California Workers' Compensation Claims Handling Manual, rev. 3.2 · Meridian Claims Services (synthetic demo TPA) · California workers' compensation · live run · engine deepinfra/moonshotai/Kimi-K2.6 + verify:claude-opus-5
Drift report
13 Drift findings — manual contradicts regulation
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2.1 Claim Intake — Providing the Claim Form
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Verified
Manual says
Upon receiving notice of an employee injury from the employer, the adjuster confirms that the employer has provided the DWC-1 claim form to the injured worker. Our service standard is that the claim form is provided to the employee within five working days of the employer's notice of injury. Document the date of notice and the date the form was provided in the claim file.
Regulation requires
Cal. Labor Code § 5401(a)The employer must provide a workers' compensation claim form (DWC-1) to the injured employee within one working day of receiving notice or knowledge of the injury.
The manual's five-working-day standard for DWC-1 delivery contradicts REG-01, which requires the employer to provide the form 'within one working day of receiving notice or knowledge of the injury.'
Suggested corrected language
Amend the service standard to one working day of employer notice/knowledge to align with Cal. Labor Code § 5401(a).
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2.4 Compensability Decision
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Verified
Manual says
Every indemnity claim must receive a compensability decision. The adjuster must accept or deny the claim within 120 days of the filing of the claim form. If the decision deadline passes without action, escalate to the supervisor. Denials must state the specific grounds and be sent to the employee and their attorney of record.
Regulation requires
Cal. Labor Code § 5402(b)If liability is not rejected within 90 days after the claim form is filed, the injury is presumed compensable and the presumption is rebuttable only by evidence discovered after the 90-day period.
Manual sets 120-day decision deadline, but Labor Code § 5402(b) requires rejection within 90 days; otherwise injury is presumed compensable.
Suggested corrected language
Change compensability decision deadline from 120 days to 90 days from claim form filing.
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4.2 Utilization Review — Decision Timeframes
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Verified
Manual says
Route all requests for authorization (RFAs) to the UR vendor on the day of receipt. For prospective and concurrent review, the UR decision is due within 10 business days of receipt of the request. Where additional information is needed, the decision may be extended per the vendor's discretion. Expedited review applies when the physician documents imminent and serious threat to health.
Regulation requires
Cal. Labor Code § 4610(i)Prospective or concurrent utilization review decisions must be made within 5 working days of receipt of the request for authorization, extendable to no more than 14 calendar days when additional information is reasonably required.
Manual sets 10-business-day deadline; REG-04 requires '5 working days.' Extensions 'per vendor's discretion' lack the 'no more than 14 calendar days' cap.
Suggested corrected language
Change prospective/concurrent UR deadline to 5 working days and cap extensions at 14 calendar days when additional information is reasonably required.
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2.5 Interim Medical Authorization (Delay Period)
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Verified
Manual says
While a claim is on delay pending the compensability investigation, authorize treatment consistent with MTUS up to a maximum liability of $5,000 until the claim is accepted or denied. Track interim medical spend in the claim system and alert the adjuster at 80% of the cap.
Regulation requires
Cal. Labor Code § 5402(c)Within one working day of the employee filing a claim form, the employer must authorize the provision of all treatment consistent with MTUS, with liability limited to $10,000 until the claim is accepted or rejected.
Manual sets a $5,000 interim treatment cap; REG-06 (Cal. Labor Code § 5402(c)) requires liability limited to $10,000 until the claim is accepted or rejected.
Suggested corrected language
Change the interim authorization cap to $10,000 to comply with Labor Code § 5402(c).
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4.4 Treating Physician Reporting
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Verified
Manual says
The primary treating physician is required to submit progress reports (PR-2) at least every 60 days. If a report is not received on schedule, send a written request to the physician's office and document the follow-up in the activity log. Missing reports for over two cycles trigger a treating physician compliance review.
Regulation requires
8 CCR § 9785(f)The primary treating physician must submit a progress report (PR-2) no less frequently than every 45 days from the last report.
Manual requires PR-2 every 60 days; REG-07 (8 CCR § 9785(f)) mandates progress reports no less frequently than every 45 days. This extends the statutory deadline by 15 days.
Suggested corrected language
Change the interval from 60 days to 45 days from the last report to match 8 CCR § 9785(f).
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2.6 Decision Review Cycle
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Verified
Manual says
Compensability determinations follow our standard review cycle: intake review in week one, investigation through the second month, and a final determination completed before the close of the four-month review window that begins when the employee's claim paperwork is filed. Supervisory sign-off is required on all denials.
Regulation requires
Cal. Labor Code § 5402(b)If liability is not rejected within 90 days after the claim form is filed, the injury is presumed compensable and the presumption is rebuttable only by evidence discovered after the 90-day period.
Manual permits a four-month (~120-day) final determination window, but REG-02 requires liability rejection within 90 days after claim filing.
Suggested corrected language
Compress review cycle so final compensability determinations, especially denials, issue within 90 days of claim filing.
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5.2 Employee Expense Reimbursement
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Verified
Manual says
Reimburse injured employees for reasonable transportation to and from authorized medical appointments at the state mileage rate. Process reimbursement requests in the order received; payment must issue within 90 days of receiving the employee's request with supporting documentation.
Regulation requires
Cal. Labor Code § 4600(e)(2)The employee is entitled to reimbursement for reasonable transportation expenses incurred to obtain treatment, payable at the mileage rate set for state employees, with reimbursement due within 60 days of the request.
REG-12 requires reimbursement within 60 days of the request; the manual allows 90 days, exceeding the statutory deadline.
Suggested corrected language
Change the reimbursement deadline from 90 days to 60 days from receipt of the employee's request.
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7.1 Supplemental Job Displacement Vouchers
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Verified
Manual says
When a claim involves permanent partial disability and no qualifying offer of regular, modified, or alternative work is made within 60 days of the first PPD report, issue the supplemental job displacement voucher in the amount of $5,000. Document voucher issuance and expiration in the claim file.
Regulation requires
Cal. Labor Code § 4658.7For injuries on or after January 1, 2013 causing permanent partial disability, the employee is entitled to a supplemental job displacement voucher of $6,000 unless the employer makes a qualifying offer of regular, modified, or alternative work within 60 days of receiving the first report finding the injury caused permanent partial disability.
Manual states SJDB voucher is $5,000, but REG-13 mandates $6,000 for injuries on or after Jan 1, 2013 causing permanent partial disability when no qualifying work offer is made within 60 days.
Suggested corrected language
Change voucher amount from $5,000 to $6,000.
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3.4 Late Payment Penalties
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Verified
Manual says
All late-payment exposure on indemnity benefits is capped at 10 percent of the late amount under any circumstances, including where a delay is later found unreasonable. Apply the increase automatically and note it on the benefit printout.
Regulation requires
Cal. Labor Code § 5814When payment of compensation is unreasonably delayed or refused, the amount unreasonably delayed is increased by up to 25 percent or up to $10,000, whichever is less — a separate and larger exposure than the 10 percent self-imposed increase for late payments under § 4650(d).
REG-14 authorizes up to 25% or $10,000 for unreasonable delay or denial. The manual states exposure is "capped at 10 percent of the late amount under any circumstances," contradicting the separate larger exposure.
Suggested corrected language
Clarify that the automatic 10% penalty applies to late payments, but unreasonable delay or denial may trigger an additional penalty of up to 25% or $10,000 under § 5814.
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3.5 Benefit Notices
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Verified
Manual says
Issue the first temporary disability benefit notice promptly. Our service standard is to have all first notices in the mail within three weeks of learning of the injury and disability, with the benefit amount and calculation method stated.
Regulation requires
8 CCR § 9812The claims administrator must send the first temporary disability benefit notice to the employee within 14 days of knowledge of the injury and disability, advising of benefits due, the payment amount, and how it was calculated.
Manual allows 21 days (three weeks) to mail the first temporary disability benefit notice, but REG-16 requires it within 14 days of knowledge. This exceeds the statutory deadline.
Suggested corrected language
Change the service standard to require mailing the first temporary disability benefit notice within 14 days of learning of the injury and disability.
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4.5 Interim Treatment Authorization Procedure
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Verified
Manual says
On receipt of a filed claim form, authorize treatment consistent with MTUS up to the $10,000 statutory liability cap pending the compensability decision. Authorization must be issued within five working days of the claim form filing and documented in the utilization log.
Regulation requires
Cal. Labor Code § 5402(c)Within one working day of the employee filing a claim form, the employer must authorize the provision of all treatment consistent with MTUS, with liability limited to $10,000 until the claim is accepted or rejected.
Cal. Labor Code § 4600; § 4604.5 (MTUS)Medical treatment must be provided consistent with the Medical Treatment Utilization Schedule (MTUS), which is presumptively correct on the issue of extent and scope of treatment.
Manual sets a five-working-day deadline; REG-06 requires authorization 'within one working day of the employee filing a claim form'.
Suggested corrected language
Change interim authorization deadline to one working day.
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3.7 Temporary Disability Rate Worksheet
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Verified
Manual says
Compute temporary total disability using the standard worksheet: gross average weekly earnings from all employment, multiplied by 60 percent, subject to the statutory minimum and maximum in effect on the date of injury. Attach the worksheet to the first payment record.
Regulation requires
Cal. Labor Code §§ 4453, 4653Temporary total disability indemnity is paid at two-thirds of the employee's average weekly earnings, subject to the statutory minimum and maximum rates in effect on the date of injury.
Manual specifies 60% rate, but REG-08 (Cal. Labor Code §§ 4453, 4653) mandates temporary total disability at two-thirds (66.67%) of average weekly earnings.
Suggested corrected language
Change the multiplier from 60 percent to two-thirds (66.67%).
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2.8 Claim Form Logistics
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Verified
Manual says
To consolidate mailings and reduce postage errors, the DWC-1 claim form is enclosed with the first benefit notice package rather than sent separately, so the employee receives the form together with the initial payment explanation.
Regulation requires
Cal. Labor Code § 5401(a)The employer must provide a workers' compensation claim form (DWC-1) to the injured employee within one working day of receiving notice or knowledge of the injury.
8 CCR § 9812The claims administrator must send the first temporary disability benefit notice to the employee within 14 days of knowledge of the injury and disability, advising of benefits due, the payment amount, and how it was calculated.
REG-01 requires the DWC-1 claim form be provided within one working day of knowledge of injury. Bundling it with the first benefit notice (sent within 14 days per REG-16) violates the one-working-day deadline.
Suggested corrected language
Send the DWC-1 within one working day of injury knowledge; do not delay it to combine with the 14-day first benefit notice.
02 Coverage gaps — no procedure covers these
Cal. Labor Code §§ 4060–4062.2QME panel process for medical disputesDisputed medical determinations are resolved through the Qualified Medical Evaluator (QME) panel process; a represented or unrepresented employee/claims administrator must follow the statutory panel request procedure and timelines after objection to a medical determination.
8 CCR § 14001 (Form 5020)Employer's report of occupational injuryThe employer must file a complete Employer's Report of Occupational Injury or Illness (Form 5020) with its claims administrator within 5 days of knowledge of any injury resulting in lost time beyond the date of injury or requiring medical treatment beyond first aid.