WCPanelIQ
PanelQMEMed-legalDenied

Peter Scatena — ADJ12221781

PETER SCATENA, Applicant vs. TOWER OF HILLSBOROUGH, permissibly self-insured, and the CITIES GROUP, Defendants

ADJ number
ADJ12221781
Decision date
Feb 8, 2021
District office
San Francisco
WCJ
Eugene Gogerman
Claim administrator
The Cities Group (for Tower of Hillsborough, permissibly self-insured)
Commissioners
—

Injury / body parts: right arm, right wrist, right hand, right upper extremity

Summary

Applicant Peter Scatena, a police officer, sustained an admitted industrial injury to his right arm and developed Complex Regional Pain Syndrome (CRPS). The WCJ found CRPS established and awarded 73 percent PPD based on the panel QME's 45 percent WPI rating. Defendant sought reconsideration arguing that the QME's CRPS diagnosis was inconsistent with the AMA Guides because fewer than eight of the 11 diagnostic criteria in Table 16-16 were documented and the QME relied largely on subjective complaints. The WCAB adopted and incorporated the WCJ's report, holding that the AMA Guides diagnostic criteria are not a legal or exclusive diagnostic standard, that the CRPS diagnosis was supported by substantial unrebutted medical evidence, and that the impairment rating accurately reflected the applicant's actual disability regardless of diagnosis. The Petition for Reconsideration was denied.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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