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

Case No. ADJ9466570
Regular
Dec 24, 2014

ELVIRA HERNANDEZ vs. NEWCO FOODS, INC., Operating As JACK IN THE BOX, SECURITY NATIONAL, Administered By AMTRUST NORTH AMERICA

The Workers' Compensation Appeals Board granted reconsideration to clarify an earlier decision regarding a Medical Provider Network (MPN). The Board affirmed the finding that the defendant failed to prove the existence of a valid MPN. Consequently, findings related to MPN access standards and transfer of care were rescinded, with the applicant permitted to continue treatment outside the invalid MPN with her chosen physician. This decision primarily hinges on the defendant's failure to establish a legally compliant MPN.

Medical Provider NetworkMPNFindings of Fact and AwardPetition for Reconsiderationprimary treating physiciantransfer of careself-procured medical treatmentTitle 8section 9767.5(b)Title 8
References
0
Case No. ADJ7644740
Regular
Dec 19, 2011

MIGUEL GARCIA vs. G.D. HEIL, INC., STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) granted reconsideration and rescinded the previous Findings and Order because the applicant raised valid issues regarding the employer's compliance with Medical Provider Network (MPN) notice requirements and the admissibility of evidence. The WCAB found the initial determination on temporary disability and MPN validity lacked sufficient evidentiary support and noted a contradiction between the WCJ's initial findings and later report. The case is returned to the trial level for further proceedings to address these evidentiary and notice issues properly.

Workers' Compensation Appeals BoardMedical Provider Network (MPN)Temporary DisabilitySelf-Procured Medical TreatmentNotice RequirementsPre-Trial Conference StatementAdmissibility of EvidenceLabor Code Section 4600Labor Code Section 4616Administrative Director's Rule 9767.12(a)
References
6
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. ADJ10836918
Regular
Sep 13, 2019

ABAS GORBANWAND vs. PACIFIC GIS, INC. dba SULTAN ADHC, OAK RIVER INSURANCE, BERKSHIRE HATHAWAY HOMESTATE COMPANIES

This case concerns an injured worker's claim that the defendant's Medical Provider Network (MPN) was invalid, entitling him to outside medical treatment. The Workers' Compensation Appeals Board affirmed the finding that a valid MPN existed. The Board determined that the applicant failed to prove the MPN lacked sufficient providers within the required access standards. Therefore, the applicant was not entitled to treatment outside the MPN at the defendant's expense, though they could use Dr. Bernstein at their own cost.

Workers Compensation Appeals BoardMedical Provider NetworkMPNLabor Code Section 4600Labor Code Section 4605Primary Treating PhysicianPTPQualified Medical EvaluatorQMEAccess Standards
References
1
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. ADJ7860847, ADJ7860626
Regular
May 14, 2012

FERNANDO SARMIENTO vs. PAYROLL MANAGEMENT GROUP, INC, BLUE CHIP RECYCLING, WAUSAU UNDERWRITERS INSURANCE COMPANY, LIBERTY MUTUAL

The Appeals Board vacated its prior grant of reconsideration and dismissed the defendant's petition as untimely and based on non-final orders. The Board granted removal on its own motion to consolidate two cases and affirmed the WCJs' denial of the defendant's petitions to compel the applicant to transfer care to a Medical Provider Network (MPN). While the defendant is generally not liable for treatment outside an MPN per *Valdez*, the Board found that MPN validity and notice issues, and the applicant's right to self-procure treatment at their own expense, were not yet determined. The Board clarified that the defendant can request an expedited hearing to determine entitlement to medical treatment, rather than compel MPN transfer.

Workers' Compensation Appeals BoardMedical Provider NetworkMPNPetition to CompelReconsiderationRemovalVenueConsolidationFinal OrderLabor Code
References
4
Case No. ADJ603509
Regular
Aug 03, 2010

PATRICIA NUNEZ vs. MAINSTAY BUSINESS SOLUTIONS

The Workers' Compensation Appeals Board reversed a prior award, ruling that lien claimants Fred Hafezi, M.D., Inc., and Whittier/Anaheim Physical Therapy Center were not entitled to reimbursement. The Board found that the defendant provided a valid Medical Provider Network (MPN) and applicant stipulated to receiving all MPN notices. Crucially, the lien claimants failed to meet their burden of proving they were within the defendant's MPN when services were rendered, thus their claims were disallowed.

Workers' Compensation Appeals BoardMedical Provider Network (MPN)Lien ClaimsCompromise and ReleaseBurden of ProofReasonable and Necessary Medical TreatmentSelf-Procured TreatmentReconsiderationFindings and AwardLabor Code
References
2
Case No. ADJ6820997
Regular
Feb 08, 2012

RODOLFO VILLALOVOS vs. ACE BEVERAGE COMPANY, TOPA INSURANCE COMPANY

This case involves a dispute over the admissibility of medical reports from a physician outside the defendant's Medical Provider Network (MPN) and the subsequent award of temporary and permanent disability benefits. The Appeals Board rescinded the original decision due to unresolved issues regarding the proper establishment and notice of the MPN. The case is returned to the trial level for further proceedings to determine the validity of the MPN and the admissibility of the medical evidence. The WCJ must also clarify whether certain QME reports were admitted into evidence, as reliance on unadmitted evidence is improper.

MPNValdezPrimary Treating PhysicianReconsiderationMedical Provider NetworkInadmissible ReportsStipulationTemporary DisabilityPermanent DisabilityMedical Treatment
References
3
Case No. ADJ8326077
Regular
Sep 20, 2018

JOSE RAMIREZ vs. LUCKY FARMS, INSURANCE COMPANY OF THE WEST

The Workers' Compensation Appeals Board granted reconsideration of a WCJ's order finding the defendant failed to prove a valid Medical Provider Network (MPN) and proper notice to the applicant. The Board rescinded the WCJ's decision and returned the case for further proceedings. The central issue is whether the defendant provided proper MPN notice and, if not, whether this failure resulted in a denial of medical care, justifying treatment outside the MPN. The Board emphasized that the defendant has the burden to prove proper notice, and lien claimants must then prove denial of care if notice was deficient.

Workers' Compensation Appeals BoardLucky FarmsInsurance Company of the WestADJ8326077Opinion and Order Granting Petition for ReconsiderationMedical Provider Network (MPN)Lien ClaimantsWCJFindings of Fact and OrderLabor Code section 4616.3
References
1
Case No. ADJ7062572
Regular
Apr 28, 2011

ANA LILIA RODRIGUEZ vs. COUNTRY VILLA HEALTH SERVICES, ZURICH AMERICAN INSURANCE CO. administered by TRISTAR RISK MANAGEMENT

The Workers' Compensation Appeals Board granted reconsideration of an award of temporary disability indemnity to an applicant who received treatment outside a valid Medical Provider Network (MPN). The Board overturned the original award, ruling that reports from physicians outside the MPN are inadmissible under current case law, *Valdez v. Warehouse Demo Services*. Consequently, the applicant is not entitled to temporary disability indemnity, reimbursement to the EDD, or attorney's fees based on those inadmissible reports. However, the applicant's unauthorized departure from the MPN was not deemed an unreasonable refusal of medical treatment.

Workers' Compensation Appeals BoardMedical Provider Network (MPN)Labor Code Section 4616.6Unauthorized Medical TreatmentAdmissibility of Medical ReportsTemporary Disability IndemnityEmployment Development Department (EDD)Attorney's FeesUnreasonable Refusal of Medical TreatmentLabor Code Section 4056
References
2
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