RAND's New Study on SB 1160 Has a Message for Claims Managers: the UR Exemption Isn't Doing Much
Updated: Sep 6
From the Desk Of:
President, Managing Attorney
Certified Specialist Workers' Compensation Law
The State Bar of California Board of Legal Specialization
A decade after Sacramento exempted early medical treatment from prospective utilization review, RAND just checked whether it worked. The short answer for claims managers: don't expect SB 1160's UR carve-out to move your numbers much, but do expect it to keep coming up in physical therapy disputes.
DWC announced the RAND findings on August 19, 2026. RAND, funded by DIR, studied claims data from January 2017 through January 2024, pulling from two large claims administrators, the Independent Medical Review database, and the Workers' Compensation Information System. SB 1160 took effect in 2018 and removed the prospective UR requirement for many treatments provided in the first 30 days after an injury, on the theory that early care shouldn't get bogged down in review while workers wait.
RAND's headline finding undercuts the case for further UR rollback: UR approval rates for treatment requested in that first 30-day window were already above 90% before SB 1160, and stayed above 90% after. Statistically, nothing moved. In other words, UR wasn't blocking early treatment in any measurable way to begin with, and removing the review requirement didn't change outcomes because there wasn't much for it to change.
Where the law made a real difference
The one place RAND found a real, measurable effect was physical therapy access. Among workers with diagnoses where PT is standard, the odds of getting PT within 30 days rose 13% after SB 1160 took effect. Average time to first PT visit dropped from 13.4 days before the law to 11.9 days after. Braces and immobilizers moved too — an 8% increase in the odds a worker got a guideline-concordant device — though the timing to first receipt didn't change significantly.
RAND's report also notes something claims administrators already knew: many routine early treatments were already exempted from UR under prior authorization programs before SB 1160 ever passed. The law formalized and expanded an exemption that, in practice, was already narrowing.
What this means for claims and costs
This is a data point for a fight that comes up constantly in early-claim handling: applicant attorneys and treating physicians sometimes frame any UR touch on early care as a violation of SB 1160's intent. RAND's numbers say the approval rate wasn't the problem before the law and isn't the problem now. Where you'll actually see friction is physical therapy authorization timing. If your UR or claims process is adding days beyond that roughly 12-day statewide average to get PT started, that's now a benchmark an applicant's counsel can point to.
What to do now
Use the PT numbers, not the general UR numbers, when you're evaluating your own timeliness on early treatment authorization. If your average time to first PT visit is meaningfully worse than 12 days, find out why — is it a UR bottleneck, a scheduling problem with your medical provider network, or something else. And when an applicant attorney argues that any UR review in the first 30 days violates the spirit of SB 1160, point to RAND's own numbers: approval rates never budged, because the exemption's job was narrower than the argument suggests.
Law Offices of Parker & Irwin
This post is for general information only and is not legal advice.
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