As the Legislature printed it
DIVISION 4. WORKERS' COMPENSATION AND INSURANCE [3200 - 6002] · PART 2. COMPUTATION OF COMPENSATION [4451 - 4856] · CHAPTER 2. Compensation Schedules [4550 - 4856] · ARTICLE 2.5. Medical-Legal Expenses [4620 - 4628]
All medical-legal expenses for which the employer is liable shall, upon receipt by the employer of all reports and documents required by the administrative director incident to the services, be paid to whom the funds and expenses are due, as follows: (a) (1) Except as provided in subdivision (b), within 60 days after receipt by the employer of each separate, written billing and report, and if payment is not made within this period, that portion of the billed sum then unreasonably unpaid shall be increased by 10 percent, together with interest thereon at the rate of 7 percent per annum retroactive to the date of receipt of the bill and report by the employer. If the employer, within the 60-day period, contests the reasonableness and necessity for incurring the fees, services, and expenses using the explanation of review required by Section 4603.3, payment shall be made within 20 days of the service of an order of the appeals board or the administrative director pursuant to Section 4603.6 directing payment. (2) The penalty provided for in paragraph (1) shall not apply if both of the following occur: (A) The employer pays the provider that portion of his or her charges that do not exceed the amount deemed reasonable pursuant to subdivision (e) within 60 days of receipt of the report and itemized billing. (B) The employer prevails. (b) (1) If the provider contests the amount paid, the provider may request a second review within 90 days of the service of the explanation of review. The request for a second review shall be submitted to the employer on a form prescribed by the administrative director and shall include all of the following: (A) The date of the explanation of review and the claim number or other unique identifying number provided on the explanation of review. (B) The party or parties requesting the service. (C) Any item and amount in dispute. (D) The additional payment requested and the reason therefor. (E) Any additional information requested in the original explanation of review and any other information provided in support of the additional payment requested. (2) If the provider does not request a second review within 90 days, the bill will be deemed satisfied and neither the employer nor the employee shall be liable for any further payment. (3) Within 14 days of the request for second review, the employer shall respond with a final written determination on each of the items or amounts in dispute, including whether additional payment will be made. (4) If the provider contests the amount paid, after receipt of the second review, the provider shall request an independent bill review as provided for in Section 4603.6. (c) If the employer denies all or a portion of the amount billed for any reason other than the amount to be paid pursuant to the fee schedules in effect on the date of service, the provider may object to the denial within 90 days of the service of the explanation of review. If the provider does not object to the denial within 90 days, neither the employer nor the employee shall be liable for the amount that was denied. If the provider objects to the denial within 90 days of the service of the explanation of review, the employer shall file a petition and a declaration of readiness to proceed with the appeals board within 60 days of service of the objection. If the employer prevails before the appeals board, the appeals board shall order the physician to reimburse the employer for the amount of the paid charges found to be unreasonable. (d) If requested by the employee, or the dependents of a deceased employee, within 20 days from the filing of an order of the appeals board directing payment, and where payment is not made within that period, that portion of the billed sum then unpaid shall be increased by 10 percent, together with interest thereon at the rate of 7 percent per annum retroactive to the date of the filing of the order of the board directing payment. (e) (1) Using the explanation of review as described in Section 4603.3, the employer shall notify the provider of the services, the employee, or if represented, his or her attorney, if the employer contests the reasonableness or necessity of incurring these expenses, and shall indicate the reasons therefor. (2) The appeals board shall promulgate all necessary and reasonable rules and regulations to insure compliance with this section, and shall take such further steps as may be necessary to guarantee that the rules and regulations are enforced. (3) The provisions of Sections 5800 and 5814 shall not apply to this section. (f) Nothing contained in this section shall be construed to create a rebuttable presumption of entitlement to payment of an expense upon receipt by the employer of the required reports and documents. This section is not applicable unless there has been compliance with Sections 4620 and 4621.
How panels applied this section
Newest released decisions whose legal-standard extraction named this section. Each quotes the passage and links to the official PDF. Unofficial guide — not legal advice.
- ADJ8710590 · 2026-05-26 · Riverside District Office§ 4622
Determinative passage · p.7A cost petitioner holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See § 3205.5, 5705.5; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 (Appeals Board en banc).) As we explained in our en banc decision in Colamonico v. Secure Transportation (2019) 84 Cal.Comp.Cases 1059 (Appeals Board en banc), section 4622 provides the framework for reimbursement of medical-
Cost petitioner met burden to show contested claim existed and services were reasonable and necessary; defendant failed to timely object with compliant Explanation of Review; cost petitioner entitled to reimbursement, penalties, and interest.
Official decision · page 7 → - ADJ10684244 · 2026-04-01 · Santa Ana District Office§ 4622
Determinative passage · p.5reimbursement of medical-legal expenses. Subsection (f) of the statute, however, specifically states that "[t]his section is not applicable unless there has been compliance with Sections 4620 and 4621." (Lab. Code, § 4622(f).) Thus, a lien claimant is required to establish that: 1) a contested claim existed at the time the expenses were incurred; 2) the expenses were incurred for the purpose of proving or disproving the contested claim; and 3) the expenses were reasonable and necessary at the time were incurred. (Lab. Code, § 4620, 4621, 4622(f); Colamonico, supra, 84 Cal.Comp.Cases 1059.)
The WCAB applied these standards to determine that a contested claim existed at the time medical-legal services were provided, supporting reimbursement.
Official decision · page 5 → - ADJ8766908 · 2026-03-03 · Fresno District Office§ 4622
Determinative passage · p.5Section 4622 provides the relevant dispute resolution protocol for medical-legal expenses,
The statute requires payment of medical-legal expenses with statutory increase and interest unless timely contested by employer with Explanation of Review (EOR).
Official decision · page 5 → - ADJ7404188 · 2026-03-02 · Long Beach Office District Office§ 4622
Determinative passage · p.6A cost petitioner holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See § 3205.5, 5705.5; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 (Appeals Board en banc).) As we explained in our en banc decision in Colamonico v. Secure Transportation (2019) 84 Cal.Comp.Cases 1059 (Appeals Board en banc), section 4622 provides the framework for reimbursement of medical- legal expenses. Subsection (f) of the statute, however, specifically states that "[t]his section is not applicable unless there has been compliance with Sections 4620 and 4621." (Lab. Code, § 4622(f).)
The WCAB applied this standard to find that the cost petitioner met its burden to show a contested claim existed at the time the medical-legal copy services were provided.
Official decision · page 6 → - ADJ10790437 · 2026-02-09 · Riverside District Office§ 4622
Determinative passage · p.7A lien claimant holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See Lab Code, § 3205.5, 5705; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 [2012 Cal. Wrk. Comp. LEXIS 160] (Appeals Board en banc).) Thus, a lien claimant is required to establish that: 1) a contested claim existed at the time the expenses were incurred; 2) the expenses were incurred for the purpose of proving or disproving the contested claim; and 3) the expenses were reasonable and necessary at the time they were incurred. (Lab. Code, § 4620, 4621, 4622(f); American Psycometric Consultants Inc. v. Workers' Comp. Appeals Bd. (Hurtado) (1995) 36 Cal.App.4th 1626 [60 Cal.Comp.Cases 559].) Pursuant to Colamonico v. Secure Transportation (2019) 84
Applied to determine whether lien claimant met burden for medical-legal expenses.
Official decision · page 7 → - ADJ19265320 · 2026-01-30 · San Jose District Office§ 4622
Determinative passage · p.6A defendant has 60 days to review and analyze a medical-legal bill or invoice. (Lab. Code, § 4622(a)(1).) A defendant has two options within this 60-day window: It may pay the bill or invoice in full or pay less than the full amount. Should a defendant decide to pay less than the full amount within the 60-day window, it may still avoid the imposition of a penalty and interest by including an EOR with its payment. Section 4622 requires that a defendant object to the invoice or billing with an EOR as described in section 4603.3. (Lab. Code, § 4622(a)(1), (e)(1); 4603.3.) Objecting to an invoice with an EOR within the 60-day window is defendant's burden. If a defendant does not pay a proper medical-legal invoice in full or fails to provide an EOR within the 60-day window, then a defendant has waived all objections, other than compliance with sections 4620 and 4621, to the medical-legal provider's billing. (Cal. Code Regs., tit. 8, § 10786(e).) A defendant is then liable for the reasonable value of the medical-legal services as well as a 10 percent penalty and 7 percent per annum interest.
The WCJ's denial of penalties was based on the finding that the payment was not unreasonably delayed and that the EOR was not properly served, but the WCAB found the record insufficient to support this and granted reconsideration.
Official decision · page 6 → - ADJ11448862 · 2026-01-26 · Riverside District Office§ 4622
Determinative passage · p.3No objection was filed by any party. Although evidence of payment was not submitted at trial, according to defendant's verified Answer, it tendered payment on May 15, 2019 pursuant to the NOI.
Defendant tendered payment on May 15, 2019, pursuant to the Order, avoiding penalties and interest.
Official decision · page 3 → - ADJ18961023 · 2026-01-23 · Van Nuys District Office§ 4622
Determinative passage · p.5WCAB Rule 10786 (Cal. Code Regs., tit. 8, § 10786) sets forth the framework for a
The WCAB considered this rule in evaluating the cost petitioner's claims for sanctions.
Official decision · page 5 →
All 43 decisions naming § 4622 →
The rules written under this section
A statute says what is owed; Title 8 says by when, on what form, and what happens if the deadline passes. These name § 4622as what they implement.
- 8 CCR § 10101Claim File--Contents.
- 8 CCR § 10101.1Claim File--Contents.
- 8 CCR § 10102Retention of Claim Files.
- 8 CCR § 10111Schedule of Administrative Penalties for injuries on or after January 1, 1990, but before January 1, 1994.
- 8 CCR § 10111.1Schedule of Administrative Penalties for Injuries on or After January 1, 1994.
- 8 CCR § 10111.2Full Compliance Audit Penalty Schedules; Target Audit Penalty Schedule.
- 8 CCR § 10451.1Determination of Medical-Legal Expense Disputes. [Repealed]repealed
- 8 CCR § 10451.4Petition to Enforce Independent Bill Review Determination. [Renumbered]repealed
- 8 CCR § 10570Petition to Enforce an Administrative Director Determination.
- 8 CCR § 10770Filing and Service of Lien Claims. [Repealed]repealed
- 8 CCR § 10786Determination of Medical-Legal Expense Dispute.
- 8 CCR § 10862Filing and Service of Lien Claims and Supporting Documents.
- 8 CCR § 10863Verification of Compliance with Labor Code Section 4903.6 on Filing of Lien Claim or Application by Lien Claimant.
- 8 CCR § 10872Notification of Resolution or Withdrawal of Lien Claims.
Also on this
Unofficial guide — not legal advice. The statute is the state’s text. The quotes are litigated applications, not a prediction.
About California Labor Code § 4622
What is California Labor Code § 4622?
Labor Code § 4622 sits in ARTICLE 2.5. Medical-Legal Expenses [4620 - 4628]. The statute on this page begins: All medical-legal expenses for which the employer is liable shall, upon receipt by the employer of all reports and documents required by. The official display is on LegInfo; this is a reprint.
Did WCAB panels apply Labor Code § 4622 in this corpus?
This corpus has 43 released decisions whose extracted legal standards named § 4622. Quotes and PDFs are on this page. That is not every case in California that ever cited the section.