FERNANDO SARMIENTO vs. PAYROLL MANAGEMENT GROUP, INC, BLUE CHIP RECYCLING, WAUSAU UNDERWRITERS INSURANCE COMPANY, LIBERTY MUTUAL

The Appeals Board vacated its prior grant of reconsideration and dismissed the defendant's petition as untimely and based on non-final orders. The Board granted removal on its own motion to consolidate two cases and affirmed the WCJs' denial of the defendant's petitions to compel the applicant to transfer care to a Medical Provider Network (MPN). While the defendant is generally not liable for treatment outside an MPN per Valdez, the Board found that MPN validity and notice issues, and the applicant's right to self-procure treatment at their own expense, were not yet determined. The Board clarified that the defendant can request an expedited hearing to determine entitlement to medical treatment, rather than compel MPN transfer.