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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ1787217
Regular
Jul 27, 2011

OFELIA LLAMAS vs. SUN TEN LABORATORIES INC., ZENITH INSURANCE CO.

The Appeals Board denied a lien claimant's petition for reconsideration, upholding the disallowance of their liens for unauthorized treatment outside the Medical Provider Network (MPN). The lien claimant's arguments regarding defendant's denial of benefits and MPN notification failures were rejected, as the evidence showed timely MPN care was offered and the MPN notification issue was not raised at trial. The Board also initiated sanctions against the lien claimant's representative for filing a frivolous petition citing non-existent documents and outside evidence, finding this constituted bad faith and a waste of Board resources.

Workers' Compensation Appeals BoardLien ClaimantMPN providersunauthorized treatmentself-procure medical treatmentMPN employee notification requirementsCCR 9767.12reasonableness and necessityPetition for ReconsiderationOrder of Removal
References
1
Case No. ADJ11377504
Regular
Oct 26, 2020

TERESA GARCIA vs. TULAPHORN, INC., ICW GROUP

The Workers' Compensation Appeals Board denied Teresa Garcia's petition for reconsideration, affirming the Administrative Law Judge's decision allowing the defendant Tulaphorn, Inc. to litigate the Medical Provider Network (MPN) issue. The Board found insufficient evidence that the defendant neglected or refused to provide treatment, a necessary condition for the applicant to self-procure care outside the MPN. Applicant's claim that a June 8, 2020 letter designating a new physician was mailed was not substantiated, and the Board rejected the argument that the defendant waived its right to litigate the MPN issue. Therefore, applicant is obligated to seek treatment within the defendant's established MPN.

Workers' Compensation Appeals BoardMedical Provider NetworkMPNPetition for ReconsiderationFinding and OrderPrimary Treating PhysicianPanel Qualified Medical EvaluatorDeclaration of ReadinessExpedited HearingLabor Code
References
7
Case No. ADJ8128004
Regular
Nov 28, 2017

GLADYS PATINO vs. ABBOTT LABORATORIES, INC./ABBOTT VASCULAR, INC., TRAVELERS PROPERTY CASUALTY COMPANY of AMERICA

The Workers' Compensation Appeals Board granted reconsideration and rescinded the original findings regarding the applicant's requirement to seek treatment within the employer's Medical Provider Network (MPN). The Board found that the employer's MPN notice may not have complied with the bilingual notice requirement under California regulations. Therefore, the issue of treatment outside the MPN was deferred, and the case was returned to the WCJ for further proceedings to develop the record on this issue.

Workers' Compensation Appeals BoardMedical Provider NetworkMPN NoticeContinuity of CarePetition for ReconsiderationFindings of FactWCJNotice of DenialPrimary Treating PhysicianDue Process
References
5
Case No. ADJ3417200 (MON 0240201)
Regular
Jul 20, 2009

CAROL CHARON vs. RALPHS

The Appeals Board granted reconsideration of the WCJ's decision regarding applicant's transfer to the defendant's Medical Provider Network (MPN). The Board found the WCJ erred by relying on a stale deposition of an Agreed Medical Evaluator (AME) that did not adequately address the MPN transfer issue under relevant case law. The Board remanded the case for further development of the record, including a new deposition of the AME and consideration of MPN notice requirements, to allow the WCJ to issue a new decision.

Workers' Compensation Appeals BoardMedical Provider Network (MPN)ReconsiderationFindings of FactAgreed Medical Evaluator (AME)Labor Code Section 4616.2Administrative Director's RulesBabbitt v. Ow JingKnight v. United Parcel ServiceMPN Notice Requirements
References
4
Case No. ADJ2803173 (STK 0160796)
Regular
Sep 21, 2009

Cynthia Krause vs. WAL-MART ASSOCIATES, INC., AMERICAN HOME ASSURANCE, AVIZENT

The Appeals Board granted reconsideration, rescinded the original findings, and remanded the case for further proceedings. The core issue was whether the defendant adequately complied with Medical Provider Network (MPN) notice requirements before demanding the applicant transfer her medical care. The Board found the record insufficient to determine if the defendant provided sufficient MPN access and ordered further development of this issue. The Board also addressed the applicant's claims regarding treatment outside the MPN and the addition of an insurer, finding no reversible error on those points.

Workers Compensation Appeals BoardMedical Provider NetworkMPNReconsiderationFindings and OrderAdministrative Law JudgeWCJPrimary Treating PhysicianSelf-InsuredThird Party Administrator
References
1
Case No. ADJ11225851
Regular
Oct 18, 2019

SUZAN ELSHAMI vs. C & A RESTAURANTS INC.; SAFETY NATIONAL CASUALTY CORPORATION, administered by BROADSPIRE

This case involves an applicant challenging a WCJ's decision regarding a Medical Provider Network (MPN) issue. The Appeals Board granted reconsideration solely to amend the order vacating submission, instructing further record development without vacating submission. The Board affirmed the WCJ's finding of injury AOE/COE, a threshold issue, while deeming the MPN development order interlocutory. The Board clarified that for MPN compliance, the network only needs at least three available primary treating physicians of an appropriate specialty within access standards.

Workers' Compensation Appeals BoardPetition for ReconsiderationPetition for RemovalVacating SubmissionFurther Development of RecordThreshold IssueFinal DecisionInterlocutory IssueInjury Arising Out of and in the Course of Employment (AOE/COE)Medical Provider Network (MPN)
References
7
Case No. ADJ1967938
Regular
Oct 18, 2012

MARITZA RENGIFO vs. MARRIOTT INTERNATIONAL

Defendant Marriott International filed an untimely petition for removal seeking a determination of liability for applicant's self-procured medical treatment outside their alleged Medical Provider Network (MPN). The Appeals Board, while dismissing the petition due to untimeliness, granted removal on its own motion. The Board found the WCJ erred in deeming the MPN and self-procured treatment issues premature lien issues. The Board rescinded the WCJ's order taking the case off calendar and directed the matter be set for trial promptly to adjudicate the MPN and treatment liability.

Removal PetitionMPNSelf-Procured TreatmentLabor Code 4903.6(b)Labor Code 4616WCAB Rule 10843(a)Untimely FilingGrant RemovalOwn MotionDecision After Removal
References
0
Case No. ADJ476925 (MON 0355919)
Regular
Jun 04, 2009

IRMA GUERECA vs. LSG SKY CHEFS, LIBERTY MUTUAL INSURANCE COMPANY

The Appeals Board granted reconsideration and rescinded a prior award, finding the record insufficient regarding MPN notice compliance. The case is returned to the trial level to determine if the employer provided proper MPN notice, whether any failure constituted a neglect or refusal to provide reasonable medical treatment, and if so, whether the applicant is entitled to self-procured treatment. Key factual issues to be developed include the date applicant stopped treating at Concentra and when MPN notice was provided, with a focus on statutory and regulatory compliance. The WCJ must issue a new decision after this record development.

MPNnotice requirementsself-procured medical treatmentneglect or refusalreasonable medical treatmentConcerta Clinicprimary treating physicianKnight v. United Parcel ServiceAppeals Board en bancLabor Code section 5705
References
2
Case No. ADJ15329380
Regular
Oct 31, 2025

BERTHA VALERIO vs. KIMCO STAFFING SERVICES, INC.; XL INSURANCE

Defendant sought reconsideration of a Findings and Award (F&A) from August 5, 2025, concerning an injury sustained by applicant Bertha Valerio on September 9, 2021. The F&A found that applicant's injury was AOE/COE, defendant failed to prove improper treatment outside the Medical Provider Network (MPN), and lien claimant Joyce Altman Interpreting, Inc. established their market rate for interpreting services. Defendant contended that medical treatment and interpreter services were unreasonable due to treatment outside the MPN and failure to adhere to MTUS/ACOEM guidelines, and that the market rate for interpreter services was not properly established. The Appeals Board denied the petition, agreeing with the WCJ that defendant failed to sustain its burden of proof on the MPN issue, the MTUS/ACOEM guideline issue was not raised at trial, and lien claimant properly established their market rate.

WCABPetition for ReconsiderationFindings and AwardMedical Provider NetworkMPNRequests for AuthorizationRFAsLien ClaimantMarket RateLabor Code Section 4600
References
10
Case No. ADJ10544145
Regular
Jun 03, 2019

WILLIAM FRANKLIN, JR. vs. SOLANO COUNTY - PROBATION DEPARTMENT

The Workers' Compensation Appeals Board granted reconsideration and deferred the issues of whether the applicant must treat within the defendant's Medical Provider Network (MPN) and whether the defendant properly followed the transfer of care procedure. The Board affirmed the finding that the applicant's predesignation of his orthopedic surgeon was not valid. Further proceedings are required to develop the record on the MPN and transfer of care issues before a final determination can be made.

Workers' Compensation Appeals BoardSolano County Probation DepartmentAthens AdministratorsPredesignation of Personal PhysicianMedical Provider Network (MPN)Administrative Director (AD) Rule 9767.9Continuity of CareTransfer of Care ProcedureQualified Medical Examiner (QME)Temporary Disability
References
3
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