[GA] Can an insurer refuse OEM repairs and rely on photo estimates in auto claims without inspection?

I have a collision claim in Georgia with an insurance company involving a 2025.5 Volvo with fewer than 6,000 miles.
The insurance company has never performed an in-person inspection; all estimates and reviews were based on photos only.
I selected an independent Volvo-certified repair facility that follows Volvo OEM repair procedures.

Independent OEM-compliant estimate: ~$10,000
The insurance company estimate: ~$5,400
Deductible: $1,000
The insurance company payment issued: ~$4,400
Disputed amount (excluding deductible): ~$4,600

The difference is primarily due to OEM-required parts, labor hours and hourly rate, scans, and calibrations that insurance company classified as unnecessary or excessive.

I submitted the independent shop’s estimate, Volvo OEM repair guidance, and requested a formal review under Georgia Rule 120-2-52. The insurance company completed a desk review only, stated nothing additional was owed, and directed the shop to submit supplements if additional damage is found. No physical reinspection was conducted.

The independent repair shop requires a standard authorization making me responsible for any unpaid balance. I want to understand my rights and best course of action before authorizing repairs.

Questions:

• Under Georgia law, when can an insurer lawfully refuse OEM-required repairs as “not necessary,” particularly on a near-new vehicle?
• Does the insurance company’s reliance on a photo-only estimate and refusal to reinspect weaken its position?
• If I pay the disputed amount after repairs and seek reimbursement, does that prejudice my legal claim?
• Is invoking the appraisal clause (if applicable) or pursuing reimbursement after repair the better approach in Georgia?

I requested a formal review of their original estimate with my concerns about their original estimate not returning the car to pre-loss condition, utilizing a non-certified shop and non-OEM parts. I included documents from Volvo requiring OEM parts and their position on replacement of certain items vs repair.

I assume so. They have been in business for a while and advised me to request the formal review through the insurance company.

No, not that I know of.

The insurance company has not provided a specific reason for why any of the OEM-required repairs are considered “unnecessary.” Their review was desk-only, based solely on photos. They stated that “nothing additional is owed at this time” and that the parts are “within the standards of what the insurance company owes.” They directed me/the shop to submit supplements if additional damage is found.

No. I took the car to the shop for an estimate prior to receiving the insurance company’s estimate so I could have a comparison, and the insurance company requested that I not leave the car at the shop until after their investigation and estimate process was completed.

So the car is currently at my house.

No.

The independent shop requires a repair authorization prior to starting work stating that I am responsible for any amounts not covered by insurance.

I had hoped to get the insurance company to agree to cover the OEM-required repairs and parts before work begins, but they have refused to revise their estimate. While they maintain I can use any shop I like, their estimate really only covers using one of their DRP shops.

I am concerned that a DRP shop would not perform repairs in accordance with Volvo OEM standards, including proper parts, labor operations, scans, and calibrations, and would likely only produce cosmetic results.

Questions / Potential Courses of Action:

• Proceed with independent shop, pay ~$4,600 difference, submit supplements, and seek reimbursement later
• Attempt another review request now
• Other strategies to protect my rights and minimize financial exposure

If I proceed and submit supplements, would that preserve my right to seek reimbursement later? Would submitting a DOI complaint at the same time strengthen my position?

The insurance company is sending me a check. If I accept it, am I waiving my rights?

Thanks.