Charley Baskett — ADJ15211632

Applicant Charley Baskett, who suffered an admitted head and brain injury, sought reconsideration of an April 14, 2026 F&O that (1) found his December 4, 2025 RFA barred under Labor Code section 4610(k) because the same treatment had been denied by a February 17, 2025 UR decision, and (2) found that although the December 8, 2025 UR decision was untimely, applicant failed to prove the medical necessity of a wheelchair-accessible hotel room. The WCAB granted reconsideration and deferred a final decision, noting the need for further review of the record. The Board emphasized the defendant's affirmative duty to investigate the need for care and home modifications, and it flagged jurisdictional questions arising from an IMR determination that found the medical necessity of ADA housing and a wheelchair-accessible van 'not medically determinable' under section 4610.5(c)(2). The panel signaled that where a UR decision is untimely or an IMR cannot determine medical necessity, the Appeals Board may retain jurisdiction under sections 4604 and 5304, and that further development of the record may be appropriate.