WCPanelIQ
PanelDenied

Heyman, Amy

AMY HEYMAN, Applicant vs. AT&T MOBILITY SERVICES, LLC, permissibly self-insured, Defendant

ADJ number
ADJ12171548
Decision date
Date unavailable
District office
Van Nuys
WCJ
—
Claim administrator
AT&T Mobility Services, LLC (permissibly self-insured)
Commissioners
JOSÉ H. RAZO, COMMISSIONER, CRAIG SNELLINGS, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR

Injury / body parts: back, low back, nervous system (Complex Regional Pain Syndrome / Neurogenic Pain Syndrome)

LC §4600LC §4610LC §4610.5LC §4062LC §5900CCR §10955

Summary

Applicant Amy Heyman sustained a work-related back injury and underwent fusion surgery, later developing complications requiring home health care. The dispute centered on whether UR determinations denying home health care (including the September 14, 2022 UR of Dr. Falkinstein's August 23, 2022 RFA) were timely, which controls whether the WCAB has jurisdiction to determine medical necessity. The WCJ found the UR timely and thus held the Board lacked jurisdiction over medical necessity, while retaining jurisdiction only to enforce the parties' stipulation to resubmit reports and the home assessment to UR. On reconsideration, the Board affirmed, finding the UR decision was issued four business days after the only documented receipt date (September 8, 2022) and was therefore timely. The Board rejected applicant's argument that failure to submit supporting medical documentation rendered the UR untimely.

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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