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

Case No. ADJ4503834 (VNO 0113665) ADJ3103605 (VNO 0113666) ADJ2309113 (VNO 0113667) ADJ2270309 (VNO 0113668)
Regular
May 18, 2009

MARIA GARCIA vs. CITY OF LOS ANGELES

The Appeals Board dismissed the applicant's petition for reconsideration as it was not from a final order. However, the Board granted removal, rescinded the WCJ's order suspending submission, and returned the case for further proceedings. The WCJ improperly suspended proceedings without statutory authority and failed to resolve issues including utilization review compliance under *Sandhagen*. The Board ordered the WCJ to first address *Sandhagen* issues and proper utilization review before any further medical record development.

Petition for ReconsiderationPetition for RemovalOrders Suspending Submissionsubstantial evidenceutilization reviewuntimelyunsignedpenaltyattorney's feesneglect and delay
References
2
Case No. ADJ4047184 (RDG 0115958)
Regular
Dec 02, 2009

BRICE SANDHAGEN vs. STATE COMPENSATION INSURANCE FUND

The court affirmed the WCJ's decision that the defendant was barred from relying on the utilization review process due to missed deadlines. The UR process is the employer's only avenue for resolving treatment requests.

RemittiturUtilization ReviewLabor Code section 4610(g)(1)Labor Code section 4062(a)Treating Physician RecommendationWCJFindings and Award and OrderPetition for ReconsiderationEn Banc DecisionCourt of Appeal
References
5
Case No. MISSING
En Banc
Feb 07, 2005

Brice Sandhagen vs. Cox & Cox Construction, Inc.; State Compensation Insurance Fund

The Appeals Board dismisses the applicant's petition for reconsideration, finding it premature because it was filed in response to an interlocutory order that remanded the case for further proceedings, rather than a final decision.

Labor Code 4610Labor Code 4062(a)Utilization ReviewQME/AMEPetition for ReconsiderationFinal OrderInterlocutory OrderRescinded DecisionRemanded MatterMandatory Deadlines
References
36
Case No. RDG 0115958
En Banc
Nov 16, 2004

Brice Sandhagen vs. Cox & Cox Construction, Inc.; State Compensation Insurance Fund

The Appeals Board held that utilization review time deadlines under Labor Code section 4610(g)(1) are mandatory. A defendant's failure to comply precludes the use of the utilization review process, renders the resulting report inadmissible, and requires the defendant, as the objecting party, to follow the dispute resolution procedures of section 4062(a).

Workers' Compensation Appeals BoardUtilization ReviewLabor Code Section 4610(g)(1)Mandatory DeadlinesAdmissibility of EvidenceACOEM GuidelinesTreating PhysicianMedical Treatment RecommendationAgreed Medical Evaluator (AME)Qualified Medical Evaluator (QME)
References
23
Case No. RDG 0115958
Significant

Brice Sandhagen, Applicant vs. Cox & Cox Construction, Inc., State Compensation Insurance Fund

The Board dismisses the applicant's petition for reconsideration because it was made from an interlocutory (non-final) order, as the matter had been remanded to a WCJ for further proceedings. The Board also observes that utilization review is not a mandatory prerequisite for a defendant to use the QME/AME process.

WORKERS' COMPENSATION APPEALS BOARDEN BANCOPINION AND ORDER DISMISSING PETITION FOR RECONSIDERATIONBrice SandhagenCox & Cox ConstructionInc.State Compensation Insurance FundLabor Code section 4610(g)(1)utilization reviewWCJ
References
39
Case No. RDG 0115958
Significant
Nov 16, 2004

Brice Sandhagen, Applicant vs. Cox & Cox Construction, Inc.; State Compensation Insurance Fund

The Appeals Board held that the utilization review time deadlines are mandatory; if a defendant fails to meet these deadlines, any utilization review report is inadmissible, and the defendant must use the AME/QME procedure as the objecting party.

Workers' Compensation Appeals BoardUtilization ReviewLabor Code Section 4610Time DeadlinesAdmissibility of EvidenceMedical Treatment RecommendationACOEM GuidelinesAgreed Medical EvaluatorQualified Medical EvaluatorSection 4062
References
23
Case No. ADJ2738569 (LAO 0759524) ADJ553488 (LAO 0759510)
Regular
Oct 29, 2010

CONNIE ALVIZO vs. STATE OF CALIFORNIA, DEPARTMENT OF INDUSTRIAL RELATIONS, Permissibly Uninsured, Adjusted By STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration regarding the applicant's entitlement to 24/7 home health care. The Board adopted the WCJ's report and emphasized that the defendant failed to submit the primary treating physician's request for this care to mandatory utilization review. Citing *Sandhagen*, the Board affirmed that Labor Code § 4610 utilization review is the sole mechanism to challenge medical treatment requests. Therefore, the defendant's failure to follow this process bars their current challenge to the 24/7 home health care.

Workers' Compensation Appeals BoardConnie AlvizoDepartment of Industrial RelationsPermissibly UninsuredState Compensation Insurance FundPetition for ReconsiderationFindings and Orderhome health care24 hour/7 days per weeksenior legal stenographer
References
1
Case No. ADJ3406569
Regular
Apr 09, 2009

JOSEPH NOVAK vs. SIERRA PACIFIC INDUSTRIES, SIERRA PACIFIC REDDING

The Workers' Compensation Appeals Board denied the applicant's petition for reconsideration. The applicant sought penalties and attorney fees, arguing the defendant unreasonably delayed a dorsal column stimulator by undertaking Utilization Review despite a prior Agreed Medical Evaluator's recommendation. The Board affirmed their prior decision, finding the defendant's actions were not unreasonable, as their claims examiner followed proper procedure by initiating UR for a non-routine treatment. The Board cited the Supreme Court's decision in *Sandhagen* to support their conclusion that UR is the appropriate process for evaluating treatment requests.

Workers' Compensation Appeals BoardUtilization ReviewLabor Code Section 5814Labor Code Section 5814.5Agreed Medical EvaluatorDorsal Column StimulatorUnreasonable DelayPenaltyAttorney's FeesSandhagen
References
2
Case No. ADJ888182 (PAS 0004570)
Regular
Jan 20, 2009

LUCRECIA TEJEDA vs. FELLINI'S RESTAURANT, FARMERS INSURANCE

The Appeals Board rescinded the WCJ's decision denying spinal surgery and returned the case for further proceedings, finding the defendant failed to conduct mandatory Utilization Review (UR) after a treating physician recommended surgery. The Board emphasized that per *Sandhagen* and *Cervantes*, defendants must follow strict UR and objection timelines for surgical requests. The WCJ was also directed to revisit the applicant's claims for medical mileage and penalties for non-payment of bills, as these issues were improperly deferred. The case will be decided anew by the WCJ, applying current legal standards.

Workers' Compensation Appeals BoardReconsiderationSpinal SurgeryUtilization ReviewLabor Code Section 4062(b)Agreed Medical EvaluatorTreating PhysicianDepositionPermanent DisabilityMedical Mileage
References
3
Case No. ADJ722399 (SDO 0324979) ADJ1109167 (SDO 0339490)
Regular
Feb 07, 2011

SAMANTHA HOWE vs. SCRIPPS HEALTH, Permissibly Self-Insured

The Appeals Board denied defendant Scripps Health's petition for removal, upholding the WCJ's decision to deny a compel order for a QME examination. Scripps Health sought to compel an examination by Dr. Strauser regarding applicant Samantha Howe's pain management treatment. The Board ruled that Scripps Health's objection to the pain management treatment must be addressed through utilization review, not a QME evaluation, citing the *Sandhagen* Supreme Court decision. Therefore, Scripps Health is barred from using Labor Code section 4062 to dispute treatment recommendations for pain management.

Petition for RemovalQualified Medical EvaluationMedical ExaminationPain Management TreatmentUtilization ReviewLabor Code Section 4610Labor Code Section 4062Industrial InjurySurgical TechnicianDental Treatment
References
1
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