As regular daisyNews readers know, there’s an unfortunate quirk to California’s Independent Bill Review (IBR) process, in which providers ask the state to resolve disputes over payment for injured workers’ treatment.

For those unfamiliar, payers sometimes engage in something we call “IBR Chicken,” whereby:

1. The payer denies the provider’s original bill.
2. The payer denies the provider’s subsequent appeal disputing the payment denial.
3. The provider assembles extensive paperwork and pays a $195 filing fee to request IBR to dispute the payment denial.
4. Before IBR occurs, the payer reverses course and pays correctly.

At each step, a mistake or untimely filing by the provider results in forfeiting their reimbursement and the payer automatically keeping the disputed amount. It’s simple for payers to deny or reduce a provider’s reimbursement, even on dubious or blatantly invalid grounds, and wait to see if the provider has the resources and stamina to see the dispute through IBR. If the provider fails, the payer wins.

Maximus, the independent reviewer that conducts IBR, is well aware of the game. Unfortunately, the California Division of Workers’ Compensation (CA DWC) does nothing to deter it, not even enforcing payment of penalties and interest or restitution of the IBR filing fee when Maximus overturns a denial.

At scale, IBR Chicken can cost providers significant revenue.

Case in point: Sentry Insurance incorrectly denied reimbursement for 26 bills for a single patient’s treatment, and subsequently denied all 26 Second Review appeals. On the provider’s behalf, daisyCollect submitted 26 IBR requests totaling over 1,100 pages of documentation, at a cost of over $5,000 in IBR filing fees.

Before Maximus could conduct IBR, Sentry paid every bill, without waiting for Maximus’ IBR decision.

This is what happens when regulators don’t do their jobs: payers commit payment violations at scale without consequence, and doctors have every reason to avoid comp patients.

IBR Chicken: An “Unfortunate” Reality

In an email to daisyBill following a previous incident, Maximus acknowledged that some payers (aka claims administrators) stand by invalid denials until the provider plays the IBR card, then suddenly have a change of heart.

As Maximus noted, nothing in California regulations specifically bars IBR Chicken. Moreover, the only sliver of a prayer a provider has of obtaining penalty and interest payments and/or a refund for the IBR filing fee is to proceed with IBR, despite having been paid (emphases ours):

“While it is unfortunate that some claims administrators are waiting until after the filing of an IBR application to properly pay some of their bills, there is unfortunately nothing in the regulations that prevents claims administrators from making such belated payments, nor are providers automatically entitled to a refund of their full IBR filing fee or to penalties and interest in such cases.”

CA DWC regulations mandate that when Maximus overturns a bogus denial, the payer must restore the IBR filing fee; however, payers frequently neglect to do so, without consequence.

Moreover, the CA DWC considers penalty and interest payments “self-executing” by payers, which in effect amounts to elegant legalese for “optional.”

In other words, the only agency with the power to deter IBR Chicken, either through new regulations or enforcement of existing ones, remains on the sidelines while providers face abuse. For the CA DWC, that’s a sadly on-brand position to take.

Sentry’s Self-Overturned Denials

In the case of a Tastes on the Fly employee, the provider obtained written authorization for treatment from Sentry, then rendered that approved treatment over 26 visits.

The provider submitted 26 bills to Sentry, each with the authorization documentation attached.

Yet the insurer denied payment for every bill, citing that the treatment was unauthorized. All 26 subsequent Second Review appeals also included proof of authorization, but were met with the same flatly (and obviously) untrue denial reasoning: no authorization.

On behalf of the provider, daisyCollect submitted 26 IBR requests on May 14, 2026.

Just over a month later, on June 19, the provider received payment for all 26 bills. Maximus did not actually conduct IBR for a single bill (largely because the CA DWC consistently violates state law by failing to assign disputes for IBR within the legal 30-day time frame).

For the oldest bills, this provider waited over four months from the date Sentry received the bills to receive payment. California requires payment of all the bills below within 15 working days, as daisyCollect submitted each electronically.

A months-long fight, involving over a thousand pages of documentation and over $5,000 in IBR fees the provider will likely never see restored, should not have been necessary for Sentry to pay what it owed. Of course, Sentry failed to pay the self-executing penalties and interest as required by California law.

This is the unfortunate reality for any doctor still willing to treat injured workers in California’s chaotic comp system.

daisyBill lets providers submit instant payment appeals and includes tools for easier IBR requests. Click below to learn more:

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