Yojan Perez Lopez — ADJ11845925

Applicant, an electrician, sustained an admitted industrial injury including a traumatic brain injury and was admitted to Casa Colina's Transitional Living Center (TLC) residential rehabilitation program, which defendant's utilization review certified for four weeks on September 26, 2020. When subsequent RFAs were submitted, defendant's UR denied certification, citing no clinically meaningful improvement. The WCJ found, and the Appeals Board affirmed, that under Patterson v. The Oaks Farm, defendant could not unilaterally cease the previously authorized ongoing residential care absent a showing of changed circumstances warranting a new UR determination. The Board held the time-limited UR certification did not automatically terminate the ongoing services, and that defendant bore the burden of proving a change in circumstances, which it failed to do. The decision was affirmed.