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PanelQMEGranted in Part

Covington, Samuel

SAMUEL COVINGTON, Applicant vs. COSTCO WHOLESALE CORPORATION, permissibly self insured; administered by HELMSMAN MANAGEMENT, Defendants

ADJ number: ADJ12205629
Decision date: Apr 22, 2024
District office: Oakland
WCJ: —
Claim administrator: Helmsman Management
Commissioners: JOSEPH V. CAPURRO, COMMISSIONER, ANNE SCHMITZ, DEPUTY COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER

Injury / body parts: right ankle

LC §4600LC §4610LC §4062LC §4610.5

Summary

Samuel Covington, in pro per, sustained an industrial injury to his right ankle while working for Costco Wholesale Corporation (permissibly self-insured). The WCJ found AOE/COE injury but denied future medical treatment, relying on a September 27, 2020 PQME report by Dr. Patrick McGahan stating no further treatment was warranted for the right ankle. Applicant sought reconsideration, arguing the medical evidence supported the need for further treatment. The Appeals Board affirmed the AOE/COE finding but amended the Findings of Fact to award future medical care, concluding the WCJ erred in finding it lacked power to award future medical care and noting applicant continued receiving treatment after the PQME report. The Board emphasized that an applicant need not prove certainty of future care, and disputes over reasonableness/necessity are resolved through UR.

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.