Dimidrios Kokkinias — ADJ11091794

Applicant Dimidrios Kokkinias sustained a serious industrial injury including head, brain, neck, and back injuries. The WCJ found that defendant's UR determinations of Dr. Patterson's May 17, 2021 RFA and Dr. Rho's June 9, 2021 RFA were untimely—Patterson's because there was no evidence it was timely communicated to applicant or the PTP, and Rho's because it was issued June 19, 2021 (beyond the statutory deadline). The WCJ accordingly exercised WCAB jurisdiction to award medical treatment, including home health aide services, RN/LVN visits, Humatrope, and a TFE injection. Defendant sought reconsideration, arguing the proofs of service raised an Evidence Code section 641 presumption of receipt and that the L3,4 injection was not reasonable or necessary. The Appeals Board denied reconsideration, agreeing with the WCJ that applicant's exhibits showing non-receipt rebutted any presumption and that the medical evidence supported the necessity of treatment.