Guillen, Joe

Applicant Joe Guillen sustained admitted industrial injury to his cervical spine, lumbar spine, and left foot, with the case in chief resolved by an indemnity-only Compromise and Release providing open future medical treatment. After an Expedited Hearing on November 27, 2024, the Minutes reflected handwritten language that 'Defendant to provide written authorization [within] 30 days to treating doctor' subject to Utilization Review. The WCJ later found this language was a mere agreement among the parties rather than a court order, and accordingly denied applicant's claims for self-procured treatment outside the MPN and for penalties, attorney's fees, and sanctions. On reconsideration, the WCAB majority concluded the November 27, 2024 Minutes constituted a valid, enforceable, and final order resolving a threshold issue, and that the WCJ erred by not reaching whether defendant's late authorization (January 28, 2025) constituted unreasonable delay or refusal/neglect of treatment. The Board rescinded the F&O and returned the matter to the trial level. Commissioner Razo dissented, arguing the Minutes reflected only a procedural agreement and were unenforceable because they failed to specify the treating physician.