 Chandra, Nundy, and Seabury (2005) find that the rising cost of medical services may explain the bulk of the growth of "compensatory awards".They also find that the greatest ten percent of the malpractice payments have grown at a smaller pace than the average payment for the years 1991 and 2003.This means that the "medical malpractice crisis" is not necessarily fueled by the growth in malpractice payments.