In this guide12 sections
- Key takeaways
- What an RFA is and who sends it
- What makes an RFA complete
- How the medical guidelines come into play
- RFA and utilization review deadlines
- Exceptions: the first 30 days and disputed claims
- Common reasons RFAs are denied or modified
- How to help your doctor build a strong RFA
- What to do if your RFA is denied
- Why RFAs matter for your whole case
- Frequently asked questions
- Talk to a California workers’ comp lawyer
A Request for Authorization (RFA) is the form your treating doctor sends to the workers’ comp claims administrator to get approval for a specific treatment, test, referral, medication or piece of equipment. Sending it starts utilization review (UR), and the insurer generally has five business days to decide, or 72 hours when your health is at serious risk. If the request is denied or cut back, you usually have 30 days to ask for Independent Medical Review.
Key takeaways
- An RFA generally must be on the state’s DWC Form RFA, signed by your treating physician, and backed by medical records dated within 30 days before it is sent.
- Routine requests must be decided within five business days and never more than 14 days after your doctor’s recommendation; urgent requests within 72 hours (Labor Code §4610).
- Only a physician reviewer can deny or modify a request for medical-necessity reasons.
- A denial or modification can be challenged through Independent Medical Review (IMR); the request is generally due within 30 days of the UR decision.
- An unreasonable delay in providing benefits can lead to a penalty of up to 25% of the delayed amount or $10,000, whichever is less (Labor Code §5814).
What an RFA is and who sends it
In California workers’ comp, most care beyond the basics has to be approved before it happens. Your treating doctor asks for that approval with an RFA. Under the state’s utilization review rules, the request generally must be on DWC Form RFA and completed and signed by a treating physician (8 CCR §9792.6.1(u)). A claims administrator can choose to accept a request in another format, but it doesn’t have to.
You can’t file an RFA yourself. What you can do is make sure your doctor knows exactly how the injury affects you, what has and hasn’t worked, and what you need. That information is what makes a request hard to deny.
RFAs are used for things like:
- Physical therapy, chiropractic or acupuncture sessions beyond what was already approved
- MRIs, CT scans, nerve studies and other diagnostic tests
- Referrals to specialists such as orthopedic surgeons, neurologists or pain specialists
- Surgery, injections and medications
- Durable medical equipment, home health care and inpatient rehabilitation
What makes an RFA complete
A complete request identifies you and the requesting provider, lists each recommended treatment with specificity, and comes with documentation that supports the need. That documentation must be dated no earlier than 30 days before the request is submitted (8 CCR §9792.6.1(u)(2)).
If the claims administrator thinks a request is incomplete, it must either accept it anyway or mark it “not complete” and return it to the doctor with the reasons within five business days of receipt (8 CCR §9792.9.1). A returned request restarts the process, so missing paperwork can cost you weeks.
When the request is sent also matters. A faxed or emailed RFA generally counts as received on the date it is electronically stamped, but one sent after 5:30 p.m. Pacific time counts as received the next business day unless it is expedited. A request sent by regular mail is generally treated as received five business days after mailing.
How the medical guidelines come into play
Utilization review measures each request against the Medical Treatment Utilization Schedule (MTUS), the state’s treatment guidelines. Under Labor Code §4604.5, the MTUS is presumed correct on the extent and scope of treatment. That presumption can be overcome with a preponderance of scientific medical evidence showing that a different approach is needed for your injury. For conditions the MTUS doesn’t cover, treatment follows other scientifically based guidelines recognized by the national medical community. Read more in our guide to the Medical Treatment Utilization Schedule.
RFA and utilization review deadlines
| Step | Deadline | Source |
|---|---|---|
| Routine (prospective) UR decision | 5 business days after receiving the RFA and needed information; never more than 14 days from the doctor’s recommendation | Labor Code §4610(i)(1) |
| Urgent (expedited) UR decision | 72 hours after receiving the needed information | Labor Code §4610(i)(3) |
| Retrospective review (care already given) | 30 days after receiving the needed information | Labor Code §4610(i)(2) |
| Decision to your doctor | No later than 24 hours after the decision | Labor Code §4610(i)(4)(A) |
| Written denial or modification to you | Within 2 business days of the decision (prospective review) | Labor Code §4610(i)(4)(B) |
| Your request for IMR | Within 30 days of service of the UR decision | Labor Code §4610.5(h) |
| IMR decision | Within 30 days, or 3 days if expedited | Labor Code §4610.6(d) |
If the reviewer needs more information to decide, it must immediately notify both your doctor and you in writing and say exactly what is needed. Once the information arrives, the normal deadlines apply again.
Exceptions: the first 30 days and disputed claims
For injuries on or after January 1, 2018, certain care in the first 30 days after the injury can be authorized without prospective utilization review, if it is for an accepted body part, provided by a doctor in your employer’s medical provider network (MPN), health care organization or a predesignated physician, and consistent with the MTUS (Labor Code §4610(b)). The exception doesn’t cover everything. Nonemergency surgery, psychological treatment, home health care, imaging other than x-rays, non-formulary drugs, nerve studies and medical equipment worth more than $250 still generally go through review (Labor Code §4610(c)).
If your employer is disputing whether the injury is work-related at all, utilization review isn’t required while that dispute is pending (Labor Code §4610(l)). But while a claim is under investigation, your employer must still authorize up to $10,000 in treatment, starting within one working day after you file a claim form (Labor Code §5402(c)).
Common reasons RFAs are denied or modified
- Vague requests. “Physical therapy” with no number of visits, frequency or body part is easy to deny or cut down.
- No link to the guidelines. The request doesn’t explain how the treatment fits the MTUS, or why your case justifies something different.
- Missing or stale records. Chart notes, exam findings or test results aren’t attached, or are more than 30 days old.
- No functional picture. The request doesn’t say how the injury limits your work, sleep or daily activities.
- No history of what was tried. Many guidelines expect conservative care first, so the request should show what you tried and how it went.
- Duplicate or incomplete forms. A repeat request with nothing new, or a form with blank sections, often comes back.
How to help your doctor build a strong RFA
- Describe your symptoms precisely at every visit. Say where it hurts, what makes it worse, and what you can no longer do at work and at home.
- Report what failed. If six weeks of therapy or a medication didn’t help, make sure that’s in the chart.
- Ask what is being requested. You can ask the office which treatment was requested, on what date and how it was sent.
- Keep your own log. Note appointment dates, RFA dates, and when you received any UR letters. UR letters list the IMR deadline.
- Read every UR letter the day it arrives. A denial or modification letter must explain the reasons and the guidelines used, and it tells you how to request IMR and by when.
Here is a hypothetical. Luis, a delivery driver, hurts his lower back lifting a package. After six weeks of therapy his leg pain is getting worse, so his doctor requests a lumbar MRI. The first RFA is denied because the chart notes attached were two months old. His doctor resubmits with a current exam showing numbness and weakness, a description of the failed therapy, and the guideline section supporting imaging. That version is approved.
What to do if your RFA is denied
A denial or modification based on medical necessity is resolved through Independent Medical Review, not by a workers’ comp judge. Request IMR as the UR letter explains, within 30 days. An IMR reviewer looks at records only and does not examine you, according to the DWC’s IMR FAQ, so your doctor’s reports carry the case. The IMR decision is binding, and it can be appealed to the Workers’ Compensation Appeals Board only on narrow grounds, within 30 days.
Your doctor can also submit a new RFA if your condition changes or new facts support the treatment. Disputes about whether the injury is covered at all, rather than whether the treatment is necessary, generally go to a workers’ comp judge. If the insurer unreasonably delays or refuses authorized care or other benefits, a judge may award a penalty under Labor Code §5814. See our guides to utilization review and delayed medical treatment.
Why RFAs matter for your whole case
Approved treatment helps you recover, and the records it creates show how serious the injury is. Denied treatment can leave you hurting longer and leave gaps in the medical record that the insurer later points to when your permanent disability is rated. A pattern of well-documented requests, even denied ones, shows what your doctors believed you needed.
Frequently asked questions
Can I submit a Request for Authorization myself?
No. The request must be completed by your treating physician. You can help by giving your doctor clear, consistent information about your symptoms and limits, and by following up with the office.
How long does the insurer have to answer an RFA?
Generally five business days after receiving the request and the information needed to decide it, and no more than 14 days from your doctor’s recommendation. Urgent requests must be decided within 72 hours.
Do I have to pay for treatment while an RFA is pending?
Medical care for a work injury is the employer’s responsibility under Labor Code §4600. Talk to your doctor or a lawyer before paying for treatment yourself, because reimbursement isn’t automatic.
What if the insurer denies the same treatment again and again?
Use IMR on each denial you want to challenge, and keep the letters. If the insurer is delaying care unreasonably or ignoring deadlines, a workers’ comp lawyer can evaluate whether penalties or other remedies apply.
Is a modified approval the same as a denial?
For IMR purposes, yes. If UR approves fewer visits or a different treatment than your doctor requested, you can request IMR on the modification within the same 30-day window.
Talk to a California workers’ comp lawyer
Employees First Labor Law represents workers exclusively, including injured workers whose treatment has been denied or delayed. We offer free virtual consultations to review your UR letters, medical records and options. Contact us online or call (310) 853-3461.
This article is general information about California law as of 2026, not legal advice for your situation. Reading it does not create an attorney-client relationship.
