Burton, Linda

Linda Burton, a bus operator for LACMTA, sustained admitted industrial injuries and was receiving authorized ongoing inpatient residential care at Casa Colina's Transitional Living Center. After defendant attempted to non-certify the residential care via a utilization review (UR) determination dated August 30, 2023, the WCJ found that under Patterson v. The Oaks Farm, the ongoing care could not be unilaterally terminated absent evidence of a change in circumstances, rendering the UR invalid ab initio. The WCJ ordered LACMTA to continue authorizing the residential care until defendant could prove a material change in circumstances warranting cessation. LACMTA petitioned for reconsideration, attacking the Patterson reasoning itself and arguing its UR was timely and provided substantial evidence of changed circumstances. The WCAB denied reconsideration, adopting and incorporating the WCJ's Report, holding that the timeliness of the UR was moot because no RFA was required for ongoing care under Patterson in the first place.