Independent Bill Review (IBR) cases in the first six months of 2026 resulted in payers being ordered to send additional reimbursements to California providers totaling roughly $2,070,000, according to WorkCompCentral.

That number represents revenue that payers wrongfully denied to providers, forcing practices to expend significant time and resources (including a $195 IBR filing fee) to pursue correct payment. It is unclear whether the $2.07 million in payments includes restitution of the filing fees, which payers notoriously fail to remit after losing IBR cases.

The good news: 87% of IBR decisions through June 2026 favored the provider. This is consistent with years of IBR data showing that IBR overwhelmingly finds the provider was right.

The bad news: providers’ IBR success rate reflects a system in which doctors must routinely battle bogus payer bill review decisions and navigate an appeals process that requires time, money, and effort just to receive what they were always owed.

In a workers’ comp environment characterized by lax or nonexistent enforcement of payment requirements, payers have little incentive to reimburse accurately, instead playing “IBR Chicken” by denying or adjusting charges later determined to be valid.

Moreover, the California Division of Workers’ Compensation (CA DWC) under its previous Administrative Director (AD), George Parisotto, routinely violated state law requiring it to promptly assign disputes for IBR. As a result, providers often went months without proper reimbursement.

IBR’s success as a backstop against errors and abuses is laudable. However, the sheer prevalence of those errors and abuses historically, and the CA DWC’s previous failure to meaningfully address them, cannot be discounted.

The CA DWC’s new AD, Nicole Richardson, has acknowledged many of these issues and pledged to meaningfully address them. We’re inclined to take her at her word and optimistic that going forward, the agency will help create a system where IBR is more fair and less necessary.

WorkCompCentral: IBR Sends Millions to Providers

From January to June of 2026, California providers requested IBR 3,675 times, with eligible disputes resulting in orders to pay $2.07 million to providers so far.

At $195 a pop, the providers collectively fronted over $716,000 just to ask the state to enforce proper payment (though, theoretically, the CA DWC may deem a dispute ineligible for IBR due to failure to pay the filing fee). The CA DWC deemed only 2,213, or 60%, of those disputes eligible for IBR; when the CA DWC deems a dispute ineligible for IBR, the provider receives a partial refund of $156 from Maximus.

Interminable Waits for IBR

The WorkCompCentral article does not mention how long it took California to order the correct payment through IBR.

The CA DWC outsources IBR to Maximus Federal Services, Inc. California Labor Code § 4603.6 requires the CA DWC to assign every IBR request to Maximus within 30 days of the provider’s request. Yet, historically, the agency routinely violated this law: in 2025, the CA DWC missed the 30-day deadline for 96% of IBR requests.

Last year, providers waited up to 232 days for the CA DWC to assign their disputes. Bear in mind that if a provider misses the 30-day deadline to request IBR by a single day, the CA DWC can rule the dispute ineligible for IBR, and the provider forfeits the disputed amount.

End the Game of Chicken

The positive news about the rate at which IBR favors the provider obscures a deeper problem with California payment laws and regulations: payers often ignore them.

Engaging in what daisyNews has dubbed “IBR Chicken,” the payer refuses to reimburse the provider's bill correctly, then denies the provider’s subsequent Second Review appeal disputing the incorrect payment. Only after the provider requests IBR does the payer finally remit the correct payment, before Maximus even takes up the dispute.

For the payer, the game is a can’t-lose:

• If the provider withdraws the IBR request, the payer has lost nothing, having paid only the amount it always owed.
• If the provider proceeds with IBR and wins, Maximus orders the payer to remit the IBR filing fee…which payers constantly fail to do without consequence.

Moreover, the CA DWC has declared the penalty and interest payments due for failure to timely pay the correct reimbursement to be “self-executing” by payers. In other words, there are effectively no consequences (at least not any that are enforced) for improperly denying or reducing providers’ payments.

An 87% IBR win rate for providers isn’t a sign that the system is working. It’s a glimmer of justice in a system that consistently defaults to the payer’s advantage, even when the payer is demonstrably in the wrong. We maintain the sincere belief and hope that the Richardson era will rebalance the scales.

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