Ken Rutledge — ADJ10711761, ADJ10901497

Applicant Ken Rutledge sustained admitted industrial injuries while working as a stocker for Costco and was provided wheelchair/medical transportation services to attend appointments based on his treating physician's recommendation. Defendant unilaterally discontinued the transportation services (around October 2020) without first obtaining a medical opinion showing a change in condition, then issued a retroactive UR denial on November 5, 2020. The WCJ found she had no jurisdiction to determine reasonableness/necessity because the dispute was subject to UR and IMR. On reconsideration, the WCAB held that under Patterson v. The Oaks Farm, a defendant may not unilaterally terminate previously authorized medical treatment (including transportation) absent substantial medical evidence of a change in circumstances. The Board rescinded the April 5, 2021 decision and remanded for further development of the record and a new decision.