Workers' Comp

QME Panel Strategy: When to Strike, When to Hold

The Qualified Medical Evaluator panel-strike decision is one of the highest-stakes early choices in a represented California workers' comp claim. Here is how counsel approach it in 2026.

Medical evaluation form and a printed panel sheet on a desk with a red felt pen

The Qualified Medical Evaluator panel-strike decision is among the highest-stakes early calls in a represented California workers’ comp claim. The mechanics are simple — each side strikes one name from a three-evaluator panel; the remaining evaluator examines the worker. The strategic content is anything but simple.

The Specialty Question

Before deciding whom to strike, applicant counsel reviews the requested specialty. The panel is issued in the specialty the parties stipulated to or that the administrative director assigned. Mismatched specialty — a chiropractic panel for a low-back case with surgical issues, or an internal-medicine panel for a psychiatric claim — is the most consequential early error. Requesting the right specialty is more important than the panel-strike that follows.

What the Strike Decision Turns On

Once the panel issues, applicant counsel typically evaluates three things:

  • Track record. The reporting tendency of each evaluator on permanent-disability ratings, future medical, and apportionment. Counsel maintains rolling lists, sometimes through aggregated services like LookupQME or internal firm databases.
  • Geography. Travel burden on the injured worker, particularly in rural counties or for workers with mobility-limiting injuries.
  • Defense-strike likelihood. If applicant counsel can predict which evaluator the defense will strike, the calculus reduces to a one-of-two pick rather than a one-of-three.

The Hold

Holding the panel — declining to strike, allowing the defense to strike first — is occasionally the right move. It transfers the first-mover information to the other side and can extract intelligence about which evaluator the defense most fears. Hold strategies work best when applicant counsel has confidence that two of the three evaluators would produce acceptable reports.

2026 Practice

The strike-versus-hold distribution in 2026 leans heavily toward striking. The information asymmetry that historically supported the hold has eroded as evaluator track records have become more transparent. Most experienced applicant counsel now strike, choose the evaluator whose reporting baseline best fits the case theory, and move forward.

For carriers and defense counsel, the implication is straightforward: the QME picture is more predictable in 2026 than it was five years ago, which both narrows settlement ranges and rewards specialty-selection rigor.