Anaya, Sandra

Sandra Anaya, while unrepresented, entered into a Stipulation with Request for Award at 14% permanent disability based on a PQME report from Dr. Pearson, even though her PTP, Dr. Wickman, had rated her at the equivalent of 25%. The QME report was not on file but the PTP report was, and the I&A Officer flagged the inadequacy. The WCJ found the stipulation inadequate, relied on Dr. Wickman's PTP reports (including a supplemental report clarifying a typo in the DRE category) as substantial medical evidence, awarded 25% PD, and granted applicant's later-retained attorney a 15% fee on the difference. Defendant petitioned for reconsideration challenging the 25% award and resulting attorney fee. The WCAB denied reconsideration, adopting the WCJ's report and holding that Dr. Wickman's opinion constituted substantial medical evidence.