LUISA SEQUEIRA vs. RANDSTAD PLACEMENT PROS, ACE AMERICAN
This case involved an applicant seeking reconsideration of a workers' compensation award, arguing that the declaration of readiness to proceed was defective due to a lack of a primary treating physician's report on permanent disability. The Appeals Board affirmed the original award, finding that Labor Code section 4061(i) does not require all treating physicians to find maximum medical improvement before proceeding to trial. The Board reasoned that the applicant's Panel Qualified Medical Evaluator (PQME) provided substantial medical evidence sufficient to support the permanent disability award, even though primary treating physicians had not yet found MMI. Therefore, the WCJ correctly relied on the PQME's report.