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Comments to Proposed Designated Doctor Plan Based Audit

November 2, 2012                                               Bulletin 2012 – No. 6


John D. Pringle has commented by letter on the Texas Department of Insurance, Division of Workers’ Compensation’s (DWC) Medical Director’s Designated Doctor Plan-Based Audit which comments were solicited by Dr. Donald Patrick on October 23, 2012. 


A portion of the comments from page 4 of the letter are set out below:


The present Section IV of the Plan-Based Audit sets out a time frame to select data for purposes of the audit.  The time frame is for designated doctor examinations that occurred from September 1, 2011, through February 29, 2012.   The Plan-Based Audit should be prospective and not retrospective.  Auditing designated doctors for conduct occurring prior to the adoption of the Plan-Based Audit with its criteria is certainly unfair and may be unconstitutional.


To see the entire letter click here.




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