Utilization Review has been with us for more than 15 years now, showing up first in 2003 when Governor Gray Davis signed SB 228. Thereafter, Governor Schwarzenegger expanded its role in 2004 with the approval of SB 899. Most recently, SB 863 added Independent Medical Review into the mix.
After all these years, you would think that there could not be any aspect of the Utilization Review process left to litigate. This being California Workers’ Compensation, you would be wrong!