Urbano Carlos — ADJ12795671

Applicant Urbano Carlos sustained a specific head injury on January 10, 2019 while working for the Bureau of Automotive Repair. His primary treating physician, Dr. Saeed Nick, requested a Tempurpedic adjustable king size bed via RFA. Defendant failed to issue a timely Utilization Review determination, so the WCAB had jurisdiction to determine medical necessity. The WCJ found Dr. Nick's reporting did not constitute substantial medical evidence because it lacked any meaningful explanation or compliance with the medical evidence search sequence, and that applicant failed to meet his burden of proof. The Appeals Board granted reconsideration, then affirmed the Findings and Order adopting the WCJ's report; Commissioner Sweeney dissented, arguing the record should be developed regarding medical necessity.