SONNY TRAVAO vs. E & J GALLO WINERY, Permissibly Self-Insured

This case involves an employer's petition for reconsideration of a Workers' Compensation Appeals Board (WCAB) decision finding an applicant sustained an industrial shoulder injury and was entitled to further medical treatment, including Lortab. The employer argued the Utilization Review (UR) denial of Lortab was timely, but the WCAB denied reconsideration. The Board determined the UR denial was untimely because it was issued after the statutory deadline for review, thus deeming the treatment authorized. The employer's arguments regarding procedural errors were deemed irrelevant to the timeliness issue.