Garibay, Susan

Applicant Susan Garibay, a device assembler, claimed injury to her left thumb/hand/wrist and complex regional pain syndrome (CRPS) on the left side from a December 4, 2018 industrial injury. QME Dr. Behrman diagnosed CRPS and rated her impairment using Table 16-10a by analogy, resulting in a 50% upper extremity impairment for CRPS combined with an 11% rating for trapezium excision arthroplasty, yielding a 34% WPI and ultimately a 65% permanent disability award. Defendant sought reconsideration, arguing that Dr. Behrman's CRPS diagnosis failed because it did not satisfy at least eight of the eleven Objective Diagnostic Criteria in Table 16-16 (page 496) of the AMA Guides. The WCAB denied reconsideration, holding that the AMA Guides are an impairment rating methodology, not a diagnostic tool, and that Dr. Behrman properly exercised clinical judgment consistent with Guzman in diagnosing CRPS based on clinical findings and a positive response to a stellate ganglion block. The Board found Dr. Behrman's reporting constituted substantial medical evidence.