Improper denials and payment adjustments are inevitable for California providers who treat injured workers. But in 2025, California providers recovered over $22 million using daisyBill's quick Second Review appeals to dispute incorrect payments.

The California Division of Workers' Compensation (CA DWC), under recently retired Administrative Director George Parisotto, has effectively incentivized payers to improperly reimburse providers by forcing providers to assume the administrative burden of disputing incorrect payments. If a provider fails to comply with the strict requirements for submitting a Second Review appeal, the provider forfeits the reimbursement owed.

As a result, payers have little incentive to properly reimburse providers, and many do not.

With the CA DWC tacitly permitting payer non-compliance, having a workflow in place to efficiently address payment errors (or "errors") is imperative for revenue management.

Since 2013, daisyBill providers have submitted over 1.3 million Second Review appeals, recovering over $121 million in revenue. Without a proactive approach to combating incorrect payments, payers would have kept every cent.

2025 CA Second Review Appeal Data

In 2025, daisyBill providers sent Second Review appeals for 11% of their California workers’ comp bills, collecting an average of $294 per bill in additional revenue.

These data prove that consistent Second Review appeals are a necessary line of financial defense and should be standard billing protocol for every practice.

Arguably, California incentivizes incorrect payment to providers.

Under CA DWC regulations, providers must submit a Second Review appeal within 90 days of receiving an Explanation of Review (EOR) from the payer. If the provider is a day late or fails to complete the mandatory SBR-1 form correctly, they forfeit any additional reimbursement.

Meanwhile, payers rarely face consequences for incorrect payment, even as a result of non-compliance (including, apparently, non-compliance with the requirement to properly respond to appeals). Even if a provider pays $195 to take a dispute all the way to Independent Bill Review (IBR), the likely outcome is that the payer will reimburse only the amount originally owed, and not a dime more:

• Penalties and interest payments are “self-executing” by payers.
• The requirement to refund the IBR fee is largely unenforced.

As a result, in the regulatory environment established under George Parisotto’s CA DWC, it can be lucrative for payers to reflexively deny and adjust reimbursement, even on dubious or downright incorrect grounds.

Protect Your Practice

Providers should make it standard operating procedure to check each reimbursement amount against the applicable fee schedule and always appeal when appropriate. When doing so, strictly observe the requirements:

• Submit the appeal within 90 days of receiving the original EOR from the payer.
• Submit the appeal using the Ca DWC Form SBR-1 (technically, providers may submit a modified version of the original bill, but we do not recommend it).
• Submit the Second Review appeal using the same delivery method (i.e., paper or electronic) as the original bill.
• Include all relevant supporting documents.

daisyBill providers have support: our software automatically flags incorrect payments, and our automated ‘Task’ system prompts practice staff to electronically submit the SBR-1 and necessary documents, which takes only seconds.

See the short video below to learn how Second Review appeals are one of the easiest ways to optimize billing and maximize revenue for treating injured workers.

If you have any questions about the Second Review process, contact our experts using the chat icon at the bottom right of this screen or email us at info@daisybill.com.

daisyBill tracks every bill and payment, with automated task prompts to submit appeals when necessary. Click below to learn more:

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