Hector Barragan Palos — ADJ19186265

Applicant Hector Barragan Palos suffered an admitted head injury when struck by a shovel on April 15, 2024. His treating physician at Casa Colina submitted an RFA on July 31, 2025 marked for expedited review, requesting continuation of a residential post-acute rehabilitation program. Defendant WCF National Insurance issued a UR determination on August 6, 2025 denying the treatment, which the WCJ found timely under the non-expedited five-day timeframe, thereby concluding the WCAB lacked jurisdiction over the medical necessity dispute. The Appeals Board granted reconsideration, holding that whether an RFA marked for expedited review qualifies as such is a medical determination that must be made by a medical professional within the 72-hour expedited timeframe, and the record did not establish this occurred. The Board rescinded the F&O and remanded for further proceedings, also directing consideration of whether a change of circumstances warranted discontinuation of ongoing care.