Patient Advocates v. Texas Workers Compensation Commission
Patient Advocates of Texas and Allen J. Meril, M.D. (Advocates) challenged rules promulgated by the Texas Workers Compensation Commission (the Commission) concerning medical fee guidelines and dispute resolution on procedural, substantive, enforcement, and constitutional grounds. The trial court initially denied all of Advocates' claims. On appeal, the court affirmed the Commission's compliance with APA reasoned-justification requirements and upheld its authority to impose mandatory fee caps. The court also affirmed the one-year statute of limitations for dispute resolution and dismissed constitutional challenges. However, the appellate court found the Commission's delegation of auditing powers to private insurance carriers to be an improper delegation under the Boll Weevil standards, reversing that specific part of the trial court's judgment and declaring those rules void. All other points of the trial court's judgment were affirmed.