WCPanelIQ
PanelQMEMed-legalGranted

Stephens, Paul

PAUL STEPHENS, Applicant vs. COUNTY OF SAN BERNARDINO, Defendants

ADJ number
ADJ14145123
Decision date
Dec 28, 2025
District office
Riverside
WCJ
—
Claim administrator
County of San Bernardino (self-insured)
Commissioners
JOSEPH V. CAPURRO, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR, PAUL F. KELLY, COMMISSIONER

Injury / body parts: respiratory system, cognitive/neurological (long COVID sequelae)

LC §5950LC §5909LC §5900LC §4600LC §4610LC §5952LC §5701LC §5906LC §5907LC §5908LC §5908.5LC §5803LC §5901CCR §10600CCR §10109CCR §35.5

Summary

Paul Stephens, a County of San Bernardino collections officer, contracted COVID-19 on December 11, 2020, sustaining injury to his respiratory system with residual cognitive, behavioral, and emotional sequelae from long COVID. The WCJ issued an F&A awarding reimbursement of self-procured home health care (HHC) provided by applicant's wife for only the 60-day period approved by Utilization Review, but found ongoing HHC after 60 days unsubstantiated. Applicant sought reconsideration, arguing he is entitled to ongoing HHC under Patterson v. The Oaks Farm and that defendant failed to rebut the need for it. The Appeals Board granted reconsideration, finding the record lacked substantial evidence to support the WCJ's decision, particularly regarding the interplay between the employer's affirmative duty to provide treatment under Braewood and the UR process under section 4610. The Board deferred a final decision pending further study and possible development of the record, noting the absence of recent AME/QME reports addressing applicant's current status following his 270-hour Brain Injury Program.

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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