Castellanos, Precious

Applicant Precious Castellanos sustained industrial injury to her head, brain, neck and right arm while working as a customer service specialist for Best Buy on November 26, 2023. The WCJ found that defendant's April 23, 2024 Utilization Review (UR) determination was timely and that the court lacked jurisdiction to determine the medical necessity of requested outpatient treatment at Casa Colina's Transitional Living Center. Applicant sought reconsideration, arguing that under Patterson v. The Oaks Farm, defendant could not unilaterally discontinue previously authorized (via IMR) treatment absent substantial medical evidence of a change in her condition or circumstances. The Appeals Board granted reconsideration on a preliminary basis, deferring a final decision pending further review of the merits and possible further development of the record. The Board highlighted the Patterson and Rivota principles as potentially relevant to whether the IMR-authorized outpatient treatment qualified as treatment that cannot be unilaterally terminated.