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.
- ADJ21274145 · 2026-10-02 · San Bernardino District Office§ 4622
Determinative passage · p.8II. Section 4060(b) allows a medical-legal evaluation by the treating physician. Section 4620(a) defines medical-legal expense as “any costs and expenses…for the purpose of proving or disproving a contested claim.” Section 4064(a) states in part that “[T]he employer shall be liable for the cost of each reasonable and necessary comprehensive medical-legal evaluation obtained by the employee pursuant to Sections 4060, 4061, and 4062.” The regulations provide that the “primary treating physician shall render opinions on all medical issues necessary to determine the employee’s eligibility for compensation....” (Cal. Code Regs., tit. 8, §9785(d).) AD Rule 9793(h) states: (h) “Medical-legal expense” means any costs or expenses incurred by or on behalf of any party or parties, the administrative director, or the appeals board for X-rays, laboratory fees, other diagnostic tests, medical reports, medical records, medical testimony, and as needed, interpreter's fees, for the purpose of proving or disproving a contested claim. The cost of medical evaluations, diagnostic tests, and interpreters is not a medical-legal expense unless it is incidental to the production of a comprehensive medical-legal evaluation report, follow-up medical-legal evaluation report, or a supplemental medical-legal evaluation report and all of the following conditions exist:
These statutes were applied to determine the lien claimant's entitlement to payment for the medical-legal report.
Official decision · page 8 → - ADJ11249966 · 2026-10-02 · Anaheim 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 Lab. Code, §§ 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).) WCAB Rule 10786 states in relevant part that: *** (b) If a defendant has failed to file and serve a petition for determination of medical legal expenses and a Declaration of Readiness in compliance with subdivision (a), a medical-legal provider may file and serve a petition for reimbursement of medical-legal expenses and a Declaration of Readiness to Proceed. Upon filing of a petition for reimbursement of medical-legal expenses and a Declaration of Readiness to Proceed, the medical-legal provider shall be added to the official address record.
Framework for reimbursement of medical-legal expenses and penalties for late payment
Official decision · page 6 → - ADJ9213906 · 2026-08-11 · Van Nuys District Office§ 4622
Determinative passage · p.8(Cal. Code Regs., tit. 8, § 10786(e) and (f).) Here, there is no evidence in the record that defendant objected to cost petitioner’s invoices or issued any EORs. At time of trial, defendant offered no exhibit evidence or witness testimony about its timely compliant objections or EORs in response to cost petitioner’s invoices. Accordingly, under section 4622(a), defendant has waived their objections to cost petitioner’s invoices, and they owe the bills, penalties of 10 percent, and 7 percent per annum interest. Furthermore, the WCJ’s order of payment per fee schedule is incorrect. Specifically, under WCAB Rule 10786(f), the fee schedule applies when defendant has sent EORs. We also note that the order to bill review is also not appropriate given that defendant failed to submit evidence that it issued timely compliant objections or EORs. (Lab.
Defendant's failure to issue timely and compliant objections or EORs results in waiver of objections and liability for payment, penalties, and interest.
Official decision · page 8 → - ADJ19682404 · 2026-08-03 · Riverside District Office§ 4622
Determinative passage · p.8Section 4060(b) allows a medical-legal evaluation by the treating physician. Section 4620(a) defines medical-legal expense as “any costs and expenses…for the purpose of proving or disproving a contested claim.” Section 4064(a) provides that the employer is liable for the cost of a comprehensive medical evaluation that is authorized by section 4060. The regulations provide that the “primary treating physician shall render opinions on all medical issues necessary to determine the employee's eligibility for compensation...” (Cal. Code Regs., tit. 8, § 9785(d).) AD Rule 9793(h) states: (h) “Medical-legal expense” means any costs or expenses incurred by or on behalf of any party or parties, the administrative director, or the appeals board for X-rays, laboratory fees, other diagnostic tests, medical reports, medical records, medical
The Appeals Board held that Dr. Haghighinia’s medical-legal report is a compensable medical-legal evaluation and that the lien claimant met the burden to show a contested claim and reasonableness of the expense.
Official decision · page 8 → - ADJ19265320 · 2026-07-30 · San Jose District Office§ 4622
Determinative passage · p.2On June 22, 2026, the parties agreed to, and filed a signed “Stipulation to Remand Matter to Trial Level for Further Proceedings.” In pertinent part, the Stipulation states that: The parties agree to remand this matter to trial level for further proceedings without withdrawing their positions or arguments. Based on the record, the parties present the following issue: whether defendant was obligated to file a Petition for Determination of Medical-Legal Expense Dispute and concurrent Declaration of Readiness within 60 days of the provider’s objection as set forth by Labor Code § 4622. In addition, the WCJ shall address any other issue he deems appropriate.
The issue presented for further proceedings was whether the defendant was obligated to file a Petition for Determination of Medical-Legal Expense Dispute and concurrent Declaration of Readiness within 60 days of the provider’s objection as set forth by this statute.
Official decision · page 2 → - ADJ4457963 · 2026-07-20 · Oxnard District Office§ 4622
Determinative passage · p.92. The September 20, 2003 report of Julie Goalwin, Ph.D., was a legally obtained medical- legal report pursuant to section 4060 as it existed in 2003. 3. The ML-103 charges of Angoal Medical are subject to statutory increase and statutory interest under Labor Code sections 4622 and 5800, respectively. 4. Angoal Medical Collections is entitled to reimbursement of the filing fee, having demonstrated liability for the charges.
The Board ordered statutory increase on the lien reimbursement under section 4622.
Official decision · page 9 → - 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 →
All 49 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 49 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.