Deann Cummins — ADJ12007769

Applicant Deann Cummins claimed a back injury while working as a bus detailer for Bos Mobile Detailing. The parties submitted a revised Compromise and Release, and the WCJ issued an Order Approving Compromise and Release (OACR) on August 24, 2021. Defendant sought reconsideration, or alternatively to set aside the OACR, arguing both parties misapprehended or overlooked the issue of permanent disability advances, as the C&R indicated PD advances were 'N/A' and did not allow defendant to take credit for them. The WCJ recommended granting the petition and setting aside the OACR, but the Appeals Board found that in the absence of an evidentiary record it could not evaluate the basis for the OACR. The Board dismissed the petition for reconsideration as premature and returned the matter to the trial level to be treated as a petition to set aside, with instructions to hold a hearing and develop the record.