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

Case No. ADJ9878675
Regular
Jan 25, 2018

Teresa Villagran vs. Penguin Natural Foods, Inc., ACE American Insurance

This case concerns whether an injured worker, Teresa Villagran, can seek medical treatment outside of her employer's Medical Provider Network (MPN) at the employer's expense. The Appeals Board rescinded a prior decision, finding that the applicant is not eligible to treat outside the MPN because the employer had a valid MPN and had authorized treatment. While the employer failed to schedule an appointment as stipulated, this failure did not justify self-procuring treatment outside the network, especially after the applicant agreed to seek treatment within the MPN. A dissenting opinion argued for further development of the record to explore the employer's failure to honor the stipulation.

Workers' Compensation Appeals BoardReconsiderationMedical Provider Network (MPN)Primary Treating Physician (PTP)Stipulation and OrderSelf-Procured TreatmentLabor CodeSubstantial EvidenceClerical ErrorTemporary Disability Benefits
References
7
Case No. ADJ10223631
Regular
May 31, 2019

SOUNG UE KIM vs. ELITE 4 PRINT, INC., BENCHMARK INSURANCE COMPANY

The WCAB reconsidered an order regarding applicant's treatment outside the employer's Medical Provider Network (MPN). Applicant sought to continue treatment with a physician not in the MPN after the claim was initially denied and later accepted. The Board amended the prior order to clarify that applicant was "improperly" treating outside the MPN, finding that Labor Code section 4603.2(a)(2) does not apply when the employer exercises medical control after accepting the claim, absent a prior final determination of entitlement to an outside physician. One commissioner dissented, arguing the case should be remanded to determine if the employer's significant delays in accepting the claim constituted a failure to provide medical care, which would allow continued treatment outside the MPN.

MPNPetition for Reconsiderationbilateral upper extremity injuriesAdministrative Director Rule 9767.9Labor Code section 4603.2Agreed Medical Examinerprimary treating physicianAOE/COEtransfer of caremedical control
References
8
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. 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. ADJ2605132 (BAK 0154195)
Regular
Jan 23, 2013

JUAN CARILLO MATANCIAS vs. MILK MAID DAIRY / TONY DRAGT, ZENITH INSURANCE COMPANY

This case involves a workers' compensation claim where the applicant self-procured medical treatment outside the defendant's Medical Provider Network (MPN). The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration, affirming the administrative law judge's award of $6,304.87 to the lien claimant for reasonable medical treatment. The Board found the defendant failed to provide adequate notice of the applicant's MPN rights, making them liable for the self-procured treatment. A dissenting opinion argued the defendant had sufficiently established MPN control and notified the applicant, therefore not being liable for outside treatment.

MPNself-procured medical treatmentlien claimantPetition for Reconsiderationworkers' compensation administrative law judgeMedical Provider Networkcompromise and releaseindustrial injuryAgreed Medical ExaminerAdministrative Director
References
2
Case No. ADJ7532078
Regular
Mar 06, 2013

JESUS GONZALEZ vs. HERMAN WEISKER, INC., NATIONAL UNION FIRE INSURANCE, CHARTIS

The Appeals Board affirmed the WCJ's finding that applicant sustained a head and neck injury and that treatment outside the employer's medical provider network (MPN) was improper. While the employer failed to provide proper MPN notice, the applicant did not demonstrate this failure resulted in neglect or refusal to provide reasonable medical treatment. Therefore, treatment outside the MPN was not authorized. The Board found no error in the WCJ's decision.

Workers' Compensation Appeals BoardMedical Provider NetworkMPNLabor Code section 4616.3Findings of FactReconsiderationWCJPetition for ReconsiderationReport and RecommendationKnight v. United Parcel Service
References
1
Case No. ADJ10581300
Regular
Dec 14, 2018

LESLIE HYNES vs. GREAT CLIPS, THE HARTFORD INSURANCE GROUP

The Workers' Compensation Appeals Board affirmed a prior order denying an employee's request to treat outside her employer's Medical Provider Network (MPN) at the employer's expense. The Board found no evidence that the employer neglected or refused to provide medical treatment. Therefore, the employee is not entitled to select a physician outside the MPN at the defendant's expense. However, the employee retains the right to self-procure treatment outside the MPN at her own cost.

Workers' Compensation Appeals BoardReconsiderationFindings of Fact and OrderMedical Provider NetworkMPNSelf-procure treatmentNeglect or refusalIndustrial injuryPrimary treating physicianWCJ
References
4
Case No. ADJ6801375
Regular
Jul 13, 2010

MICHAEL DAVID HERNANDEZ vs. VINCE'S ITALIAN TO GO, PREFERRED EMPLOYERS

The Workers' Compensation Appeals Board (WCAB) granted reconsideration and rescinded a prior award. The WCAB found that the applicant was not entitled to medical treatment outside the employer's Medical Provider Network (MPN) for a meniscus transplant or graft. The applicant failed to follow the required procedures for obtaining a second and third opinion within the MPN before seeking treatment from an out-of-network physician. Therefore, the WCAB concluded there was no showing that treatment outside the MPN was justified under the relevant rules.

Workers' Compensation Appeals BoardMedical Provider NetworkMPNFurther Medical TreatmentSports Medicine DoctorMedical Meniscus TransplantGraft ProcedureDr. Patrick O'MearaDr. John DeSantisSubspecialist
References
2
Case No. GRO 0032684
Regular
Aug 28, 2007

LUIS CONTRERAS vs. NORTH AMERICAN FIRE HOSE, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board affirmed the WCJ's decision finding an industrial injury and a penalty for unreasonable delay in medical treatment, but denied the applicant's request to go outside the Medical Provider Network (MPN). Although a four-month delay occurred, the Board found that the employer's good-faith efforts to secure treatment within the MPN meant there was no "neglect or refusal" to justify going outside the network. Therefore, the applicant remains within the MPN for treatment.

Workers' Compensation Appeals BoardReconsiderationMedical Provider Network (MPN)Unreasonable DelayLabor Code Section 5814Self-Procured TreatmentNeglect or RefusalKnight v. United Parcel ServiceAndrade v. State Comp. Ins. FundPhysician Choice
References
2
Case No. ADJ10296560
Regular
Aug 09, 2016

ISAC VALLADRES vs. HMN, INC., SECURITY NATIONAL INSURANCE

The Workers' Compensation Appeals Board granted reconsideration, rescinding the prior Finding of Fact. The Board found that the applicant was not allowed to treat outside the defendant's Medical Provider Network (MPN) from October 22, 2015, through May 2, 2016. The Board deferred the issue of treatment outside the MPN after May 2, 2016, returning the case to the trial level for further proceedings. This decision stems from disputes over the defendant's timely authorization of medical treatment and the applicant's attempts to change treating physicians within and outside the MPN.

MPNPetition for ReconsiderationFinding of FactMedical Provider NetworkAuthorization of TreatmentDeclaration of Readiness to ProceedExpedited HearingAdministrative Law JudgeWorkers' Compensation Appeals BoardIndependent Medical Review
References
0
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