RION NAUS vs. CENTRAL COAST VILLAGE CENTER, STATE COMPENSATION INSURANCE FUND

This case concerns a defendant's petition for reconsideration of a Workers' Compensation Appeals Board (WCAB) decision. The WCJ found the applicant required a spinal cord stimulator trial and that the defendant unreasonably delayed treatment. The defendant argued a prior Utilization Review (UR) and Independent Medical Review (IMR) denial was binding. However, the defendant failed to submit a subsequent Request for Authorization (RFA) with new medical information to UR. The WCAB affirmed the WCJ's decision, finding the defendant's failure to seek a new UR was unreasonable and allowed for the treatment, penalty, and attorney fees.