Workers’ Compensation · Primary-source case analysis

Sandhagen: Missing Utilization-Review Deadlines Excludes the UR Report

By Aneeta Mishra and Timothy Chan

Published May 16, 2026

Decision: Sandhagen v. Cox & Cox Constr., No. RDG 115958 (WCAB Nov. 16, 2004) (en banc).

Sandhagen v. Cox & Cox Construction addressed the consequences of an employer’s untimely utilization review of a treating physician’s recommendation.

Section 4610 deadlines were mandatory

A defendant that chose utilization review had to complete the process within the statutory time limits for the treatment request.

An untimely report was inadmissible

The Board excluded the late UR report from evidence concerning the particular disputed treatment.

The report could not be routed to an evaluator

The untimely UR analysis also could not be forwarded to an AME or QME when section 4062 procedures were timely pursued.

The defendant could still use the statutory dispute path

After missing UR deadlines, the defendant became the objecting party and had to comply with section 4062 timing unless extended for good cause or agreement.

Key takeaways

• Record receipt of every treatment request.
• Calculate each UR deadline from the governing statute and rules.
• Challenge late reports before they enter the medical record.
• Calendar the alternative section 4062 objection deadline immediately.

Discussed in: Workers’ Comp Treatment Denied in California? Understanding UR and IMR.