When a Medical Panel assesses hip impairment using the range of motion method under Table 40 of the AMA Guides (4th edition), the Panel is not required to treat each plane of motion as a separate impairment and combine them using the Combined Values Chart. The Panel may treat each column of Table 40 as describing a constellation of measurements that together produce a grading of mild, moderate or severe impairment. The 'heavy onus' language from Gamble should be understood as reflecting the nature of the Guides as a medical document, not as imposing a formal evidentiary burden on the challenging party.
The full text is available to signed-in members, including the 7 later cases that cite this judgment.
2 of the 7 citing cases carry a classified treatment. How each court treated it is available to signed-in members.