Home/Case Law/JENNIFER PATTERSON vs. THE OAKS FARM, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION for CALIFORNIA COMPENSATION INSURANCE COMPANY, in liquidation
Regular DecisionSignificant Panel Decision

JENNIFER PATTERSON vs. THE OAKS FARM, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION for CALIFORNIA COMPENSATION INSURANCE COMPANY, in liquidation

Filed: Jul 24, 2014
Oxnard
ADJ3905924 (ANA 0339374)

CompFox AI Summary

This case concerns the unilateral termination of nurse case manager services by an employer, which the Workers' Compensation Appeals Board affirmed as a form of medical treatment. The Board held that employers cannot unilaterally cease approved nurse case manager services without substantial medical evidence showing they are no longer necessary. Additionally, the Board clarified that an injured worker does not need to obtain a Request for Authorization to challenge such a termination, and expedited hearings are appropriate for these disputes. Ultimately, the employer failed to meet its burden of proving a change in the applicant's condition justifying the discontinuation of services.

Full Decision Text1 Pages

This case concerns the unilateral termination of nurse case manager services by an employer, which the Workers' Compensation Appeals Board affirmed as a form of medical treatment. The Board held that employers cannot unilaterally cease approved nurse case manager services without substantial medical evidence showing they are no longer necessary. Additionally, the Board clarified that an injured worker does not need to obtain a Request for Authorization to challenge such a termination, and expedited hearings are appropriate for these disputes. Ultimately, the employer failed to meet its burden of proving a change in the applicant's condition justifying the discontinuation of services.

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JENNIFER PATTERSON vs. THE OAKS FARM, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION for CALIFORNIA COMPENSATION INSURANCE COMPANY, in liquidation (2014) – Oxnard | CompFox