If your treating doctor requests surgery, therapy, injections, medication, imaging, or another treatment after a work injury, the first fight may be getting the request submitted correctly. That is the RFA problem.
The next fight can be worse: Utilization Review denies, delays, or modifies the treatment, and now you are told the answer has to go through Independent Medical Review, or IMR.
That is where many injured workers get lost. The denial letter arrives. The acronyms multiply. The doctor says treatment is needed. The claims administrator says the review process says no. Meanwhile, pain, work restrictions, missed shifts, and bills keep moving.
DWC's 2025 IMR report shows this is not a small corner of the system. Maximus Federal Services, which administers IMR, received 201,037 IMR applications and issued 152,351 final determination letters in 2025. Treatment denials were overturned at an overall rate of 10.2%.
That number matters, but not because it predicts the result of any specific claim. It matters because IMR is a document-driven process. If treatment is denied, the record has to be built before the system decides what it is looking at.
What Is IMR?
Independent Medical Review is the process used in California workers' compensation to resolve certain disputes over medical treatment after Utilization Review denies, delays, or modifies a treatment request.
In plain English:
- your treating doctor requests treatment,
- the request goes through Utilization Review,
- UR denies or changes the request,
- IMR may review whether the treatment is medically necessary under California's treatment guidelines and the medical records submitted.
IMR is not a second doctor visit. It is not a courtroom hearing. It is not a chance to explain everything from scratch in your own words.
It is a review built around medical records, treatment requests, UR decisions, and the applicable medical guidelines. That is why the paperwork matters so much.
What DWC's 2025 IMR Report Shows
The California Department of Industrial Relations and Division of Workers' Compensation released the annual IMR report for 2025. According to DWC:
- Maximus received 201,037 IMR applications,
- Maximus issued 152,351 final determination letters,
- decisions were issued an average of six to seven days after all required medical records were received,
- nearly 91% of unique IMR filings were deemed eligible for review,
- pharmaceutical requests made up 31% of treatment requests submitted for IMR,
- opioids made up 22% of pharmaceutical requests,
- treatment request denials were overturned at an overall rate of 10.2%, down from 12.7% in 2024,
- the Medical Treatment Utilization Schedule remained the primary resource for deciding medical necessity.
The brutal part is this: IMR can move quickly once required records are received, but that speed does not help if the record is incomplete, unclear, or missing the medical support your doctor relies on.
What Workers Should Save After a Treatment Denial
If treatment is denied or changed, do not rely on memory. Build the file.
Save:
- the RFA or treatment request,
- the treating physician report supporting the request,
- the Utilization Review denial or modification letter,
- the date the denial was received,
- any IMR application or notice,
- diagnostic reports, imaging, operative reports, and therapy notes,
- work-status slips and restrictions,
- medication lists and pharmacy denials,
- messages from the adjuster, nurse case manager, doctor, or claims administrator,
- appointment cancellations or delays caused by the denial,
- notes showing how symptoms changed while treatment was pending,
- wage records if the denial affects your ability to work.
The point is not to drown the case in paper. The point is to keep the documents that show what treatment was requested, why it was requested, why it was denied, and how the denial affected recovery and work status.
Questions to Ask After UR Says No
After a denial, modification, or delay notice, ask practical questions fast:
- What exact treatment was denied or modified?
- Was the request denied because of medical necessity, missing records, timing, or something else?
- Did the UR reviewer have the most recent medical records?
- Did the treating doctor explain why the treatment is needed?
- Does the denial letter identify the guideline or reason relied on?
- Is there an IMR deadline or application step?
- Has the doctor's office received the denial and reviewed it?
- Are work restrictions still being honored while treatment is disputed?
Get answers in writing when possible. A portal message or letter is better than a phone call that becomes fog later.
Why IMR Is Not the Whole Case
IMR focuses on medical necessity for disputed treatment. It does not solve every workers' comp problem.
A treatment denial may also connect to:
- temporary disability if you cannot work while treatment is pending,
- permanent disability if the untreated condition worsens or stabilizes with lasting limitations,
- disputes over the treating doctor's reporting,
- QME or AME issues,
- pressure to return to work before treatment is resolved,
- claim denial or body-part disputes,
- delays that may require action before the Workers' Compensation Appeals Board.
That is why injured workers should not treat IMR as a magic appeal button. It is one part of the claim, and the surrounding record still matters.
When to Get Legal Help
Not every treatment denial requires a lawyer. Some denials can be fixed by the treating doctor's office submitting clearer records or addressing the reason for denial.
But legal help may be important when:
- treatment is repeatedly denied or modified,
- the denial involves surgery, injections, imaging, therapy, medication, or a referral to another treating doctor,
- the denial affects your ability to work,
- temporary disability checks stop or shrink,
- the adjuster says records are missing but the doctor says they were sent,
- you are pushed back to work despite active symptoms,
- the claim is also disputed, delayed, or partially denied,
- you do not understand the IMR paperwork or deadlines.
At that point, the question is not just, "Can I appeal this denial?" It is, "Can we build the medical and wage record before the denial controls the claim?"
Source
This post is based on the California Department of Industrial Relations and Division of Workers' Compensation Newsline: DIR, DWC release Independent Medical Review report for 2025. DWC's release summarizes the 2025 IMR annual report and explains IMR activity, eligibility, denial overturn rates, pharmaceutical request data, and the role of the Medical Treatment Utilization Schedule.
Bottom Line
IMR is the process that may come after Utilization Review denies or changes workers' comp medical treatment. It is fast once the required records are received, but it is still built on documents.
If your treatment is denied, save the RFA, UR denial, IMR notices, medical reports, work restrictions, wage records, adjuster messages, and proof of how the delay affects your recovery and job.
If you were hurt at work in Downey, the Gateway Cities, Southeast Los Angeles County, or anywhere in California, Workers' Compensation Law Group can help you understand what records matter, what deadlines may apply, and how to protect your medical treatment and wage benefits. Contact WCLG for a free consultation about your specific situation.