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2. Whatever you tell the claims examiner about your physical capacity should be the same as what you tell the IME physician, and should also be the same as any observed activity should the company surveil you just before the exam. Keep in mind when speaking with the insurance company to answer only the questions asked, and then be quiet. Never volunteer or offer additional information other than what is asked. Frankly, this can be very difficult for some claimants, but you must resist the temptation to "tell the story of your life." Be quiet. Answer only the questions you are asked and nothing else.

3. Once you know the date and time of the evaluation, call your primary care physician and make an appointment with him/her preferably after the scheduled IME. Inform your primary care physician at that time that your disability insurer has asked you to submit to an IME. This second examination serves two purposes: 1) it provides documentation of your physical condition by your physician on the same day as the IME exam, and 2) sometimes the IME physician may be a little rough and cause you to swell or have pain. These physical symptoms will be documented by your physician as well. Tell your physician if you have pain, swelling, or any other physical symptoms as a result of the IME. The documentation of your own doctor may be extremely important when pointing out inconsistent and unreasonable conclusions made by the IME physician.

4. You should meet with your attorney, if you have one, in advance to go over all of your prior medical records and history of your present illness. One way in which the IME physician may draw suspicion to your claim is to "catch" you in inconsistencies when you talk about your prior medical history. A simple lapse of memory by not mentioning a particular doctor, or lab test you had in the past is sufficient for the IME doctor to conclude you are trying to hide something and your claim is fraudulent. No prior physician visit or treatment should be left out of your history, as you will certainly be asked about it at the beginning of the exam.

5. You should be prepared either by your attorney, or by studying your own medical records, well in advance of your IME date. Refresh yourself with the following information: chronological medical history; a statement of the nature and extent of disability; the date you first stopped working and why; how your disability has affected your activities of daily living (toileting, transferring, meal preparation, dressing and undressing, preparation of meals etc.); restrictions and limitations given by all treating physicians,; and a complete description of your treatment plan discussed previously with your physician. Only when you are thoroughly prepared for discussing your medical history, can you avoid the "traps" of giving an inaccurate or inconsistent medical history. Skilled IME physicians will literally "pounce" on every omitted detail no matter how insignificant it may seem.

6. Prepare a list of all of the above and place it in your IME folder. When you are asked to provide specific information, just pull the sheet from the folder and give it to the IME physician. Never work from memory during a IME. No one can possibly tell the same story twice. Write it down.