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PanelGranted

Moss, David

DAVID MOSS, Applicant vs. UNITED CONTINENTAL HOLDINGS, INC., doing business as UNITED AIRLINES, permissibly self-insured, administered by SEDGWICK CLAIMS MANAGEMENT SERVICES, Defendants

ADJ number: ADJ14478876
Decision date: Mar 9, 2025
District office: San Francisco
WCJ: —
Claim administrator: Sedgwick Claims Management Services
Commissioners: CRAIG L. SNELLINGS, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER, KATHERINE WILLIAMS DODD, COMMISSIONER

Injury / body parts: back, hips

LC §5909LC §5900LC §5950LC §4600LC §5313LC §5907LC §5908LC §5908.5LC §5803LC §5901CCR §10600CCR §10305

Summary

Applicant David Moss sustained an industrial injury to his back and hips while employed by United Airlines. The WCJ found that defendant timely conducted utilization review (UR) for several RFAs from Dr. Date but also awarded continuing home healthcare services (8-10 hours per day) under the Patterson significant panel decision, finding defendant had not shown a change of circumstances justifying cessation of previously authorized care. Defendant sought reconsideration, arguing Patterson was limited to nurse care management services and that there was evidence of significant changes in applicant's condition since the original UR certification of February 1, 2024. The Appeals Board granted reconsideration to allow further review of whether the record was complete, particularly regarding the initial RFA received January 23, 2024 and certified by UR February 1, 2024. The Board deferred a final decision on the merits pending further review of the entire record.

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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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.