Applicant Ricardo Rubalcaba sustained an admitted industrial injury on May 23, 2024 when his cement truck tilted over, injuring his left eye, face, head, neck, left arm, chest, left shoulder, and causing a concussion/traumatic brain injury. He received authorized inpatient and residential rehabilitation care at Casa Colina. After defendant certified a June 19, 2025 RFA for continued care, it retroactively non-certified that RFA on August 14, 2025 and also non-certified an August 8, 2025 RFA. The WCJ found defendant failed to show a change in circumstances under Patterson and awarded continued treatment without requiring a new RFA. On reconsideration, the Board granted the petition to allow further study of jurisdictional UR/IMR issues, the apparent conflict between the retroactive non-certification and Labor Code section 4610.3(a), the section 4610(i)(4)(C) concurrent review/care plan requirement, and gaps in the evidentiary record, deferring a final decision.
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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