Writing the Medication Necessity Narrative for PI Demands

Amar Lunagaria — Co-Founder & Chief Pharmacist, LienScripts | March 25, 2026 | 7 min read

How to write the medication necessity narrative section of a PI demand package. Use pharmacist documentation to support each medication's medical necessity and strengthen the damages presentation.

Writing the Medication Necessity Narrative for PI Demands

The medication necessity narrative is the section of the demand package that explains why each prescribed medication was medically necessary for the plaintiff's accident-related injuries. A well-written necessity narrative transforms pharmacy charges from bare numbers into clinical evidence of injury severity, preventing adjusters from dismissing medications as unnecessary or unrelated to the accident.

• The necessity narrative explains the clinical rationale for each medication, connecting prescriptions to documented injuries
• Pharmacist documentation from the LienScripts MERIT (Medication Evaluation & Rationale for Injury Treatment) report provides the clinical foundation for the narrative
• Each medication must be justified individually — grouping medications without individual explanations invites blanket challenges
• The narrative should address anticipated adjuster objections (causation, necessity, brand vs. generic) preemptively
• Medical necessity is established by the treating physician's clinical judgment, supported by pharmacist documentation

Structure of the Medication Necessity Narrative

The necessity narrative appears in the demand letter after the medical treatment summary and within or immediately following the special damages section. It bridges the gap between "these medications were dispensed" and "these medications were medically necessary because of the defendant's negligence."

Opening Statement

Begin with a statement that frames the medications as a clinical response to documented injuries:

"The following prescription medications were prescribed by [plaintiff's] treating physicians as medically necessary treatment for the injuries documented in the medical records. Each medication addresses a specific injury component and was prescribed based on clinical findings established during the course of treatment."

Per-Medication Justification

For each medication, provide:

1. The injury it treats — reference the specific diagnosis from the medical records
2. Why this medication — explain the drug class and mechanism in plain language
3. The clinical decision — note the treating physician's rationale, if documented
4. Treatment duration — explain why the medication was needed for the prescribed period

[!KEY] Every medication in the demand narrative must be individually justified with a clinical rationale tied to a documented injury. Grouping medications without individual explanations invites the adjuster to challenge the entire group.

How Pharmacist Documentation Supports the Narrative

According to James Wong, PharmD, founder of LienScripts, "The medication necessity narrative is where most demand packages fall short. Attorneys know the legal arguments for damages but often lack the clinical vocabulary to explain why a specific medication was the right choice for a specific injury. That is exactly what the MERIT report provides."

LienScripts generates a MERIT (Medication Evaluation & Rationale for Injury Treatment) report for every case, providing pharmacist-signed documentation for demand packages. The MERIT contains:

Clinical indication narratives: For each medication, the pharmacist explains in clinical terms why the medication is indicated for the plaintiff's specific injuries. These narratives use medical terminology that lends clinical authority while remaining accessible to non-clinician adjusters.

Mechanism of action explanations: The MERIT explains how each medication works — what biological system it targets and why that system is affected by the plaintiff's injuries. This prevents adjusters from arguing that medications are redundant or unnecessary.

Standard-of-care references: The MERIT places each medication within the context of accepted medical practice, demonstrating that the prescribing physician followed established treatment protocols.

Drug interaction considerations: When a plaintiff takes multiple medications, the MERIT addresses potential interactions and explains how the regimen was designed to be clinically appropriate as an integrated treatment plan.

Writing Techniques for Maximum Impact

Use the physician's own language

When the treating physician's notes include specific clinical findings, quote them. Example:

"Dr. [Name]'s assessment of [date] documents 'moderate to severe L4-L5 radiculopathy with positive straight leg raise and diminished sensation in the L5 dermatome.' Gabapentin 300mg was prescribed on the same date to address the neuropathic component of this radicular pain."

Connect medications to functional limitations

Adjusters respond to functional impact. Instead of just stating the diagnosis, explain what the injury prevents:

"The cervical disc herniation documented on MRI caused radiating pain into the right arm that prevented [plaintiff] from lifting, driving, and performing occupational duties. Pregabalin was prescribed to reduce the neuropathic pain that caused these functional limitations."

Address the treatment timeline

Explain why medications continued for the duration they did:

"[Plaintiff] remained on gabapentin for eight months because follow-up evaluations on [dates] documented persistent neuropathic symptoms. The treating physician's ongoing clinical assessments — not patient self-reporting alone — supported the continued prescription."

[!TIP] When writing the medication necessity narrative, draft the MERIT-supported justification for the most expensive or most challenged medications first. These are the medications the adjuster will scrutinize most closely, and they require the strongest clinical support.

Addressing Anticipated Objections

"This medication was for a pre-existing condition"

The narrative should proactively address any medication that could be characterized as pre-existing. As Amar Lunagaria, PharmD, LienScripts' Chief Pharmacist explains, "The eggshell plaintiff doctrine means that an accident that aggravates a pre-existing condition — triggering higher doses or additional medications — creates damages attributable to the accident. The necessity narrative should document the change in medication regimen after the accident date."

"A cheaper alternative was available"

Address brand-name prescriptions by explaining the clinical rationale for the specific medication selected. If the treating physician prescribed Qulipta instead of topiramate, the narrative should explain that these medications work through entirely different mechanisms — Qulipta is a CGRP receptor antagonist while topiramate is an anticonvulsant — and the physician selected the medication best suited to the plaintiff's clinical presentation.

"Too many medications — this is over-treatment"

The per-medication justification structure inherently addresses this objection. When each medication is individually justified with a different injury component and a different mechanism of action, the multi-drug regimen is presented as comprehensive treatment, not over-treatment.

Integrating with the Demand Package

The medication necessity narrative should:

1. Reference the MERIT report by exhibit number — "See Exhibit [X], MERIT Report, for detailed clinical justification of each medication"
2. Cross-reference the medication table — link the narrative to the itemized pharmacy charges
3. Mirror the medical treatment summary — use the same injury descriptions and physician names used earlier in the demand letter
4. Precede the damages calculation — establish necessity before presenting the total damages figure

Related Resources

• How to Present Pharmacy Costs in Your Demand Package
• Itemizing Pharmacy Charges in Demand Letters
• Pharmacy Lien Demand Letter Template for PI Attorneys
• Pharmacy Lien Special Damages Calculation
• Top Adjuster Attacks on Pharmacy Liens — And How to Rebut Them