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

Case No. ADJ8331259
Regular
Dec 21, 2012

MARIELA GOMEZ vs. PROVIDENCE FARMS, LLC, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board denied the defendant's Petition for Reconsideration. The Board adopted the WCJ's report, emphasizing that the defendant's failure to properly notify the applicant about changing treating physicians within the Medical Provider Network (MPN) resulted in a denial of necessary medical treatment. This failure to inform the applicant of her rights, particularly regarding physician selection and dispute resolution processes within the MPN, constituted a neglect or refusal to provide reasonable medical treatment, as established by precedent. Consequently, the applicant was permitted to continue receiving treatment outside the MPN until she could begin care with a designated physician within the network.

Workers' Compensation Appeals BoardProvidence FarmsLLCZenith Insurance CompanyMariela GomezADJ8331259Order Denying ReconsiderationPetition for ReconsiderationMedical TreatmentMedical Provider Network
References
2
Case No. ADJ10064259
Regular
Nov 19, 2015

, Applicant, CHARLES WAGNER, vs. , Defendants. BARRETT BUSINESS SERVICES; ACE AMERICAN INS. CO.; CORVEL ADMINSTRATOR

The Workers' Compensation Appeals Board granted reconsideration and rescinded a prior order allowing the applicant to treat outside the defendant's Medical Provider Network (MPN). The Board found that while MPN notice requirements are crucial, an employee can only treat outside the network at the employer's expense if a failure to provide notice resulted in a denial of medical care. In this case, the applicant received timely medical treatment, and the defendant presented evidence of providing MPN notices, thus, the applicant was not entitled to self-procured treatment outside the MPN.

Workers' Compensation Appeals BoardMedical Provider Network (MPN)ReconsiderationFindings and OrderAdministrative Law Judge (WCJ)Labor CodeRule 9767.12Medical TreatmentExpedited HearingForklift Operator
References
1
Case No. ADJ3158190
Regular
Jan 17, 2012

RICK OSEGUERA vs. MITSUMI NAKAMURA, ZENITH INSURANCE COMPANY

In this workers' compensation case, the defendant insurer sought reconsideration of an award for lien claimants' medical services provided outside their Medical Provider Network (MPN). The Appeals Board granted reconsideration, reversing the original award. The Board found that the defendant provided timely MPN notice to the applicant and consistently offered necessary medical treatment within the network. Therefore, the Board concluded the defendant was not liable for treatment obtained outside the MPN and disallowed the lien claimants' claims.

MPNMedical Provider NetworkLien ClaimantsReconsiderationFindings and AwardWCJPenaltiesInterestCompromise and Release AgreementStipulations
References
5
Case No. ADJ4189084 (AHM 0150210), ADJ2609035 (MON 0237343), ADJ2256301 (MON 0237524), ADJ4536480 (MON 0315454)
Regular
Feb 05, 2015

Dennis Pasquel vs. The Boeing Company, ACE American Insurance Company, Sedgwick Claims Management Services, Inc.

The Workers' Compensation Appeals Board overturned a judge's decision and allowed a lien for medical treatment provided by Dr. Powers at Griffin Medical Group. The Board found that while Dr. Powers was listed in the employer's Medical Provider Network (MPN) at a specific facility, there was no explicit restriction in the MPN listing prohibiting him from treating patients elsewhere. The Board concluded that contract disputes between a physician and an MPN provider should not prevent payment for medically necessary treatment when the MPN itself acknowledged the physician as a provider. This decision allows Griffin Medical Group to be paid for Dr. Powers' services rendered at their facility.

Workers' Compensation Appeals BoardMedical Provider NetworkMPNLien claimantPrimary treating physicianJoint Findings and OrderReconsiderationStipulated awardsCumulative trauma injuryIndependent Contractor Agreement
References
3
Case No. ADJ9415335
Regular
Oct 21, 2014

ALICIA LYNCH vs. COUNTY OF KERN

The Workers' Compensation Appeals Board granted reconsideration and rescinded a prior finding that the applicant was entitled to treat outside the defendant's Medical Provider Network (MPN). The Board found that the applicant failed to meet her burden of proving that the defendant neglected or refused to provide medical care within the MPN. Specifically, the applicant's unsubstantiated claim of one failed appointment attempt with an MPN physician and subsequent designation of an out-of-network doctor was insufficient. Therefore, the defendant retains control of the applicant's medical treatment within the MPN.

Workers' Compensation Appeals BoardMedical Provider NetworkMPNPetition for ReconsiderationPetition for RemovalFindings and OrderPrimary Treating PhysicianPTPKnight v. United Parcel ServiceSB 863
References
2
Case No. ADJ2359364 (FRE 0248119) ADJ4245839 (FRE 0248120) ADJ3951771 (FRE 0248121)
Regular
Feb 04, 2010

MARIA SOLANO DE SOTO vs. FOSTER FARMS

Lien claimants sought reconsideration after their claims were denied for providing medical services outside the defendant's Medical Provider Network (MPN). The Board denied reconsideration, affirming the original decision that services provided after the applicant received proper MPN notice were not compensable. Petitioners stipulated to the applicant's MPN notice and their own lack of MPN participation, undermining their claim that the defendant's notice was deficient. Ultimately, the petitioners failed to prove the defendant neglected or refused to provide reasonable medical treatment, a necessary element for self-procured treatment claims under *Knight*.

MPNMedical Provider NetworkKnight v. United Parcel Servicelien claimantsFindings and Awarddisallowed liensproper MPN noticeLabor Code sections 4613.1 and 4613.3Administrative Director Rule 9767.12(a)self-procured medical treatment
References
1
Case No. LBO 0375714
Regular
Jul 09, 2008

VICENTE CARMEN vs. SKB CORPORATION

This case involves a lien claim by California Pharmacy Management for medication provided to an injured worker, Vicente Carmen. The Workers' Compensation Appeals Board denied reconsideration, upholding the finding that the pharmacy's lien was invalid because the medication was not prescribed by a physician within the defendant employer's Medical Provider Network (MPN). The Board reiterated that once an employer provides a MPN, an employee's self-procured treatment outside that network is not compensable, and the pharmacy's reliance on Labor Code section 4600.2 was misplaced as there was no evidence of a contract with the employer.

MPNLien claimMedical treatmentSelf-procuredPharmacy benefit networkLabor Code section 4600.2Treating physicianWorkers' Compensation Appeals BoardFindings and OrderReconsideration
References
1
Case No. ADJ11315508
Regular
Sep 12, 2018

SIERRA PRADO vs. PCG HOSPITALITY, TRAVELERS INSURANCE CO.

This case concerns an applicant's request to treat outside her employer's Medical Provider Network (MPN) due to alleged difficulties in scheduling an appointment with an MPN physician. The applicant argued the Medical Access Assistant (MAA) failed to secure an appointment with available MPN doctors, leading to a denial of care. The Workers' Compensation Appeals Board affirmed the WCJ's decision, finding no denial of care because the MPN list is not a guarantee of immediate appointment and the MAA reasonably attempted to find a suitable physician. The majority determined that the applicant did not exhaust reasonable efforts to find an MPN doctor, and a dissenting opinion argued the inaccurate MPN list constituted a failure to provide care, justifying out-of-network treatment.

Workers' Compensation Appeals BoardMedical Provider Network (MPN)Medical Access Assistant (MAA)Primary Treating Physician (PTP)Denial of CareOut-of-Network TreatmentLabor Code Section 4600Labor Code Section 4616Cal. Code Regs. tit. 8§ 9767.5
References
18
Case No. ADJ15777619, ADJ15777625
Regular
Oct 13, 2025

VIRGINIA GALVAN vs. REGIONAL CENTER OF ORANGE COUNTY, INC.; CYPRESS INSURANCE COMPANY

Defendant sought reconsideration of the Joint Findings and Order issued on August 12, 2025, which found applicant sustained an employment-related injury and could self-procure treatment outside the defendant's medical provider network (MPN). Defendant contended the applicant failed to establish a neglect or refusal to provide reasonable medical care and that the WCJ's order allowing treatment outside the MPN was unsupported. The Appeals Board, after considering the petition, answer, and the WCJ's report, denied reconsideration. The Board adopted and incorporated the WCJ's findings that defendant failed to provide evidence of a valid MPN, proper notices, or treatment within the MPN, thereby constituting a denial of medical care and allowing the applicant to treat outside the MPN.

Workers' Compensation Appeals BoardPetition for ReconsiderationJoint Findings and OrderMedical Provider Network (MPN)Self-Procure TreatmentNeglect or Refusal to TreatAdverse InferencePre-Trial Conference Statement (PTCS)Discovery ClosureMandatory Settlement Conference (MSC)
References
12
Case No. ADJ7431195, ADJ7431206
Regular
Aug 12, 2011

Maricela Sanchez vs. American Printworks / P & Y T-Shirts and Silk Screenings Company, Inc., Zenith Insurance Company

The Appeals Board granted reconsideration, overturning the WCJ's finding that the defendant failed to provide adequate notice of its Medical Provider Network (MPN). The Board found that the defendant met its burden by providing reasonable medical treatment and sending MPN information to the applicant on August 16, 2010, as evidenced by a proof of service. Therefore, the defendant is not liable for the applicant's self-procured medical treatment outside the MPN. The Board rescinded the WCJ's order and substituted new findings of fact.

Workers' Compensation Appeals BoardMedical Provider Network (MPN)Petition for ReconsiderationJoint Findings and OrderIndustrial InjuryReasonable Medical TreatmentMPN NoticeSelf-Procured TreatmentPrimary Treating Physician (PTP)Proof of Service
References
7
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