15 Best Practices for Creating Memorable CLNC^® Reports

Everything you put into a comprehensive report as a Certified Legal Nurse Consultant should be there for one purpose and one purpose only – to inform your attorney-client of the information necessary to win the case. Every opinion, every paragraph, every table, every exhibit, every reference should serve that purpose. Your job as a Certified Legal Nurse Consultant is to make sure the purpose of each part of your report is clear to the attorney reading it. After all, if the attorney has to figure out what you mean by something or why you included something, he might as well do the work himself.

Your attorney-client will be a lot more likely to call on you again and again for comprehensive reports if you make his job easy by following these strategies for creating first-class comprehensive reports.

1. Identify the attorney’s preferences
   The attorney-client may not always know what he needs but often before you provide what you know he needs you may have to first give him what he thinks he needs. Inquire about the intended purpose of the report, potential users of the report and any preferences for format or design. This will accomplish two things in advance:
   • You can more easily judge the format (chronology, narrative, etc.) and amount of detail required for specific portions of the report.
   • You and your attorney-client both know what is being requested, which decreases the risk of providing an unwanted, unnecessary or surprise work product to an attorney.

   This approach will never fail to earn you positive feedback.

2. Keep it real
   Try to learn how much medical knowledge and experience the attorney has with similar cases. For example, if an attorney handles a large number of failure-to-diagnose myocardial infarction (MI) cases, you may not have to include an extensive discussion about anatomy or physiology because the attorney may already be familiar with this information. Instead, tailor this portion of the report to the specific case issues regarding this specific MI. Conversely, if an attorney does not have extensive medical malpractice experience with MI cases, you may devote a section of the report to a review of anatomy and physiology, disease process and current treatment protocols. Don’t assume the attorney knows how this information applies to the case. Always explain how it applies both to the case and the client the attorney is representing. Assessing the attorney’s medical knowledge also guides you in knowing how much you need to translate the medical record and medical terminology.
3. Do Your Research Before You Start Writing
   Review applicable standards of care and scientific literature and identify the sources you will use before drafting the report. This time-saving procedure helps you organize your thoughts and determine where to include the relevant resource material.
4. Recycle your research from other reports for greater efficiency
   Depending on the type of case, you may be able to re-use sections from previous legal nurse consulting reports or summaries prepared for similar cases. For example, in two cases involving delay in diagnosis of myocardial infarction or chest pain evaluation, the standards you applied to the first case may be relevant to the second case. Review your other reports on similar cases to determine if any of the material applies to your current case before starting the report. Of course, there is no “one size fits all” approach to report writing. Each case must be analyzed individually, but occasionally, you may be able to avoid duplicating your effort and research.
5. Create an outline to ensure you cover all important issues

   Outline your opinions as well as your plan for presenting them.

   A comprehensive report includes some or all of the following:

   • Letter to the attorney.
   • Cover sheet.
   • Table of contents.
   • List of records, documents and tangible items reviewed and examined to date.
   • List of significant players.
   • Summary of the case or summary of relevant information.
   • General and specific deviations from, and adherences to, the standards of care (malpractice cases only).
   • Summary of scientific theory, research and standards.
   • Additional discovery.
   • Definitions of all medical terminology and abbreviations in simple terms.
   • Potential opposition arguments.
   • Conclusions.
   • Follow-up questions.
   • Recommendations.
   • Reference list.
   • Summary of testifying experts’ opinions.
   • Abstracts of pertinent articles
   • Copies of relevant scientific literature.
6. Apply a systematic approach to keep chronologies reliable
   Even a small error in date or time can influence the rest of your report. To minimize these costly typos, enter data from one complete section of the chart before moving on to another section. For example, start entering data with nursing and vital sign graphic entries because these data are usually dated and timed and occur more frequently than entries by other healthcare providers. Then, enter all lab report data in the appropriate order before moving on to radiology reports. It may then be possible to place undated or, more often, untimed physician’s progress notes and orders based on the chronology you have already created. In putting the pieces of the puzzle together in this fashion, you may identify other important issues to address in your evaluation and report.
7. Customize the report format to meet the attorney-client’s needs
   Avoid using the same format and length for each and every case. You may wind up including information that is not cost effective or relevant. Instead, write a report that meets your attorney-client’s needs and presents the information in the most logical manner. If you have difficulty organizing your thoughts or facing a blank computer screen, use a computer software program that can help with formatting case reports and chronologies. The key, however, to producing an effective work product is not only format and visual appeal, but the content, analysis, and conclusions you draw. This is the value you bring to case analysis that other members of the legal team are not qualified to do.
8. Break up the topics
   Break up long paragraphs. Stick to one topic per paragraph, just like your English teacher taught you.
9. Use lists to communicate a sequence of items
   To make groups of related points clearer, use bulleted lists. If the sequence of items is important, number the list instead of using bullets, e.g., number a sequence of steps that came or should come in order.
10. Format consistently throughout the report
    Refer to dates and times consistently. You may be used to “military” time, but if your attorney-client isn’t, help the attorney out by also indicating the standard. If using a.m. and p.m., choose a standard format for this and stick to it. Likewise for dates, pick one way of formatting dates and use it throughout the report. Vickie Milazzo Institute standard is the mm/dd/yy format – i.e., March 5, 2010 is formatted 03/05/10. You may choose to spell out dates in the body of your report and use a numerical format for tables.
11. Respect your attorney-client’s intelligence
    When writing your legal nurse consulting report, explain a medically complex situation with the preface, “This is the way I would explain it to a jury.” This allows you to get down to the attorney’s level without insulting his intelligence.
12. Use a cover letter
    If the report is comprehensive, be sure to include a cover letter introducing the report, restating your assignment briefly, summarizing your bottom-line opinion, and conclude by thanking the attorney-client and offering to  provide additional CLNC® services on this or future cases. Also include a table of contents listing the major subheadings within the report.
13. Clarify medical terms and abbreviations
    Either define medical terms and abbreviations on the spot (if few terms are used) or provide a glossary at the end of the report (if numerous terms are used). Whenever you use an abbreviation for the first time, unless you’re absolutely sure your attorney-client is familiar with it (e.g., MD, RN), spell out the term then put the abbreviation in parentheses – for example, advanced cardiac life support (ACLS). Then on subsequent uses of the term, you can simply use the abbreviation. Most acronyms can be formatted without periods. Remember, you’re so familiar with many medical acronyms, you don’t even notice them – but if your attorney-client has to stop and look up a term or puzzle it out, he won’t appreciate your wasting his time.
14. Correctly shorten units of measure
    Use consistent notation for units of measurement throughout the report. In general, abbreviations for units of measurement do not require periods (unless they’re used at the end of a sentence), nor do they require adding an “s” for the plural. For example, 1.5 cc, 0.5 mg, 127 lb (not 127 lbs), etc.
15. Make your report shine by setting it aside
    If time allows, put the report aside for one or two days before doing any final proofreading or editing. Check the report for overall continuity and format, then review each paragraph for content, relevancy and grammar. Finally, analyze each sentence for grammar, proper placement and always check spelling.

    Be sure you deliver what you promised. Before you submit your final report, go back over your notes and the original letter from your attorney-client. What did the attorney ask for? Did you include this information? In your cover letter for your report, do you state that you’re including requests for production, a list of references or a glossary? Make sure it’s all there in the final draft.

Your CLNC^® report will linger in the case file long after your meeting with your attorney-client. It may travel to other law firms or co-counsel, and will be used by many members of the legal team before the case concludes. What type of first (and sometimes, only) impression are you leaving with your attorney-clients and potential future clients? Make every report the best ever by paying stellar attention to detail.

Success Is Inside!