Hannah Sanchez, Nicol

Applicant Nicol Hannah Sanchez sustained industrial injury on December 12, 2011 while employed as a banker, to multiple body parts including bilateral upper extremities, shoulders, neck, dental, internal, psyche, and voice. Her primary treating physician requested an extension of previously approved live-in home healthcare, which UR certified on August 5, 2025 (after an intervening July 21, 2025 non-certification of a related request). Defendant sought reconsideration arguing the WCAB had jurisdiction to invalidate the UR certification because the underlying RFA and PTP report were based on a mistake of fact and were not substantial medical evidence, and alternatively that the July 21, 2025 non-certification controlled for 12 months. The WCAB denied reconsideration, holding that a valid, timely UR certification of medical necessity is binding on the employer and the WCAB lacks jurisdiction to second-guess it, as UR is the employer's only avenue for resolving treatment requests under Sandhagen and Dubon. The Board emphasized there is no collateral appeal mechanism for an employer dissatisfied with a UR certification.