Coronado, Phyllis Felicit

Applicant Phyllis Coronado, an 80+ year-old former county clerk with a 65% industrial injury, petitioned for reconsideration of a WCJ decision regarding home health care (HHC) services requested by her primary treating physician Dr. Ahmed via a January 18, 2018 RFA. The WCJ found UR was untimely (preserving WCAB jurisdiction) and that HHC was reasonable and necessary only from January 18, 2018 through June 27, 2019, not on an ongoing basis, while disallowing lien claimant Lucila Alfaro's $43,449 lien for HHC services from March 1, 2018 to February 28, 2022 and related attorney fees. Applicant argued the RFA was for indefinite care, that Patterson v. The Oaks Farm shifted the burden to defendant to prove HHC was no longer needed, and that the lien claimant's due process rights were violated. The Appeals Board granted reconsideration, deferring a final decision pending further review, noting potential inconsistencies in the record (including the WCJ's failure to formally admit exhibits and overlap between the awarded HHC period and the disallowed lien period) and questioning whether the existing record constitutes substantial evidence.