Derboghos

Applicant sustained a 1994 industrial injury resulting in permanent total disability, including blindness and psychiatric injury. In 2011, defendant authorized and paid for a home security system prescribed by applicant's treating physician, and paid for upgrades in 2012. In 2019, applicant self-procured a replacement security system and sought reimbursement; defendant delayed, attempted utilization review without an RFA, and only stipulated to the system's necessity after litigation. The WCJ awarded penalties under section 5814 and attorney's fees under section 5814.5 for the unreasonable delay. The WCAB affirmed, holding that once durable medical equipment is provided as medical treatment, the defendant must maintain it so long as the applicant requires its use, and defendant's delayed investigation justified the penalties and fees.