Randall Otten vs. Cardinal Newman High School, California Insurance Guarantee Association for Superior National Insurance Company, in liquidation

This case concerns the validity of a Utilization Review (UR) determination regarding the applicant's need for a radiofrequency rhizotomy injection for his low back injury. The Appeals Board reversed the lower judge's decision, finding the UR determination valid. They held that the omission of certain medical reports was not a material procedural defect because they would not have changed the UR physician's conclusion. Furthermore, the Board found the applicant failed to present substantial medical evidence to support the necessity of the treatment or prove the UR was invalid. The issue of medical necessity is now subject to Independent Medical Review (IMR).