Sandhagen v. Cox & Cox Construction; SCIF (2004) 69 CCC 1542 WCAB En Banc Decision

UR doctors fear this decision, for it mandates that PR-2 reports (that are submitted in a timely fashion) MUST be responded to with 14 days or else they are inadmissible at the WCAB and may not even be sent to a QME or AME doctor. Here’s the commissioner’s exact verbiage:

“The utilization review time deadlines of section 4610(g)(1) [14 days maximum] are mandatory and, if a defendant [insurer] fails to meet these mandatory deadlines, it is precluded from using the utilization review procedure for the particular medical treatment dispute in question.”

And:

“If a defendant undertakes an untimely utilization review procedure, any utilization review report obtained as to the particular treatment in dispute is not admissible in evidence, and any utilization review report obtained cannot be forwarded to an AME or QME if section 4062(a) procedures are timely pursued.”