Matter of Madigan v. ARR ELS
In 1994, the claimant sustained a low back injury during employment as a machinist, leading to workers' compensation benefits. Liability for the case was transferred to the Special Fund for Reopened Cases in 2003. Due to poor surgical outcomes, the claimant has been on pain medication, including oxycontin, since at least 2007, with doses escalating. A consultant for the Special Fund questioned the necessity of the increased medication, prompting a hearing. A Workers’ Compensation Law Judge ruled that the pain medications should continue, with the Special Fund covering the costs, until new Board guidelines or physician recommendations advised otherwise. The Workers’ Compensation Board affirmed this decision, citing that their Medical Treatment Guidelines for chronic pain were still in draft form at the time. The appellate court subsequently affirmed the Board's decision, noting that the guidelines were not yet in effect at the time of the Board's ruling and that the Board's interim guidance was rational.