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PanelGranted in Part

Harvey, Warren

WARREN P. HARVEY, Applicant vs. SOCAL MACHINE, INC., insured by TRUCK INSURANCE EXCHANGE, administered by FARMERS INSURANCE, Defendants

ADJ number: ADJ17547374
Decision date: Jan 6, 2026
District office: San Diego
WCJ: —
Claim administrator: Farmers Insurance (administering for Truck Insurance Exchange)
Commissioners: KATHERINE A. ZALEWSKI, CHAIR, KATHERINE WILLIAMS DODD, COMMISSIONER, CRAIG L. SNELLINGS, COMMISSIONER

Injury / body parts: neck

LC §4659LC §5909LC §5900LC §4600LC §5903

Summary

Applicant Warren Harvey, permanently and totally disabled from a 2022 neck injury requiring 24/7 home care, sought reconsideration on two fronts: the home healthcare reimbursement rates for services provided by his spouse, and errors in an October 16, 2025 O&A approving stipulations (regarding the section 4659(c) SAWW adjustment commencement date and an attorney fee calculation error). The WCJ's October 23, 2024 F&A had set reimbursement at $17.53/hour for regular caregiver duties and $53.55/hour for nursing-equivalent duties. The Board affirmed the WCJ's two-tier approach of distinguishing caregiver from skilled nursing services, but held the proper metric is the employer's cost to provide equivalent services through a third-party provider, amending the rates to $38.00/hour for caregiver duties and $80.00/hour for skilled nursing. The Board rescinded the October 16, 2025 O&A to allow correction of attorney fee commutation errors and clarification of the section 4659(c) adjustment date, deferred the home healthcare attorney fee issue, and returned the matter to the trial level.

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.