Jankowski, Deborah

The WCJ awarded applicant Deborah Jankowski 100% permanent total disability and attorney fees based on vocational and treating physician evidence, while expressly assuming the case was compensable because the parties had declined to have the court address compensability, parts of body, and apportionment. Defendant petitioned for reconsideration, arguing there was no established schedule rating, the vocational reporting was not substantial evidence, the WCJ failed to rely on the AMEs' findings and apportionment, and that causation as to each disputed body part had to be determined before awarding permanent disability. The Appeals Board granted reconsideration, finding that no stipulation of industrial injury existed and that an award cannot issue absent a finding of injury AOE/COE and findings on parts of body industrially injured. The Board also found the WCJ failed to explain why he relied on treating physicians over the AMEs (Drs. Minor and Majcher) and raised concerns about impermissible vocational apportionment under Nunes. The Board deferred a final decision and ordered the matter set for a status conference to develop the record.