California employers pay four times more in Medical-Legal costs for Subsequent Injuries Benefits Trust Fund (SIBTF) claims than for standard workers' comp claims.

The SIBTF claims cover benefits for injured workers with pre-existing injuries, whether work-related or not. The program was originally designed to encourage employers to hire disabled workers (initially war veterans) by offsetting the risk that a new workplace injury could compound an existing one.

California employers fund the SIBTF through mandatory assessments.

When a workers' comp injury is disputed, California employers foot the bill for the Medical-Legal process to resolve questions ranging from the injury's work-relatedness to the worker's level of impairment. Under the current Medical-Legal Fee Schedule, effective April 1, 2021, a single Comprehensive Medical-Legal evaluation costs $2,015. Follow-up and Supplemental Evaluations cost $1,316.25 and $650, respectively.

On top of these flat fees, physicians charge a record review fee of $3 per page when records exceed certain page thresholds (which is frequent).

The cost gap between standard and SIBTF Medical-Legal bills is staggering.

From April 1, 2021 through February 28, 2026, the average payment for over 500,000 non-SIBTF Medical-Legal bills daisyBill clients submitted was $2,193 per paid bill. By comparison:

• The average payment for over 8,400 paid SIBTF Medical-Legal bills was $8,788, four times higher.
• The highest single SIBTF Medical-Legal bill payment reached $146,956.
• For a single SIBTF injury claim, total Medical-Legal payments reached $725,570.

When the Medical-Legal costs for a single SIBTF claim exceed $700,000, something is fundamentally broken.

California employers already pay some of the highest premium rates in the nation for workers' comp coverage, and may soon pay even more. The SIBTF's sky-high Medical-Legal costs, along with the assessments funding the program, are yet another way employers are shouldering California's bloated, broken, inefficient workers’ comp system.

daisyData: SIBTF Medical-Legal Expenses

The table below displays SIBTF Medical-Legal payment data from our systems for April 1, 2021 through February 28, 2026. In that time frame, California employers paid daisyBill evaluators for 8,456 Medical-Legal bills on SIBTF claims.

In total, paid SIBTF claims cost over $74 million in Medical-Legal services, with an average payment of $8,788 per paid bill.

The SIBTF has been at the center of serious controversy for years, with costs spiraling out of control and multiple failed and ongoing attempts at reform.

The California Division of Workers’ Compensation (CA DWC) is responsible for managing SIBTF claims. Under the former Administrative Director, George Parisotto, SIBTF payments grew exponentially and, by extension, so did California employers' assessments (see the chart below from a 2024 RAND report).

Workers’ Comp Executive reported that SIBTF had generated around $26 billion in future liabilities as of August 2025. Effectively, California employers are on the hook for $26 billion in future assessments.

Under the CA DWC management, according to the RAND report, aggregate annual SIBTF Medical-Legal payments grew from $492,000 in 2010 to $43 million in 2022, an increase of nearly 9,000%.

daisyData: 25 Most Expensive SIBTF Injuries

Below are the 25 most expensive SIBTF injuries in our system. For each injury, we list the number of Medical-Legal bills daisyBill evaluators submitted for that injury, and the total amount paid across all of those bills.

For the single most expensive injury, California employers via SIBTF assessments paid $725,570 across 6 bills, while the 25th-most expensive injury cost $146,240 across 3 bills.

Collectively, these 25 injuries accounted for over $6.2 million in reimbursement across just 119 Medical-Legal bills, an average of over $52,000 per bill.

AB 1576 Seeks to Rein in SIBTF Costs

According to WorkCompCentral, the California Assembly’s Insurance Committee advanced Assembly Bill 1576. AB 1576 seeks to introduce cost-control measures to the SIBTF by, among other things:

• Requiring the same Medical-Legal process for SIBTF claims as for traditional claims
• Requiring the CA DWC to create a database of Qualified Medical Evaluators (QMEs) with specific expertise in secondary injuries

Whether AB 1576 passes or not, the CA DWC has a poor track record of collecting data as required by law. Reform legislation only works if the agency actually complies.

California employers are paying twice over: once through some of the highest workers' comp premium rates in the nation, and again through assessments for an SIBTF program the CA DWC has allowed to balloon unchecked from under $500,000 in Medical-Legal payments in 2010 to $43 million in 2022, with $26 billion in future liabilities, with employers footing the bill.

California needs to stop asking for higher premiums and assessments and start spending employers' money more effectively.

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