her designee and shall be related to the violations charged in the accusation. Respondent shall successfully complete the training program and may be required to pass an examination administered by the Administrative Director or its designee related to the program's contents prior to performing work as a Qualified Medical Evaluator or Agreed Medical Evaluator.
Within sixty (60) days of the effective date of this decision, (or upon completion of the required education or ethics course) (or upon completion of the required clinical training program), Respondent shall take and pass a(n) (oral, clinical and/or written) examination to be administered by the Administrative Director or his/her designee. If Respondent fails this examination, Respondent must wait three months between reexaminations, except that after three failures Respondent must wait one year to take each necessary reexamination thereafter. Respondent shall pay the costs of all examinations.
(Use either of the following paragraphs with the above paragraph):
Option #1: Condition Precedent
Respondent shall not perform any functions as a Qualified Medical Evaluator or Agreed Medical Evaluator until Respondent has passed this examination and has been so notified by the Administrative Director in writing.
Option #2: Condition Subsequent
If Respondent fails to take and pass the first examination,Respondent shall cease performing any functions as a Qualified Medical Evaluator or an Agreed Medical Evaluator until this examination has been successfully passed and Respondent has been so notified by the Administrative Director in writing.
Respondent shall provide restitution to ____________________ in the amount of $ ____________________ prior to completion of the first year of probation.
During probation, Respondent shall have a third party present while examining, evaluating or treating (enter appropriate: male/female/minor) injured workers. Respondent shall, within fifteen (15) days of the effective date of the decision, submit to the Administrative Director or his/her designee, for his/her approval, the name(s), business and home phone number(s), and business address, of the persons who will act as the third party present. Respondent shall execute a written release authorizing the designated third party(s) to divulge any information that the Administrative Director may request during interviews by the probation monitor on a periodic basis.
Respondent is prohibited from engaging in solo practice. Within thirty (30) days of the effective date of this decision, Respondent shall submit to the Administrative Director and receive his/her prior approval for a plan of practice limited to a supervised, structured environment in which respondent's activities will be overseen and supervised by another QME, who shall provide periodic reports to the Administrative Director.
Within thirty (30) days of the effective date of this decision, Respondent shall submit to the Administrative Director and receive his/her prior approval for a plan of practice in which Respondent's activities as a QME or AME will be monitored by another QME, who shall provide periodic reports to the Administrative Director or his/her designee.
If the monitor resigns or is no longer available, Respondent shall, within five (5) days, provide the Administrative Director or his/her designee the name, address and phone number of a new monitor, for the Administrative Director's approval.
Respondent shall execute a written release authorizing the designated third party(s) to divulge any information that the Administrative Director may request during interviews by the probation monitor on a periodic basis.
Within thirty (30) days of the effective date of this decision, and on a periodic basis thereafter as may be required by the Administrative Director or his/her designee, Respondent shall undergo a psychiatric evaluation by a psychiatrist/psychologist appointed by the Administrative Director. The appointed evaluator shall furnish a report to the Administrative Director or his/her designee.
If Respondent is required by the Administrative Director or his/her designee to undergo psychiatric treatment, Respondent shall within thirty (30) days of the requirement notice, submit to the Administrative Director for his/her prior approval the name and qualifications of a psychotherapist of Respondent's choice. Upon approval of the treating psychotherapist, Respondent shall undergo and continue psychiatric treatment until further notice from the Administrative Director. Respondent shall have the treating psychotherapist submit quarterly status reports to the Administrative Director.
(Optional)
Respondent shall not perform any function as a Qualified Medical Evaluator or an Agreed Medical Evaluator until notified by the Administrative Director of his/her determination that Respondent is mentally fit to resume such forensic practice.
Within sixty (60) days of the effective date of this decision, Respondent shall submit to the Administrative Director for his/her prior approval the name and qualifications of a psychotherapist of Respondent's choice. Upon approval, Respondent shall undergo and continue treatment until his or her treating psychotherapist (i.e. psychiatrist, psychologist, other licensed mental health practitioner) deems that no further psychiatric treatment is necessary. Respondent shall have the treating psychotherapist submit quarterly status reports to the Administrative Director. The Administrative Director may require Respondent to undergo psychiatric evaluations by an Administrative Director-appointed psychiatrist/psychologist.
(Note: This condition is for those cases where the evidence demonstrated that the respondent has had impairment [i.e. impairment by mental illness, alcohol abuse and drug self abuse] related to the violations but is not at present a danger to his/her patients.)
Within thirty (30) days of the effective date of this decision, and on a periodic basis thereafter as may be required by the Administrative Director or his/her designee, Respondent shall undergo a medical evaluation by an Administrative Director appointed physician who shall furnish a medical report to the Administrative Director or his/her designee.
If Respondent is required by the Administrative Director or his/her designee to undergo medical treatment, Respondent shall within thirty (30) days of the requirement notice, submit to the Administrative Director for his/her prior approval the name and qualifications of a physician of Respondent's choice. Upon approval of the treating physician, Respondent shall undergo and continue medical treatment until further notice from the Administrative Director. Respondent shall have the treating physician submit quarterly reports to the Administrative Director.
(Optional)
Respondent shall not perform any functions as a Qualified Medical Evaluator or an Agreed Medical Evaluator until notified by the Administrative Director of his/her determination that Respondent is medically fit to resume forensic practice safely.
(Note: This condition is for those cases where the evidence demonstrates that medical illness or disability was a contributing cause of the violations.)
Within sixty (60) days of the effective date of this decision, Respondent shall submit to the Administrative Director for his/her prior approval the name and qualifications of a physician of Respondent's choice. Upon approval, Respondent shall undergo and continue treatment until the Administrative Director deems that no further medical treatment is necessary. Respondent shall have the treating physician submit quarterly reports to a physician appointed by the Administrative Director to evaluate Respondent. Such reports shall indicate whether Respondent is capable of practicing forensic medicine safely. The Administrative Director may require Respondent to undergo periodic medical evaluations by an Administrative Director appointed physician. The Respondent shall pay the costs of all required evaluations.
(Note: This condition is for those cases where there is evidence that medical illness or disability was a contributing cause of the violations but the Respondent is not at present a danger to his/her patients.)
Respondent shall immediately submit to biological fluid testing, at Respondent's cost, upon the request of the Administrative Director or his/her designee.
Within thirty (30) days from the effective date of this decision, Respondent shall enroll and participate in a diversion program designated by the Administrative Director or his/her designee, until the Administrative Director determines that further treatment and rehabilitation is no longer necessary. Quitting the program without permission or being expelled for cause shall constitute a violation of probation by Respondent.
Respondent shall abstain completely from the personal use or possession of controlled substances as defined in the California Business and Professions Code, or any drugs requiring a prescription. This prohibition does not apply to medications lawfully prescribed to respondent for a bona fide illness or condition by another practitioner.
Respondent shall maintain a record of all controlled substances prescribed, dispensed or administered by Respondent during probation, showing all the following:
Respondent shall keep these records in a separate file or ledger, in chronological order, and shall make them available for inspection and copying by the Administrative Director or his/her designees, upon request.
Respondent shall abstain completely from the use of alcoholic beverages.
Upon the effective date of this decision, the Administrative Director shall make a notation on each letter sent to an unrepresented injured worker, which lists Respondent's name on a panel of QMEs, indicating that Respondent is currently on probation as a QME. Administrative Director also shall make a notation next to Respondent's name wherever it appears in each QME roster issued during the period in which Respondent is on probation on the date the roster is issued. Respondent shall answer truthfully any questions from injured workers or other parties about Respondent's probationary QME status.
Respondent shall submit to the Administrative Director copies of the next five medical/legal reports written by Respondent after the effective date of this decision, in the capacity of a Qualified Medical Evaluator. Respondent shall submit a copy of each such report to the Administrative Director probation monitor within 10 working days of forwarding the report to any party in the case.
Respondent shall ensure all statements regarding Respondent's professional training and area of practice, appearing on letterhead, advertising, business cards, web sites and other public communications, conform to the provisions of Business and Professions Code 651. Further, Respondent shall refrain from using terms, including (state specific terms or phrases used which resulted in discipline). Respondent further agrees to (add specific terms as applicable to case).
1. New section filed 4-14-2000; operative 5-14-2000 (Register 2000, No. 15).
2. Change without regulatory effect amending section filed 10-29-2001 pursuant to section 100, title 1, California Code of Regulations (Register 2001, No. 44). Pursuant to this filing, material adopted pursuant to the Administrative Procedure Act that had previously been incorporated by reference in the California Code of Regulations was instead printed in full in the California Code of Regulations.
3. Amendment of section heading, section and NOTE filed 1-13-2009; operative 2-17-2009 (Register 2009, No. 3).
Note: Authority cited: Sections 133, 139.2 and 5307.3, Labor Code. Reference: Section 139.2, Labor Code.