Cohen, Sydney

Applicant Sydney Cohen suffered a cumulative trauma injury to her back and psyche while working for Fitness 19, insured by Zurich American Insurance Company. The WCJ found that her TMJ/dental conditions were a compensable consequence of the original injury but held that the nature and extent of treatment was subject to retrospective utilization review, finding that Defendant validly deferred UR while disputing liability for the dental condition. Applicant petitioned for reconsideration, arguing the UR deferral was invalid because the medical evidence clearly established compensability and Defendant failed to provide an adequate explanation for disputing liability. The Board adopted and incorporated the WCJ's Report and denied reconsideration, concluding the deferrals were timely and proper under Labor Code section 4610(l). The Board also addressed the timeliness of its own decision under the amended section 5909, finding it acted within 60 days of transmission.