Steven Odessky — ADJ8908424

Applicant Steven Odessky, a warehouse manager, claimed injury AOE/COE to the arm, left elbow, skin (plaque psoriasis), and psyche from a March 21, 2013 lifting incident. Defendant accepted the arm and left elbow but disputed the skin and psyche, and the WCJ found all four body parts compensable. On reconsideration, the Board held that the dermatological QME's causation opinion for psoriasis was speculative—resting solely on the temporal relationship between the flare and the orthopedic injury—and therefore not substantial evidence. Because the psychiatric injury was pled as a compensable consequence of the (non-yet-established) psoriasis, and because the psychiatric QME relied on an admittedly unclear and inadequate history, that opinion was also not substantial evidence. The Board rescinded the F&A and remanded for further development of the record, including supplemental reporting from both QMEs.