Utilization review in mental health takes a number of forms; its most controversial incarnation is the review by professionals in the employ of insurance companies to determine whether or not claims will be honored. In a short time, utilization review has grown into a powerful force in determining how-and whether-psychiatric care will be delivered. Disagreements over coyerage ofpatients have pitted treating professional against reviewing professional. In the absence of standards for review, these disagreements have often resulted in charges that the reviewer has been co-opted by the insurance company and in countercharges that unnecessary treatment is being administered. A recent case, Hughes z’. Blue Cross of Northern California (1), highlights some of the issues courts might consider important in resolving such disputes. In psychiatry, utilization review on behalfofthird-party payers began in the 1970s when the Civilian Health and Medical Programs of the Uniformed Services (CHAMPUS), which insures dependents of military service personnel, was faced with widespread abuses of psychiatric benefits. Fraudulent claims and unscrupulous provision of unnecessary