In the Matter of the Claim of Alberto Gomez
Claimant Alberto Gomez, who sustained work-related injuries in 2017, sought payment for medical treatment received in New Jersey from a New Jersey-licensed physician also licensed in New York. The employer's workers' compensation carrier objected to payment, arguing the physician lacked authorization from the Workers' Compensation Board. Both a Workers' Compensation Law Judge and a Board panel affirmed the carrier's position. However, the Appellate Division, Third Judicial Department, reversed these decisions. The court ruled that New York's physician authorization requirements do not apply to out-of-state physicians treating claimants in their home states, even if the physician holds a New York license. The Board's contrary interpretation was found to be irrational and unreasonable, leading to the reversal of the decisions and remittal of the matter to the Board for further proceedings.