Expert Review Preparation Guide

A structured framework for organizing records, facts, and clinical questions to streamline expert review and strengthen breach and causation opinions.

Expert Review Preparation Guide

Expert reviews are critical in healthcare negligence cases. The strength of the expert’s opinion depends on how clearly the issues are framed, how cleanly the timeline is structured, and how precisely breach and causation questions are presented.

This guide helps attorneys prepare litigation-ready expert packets that organize key facts, identify breach indicators, and support defensible expert opinions during case screening, expert selection, deposition preparation, and trial strategy.

Case Summary for Expert

Provide a clear, concise summary of the case to help the expert quickly understand the key facts and issues.

Provide a Clear Overview

  • Patient demographics
  • Care setting (hospital, LTC, home health, hospice, ALF)
  • Primary diagnosis and comorbidities
  • Key clinical dates
  • Summary of events
  • Outcome (injury, hospitalization, death)

Highlight Key Issues

  • Change in condition
  • Delayed interventions
  • Missed assessments
  • Medication errors
  • Communication failures
  • Escalation delays

Records to Include

Organize the essential medical records to ensure that the expert has a full picture of the clinical history and actions taken.

Core Medical Records

  • Admission assessments
  • Daily notes and vitals
  • Medication administration records
  • Lab and imaging results
  • Provider orders
  • Care plans
  • Wound care documentation
  • Incident reports
  • Transfer or discharge summaries

Supplemental Records

  • Facility policies
  • Staff training records
  • Staffing schedules
  • Prior complaints or deficiencies
  • EMS reports
  • Hospital transfer records

Clinical Timeline Structure

Provide a clean, organized timeline to illustrate the patient’s clinical course, highlighting delays and gaps in care.

Provide a Clean, Organized Timeline

  • Baseline condition
  • Daily clinical course
  • Change in condition
  • Provider notifications
  • Interventions and reassessments
  • Escalation or transfer
  • Outcome

Highlight Delays or Gaps

  • Missing documentation
  • Contradictory entries
  • Failure to reassess
  • Failure to notify provider
  • Delayed escalation

Breach & Causation Framework

Define expected standards of care, compare them with the actual care provided, and evaluate the causation questions that link the breach to harm.

Identify Expected Standards

  • Regulatory requirements
  • Facility policies
  • Professional guidelines
  • Industry norms

Compare to Actual Care

  • What should have happened
  • What actually occurred
  • Deviations from standards
  • Missed opportunities

Causation Questions

Address the critical causation questions to establish whether the breach led to harm, and how it worsened the patient’s condition.

Key Causation Questions

  • Would timely intervention have prevented deterioration?
  • Did delays worsen the condition?
  • Was the harm foreseeable?
  • Did the breach contribute to injury or death?

Build the Causation Narrative

  • "If X had occurred, Y would likely have been prevented."
  • "The delay in Z allowed the condition to worsen."
  • "Failure to escalate resulted in preventable deterioration."

Submit Records for Expert Review Preparation

Ensure all medical records are HIPAA-secure and expert-ready with organized documentation for efficient analysis.

Submit Records