Joiner, Colin

Applicant Colin Joiner sustained industrial injuries in falls on 1/25/22 and 3/17/22, leading to inpatient/residential treatment at Casa Colina that defendant initially authorized and that was previously ordered continued by the WCJ. After multiple RFAs for continued inpatient care were denied through UR, the WCJ issued a 12/7/23 F&O upholding the denial of inpatient care while preserving outpatient care, reasoning that the burden shifted to applicant because authorizations were time-limited and because the treatment goal changed from rehabilitation to maintenance. The Appeals Board granted reconsideration and rescinded the F&O, holding that under Patterson v. The Oaks Farm and Nat'l Cement Co. v. WCAB (Rivota), defendant bore the burden of proving a change in applicant's circumstances or condition supported by substantial medical evidence before discontinuing previously authorized treatment. The Board found defendant relied only on lack of improvement, lack of a discharge plan, and lack of new information—none of which establish a qualifying change—and that the WCJ improperly substituted his own lay judgment ('seemingly able-bodied') for medical expert opinion. The Board substituted a finding that defendant failed to meet its burden and deferred all other issues.