July was packed with opportunities to connect, collaborate, and celebrate. From industry events like the California Workers' Compensation Conference and AWCP's Summer Fun event to team gatherings—including our Employment Law Team retreat and a 30th anniversary bowling celebration—our Team Rhino members stayed busy building relationships, sharing knowledge, and enjoying time together.
Injuries sustained during an employee's commute to or from work generally are not compensable under the "going and coming" rule, which deems that such injuries do not arise out of and in the course of employment. The rule, however, has been described as having a "tortuous history," and has numerous exceptions, which make it difficult to uniformly apply. (Price v. WCAB (1984) 37 Cal. 3d 559, 565.)
June was another busy month for Team Rhino! From connecting with clients and industry partners at conferences and golf tournaments to hosting educational training events and joining clients for summer celebrations, our team had the opportunity to build relationships, share knowledge, and stay engaged with the communities we serve.
A workers' compensation compromise and release (C&R) agreement is not enforceable until approved by the Workers' Compensation Appeals Board[1] (LC 5001). Under CCR 10700, the WCAB is affirmatively required to inquire into the adequacy of all C&R agreements and may set a hearing to take evidence when necessary to determine whether a settlement should be approved or disapproved.
The doctrines of res judicata and collateral estoppel can bar parties from re-litigating claims and issues that were decided previously in workers' compensation proceedings. Res judicata, or claim preclusion, acts to bar claims that were, or should have been, advanced in a previous suit involving the same parties. It arises if a second suit: (1) involves the same cause of action; (2) is between the same parties; and (3) occurs after a final judgment on the merits. (DKN Holdings LLC v. Faerber (2015) 61 Cal. 4th 813, 824.)
May was a busy month for MS&A, filled with opportunities to connect, learn, and engage with the communities we serve. From industry conferences and educational presentations to client gatherings and team-building events, our attorneys and staff were on the move throughout the month.
As Michael Sullivan & Associates celebrates 30 years of serving California employers, we’re taking time throughout the year to reflect on the people, relationships, and milestones that have shaped our journey since the firm opened for business in 1996. To mark this occasion, MS&A Founder and General Managing Partner Michael Sullivan shares a personal letter reflecting on the firm’s growth—from its humble beginnings to the statewide industry leader it is today.
The utilization review (UR) process begins when a claims administrator receives a completed request for authorization from a treating physician. Under the updated UR regulations that became effective April 1, 2026, California Code of Regulations (CCR), Title 8, § 9792.6.1(u) defines what constitutes a valid "request for authorization," and specifies the conditions under which a request is deemed "completed" for purposes of triggering the UR clock. CCR 9792.9.1(b) addresses the claims administrator's obligations on receipt of a request that does not meet the definition of a completed request.
