Elena Campos — ADJ12221306

Applicant Elena Campos, a certified nursing assistant, sustained an admitted injury to her left shoulder on July 12, 2018 while lifting a heavy patient. Pain medicine QME Dr. Michael Amster provided a strict AMA Guides rating of 11% WPI but found this did not accurately represent her functional loss, instead applying an alternative Almaraz/Guzman rating by analogy to Chapter 13, Table 13-16, yielding 22% WPI. The WCJ adopted Dr. Amster's alternative rating and found 38% permanent partial disability. Defendant sought reconsideration, arguing Dr. Amster's reports did not constitute substantial evidence supporting an Almaraz/Guzman analysis and that the disability should be rated by strict application of the AMA Guides. The Board denied reconsideration, adopting the WCJ's Report and finding that Dr. Amster properly provided a strict rating, explained why it was inaccurate, and offered an alternative rating within the four corners of the AMA Guides supported by detailed analysis of activities of daily living.