Armando Zepeda — ADJ11438423

Applicant Armando Zepeda, a teacher who sustained an industrial brain and head injury, was receiving inpatient residential rehabilitation at Casa Colina. After defendant previously authorized this treatment, his treating physician Dr. Patterson submitted concurrent RFAs to continue inpatient care (dated 2/18/21, 3/17/21, 4/22/21, and 5/14/21), which defendant subjected to UR and denied as exceeding guideline length-of-stay recommendations. The WCJ found Patterson v. The Oaks Farm inapplicable and held that the RFAs were subject to the exclusive remedy of IMR. The Board rescinded the F&O, holding that the RFAs sought continuation of previously authorized treatment and could not be subjected to UR absent substantial medical evidence of a change in applicant's circumstances or condition. The Board further found defendant violated section 4610(i)(4)(C) by attempting to discontinue concurrent care without a safe discharge plan agreed upon by the treating physician, and that defendant failed to timely conduct UR. The matter was remanded for further proceedings.