George Patton — ADJ12371456

Applicant George Patton claimed injury to various body parts on December 5, 2018, while working as an associate for Sherwin-Williams. The unrepresented parties entered into a Compromise and Release based on QME Dr. Steven Pearson's report, stipulating that applicant had no reasonable expectation of becoming a Medicare beneficiary within 30 months. The WCJ approved the OACR on November 17, 2020, without holding a hearing. Defendant petitioned for reconsideration or to set aside the OACR, arguing the Medicare stipulation was erroneous because applicant was 65 at the time of approval and likely eligible for Medicare. The Board found the record insufficient to assess adequacy because no hearing was held, vacated its prior order granting reconsideration, dismissed the petition as premature, and returned the matter to the trial level to treat the petition as one to set aside the OACR.