QME Billing Made Simple: A Clear Breakdown of MLFS Rules and Rates (CCR §9795)
California’s Qualified Medical Evaluators (QMEs) are paid according to a specific, state-regulated structure — the Medical-Legal Fee Schedule (MLFS). The new Fee Schedule has been in effect since April 1, 2021, but many physicians unknowingly bill incorrectly and leave money on the table.
At United Medical Evaluators (UME), we help doctors bill accurately under the current MLFS, avoid compliance issues, and ensure all permissible fees are captured.
💼 Overview of the Medical-Legal Fee Schedule
The MLFS is governed by CCR §9795 and §9795.1, effective April 1, 2021. It establishes:
· Flat fees for specific medical-legal services (ML200–ML203)
· Add-on fees for excess records, extended evaluations, and interpreter coordination — if properly documented
🧾 Core Medical-Legal Service Codes
Billing Code, Description, & Reimbursement
ML200 Missed Appointment
Missed appointment for a Comprehensive or Follow-Up Medical-Legal Evaluation, $503.75
ML201 Comprehensive Medical-Legal Evaluation
All comprehensive medical-legal evaluations that do not qualify as follow-up or supplemental medical-legal evaluations, $2,015
ML202: Follow-up Medical-Legal Evaluation
Follow-up medical-legal evaluation by a physician which occurs within eighteen (18) months of the date on which a prior comprehensive medical-legal evaluation was performed by the same physician, $1,316.25
ML203: Supplemental Medical-Legal Evaluation
Services for writing a report after receiving a request for a supplemental report from a party to the action, or receiving records that were not available at the time of the initial or follow-up comprehensive medical-legal evaluation, $650.00
ML204: Medical-Legal Testimony
All itemized reasonable and necessary time spent related to the testimony, including reasonable preparation and travel time, $455/hour ($113.75 per each 15-minute increment)
ML205: Sub Rosa Recording Review
Time spent reviewing sub rosa recordings. $325/hour ($81.25 per each 15-minute increment)
MLPRR: Record Review
Used to identify charges for review of records in excess of pages included in medical-legal numerical billing codes, $3.00 per page
➕ Fee Schedule Detailed Breakdown
ML200 Missed Appointment
The injured worker does not show up for the evaluation
The interpreter does not show up for the evaluation which makes it impossible to go forward with the exam
The injured worker leaves the evaluation before the completion of the evaluation
The injured worker is more than 30 minutes late for the appointment and the QME is unable to continue with the scheduled QME appointment
The appointment has been canceled within six business days of the scheduled appointment date.
If the physician produces a record review report within 30 days of the date of the missed appointment the physician shall be reimbursed at the rate of $3.00 per page for any records reviewed in excess of 200 pages.
Any pages reviewed for this record review report will be excluded from the page count for reimbursement when the face-to-face or supplemental evaluation takes place.
ML201 Comprehensive Medical-Legal Evaluation
Includes all comprehensive medical- legal evaluations that do not qualify as
Follow-up or Supplemental Medical-Legal Evaluations
The fee includes review of 200 pages of records
Review of records in excess of 200 pages shall be reimbursed at the rate of $3.00 per page
ML202: Follow-up Medical-Legal Evaluation
Follow-up medical-legal evaluation by a physician which occurs within eighteen (18) months of the date on which a prior comprehensive medical-legal evaluation was performed by the same physician,
The fee includes review of 200 pages of records that were not reviewed
as part of the initial comprehensive medical-legal evaluation
or as part of any intervening supplemental medical-legal evaluations.
Review of records in excess of 200 pages that were not reviewed as part of the initial comprehensive medical-legal evaluation or as part of any intervening supplemental medical-legal evaluations shall be reimbursed at the rate of $3.00 per page
ML203: Supplemental Medical-Legal Evaluation
Services for writing a supplemental report after receiving a request for a supplemental report from a party to the action, or receiving records that were not available at the time of the initial or follow-up comprehensive medical-legal evaluation
Fees will NOT be allowed under this section for supplemental reports:
Following the physician's review of information which was available in the physician's office for review or was included in the medical record provided to the physician prior to preparing a comprehensive medical- legal report or a follow-up medical-legal report; or
Addressing an issue that was requested by a party to the action to be addressed in a prior comprehensive medical-legal evaluation, a prior follow- up medical-legal evaluation, or a prior supplemental medical-legal evaluation.
The fee includes review of 50 pages of records
Review of records in excess of 50 pages that were received as part of the request for the supplemental report shall be reimbursed at the rate of $3.00 per page
ML204: Medical-Legal Testimony
The physician shall be reimbursed $455/hour or his or her usual and customary fee, whichever is less
Time is rounded to the nearest quarter hour, spent by the physician
The physician shall be entitled to fees for all itemized reasonable and necessary time spent related to the testimony, including reasonable preparation and travel time
The physician shall be paid a minimum of two hours for a deposition
If a deposition is canceled fewer than eight (8) calendar days before the scheduled deposition date, the physician shall be paid a minimum of one hour for the scheduled deposition
ML205: Sub Rosa Recording Review
The physician shall be reimbursed at the rate of $325.00/hour or his or her usual and customary hourly fee, whichever is less, for each quarter hour or portion thereof, rounded to the nearest quarter hour, spent by the physician for time spent reviewing sub rosa recordings.
The fee for reviewing sub rosa recordings may be allowed in addition to any fee for any single report written by the physician as a result of the review of the sub rosa recordings.
If the sub rosa recordings are received by a physician prior to the issuance of a pending report related to a medical-legal evaluation, the physician may not also bill a supplemental report fee in connection with the review of the sub rosa material.
📄 MLPRR - Record Review
ML200, 201 & 202
Base fee includes review of up to 200 pages
If more than 200 pages are reviewed:
Bill $3.00 per page over 200 pages
This pertains to records that were not previously reviewed as part of the initial comprehensive medical-legal evaluation or as part of any intervening supplemental medical-legal evaluations
No time tracking required
Must be documented in your report
✅ Example: Reviewed 575 pages for an ML201? You may bill 375 pages × $3.00 = $1,125.00 additional
ML203 (Supplemental Reports)
Base fee includes up to 50 pages of records
If more than 50 pages are reviewed (after the initial evaluation):
Bill $3.00 per page over 50
Applies only to new records received after the ML201/ML202
Must be documented
✅ Example: If you receive 200 new pages post-evaluation, you may bill 150 excess pages × $3.00 = $450.00
🧾 Record Review Details
Record review must be conducted by the physician
Records are documents sent to the physician in connection with a medical-legal evaluation or request for report.
The documents may consist of medical records, legal transcripts, medical test results, and or other relevant documents.
A page is defined as an 8 ½ by 11 single-sided document, chart or paper, whether in physical or electronic form.
Multiple condensed pages or documents displayed on a single page shall be charged as separate pages.
Documents sent to the physician for record review must be accompanied by a declaration under penalty of perjury that the provider of the documents has complied with the provisions of Labor Code section 4062.3 before providing the documents to the physician.
The declaration must also contain an attestation as to the total page count of the documents provided.
A physician may not bill for review of documents that are not provided with this accompanying required declaration from the document provider.
Any documents or records that are sent to the physician without the required declaration and attestation shall not be considered available to the physician or received by the physician for purposes of any regulatory or statutory duty of the physician regarding records and report writing.
When billing for a record review, MLPRR, the physician shall include in the report a verification under penalty of perjury of the total number of pages of records reviewed by the physician as part of the medical-legal evaluation and preparation of the report.
🚫 Non-Billable Items (Across All Codes)
Per §9795.1(d), the following are not reimbursable:
Staff time, clerical time, or administrative overhead
Photocopying, faxing, or mailing costs
Office expenses (rent, phone, EHR systems)
Time preparing invoices
🌐 Medical-Legal Modifiers
The services described by Procedure Codes ML-201 through ML-203 may be modified under the circumstances described in this subdivision.
The modifiers shall not be applicable to per page charges for record review in any of the Procedure Codes ML-201 through ML-203.
The modifying circumstances shall be identified by the addition of the appropriate modifier code, which is reported by a two-digit number placed after the usual procedure number separated by a hyphen.
The modifiers available are the following:
-93
Interpreter needed at time of examination, or other circumstances which impair communication between the physician and the injured worker and significantly increase the time needed to conduct the examination.
Requires a description of the circumstance and the increased time required for the examination as a result.
Where this modifier is applicable, the value for the procedure is modified by multiplying the normal value by 1.1. This modifier shall only be applicable to ML- 201 and ML-202.
-94
Evaluation performed by an Agreed Medical Evaluator.
Where this modifier is applicable, the value of the procedure is modified by multiplying the normal value by 1.35.
If modifier -93 is also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 1.45.
-95
Evaluation performed by a panel selected Qualified Medical Evaluator. This modifier is added solely for identification purposes, and does not change the normal value of any procedure.
-96
Evaluation performed by a Psychiatrist or Psychologist when a psychiatric or psychological evaluation is the primary focus of the medical-legal evaluation.
Where this modifier is applicable, the value of the procedure is modified by multiplying the normal value by 2.
If modifier -93 is also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 2.10.
If modifier -94 is also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 2.35.
If both modifier -93 and -94 are also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 2.45.
-97
Evaluation performed by a physician who is board certified in Toxicology, a physician who is certified as a Qualified Medical Evaluator in the specialty of Internal Medicine or a physician who is board certified in Internal Medicine, when a Toxicology evaluation is the primary focus of the medical-legal evaluation.
Where this modifier is applicable, the value of the procedure is modified by multiplying the normal value by 1.50.
If modifier -93 is also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 1.60.
If modifier -94 is also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 1.85.
If both modifier -93 and -94 are also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 1.95.
-98
Evaluation performed by a physician who is board certified in Medical Oncology, a physician who is certified as a Qualified Medical Evaluator in the specialty of Internal Medicine or a physician who is board certified in Internal Medicine, when an Oncology evaluation is the primary focus of the medical-legal evaluation.
Where this modifier is applicable, the value of the procedure is modified by multiplying the normal value by 1.50.
If modifier -93 is also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 1.60.
If modifier -94 is also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 1.85.
If both modifier -93 and -94 are also applicable for an ML-201 or ML-202, then the value of the procedure is modified by multiplying the normal value by 1.95.
🤝 How UME Supports QME Billing
UME ensures you:
✅ Use the correct code and add-ons for each evaluation
✅ Document excess pages, time, and interpreter use properly
✅ Submit compliant invoices within required timelines
✅ Get paid fully and promptly — with less stress
We help you optimize every med-legal evaluation.
🩺 Final Thoughts
California’s updated Medical-Legal Fee Schedule is detailed but navigable — and it rewards physicians who document thoroughly and bill precisely. Let UME handle the administrative side so you can focus on providing quality med-legal care.
👉 Schedule a consultation to learn how UME can simplify your QME billing and ensure nothing gets missed.