Conlin, Emily

Emily Conlin, a delivery driver, sustained industrial injuries on August 19, 2019 to multiple body parts. The WCJ found a December 6, 2023 UR noncertification of an outpatient neurological treatment program (at the Centre for Neuro Skills) timely and binding, and found a May 5, 2023 UR noncertification untimely but moot due to applicant's contemporaneous change of treating physicians. Applicant sought reconsideration arguing that under Patterson v. The Oaks Farm, defendant could not discontinue previously authorized treatment absent substantial medical evidence of a change in circumstances. The Appeals Board granted reconsideration, finding the matter required further review of whether the outpatient CNS treatment qualifies under Patterson and Rivota based on the nature of treatment rather than quantity authorized, and that further development of the record may be appropriate. The Board deferred a final decision after reconsideration.