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SignificantDenied

Jennifer Patterson

ADJ number: ADJ3905924
Decision date: Jul 23, 2014
District office: Oxnard District Office
WCJ: —
Claim administrator: California Insurance Guarantee Association (CIGA) for California Compensation Insurance Company, in liquidation
Commissioners: —

Injury / body parts: head, neck, lumbar spine, psyche, headaches

LC §4600LC §5502LC §4610LC §4610.5LC §5307.27

Summary

Applicant Jennifer Patterson sustained serious industrial injuries in 1999 when a horse she was training threw her, injuring her head, neck, lumbar spine, and psyche. Defendant CIGA (for California Compensation Insurance Company, in liquidation) authorized and provided nurse case manager (NCM) services, but unilaterally terminated them in December 2013, characterizing applicant as 'difficult to deal with.' The WCJ ordered reinstatement of NCM services at an expedited hearing, finding NCM is medical treatment under Labor Code section 4600 and that no RFA was required to challenge the unilateral termination. On reconsideration, the WCAB (designating this a significant panel decision) affirmed, holding that NCM services are a form of medical treatment, that an employer may not unilaterally cease approved NCM services absent substantial medical evidence of changed circumstances, that expedited hearings are proper under section 5502(b)(1), and that no RFA is required to challenge unilateral termination.

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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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

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