Gordon G. McWatt, D.O. v. David Mattax, Texas Commissioner of Insurance Ryan Brannan, Commissioner of Workers' Compensation And Texas Department of Insurance, Division of Workers' Compensation
Gordon G. McWatt, D.O., appealed an administrative penalty of $15,000 and an order to attend an educational course for violating reporting and record-keeping requirements as a 'designated doctor' with the Division of Workers’ Compensation. The audit focused on the timely submission and electronic transmission of DWC Form-69s. McWatt argued that the ALJ and Commissioner lacked authority, retroactively applied rules, misinterpreted Rule 130.1 by holding him responsible for his employer Concentra's failures, and arbitrarily assessed penalties. The court found that the Division had proper authority for the audit and that Rule 130.1 held McWatt ultimately responsible for compliance, irrespective of his employer's role in filing. Consequently, the trial court's judgment affirming the ALJ's monetary penalty and the Commissioner's non-monetary sanction was affirmed.