McFall, Anika

Applicant Anika McFall sustained an industrial injury in 2016 to her back and right shoulder (with claimed additional injuries) while working as a sales account manager for ADT. After undergoing multiple surgeries and a hospitalization with infection, her treating physician Dr. Itamura prescribed home caregiver services of 8 hours per day, which defendant authorized on a limited basis (2 weeks) and which UR certified. Defendant then unilaterally discontinued the caregiving services based on a series of inconsistent subsequent UR determinations. The WCJ found that under Patterson v. The Oaks Farm, once ongoing caregiving services are authorized, defendant bears the burden of proving a change in circumstances before terminating services, and may not restart the RFA/UR process to relitigate medical necessity. The WCAB denied defendant's petition for reconsideration, adopting the WCJ's Report, and held that Patterson applies to McFall's ongoing home health care.