GUIDE FOR CLAIMS ADMINISTRATORS
California utilization review timelines for claims administrators
Every UR deadline a California claims administrator owes, the clock that starts it, and the penalty for missing it. Updated for the regulations in effect April 1, 2026.
Reviewed by Sure Log, Esq. · Last reviewed October 2026
Short answer: A prospective or concurrent utilization review decision in California is due within 5 normal business days of receiving the request for authorization and the supporting information reasonably necessary to decide, and in no event more than 14 days from the date of the physician's treatment recommendation. Expedited review is 72 hours. Retrospective review is 30 days. Those four numbers are set by Labor Code §4610(i), and the amended regulations that took effect April 1, 2026 did not change them. What changed is the penalty for missing them.
Every UR deadline in one table
| Decision type | Deadline | Clock starts | Source |
|---|---|---|---|
| Prospective or concurrent | 5 normal business days | Receipt of the RFA and the supporting information reasonably necessary to decide | LC §4610(i), 8 CCR §9792.9.3 |
| Prospective or concurrent: outer limit | 14 calendar days, if additional information is requested within the 5 business day period | On receipt of the additional information, up to 14 days from receipt of the RFA | LC §4610(i)–(j), 8 CCR §9792.9.6 |
| Expedited | 72 hours | Receipt of the information reasonably necessary to decide | LC §4610(i), 8 CCR §9792.9.3 |
| Retrospective | 30 days | Receipt of the information reasonably necessary to decide | LC §4610(i), 8 CCR §9792.9.3 |
| Formulary drug, non-exempt on the MTUS list | 5 normal business days, not extendable | Receipt of the request | 8 CCR §9792.9.8(b) |
| Request for more information, formulary | 4 business days | Receipt of the request | 8 CCR §9792.9.8(b) |
| Returning an incomplete RFA | 5 business days | Receipt of the incomplete request | 8 CCR §9792.9.1 |
Where adjusters actually miss the deadline
The clock starts for UR when the RFA is received, whether by fax, email or electronic data exchange. Requests received after 5:30 PM Pacific Time shall be deemed to have been received on the following business day, except in the case of an expedited or concurrent review.
Prospective or concurrent review must generally be performed within 5 business days. The extension to 14 calendar days only applies if a request for additional information is made within the 5 business day period. Once the additional information is received, the prospective or concurrent review must still be completed within 5 business days of receipt of the additional information, up to 14 calendar days from receipt of the RFA.
Expedited is measured in hours, and the penalty is charged in hours. See the penalty table.
What changed on April 1, 2026
The DWC's amended utilization review regulations took effect April 1, 2026. The statutory decision timeframes in Labor Code §4610 were not amended. Three things did change, and all three increase administrator exposure:
1. Incomplete requests now have a hard return deadline. On receiving a request that does not meet the definition of a complete request for authorization, the claims administrator, non-physician reviewer or physician reviewer must either accept it as complete and comply with the ordinary timeframes, or mark it "not complete" and return it within five business days, specifying the reasons for the return. Sitting on an incomplete request is no longer a neutral act.
2. The penalty schedule was raised substantially. Under 8 CCR §9792.12:
| Failure | Penalty |
|---|---|
| Late prospective or concurrent decision | $250 per day, to a maximum of $5,000 |
| Late expedited response | $250 per hour, to a maximum of $18,000 |
| Late retrospective response | $150 per day, up to a maximum $3,000 |
3. The performance-rating waiver is gone. The prior scheme allowed penalties to be waived on the strength of a performance rating. That relief has been eliminated, so a late decision now carries its penalty on its own facts.
Does the provider have to use the DWC Form RFA?
Yes, as the standard. In News Release 2026-42 dated May 14, 2026, the DWC clarified that a request for authorization is formally defined as a written request for a specific course of proposed medical treatment, and that the DWC Form RFA is the mandatory standard. A narrative report may substitute only where the claims administrator voluntarily agrees to accept it and the report contains all the required data elements.
Practically: you may accept a narrative report, but you cannot be made to. If you do accept one, you have accepted the clock that comes with it. If you do not accept one, it must be marked "not complete" and returned to the requesting physician with a written explanation specifying the reason for the return.
Is treatment in the first 30 days subject to UR?
No, and this is routinely missed. Under Labor Code §4610(b), medical treatment rendered within 30 days of the initial date of injury shall be authorized without prospective utilization review, subject to the exceptions in §4610(c). Running UR on a request that falls inside that window is not a neutral error; it delays care the statute already authorized. The Audit Unit imposes a penalty of $3,000 for each violation.
When does a request qualify for expedited review?
When the employee faces an imminent and serious threat to health (including the potential loss of life, limb or another major bodily function), or when the ordinary timeframe would be detrimental to the employee's life or health, or would jeopardize their ability to regain maximum function. The requesting physician must certify and document the need in writing. Nevertheless, if a treating physician requests an expedited review, a UR physician must determine whether expedited review is required.
What happens after a denial: IMR
| Step | Deadline | Source |
|---|---|---|
| Worker files for IMR | 30 days after service of the UR decision | LC §§4610.5–4610.6 |
| Worker files for IMR: formulary or MTUS drug dispute | 10 days | 8 CCR §9792.10.1 |
| IMR determination | 30 days from receipt of the request and supporting documents | LC §4610.6, 8 CCR §9792.10.6(g)(1) |
| IMR determination: expedited review | 3 days from receipt of the request and supporting documents | LC §4610.6, 8 CCR §9792.10.6(g)(2) |
| IMR determination: formulary | 5 working days | LC §4610.6, 8 CCR §9792.10.6(g)(4) |
IMR is administered by Maximus under contract to the DWC. The reviewing physician's identity is not disclosed to the parties.
The one-line version
Five business days to decide, fourteen days if additional information is requested, seventy-two hours if it is expedited, thirty days looking backwards. And since April 1, 2026, five business days to return anything incomplete and a real penalty if you are late.
Reviewed by Sure Log, Esq., Of Counsel at Michael Sullivan & Associates and co-author of Sullivan on Comp. Last reviewed October 2026.
Sources. Labor Code §4610; §§4610.5–4610.6. 8 CCR §§9792.9.1, 9792.9.3, 9792.9.5, 9792.9.6, 9792.9.7, 9792.9.8, 9792.10.1, 9792.10.6, 9792.12. DWC News Release 2026-42, May 14, 2026. Statutory text verified against leginfo.legislature.ca.gov on 25 August 2026.
Educational content for claims professionals. Not legal advice.
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