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.
Once a qualified medical evaluator (QME) has been selected in a represented case, California Code of Regulation (CCR) 34(b) explains that any subsequent evaluation may be performed at a different medical office of the selected QME if that office is listed with the medical director and is "within a reasonable geographic distance from the injured worker's residence." Labor Code § 4062.3(k) further directs that, after a medical evaluation is prepared, the parties "shall utilize the same medical evaluator who prepared the previous evaluation to resolve the medical dispute" to the extent possible. Together, those provisions reflect a strong preference for continuity of the medical-legal evaluator, and they set the framework for disputes that arise when a QME relocates his or her practice.
April kept the MS&A team on the move—from engaging with HR leaders at industry events to hosting a Lunch & Learn with clients, connecting across our offices, and even taking in a ballgame together in San Diego. It was a month full of meaningful conversations, team-building moments, and opportunities to strengthen the relationships that drive what we do.
In accepted cases, Labor Codes 4061 and 4062 establish the procedures by which parties may dispute a medical determination made by a primary treating physician (PTP) and, when the employee is represented by an attorney, obtain a comprehensive medical evaluation through the qualified medical evaluator (QME) panel process under LC 4062.2. Under LC 4061(b), a valid objection may be raised to a PTP's medical determination "concerning the existence or extent of permanent impairment and limitations or the need for future medical care." Under LC 4062(a), objections to medical determinations may be raised to issues not covered by LC 4061 (for example, ongoing temporary disability, body parts injured, work restriction).
March kept the MS&A team on the move! From connecting with clients at a hosted happy hour to sharing insights at conferences like Central California SHRM and EWC&R, it was a month full of learning, collaboration, and great conversations.
We also enjoyed time with our community at events like crab feeds and local SHRM gatherings, continued our North State Training series, and hosted a happy hour for our El Segundo office.
California lawmakers are taking a closer look at how artificial intelligence is shaping the workplace—and what it means for employers.
A new slate of proposed legislation—supported by organized labor and policymakers involved in recent worker protection efforts—aims to introduce guardrails around the use of AI on the job. Two key bills—SB 951 and SB 947—take different but complementary approaches.
Labor Code § 4610(l) allows an employer to defer conducting utilization review (UR) of a request for medical treatment "while the employer is disputing liability for injury or treatment of the condition for which treatment is recommended pursuant to Section 4062." Former California Code of Regulation (CCR) 9792.9.1(b) and new CCR 9792.9.2(a), effective April 1, 2026, state that a request for authorization "may be deferred if the claims administrator disputes liability for either the occupational injury for which the treatment is recommended or the recommended treatment itself on grounds other than medical necessity." That procedure protects defendants from having to immediately determine the medical necessity of treatment for a potentially nonindustrial condition.
