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 reviews are critical in healthcare negligence cases. The quality of the expert’s opinion depends heavily on how well the case is organized and how clearly the issues are framed.
This guide helps attorneys prepare comprehensive, litigation‑ready expert packets that highlight key facts, identify breach indicators, and support strong, defensible expert opinions.
Use this tool during case screening, expert selection, and pre‑deposition preparation.
CASE SUMMARY FOR EXPERT
✔ Provide a Clear Overview
• Patient demographics
• Setting (hospital, LTC, home health, hospice, ALF)
• Primary diagnosis
• Comorbidities
• Key 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
✔ Core Medical Records
• Admission assessments
• Daily notes
• 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 records (if transferred)
CLINICAL TIMELINE FOR EXPERT
✔ Provide a Clean, Organized Timeline
• Baseline condition
• Daily clinical course
• Change in condition
• Provider notifications
• Interventions
• Reassessments
• Escalation or transfer
• Outcome
✔ Highlight Delays or Gaps
• Missing documentation
• Contradictory entries
• No reassessment
• No provider notification
• Delayed escalation
BREACH ANALYSIS FRAMEWORK
✔ Identify Expected Standards of Care
• Regulatory requirements
• Facility policies
• Professional guidelines
• Industry norms
✔ Compare to Actual Care
• What should have happened
• What actually happened
• Deviations from standards
• Missed opportunities
CAUSATION ANALYSIS PREP
✔ Provide Key Causation Questions
• Would timely intervention have prevented deterioration?
• Did delays worsen the patient’s condition?
• Was the harm foreseeable?
• Did the breach contribute to injury or death?
✔ Provide Supporting Evidence
• Timeline excerpts
• Abnormal labs or vitals
• Missed interventions
• Documentation gaps
QUESTIONS FOR THE EXPERT
✔ Breach Questions
• Did the provider meet the standard of care?
• Were assessments timely and complete?
• Were interventions appropriate?
• Should escalation have occurred sooner?
✔ Causation Questions
• Did the breach contribute to harm?
• Would earlier intervention have changed the outcome?
• Was the deterioration preventable?
✔ Systemic Questions
• Were staffing levels adequate?
• Were policies followed?
• Were there systemic failures?
PACKET ORGANIZATION
✔ Recommended Structure
• Cover sheet
• Case summary
• Timeline
• Key records
• Highlighted excerpts
• Policies
• Expert questions
• Exhibits
✔ Formatting Tips
• Use clear headings
• Highlight key facts
• Remove duplicates
• Organize chronologically
• Include only relevant records