Aaron Smith — ADJ11407468

Applicant Aaron Smith, a job coach, claimed a cumulative trauma injury ending July 20, 2018 to his cervical spine, shoulders, lumbar spine, and right wrist. The WCJ found industrial injury based on the credible testimony of applicant and the reports of treating physician Dr. Tabibian and PQME Dr. Roberts, both of whom opined the injury was industrial. Defendant petitioned for reconsideration arguing the WCJ erred in finding industrial injury, partly because Dr. Tabibian failed to review prior medical records and because Dr. Roberts opined the CT did not contribute to permanent disability. The Board affirmed, holding that employment need only be a 'contributing cause' of injury and that causation of injury is distinct from causation of permanent disability for apportionment purposes. The Board also corrected the WCJ's erroneous statement that Dr. Roberts stepped outside his role, noting that opining on compensability was the PQME's statutorily required function under Labor Code section 4060(c).