On this page
In thirty seconds
- A shoulder surgery that restores motion reduces your rating. A shoulder surgery that removes bone adds a fixed value. The tear itself is worth nothing; only the motion you lost — and one specific procedure — carry a number.
- “20% upper extremity impairment” is 12% whole person, not 20% disability. Read as whole person, an upper extremity figure overstates by two thirds.
- Check your operative report for distal clavicle resection — “Mumford,” “distal clavicle excision,” “co-planing.” A fixed 10% upper extremity, frequently the largest single component, and routinely omitted.
Most shoulder cases turn on three checkable things: whether the upper extremity number was correctly converted, whether a distal clavicle resection was performed and rated, and whether the apportionmentApportionment Dividing permanent disability between industrial and non-industrial causes. It is to disability, not to findings on an image. opinion does more than cite a study about people who are not you.
Why the number is so low
Three things compound.
FIRST, THE CONVERSION
Shoulders are rated in upper extremity percent, then converted to whole person at a fixed ratio: 100% upper extremity equals 60% whole person. So a report saying “20% upper extremity impairment” is 12% whole person — not 20% disability. Workers read that first number and understandably assume it is their case.
SECOND, THERE IS NO DIAGNOSIS-BASED VALUE
Chapter 16 gives the shoulder essentially one method — range of motion — plus a short table for joint replacement and bone resection. There is no entry for a rotator cuff tear. There is no entry for a labral or SLAP tear. A documented full-thickness supraspinatus tear, surgically repaired, with motion recovered has a strict rating of zero — no matter how much pain remains. That is not an oversight by your doctor. It is what the book says.
THIRD, WEAKNESS GENERALLY CANNOT BE RATED
The Guides permit a strength rating “only in the rare case,” and strength cannot be rated where there is decreased motion, pain, or deformity. Almost every shoulder case involves decreased motion or pain — the single most common source of felt injustice in this body part, and it is a real rule, not an evaluator’s choice.
What actually carries a value
| DIAGNOSIS | HOW IT RATES · REALITY |
|---|---|
| Rotator cuff repair, good result | Motion only · Often 0–3% upper extremity |
| Rotator cuff repair, residual stiffness | Motion only · The stiffness is the value |
| Impingement / decompression alone | Motion only · Full motion means a strict rating of zero |
| Labral / SLAP repair | Motion only · No diagnosis value exists |
| Distal clavicle resection | A fixed 10% upper extremity, combined with motion loss · The most reliable value in a shoulder case |
| Adhesive capsulitis | Motion · Rates well, because it is motion loss |
| Total shoulder replacement | Table value, combined with motion · The highest ordinary rating |
| Reverse total shoulder replacement | Not addressed by the Guides at all |
Check your operative report for one procedure: distal clavicle resection — also written as “Mumford,” “distal clavicle excision,” or “co-planing.” It carries a fixed 10% upper extremity impairment, combined with any motion loss on top of it, and is frequently the largest single component of a shoulder rating. It is routinely omitted, because surgeons often perform it at the same time as a cuff repair and it gets buried in the middle of the operative report.
And if you had a reverse replacement: reverse total shoulder arthroplasty was not in general use when the Fifth Edition of the Guides was published, and the text does not address it. The procedure deliberately trades motion for stability — so rating it on motion alone badly understates what happened. This is one of the cleanest arguments in California for a physician to give the strict rating, explain why it fails, and provide an alternate rating under Almaraz/GuzmanAlmaraz/Guzman The doctrine permitting a physician to depart from the strict AMA rating where it does not accurately reflect the impairment, using another method inside the “four corners” of the Guides.. If you were rated on range of motion alone, that is worth a second look.
What the treatment guidelines say
The shoulder guideline was replaced effective January 2, 2026. Anything written about California shoulder treatment standards before that date describes a guideline that no longer applies.
| TREATMENT | WHERE IT STANDS |
|---|---|
| MRI for rotator cuff tendinopathy | Strongly recommended — one of the most approvable advanced imaging studies in the system |
| MR arthrogram for labral tears | Moderately recommended |
| Rotator cuff repair — small, medium, large tears | Moderately recommended |
| Rotator cuff repair — chronic massive tears | Not recommended |
| Subacromial decompression for impingement | Recommended |
| Steroid injection for adhesive capsulitis | Strongly recommended |
| Total shoulder replacement for severe arthritis | Moderately recommended |
| Reverse replacement for massive tears | Recommended, insufficient evidence |
| Platelet-rich plasma | No recommendation — insufficient evidence |
A SHOULDER MRI DENIAL IS WORTH APPEALING
It carries the highest grade of recommendation in the guideline.
A FROZEN-SHOULDER INJECTION DENIAL IS WORTH APPEALING
Also the highest grade.
PRP WILL BE DENIED, EVERY TIME
“No recommendation, insufficient evidence” produces an automatic denial under the review rules.
A CHRONIC MASSIVE TEAR REPAIR DENIAL IS SUBSTANTIVE
The most common shoulder surgery denial in an older worker with a retracted, atrophied tear — and it is the guideline’s actual position, so the appeal has to be built on why this worker is different, not on a procedural defect.
The apportionment fight
The epidemiology is real. Asymptomatic cuff tears genuinely are common with age, and they are frequently bilateral. But the literature cuts both ways, and this is the strongest single argument in a shoulder case. If more than half of people over sixty have asymptomatic cuff tears and are not disabled, then the tear by itself does not produce disability. What produced disability was the industrial event that converted an asymptomatic tear into a symptomatic, function-limiting one. Apportionment is to disability, not to pathology.
WHAT THE DEFENSE EVALUATOR WRITES
“MRI of the uninjured shoulder demonstrates a partial-thickness tear. The literature establishes that the prevalence of asymptomatic rotator cuff tears exceeds 50% in individuals over 60. The applicant’s tear is degenerative rather than traumatic. I apportion 60% to pre-existing degenerative disease.”
THE PERCENTAGE HAS TO BE EXPLAINED
Why 60% rather than 25%? What in the record — prior treatment, prior complaint, prior restriction, prior imaging — supports it? An evaluator who reviewed no pre-injury records has no factual basis for any number.
THE IMAGING CAN REBUT CHRONICITY
The defense uses fatty infiltration of the muscle and tendon retraction to argue the tear is old. Their absence — along with fluid signal, muscle edema, an acute mechanism, and immediate loss of function — supports an acute traumatic tear. That is technical, and it is where these cases are actually won.
FROZEN SHOULDER IS USUALLY A CONSEQUENCE OF THE TREATMENT
Post-operative or post-immobilization adhesive capsulitis is frequently the largest part of the impairment, and where it flows from industrial treatment there is a real argument against apportioning it at all.
What the work does
Shoulder cumulative traumaCT — Cumulative trauma Injury from repeated exposure over time. The largest injury category in California and the least claimed. comes from sustained or repeated work at or above shoulder height, and from load-bearing on a raised arm: warehouse order-selectors and stockers reaching to upper racks; painters, drywall finishers, electricians, HVAC and overhead installers; auto mechanics working under a lift; grocery clerks stocking upper shelves; nurses, CNAs, and caregivers lifting and repositioning patients; hotel housekeepers — bed-making, high dusting, curtains and linen; assembly and packing lines with elevated conveyors; longshore and baggage handling; hairstylists and barbers; firefighters and law enforcement.
The mechanism is repeated compression of the supraspinatus tendon during elevation, producing degeneration inside the tendon and eventually a partial and then full-thickness tear — with secondary arthritis at the AC joint from repeated load.
If your shoulder wore out over years rather than in one moment, that is a cumulative trauma claim.
Have the operative report and the rating read together
- Was the upper extremity number converted? — 100% upper extremity equals 60% whole person. 20% UE is 12% WP.
- Search the operative report for four phrases — Mumford · distal clavicle resection · distal clavicle excision · co-planing. Any of them means a fixed 10% upper extremity that belongs in your rating.
- If you had a reverse replacement, was it rated on motion alone? — The Guides do not address the procedure. There is a recognized route to a more accurate rating.
- Does the apportionment opinion do more than cite a study? — Prior records reviewed, a reason for the percentage, and the imaging signs of chronicity actually present.
Frequently asked questions
I tore my rotator cuff. What’s it worth?
The tear itself has no impairment value under the Guides. What carries value is the motion you lost — and any bone that was removed.
My report says 20% impairment. Is that my disability?
Almost certainly not. Shoulder impairment is stated in upper extremity percent, and 20% upper extremity is 12% whole person — which then runs through the rating schedule to produce your actual percentage.
My surgery went well and my rating is zero. How?
Because the rating is based on motion, and your motion came back. It feels wrong and it is what the book provides. If a distal clavicle resection was done, though, there should be a value — check the operative report.
My shoulder is weak. Doesn’t that count?
Generally no. Strength cannot be rated where there is decreased motion, pain, or deformity — which covers nearly every shoulder case.
I had a reverse replacement.
The Guides do not address that procedure. Rating it on motion alone understates it, and there is a recognized route to a more accurate rating.
They said my tear is just from age.
Their own literature says most people with those tears are not disabled. The question is what caused the disability, not what caused the tear.
They denied my MRI.
Shoulder MRI for suspected cuff pathology carries the highest grade of recommendation in the guideline. That denial is worth appealing.
They denied my surgery.
If it was for a chronic massive tear, the guideline itself does not recommend it — so the appeal has to be built on why your case is different.
Sources
AMA Guides to the Evaluation of Permanent Impairment, 5th Edition, ch. 162005 California Permanent Disability Rating ScheduleMTUS Shoulder Disorders Guideline, effective January 2, 2026ACOEM Shoulder DisordersLabor Code § 4663§ 4664Escobedo v. Marshalls (WCAB en banc)City of Jackson v. WCAB (2017)City of Petaluma v. WCAB (Lindh) (2018)Almaraz/Guzman II (WCAB en banc)Hikida v. WCAB (2017).
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
Printed from https://www.solovteitell.com/injuries/shoulder/ · Last reviewed