Dai, Hong Guo

Defendant Baron HR/Zurich petitioned for reconsideration of a WCJ decision concerning continuing liability for applicant Hong Guo Dai's outpatient physical rehabilitation services. The decision contained a threshold finding (making it final and subject to reconsideration) but defendant only challenged interlocutory findings, so the Board applied the removal standard. The Board found no significant prejudice or irreparable harm and concluded the WCJ correctly applied Labor Code section 4600 and CCR section 9767.5(f)-(h). Rejecting defendant's jurisdictional argument, the Board relied on Patterson v. The Oaks Farm and National Cement Co. (Rivota) to hold that the WCJ retains jurisdiction to determine whether previously authorized medical treatment is no longer reasonably required, and that a defendant cannot unilaterally terminate authorized care absent substantial medical evidence of a change in condition or circumstances. The Petition was denied.