California workers' comp

California second bill review (SBR): the 90-day deadline, Form SBR-1 and how to file

When a claims administrator pays less than you billed, the explanation of review (EOR) starts a 90-day clock. Second bill review is the provider's only route to contest the amount. If you skip it, you can't get to Independent Bill Review, and if you miss it the carrier owes nothing more on that bill.

What second bill review is for

Second bill review is for disputes over how much you were paid, not whether the treatment should have happened. If the carrier denied a service as not medically necessary, that dispute goes through utilization review and Independent Medical Review (LC 4610.5), not this process. If the carrier paid the line but paid it wrong, second review is the first step.

Reductions worth challenging

Every EOR carries reason codes (how to read them). Some reductions are correct. Others are routinely wrong and worth a second review:

• Fee schedule misapplied. The line was priced to the wrong Official Medical Fee Schedule (OMFS) version, conversion factor, geographic adjustment or modifier rule.
• PPO or network discount. A discount was taken under a contract that doesn't apply to your practice, or was applied on top of a fee-schedule reduction. Pair the second review with a written demand under LC 4609(c)(2) that the payor prove its right to the rate.
• Bundling. A separately payable service was folded into another code.
• "Not authorized." The service was in fact authorized, and the authorization can be attached.
• "Unrelated to the claim." The treatment is tied to the accepted body part or condition.
• Duplicate. The bill was a corrected or separate service, not a resubmission.

What the request must include

A second review request has to carry specific information. 8 CCR 9792.5.5(d) requires:

1. The original dates of service and the same itemized services as the original bill. "No new dates of service or additional billing codes may be included."
2. The date of the EOR and the claim number or other identifier on it.
3. The item and amount in dispute.
4. The additional payment requested, and the reason for it.
5. Any additional information the first EOR asked for, and anything else that supports your amount.

Get this right. A carrier may answer a request that's missing these items, but its answer isn't bound by the 14-day and 21-day deadlines (9792.5.5(f)). An incomplete request gives up the clock that protects you.

How to file a second bill review

1. Calendar the deadline the day the EOR arrives. The 90 days run from service of the EOR, not from the date of service or when someone gets to it. Keep the envelope: if there's no proof of service, the postmark sets the date.
2. Price each disputed line to the OMFS for the date of service and write down the specific provision that supports your amount.
3. Prepare the request: DWC Form SBR-1 on top, or the original bill marked BG/W3, with every item listed above.
4. Attach the support: the original bill, the EOR, authorizations, reports, and any contract that bears on a discount.
5. Send it to the claims administrator at the address or channel listed on the EOR, and keep proof of when it went out.
6. Track the 14-day response and 21-day payment. If the result is still wrong, the 30-day clock for Independent Bill Review starts when the determination is served.

A worked example

A Sacramento orthopedic office billed an MRI (CPT 73721) on April 21, 2026, with the authorization number in box 23. The EOR paid $0.00 with CARC 197, "authorization absent". The OMFS maximum for that MRI, in that office and on that date, is $355.77.

The second review lists the original date of service and code, the EOR date and claim number, the amount in dispute ($355.77), and the reason: the service was authorized, with a copy of the authorization attached. A complete request starts the clock. The carrier owes a written determination within 14 days and payment within 21.

OMFS maximums are base maximum fees under 8 CCR 9789.12.2 for an office (place of service 11) in the Sacramento locality, from the CMS RVU26B file and the $51.6091 conversion factor adopted in 8 CCR 9789.19(m) (DWC OMFS), computed by Redress's fee schedule engine. The visit, bill and carrier responses are illustrative.

Why so few reductions get challenged

The money in each dispute is small, and the work is not. DaisyBill reports that its California clients filed 225,194 second bill reviews in 2023, about 10.4% of their bills, and recovered $21.7 million, roughly $96 per review (DaisyBill; vendor-reported figures). Those are clients of a dedicated workers' comp billing platform. At most practices the share is lower, and the reductions that go unchallenged are written off once 90 days pass.

That's the gap Redress fills. We read every EOR, classify every reduction, and file second reviews for the improper ones inside the window. A licensed biller signs each one, and we're paid only on what we recover. For the full path from EOR to IBR award, see the step-by-step appeal guide.

Last reviewed October 14, 2026. This guide is general information about California workers' compensation billing rules, not legal advice. Check the current statute and regulation before filing.