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PanelQMEMed-legalGranted

Hill, Tiffany

TIFFANY HILL, Applicant vs. STATE OF CALIFORNIA, IN-HOME SUPPORT SERVICES; legally uninsured, adjusted by INTERCARE, Defendants

ADJ number: ADJ7701836
Decision date: Feb 19, 2024
District office: Oakland
WCJ: —
Claim administrator: Intercare (TPA for State of California, In-Home Support Services, legally uninsured)
Commissioners: KATHERINE A. ZALEWSKI, CHAIR, JOSEPH V. CAPURRO, COMMISSIONER

Injury / body parts: bilateral upper extremities, left shoulder, cervical spine, psyche

LC §4660LC §5803LC §5901LC §5907LC §5908LC §5908.5LC §5950

Summary

Tiffany Hill, an in-home care giver, sustained industrial injury on October 20, 2010 to her bilateral upper extremities, including left shoulder, cervical spine and psyche, and was found permanently totally disabled by the WCJ in a December 1, 2023 Findings and Award. Defendant sought reconsideration, arguing the WCJ improperly considered facts not in evidence in discounting sub rosa surveillance video and that PQME Dr. Ronald Wolfson's opinion was not substantial medical evidence because it deviated from the AMA Guides (5th Edition). The WCJ's Report explained that both Dr. Zwerin and Dr. Wolfson deviated from the AMA Guides only regarding the CRPS diagnosis (not impairment rating), providing detailed explanations that the 5th edition CRPS criteria were outdated and inaccurate. The Board granted reconsideration to allow further study of the merits and deferred issuance of a final decision after reconsideration. The grant is not a final order and the entire record is reopened for review.

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.

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.

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.

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.