State Compensation Insurance Fund v. Workers' Compensation Appeals Board

Opinion

MORENO, J.

This case presents two related workers’ compensation issues; (1) When deciding whether to approve or deny an injured employee’s request for medical treatment, must an employer conduct utilization review pursuant to Labor Code section 4610?1 (2) As an alternative to utilization review, may an employer elect to dispute a request for medical treatment under section 4062, which permits an employer to object to “a medical determination . . . concerning any medical issues . . . not subject to Section 4610 . . .”? (§ 4062, subd. (a).) We conclude the Legislature intended to require…