Burton, Linda

Applicant Linda Burton sustained industrial injuries to multiple body parts and developed compensable consequences including urinary and fecal incontinence. After defendant failed to perform timely utilization review (UR) of PTP Dr. Sangnil's June 21, 2024 RFA, the WCJ exercised Dubon II jurisdiction and awarded numerous treatment items, including a wheelchair access assessment, home modification evaluation, and wheelchair transportation. Defendant sought reconsideration, arguing applicant's condition had improved (she allegedly no longer used a wheelchair and now used a walker) such that the supporting medical reports were no longer germane and not based on substantial evidence. The Appeals Board granted reconsideration and deferred a final decision, finding the record was not properly developed given changes in applicant's location, condition, and evidence over the more than 18 months since the disputed treatment was recommended. The Board also corrected the WCJ's reliance on Onruang, clarifying that transportation and home modifications are within the scope of UR, and that jurisdiction here arose from the untimely UR, not from any inherent exemption.