Workers’ Compensation · Primary-source case analysis

Willette: An Unrepresented Worker Must Use the Panel-QME Path After UR

By Aneeta Mishra and Timothy Chan

Published May 17, 2026

Decision: Willette v. AU Electric Corp., No. SJO 0245781 (WCAB Oct. 5, 2004) (en banc).

Willette v. AU Electric Corporation addressed the medical-legal path for an unrepresented employee after utilization review did not approve requested treatment in full.

A timely objection begins the dispute process

An unrepresented employee who contests the UR determination must object within the governing period rather than allow the decision to become final.

A panel QME resolves the medical dispute

The statutory procedure calls for a panel evaluator after the worker makes the timely objection.

The treating and UR physicians do not reopen the contest

After the QME evaluation, those physicians may not issue additional reports addressing the same post-UR treatment dispute.

No single medical report automatically controls

At trial the QME, treating-physician, and UR reports may all be considered, with weight determined from the complete record.

Key takeaways

• Serve and calendar the objection immediately.
• Request the correct panel-QME process for an unrepresented worker.
• Provide the evaluator the treatment and UR reports.
• Build a complete admissible record without unauthorized post-QME reports.