Oliver Winston — ADJ1480768

Applicant, a correctional officer, sustained admitted industrial injury to his bilateral upper extremities, hands, and wrists during employment from 1985 to 2002. After the Board had previously held the 2005 Rating Schedule applied, the WCJ found 72% permanent disability based on a DEU rating of the AME report of Dr. Glenn Cohen, which included both range-of-motion and compression neuropathy (carpal tunnel) impairments. Defendant sought reconsideration arguing the proper rating was 58% because the AMA Guides prohibit rating decreased range of motion in addition to compression neuropathy. The Board rescinded the WCJ's decision, finding Dr. Cohen's report was not substantial medical evidence because it contained no narrative reasoning and failed to address the AMA Guides restriction, and finding the WCJ's rating instructions violated Blackledge. The Board deferred the issues of permanent disability and attorney fees and remanded for further development of the record.