JAMES MERRY, Applicant vs. ALAMEDA HEALTH SYSTEMS, Permissibly Self-Insured, Defendant
ADJ number
ADJ18090375
Decision date
Oct 10, 2024
District office
Oakland
WCJ
—
Claim administrator
Alameda Health Systems (Permissibly Self-Insured)
Commissioners
—
Injury / body parts: head, brain, eye, psyche
LC §5909LC §5900LC §4610CCR §9792.9.1CCR §10116.9
Summary
Applicant, a nurse anesthetist, sustained a traumatic brain injury on October 7, 2022 when a large cardiac monitor fell on his head. His treating physician, Dr. Henry Koh of the Centre for Neuro Skills (CNS), submitted an RFA on April 10, 2024 requesting expedited review for a 60-day supported living program, accompanied by a PR-4 report. The UR vendor did not issue a non-certification until April 17, 2024, beyond the 72-hour timeframe for expedited review. The WCJ found the RFA properly requested expedited review, that UR was untimely, that the WCAB therefore had jurisdiction under Dubon, and that the treatment was reasonably required. The Appeals Board denied defendant's Petition for Reconsideration, holding that Dr. Koh's report adequately documented the need for expedited review without requiring specific statutory language.
Issues
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Applicant takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Provider takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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