CompFox AI Summary
The Workers' Compensation Appeals Board (WCAB) affirmed a judge's decision denying the applicant's claim for acupuncture and lidocaine patches. The applicant argued that acupuncture was not subject to utilization review (UR) based on Patterson v. The Oaks Farm, but the Board found Patterson inapplicable as there was no evidence of ongoing authorization for acupuncture. All Independent Medical Review (IMR) determinations upholding UR denials were affirmed, as the WCAB's review of IMR decisions is limited to specific grounds. The applicant failed to present clear and convincing evidence of plainly erroneous factual findings by IMR.
Full Decision Text1 Pages
The Workers' Compensation Appeals Board (WCAB) affirmed a judge's decision denying the applicant's claim for acupuncture and lidocaine patches. The applicant argued that acupuncture was not subject to utilization review (UR) based on Patterson v. The Oaks Farm, but the Board found Patterson inapplicable as there was no evidence of ongoing authorization for acupuncture. All Independent Medical Review (IMR) determinations upholding UR denials were affirmed, as the WCAB's review of IMR decisions is limited to specific grounds. The applicant failed to present clear and convincing evidence of plainly erroneous factual findings by IMR.
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