Request for Authorization (RFA)
Workers' Compensation Appeals Board (WCAB)

Saunders v. Loma Linda University Medical Group (6/10/15)

Last update
August 8, 2022

WCAB Split Panel Opinion

Stacey Saunders v. Loma Linda University Medical Group (Jun 10, 2015)


In rescinding its prior decision (Saunders v. Loma Linda Univ. Med. Group, 2014 Cal. Wrk. Comp. P.D. LEXIS 659), the majority panel held that, as with an untimely utilization review (UR) decision, an untimely Independent Medical Review (IMR) determination is invalid and that therefore the Workers’ Compensation Judge can decide medical treatment. The Appeals Board relied on Labor Code § 4610.6(d) and Dubon II. Commissioner Zalewski dissented, reasoning that “the Legislature intended to make IMR the exclusive process for determining a medical treatment dispute that is not finally resolved by UR...”

Additional Information

California Labor Code § 4610.6

DaisyBill Resources

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

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