Jose Albarran — ADJ15539450

Applicant Jose Albarran claimed injury to the back, chest, ribs and left shoulder while employed by Aramark; defendant admitted the back, chest and ribs but disputed the left shoulder. While applicant was unrepresented, defendant sent a July 7, 2021 letter denying a left shoulder MRI but failed to provide the QME panel request form. After applicant retained counsel, defendant on January 13, 2022 requested a QME panel relying on the July 7, 2021 objection. The WCJ found panel no. 7464239 invalid, and the Board denied defendant's petition (treated as one for reconsideration because the decision contained final findings on employment and injury AOE/COE). The Board held the disputed-body-part issue is governed by section 4062, which—like section 4061—mandates that an unrepresented employee be immediately provided the QME panel request form, and defendant's failure to do so invalidated its objection and the subsequent panel request.