WCPanelIQ
PanelDenied

Correa, Silvia

SILVIA CORREA, Applicant vs. DISPLAY PRODUCTS, INC.; TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA, Defendants

ADJ number
ADJ9036010
Decision date
Jul 1, 2024
District office
Van Nuys
WCJ
—
Claim administrator
Travelers Property Casualty Company of America
Commissioners
CRAIG SNELLINGS, COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER

Injury / body parts: wrists, lumbar spine, respiratory disorder, psyche

LC §4610CCR §9792.9.1

Summary

Treating physician Dr. Shamie submitted an RFA on February 16, 2024 marked for expedited review, requesting an increase in home caregiver assistance to 12 hours per day, seven days per week, for six months, plus medical transportation. Defendant Travelers issued a non-certification UR decision on February 21, 2024, treating the request under the standard five-business-day timeframe rather than the 72-hour expedited timeframe. The WCJ found the UR untimely because no medical professional reviewed the request within 72 hours, and found the requested treatment medically necessary. The Board affirmed, holding that the determination of whether expedited review is warranted is an inherently medical determination that must be made by a medical professional within the 72-hour expedited window, not retroactively by a claims administrator. The Petition for Reconsideration was denied.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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