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Bodam v. San Bernardino County (11/20/2014)

Last update
May 15, 2024

WCAB Significant Decision

Timothy Bodam v. San Bernardino County/ Department of Social Services legally uninsured (Nov. 20, 2014)

  • Case No. ADJ8120989 (SBR 0041910)
  • 79 Cal. Comp. Cases 1519
  • 2014-SPD-4


In affirming the Workers’ Compensation Judge’s finding that defendant’s Utilization Review (UR) decision was not timely communicated to the requesting physician and the employee as required by Labor Code section 4610(g)(3)(A) and Administrative Director’s Rule 9792.9.1(e)(3), the Appeals Board held: (1)  A defendant is obligated to comply with all time requirements in conducting a UR, including the timeframes for communicating the UR decision; (2)  A UR decision that is timely made but is not timely communicated is untimely; (3) When a UR decision is untimely and, therefore, invalid, the necessity of the medical treatment at issue may be determined by the WCAB based upon substantial evidence.

Additional Information

California Labor Code § 4610

California Code of Regulations § 9792.9.1(e)(3)

Department of Industrial Relations Significant Panel Decisions

DaisyBill Resources

Blog: Your Request for Authorization (RFA) Questions Answered
WCAB Emphasizes UR Decisions

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