Reyna Castillo — ADJ11092501

Applicant Reyna Castillo sustained an admitted industrial injury to her head and brain on October 13, 2017, and received outpatient multidisciplinary neuro-rehabilitation at Casa Colina Transitional Living Center under her primary treating physician Dr. David Patterson. Defendant approved and provided treatment from December 2018 to July 2019, but then denied a July 2019 RFA via UR; however, the UR determination was served to an incorrect suite number and was therefore untimely and invalid. The WCJ found defendant liable for continuing the outpatient rehabilitation, transportation, and interpreter services, relying on substantial medical evidence and the Patterson doctrine. The Board granted reconsideration and affirmed, holding the WCAB had jurisdiction because the UR was untimely, that substantial medical evidence supported the ongoing treatment, and that under Patterson defendant could not unilaterally terminate previously authorized treatment absent a showing of changed condition or circumstances.