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The utilization review (UR) process begins when a claims administrator receives a completed request for authorization from a treating physician. Under the updated UR regulations that became effective April 1, 2026, California Code of Regulations (CCR), Title 8, § 9792.6.1(u) defines what constitutes a valid "request for authorization," and specifies the conditions under which a request is deemed "completed" for purposes of triggering the UR clock. CCR 9792.9.1(b) addresses the claims administrator's obligations on receipt of a request that does not meet the definition of a completed request.
On May 14, 2026, the Division of Workers' Compensation (DWC) issued Newsline Release No. 2026-42, providing guidance in response to inquiries about whether use of the form DWC RFA is mandatory for treating physicians. It confirms that the form is required for requests for authorization under the April 2026 regulations, and identifies the circumstances in which a narrative report may be accepted as a functional equivalent.
REGULATORY REQUIREMENTS
Under CCR 9792.6.1(u), a "request for authorization" is defined as a written request for a specific course of proposed medical treatment that meets specific criteria. One, unless accepted by a claims administrator under CCR 9792.9.1(b), the request must be defined on the form DWC RFA contained in CCR 9785.5. Two, a request is "completed" only if it identifies both the employee and the requesting provider; identifies with specificity all recommended treatments in the designated section of the form, or on the first page if a narrative report is used; and is accompanied by documentation issued or created no earlier than 30 days before submission that substantiates the need for the requested treatment. Three, the request must be signed by the treating physician and transmitted by mail, fax or encrypted electronic means to the address designated by the claims administrator.
Under CCR 9792.9.1(b), when a claims administrator receives a request for authorization that does not meet the definition of a completed request under CCR 9792.6.1(u), the administrator, or its nonphysician or physician reviewer, must do one of two things within five business days of receipt: (1) either accept the request as a complete request for authorization and comply with all applicable UR requirements; or (2) mark it "not complete" and return it to the requesting physician with a written explanation specifying why. A request that is accepted as complete, even if it was technically deficient when received, is then subject to investigation under CCR 9792.11 and the assessment of administrative penalties under CCR 9792.12.
THE DWC'S CLARIFICATION
In Newsline Release No. 2026-42, the DWC confirmed that form DWC RFA is the mandatory standard for requests for authorization under the April 2026 regulations. The DWC characterized standardized use of the form as "a critical regulatory requirement intended to ensure clear, consistent communication between medical providers and claims administrators, thereby reducing delays in the delivery of necessary medical care."
The DWC stated that a narrative report may serve as a functional equivalent to the form only under specific and limited conditions. They are: (1) The claims administrator must voluntarily accept the narrative report in lieu of the form DWC RFA. That is, the treating physician cannot unilaterally elect to submit a narrative report as a substitute. (2) The narrative report must satisfy the minimum content standards required for a "completed" request under CCR 9792.6.1(u) — it must clearly identify both the employee and the requesting provider; identify specifically all recommended treatments on the first page of the narrative; be accompanied by substantiating documentation created no earlier than 30 days before submission; and be signed by the treating physician.
The DWC emphasized that a request lacking specificity or the required substantiating documentation does not qualify as "completed," and could affect the timelines for UR decisions and the overall adjudication of treatment requests.
ANALYSIS
The DWC resolves a straightforward question — whether form DWC RFA is mandatory — and its practical implications are significant for both treating physicians and claims administrators operating under the April 2026 regulations.
For treating physicians, the clarification leaves no ambiguity: The form is the required vehicle for requesting authorization, and a narrative report is a permissible substitute only if the claims administrator agrees to accept it. A physician who submits a narrative report without the claims administrator's agreement risks having the submission returned as incomplete, restarting the authorization process and delaying treatment. The requirement that substantiating documentation be created within 30 days of submission is a separate and recurring compliance obligation that practitioners should build into their RFA workflow, as stale documentation is an independent basis for a "not complete" return under CCR 9792.9.1(b).
For claims administrators, the five-business-day election under CCR 9792.9.1(b) creates a binary and time-sensitive obligation. On receipt of an incomplete RFA, the claims administrator must either accept it as complete, and thereby assume all associated utilization review obligations and penalty exposure, or return it with a written explanation of the deficiency. There is no middle ground. Silence or inaction risks foreclosing the claims administrator's ability later to challenge the sufficiency of the request. The DWC's reminder that a request accepted as complete is subject to investigation and penalty assessment under CCR 9792.12 signals that the election to accept an incomplete RFA as complete is not a cost-free accommodation; it carries full regulatory consequences as though the RFA were properly submitted.
It is worth noting that the DWC's clarification does not address what happens when a claims administrator timely returns an incomplete RFA, but the deficiency is minor. Per CCR 9792.6.1(u)(2), the definition of "completed" applies only "for the purpose of this section and for purposes of investigations and penalties." It does not necessarily control whether a request for authorization will be deemed "completed" for treatment purposes by the Workers' Compensation Appeals Board. That could become a point of contention in future litigation, and practitioners should be aware.
For further discussion on the requirements of a request for authorization for medical treatment, see Section 7.34 Utilization Review — Request for Authorization.