Santos Cerda — ADJ10816168

Applicant Santos Cerda sustained an admitted industrial head, neck, and back injury on November 4, 2016 while working for Silver Saddle Ranch Club, and was receiving inpatient care at Casa Colina Transitional Living Center. The parties stipulated that a March 12, 2026 UR denial was timely, that no change of circumstances was shown in the report supporting the March 10, 2026 RFA, and that the UR denial could not terminate inpatient treatment without a release plan. The sole trial issue was whether a UR addressing medical necessity requires a documented change of circumstances (per the significant panel decision Patterson v. The Oaks Farm) or not (per the Court of Appeal decision in Rodriguez). The WCJ found Rodriguez more persuasive and binding, holding no change in circumstances is required. Applicant petitioned for reconsideration, and the Appeals Board granted the petition, deferring a final decision pending further review given the conflict in authority and the pending California Supreme Court review of Rodriguez.