Review EAMS and Index reports and order records from all prior claims

Review EAMS and Index reports and order records from all prior claims. The information in the EAMs and Index reports as to what body parts were injured can be inaccurate.  If you rely on them and rule out ordering records as a result, you might miss out on evidence that proves the claim is nonindustrial or establishes apportionment.  Subpoena all the records you can identify, as they may lead you to even more relevant records.  Set a diary to send out subpoenas every 3-6 months for updated records, especially on denied claims where the applicant is treating under private insurance or on a lien basis.