California Workers’ Comp Therapy Visits: The 24-Visit Limit and Exceptions

In a California workers' compensation claim, a physical therapist may recommend more visits while the claims administrator says the worker has reached a “24-visit limit.” The first questions are which kind of treatment was provided, how many visits were charged to this industrial injury, and whether an exception applies. A calendar of appointments alone may not answer them.

How the 24-visit limit counts three kinds of therapy

For an injury on or after January 1, 2004, California Labor Code section 4604.5(c)(1) sets a ceiling of 24 chiropractic visits, 24 occupational therapy visits, and 24 physical therapy visits per industrial injury. These are separate categories, not 24 visits shared among all three. The statute sets a maximum; it does not itself establish that every proposed visit is medically necessary or already authorized.

Request an itemized visit history in writing from the claims administrator and providers, identifying the claim number and the treatment period. Match each date to the billed service and injury claim, then compare it with the treating physician's treatment requests and the written responses. Start before the next proposed visit when possible, so the physician has time to submit a supported request. This can reveal whether the disputed appointment was counted in the right category and claim.

What a written authorization changes

The 24-visit ceiling does not apply when the employer authorizes additional physical-medicine visits in writing. Keep the actual authorization document, noting its approved visit count and date range, along with any later decision on a subsequent request. Under section 4604.5(c)(2)(A), payment or authorization for treatment beyond the ceiling is not a waiver of that ceiling for future requests. An earlier paid visit therefore should not be mistaken for blanket approval of an ongoing course.

If further care is proposed, ask the treating physician to identify the requested service and supporting medical records in the treatment request. Title 8, section 9785(h) calls for a DWC Form RFA with documentation substantiating the need for the proposed treatment. The RFA is the physician's request; it does not itself authorize visits beyond the ceiling. The employer's written authorization is the document that changes the statutory limit for those additional visits.

Postsurgical rehabilitation has a defined window

The statutory ceiling does not apply to postsurgical physical medicine and rehabilitation provided in compliance with the applicable postsurgical treatment schedule. A surgery alone does not exempt every later therapy visit. Title 8, section 9792.24.3 says the postoperative recommendations apply during the postoperative period for surgeries covered by the guidelines. At its conclusion, the applicable 24-visit limit resumes.

Preserve the operative report, surgeon's rehabilitation plan, therapy progress reports, visit dates, and any decision identifying when the postoperative period ended. If the parties disagree about whether a proposed visit belongs to that period, these records frame the specific question.

If the treating physician is a chiropractor

A related rule affects who can manage the claim's treatment. For an injury on or after January 1, 2004, title 8, section 9785(a)(1)–(2) generally bars a chiropractor from serving as the primary or secondary treating physician after 24 chiropractic visits unless the employer authorizes more in writing; the regulation also has a postsurgical exception. A chiropractic office visit counts even if it involved evaluation and management rather than manipulation. The visit ledger and any written extra-visit authorization therefore matter to both payment and physician status.

Build a record before the next requested visit

Keep one packet with:

• The claim number and injury date;
• Separate chiropractic, occupational-therapy, and physical-therapy visit totals;
• The treating physician's requests and written authorizations or denials; and
• Any surgery and postoperative records.

Ask the administrator to identify the exact visit count and legal basis for a cap decision in writing. That gives the physician and counsel a concrete record to assess whether the next proposed service fits the ordinary ceiling, an additional written authorization, or the postsurgical rule.