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Also called RSD — reflex sympathetic dystrophy — and causalgia.
The rule that decides these cases:
The AMA Guides list eleven objective signs of CRPS and look for at least eight of them at the time of the examination.
At the examination. Not “the treating physician diagnosed it.” Not “the records reference RSD.” Present when the evaluator examines the limb, and documented.
Most CRPS cases in California fail at that step, and the failure is almost always preventable.
The eleven signs
The Guides group the objective findings into four categories:
| Category | What the examiner looks for |
|---|---|
| Vasomotor changes | Skin color (mottled or cyanotic), skin temperature (cool), edema |
| Sudomotor changes | Skin dry or overly moist |
| Trophic changes | Skin texture (smooth, nonelastic), soft tissue atrophy, joint stiffness and decreased passive motion, nail changes, hair growth changes |
| Radiographic signs | Plain radiographs showing trophic bone changes or osteoporosis; bone scan findings consistent with CRPS |
At least eight of the eleven must be present at the time of the examination.
This is a strict criterion and it has been criticized as unrealistically strict. It requires a level of simultaneous objective finding that many genuinely affected patients do not display on any single day — CRPS fluctuates, and treatment suppresses signs. At least one state supreme court has refused to apply the criteria for exactly that reason.
In California, evaluators apply the criteria. Some WCABWCAB Workers’ Compensation Appeals Board. The court system that decides these cases. 23 district offices statewide. panel decisions have said the Guides are a way to rate, not a test for the diagnosis, and one called the table optional. Panel decisions are not binding, so plan for the criteria to be applied. The question is not whether the standard is fair. It is what to do about it.
What to do about it
Get the examination scheduled and prepared for.
Objective signs of CRPS are strongest when the limb is unmedicated, unsplinted, and has not just been through a sympathetic block. Several of the eleven — skin color, skin temperature, sweating, edema — are transient and observer-dependent. If the evaluator does not look for them, they are not in the record.
Get the objective testing done.
- Three-phase bone scan — one of the eleven, and the closest thing to an objective imaging marker.
- Plain radiographs looking for patchy demineralization — also one of the eleven.
- Infrared thermography for temperature asymmetry, where available.
- Quantitative sudomotor testing for sweating asymmetry, where available.
Document the signs across time. A single examination catching six of eleven, plus treating records documenting the other findings on other dates, is a materially different record from a single examination and nothing else. The treating physician should be documenting these findings at every visit — and usually is not, unless asked.
And photograph the limb. Color and trophic changes are visible. Contemporaneous, dated photographs are evidence.
The single highest-value action in a CRPS case is making sure the physician knows the eight-of-eleven criterion exists before the examination — not after the report comes back at zero.
Where the impairment comes from
Once the criteria are satisfied, CRPS is rated in the extremity chapters, and the pathway is different in the upper and lower limbs.
In the upper extremity, CRPS is rated by combining the sensory and motor deficits and the loss of motion, using the peripheral nerve methodology.
In the lower extremity, CRPS and causalgia are one of the thirteen enumerated methods, and the mutual-exclusivity rules in that chapter apply — including the instruction that where more than one method applies, the method producing the higher rating should be adopted.
Two things get left out routinely:
The contralateral limb. CRPS spreads. Mirror-image symptoms in the opposite limb are documented in the literature and are a compensable consequenceCompensable consequence A new problem caused by the original injury or its treatment. Overusing the other side, the joint above or below, a surgical complication..
The psychiatric component. CRPS is one of the most psychologically destructive orthopedic conditions there is, and for injuries on or after January 1, 2013, § 4660.1(c)(1) bars adding it to the rating unless an exception applies. CRPS is not one of the four injuries the Legislature named, so the route is the Wilson factors — and CRPS lines up well against them: intensity and duration of treatment, poor outcome at permanent and stationaryP&S / MMI Permanent and Stationary / Maximum Medical Improvement. Your condition has plateaued — not that you are healed. Temporary disability ends here., and severe impact on activities of daily living. In severe cases it may also be argued as “an incurable and progressive disease,” which is the fifth Wilson factor. How that works.
The treatment fight
CRPS treatment is where utilization reviewUR Utilization Review. The process that approves, modifies, or denies each treatment request. A modification is a denial of what it left out. does the most damage in these cases, because the two mainstays are both heavily gate-kept.
Spinal cord stimulators for CRPS are “Recommended, Evidence (C)” in the MTUSMTUS Medical Treatment Utilization Schedule. California’s treatment guidelines. Four of them — shoulder, elbow, hand/wrist/forearm and traumatic brain injury — were replaced January 2, 2026. Chronic Pain Guideline in effect since June 1, 2026 — but the recommendation carries indications that have to be documented in the request, and utilization review holds the request to them.
A denial of a spinal cord stimulator is therefore usually a substantive denial, not a paperwork defect — which means the appeal has to be built on why this worker satisfies the guideline’s indications, with the documentation assembled in advance.
Sympathetic blocks face repetition and response-documentation limits. Where a block produced a documented, measured, sustained response, that documentation is what supports the next authorization. Where the response was never measured, the next request fails.
Check every denial for procedural defects anyway — timeliness, the reviewer’s qualifications, and whether the decision addressed the actual request. How to check a UR denial. · How to appeal through IMR.
Apportionment
Expect: pre-existing pain condition, fibromyalgia, psychiatric history, and smoking.
And expect the harder argument, which is causation rather than apportionmentApportionment Dividing permanent disability between industrial and non-industrial causes. It is to disability, not to findings on an image.: that CRPS did not occur at all, or that the symptoms are not organic. That is an attack on the diagnosis, and it is answered with the objective findings — which is the same reason the eight-of-eleven documentation matters at both ends of the case.
Where apportionment is asserted, the ordinary rules apply. Under EscobedoEscobedo The en banc decision requiring an apportionment opinion to explain how and why. A percentage without reasoning is not substantial evidence., an opinion has to explain how and why a non-industrial factor caused a percentage of the disability, not merely name a risk factor.
How CRPS starts
It follows trauma, and frequently minor trauma. The recurring patterns in California work injuries:
Crush and fracture of the hand, wrist, foot, or ankle. Post-surgical — after carpal tunnel release, after ankle or wrist fixation, after knee arthroscopy. Amputation and degloving. Burns. Immobilization — a limb casted or splinted for an extended period. Nerve injury, which is causalgia specifically.
The disproportion between the injury and the outcome is characteristic, and it is also why these claims are met with disbelief. A wrist fracture that healed on imaging, followed by a permanently useless hand, is exactly what CRPS looks like.
Frequently asked questions
My doctor diagnosed RSD but the rating came back at zero.
Most often, the eight-of-eleven criterion. The Guides look for at least eight of eleven objective signs present at the time of the examination, and a treating diagnosis in the records, on its own, usually does not meet it.
What are the eleven signs?
Skin color that is mottled or bluish, cool skin, edema, skin that is dry or overly moist, smooth and nonelastic skin, soft tissue atrophy, joint stiffness with decreased passive motion, nail changes, hair growth changes, bone changes on plain X-rays, and bone scan findings consistent with CRPS.
Can I do anything before the evaluation?
Yes, and it is the most valuable thing in the case. Get a three-phase bone scan, make sure the treating physician is documenting the objective signs at every visit, and take dated photographs of the limb.
They denied my spinal cord stimulator.
The MTUS Chronic Pain Guideline recommends it for CRPS, with indications attached, so the denial is usually about whether those indications are documented. The appeal has to show that you meet them.
Does my depression count?
Not automatically, for injuries on or after January 1, 2013. CRPS is not one of the four injuries named in the statute, so the catastrophic argument runs through the Wilson factors — where severe CRPS lines up well.
My injury was minor. They don’t believe me.
Disproportion between the injury and the outcome is characteristic of CRPS. It is answered with objective findings, not with argument.
Sources
AMA Guides to the Evaluation of Permanent Impairment, 5th Edition, Table 16-16 (the objective diagnostic criteria for CRPS) and chs. 16–17Labor Code § 4660.1(c)(1)§ 4663MTUS Chronic Pain Guideline (in effect since June 1, 2026)Wilson v. State of California Cal Fire (2019, WCAB en banc)Escobedo v. Marshalls (WCAB en banc)Scatena (WCAB panel, 2021)Fana (WCAB panel, 2024).
General information about California law, not legal advice about your case.
Impairment values described are from the AMA Guides, 5th Edition as applied under the California rating schedule; the Guides are a copyrighted medical text and figures here are summarized rather than reproduced. Your rating depends on your own examination findings.
Reviewed by Jamey Teitell, Partner & Trial Attorney · Last reviewed
Law Offices of Solov & Teitell, APC · (213) 380-9310
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