QMEs; Ex Parte Communications. WCAB denied applicant's petition for removal from WCJ's order admitting medical reports of panel QME over applicant's objection on basis that reports were inadmissible because panel QME's service of reports only on defendant constituted an ex-parte communication in violation of LC 4062.3, when WCAB found that even if panel QME's service of medical reports solely on defendant could be deemed an ex parte communication, such communication fell within the "insignificant and inconsequential" exception as set forth in Alvarez v. W.C.A.B. See Lenier panel decision.

Medical Provider Networks; Reasonable Geographic Area. WCAB affirmed WCJ's finding that applicant was not precluded from treating with MPN physician whose office was located approximately 51 miles from applicant's residence, as there is no express statutory or regulatory "reasonable geographic area" limitation for treatment by MPN physicians, and WCAB found that no such limitation could be implied based upon "reasonable geographic area" limitation for non-MPN treatment set forth in LC 4600 and Rule 9780(h), and that LC 4660.3 and Rule 9767.6(e) allow injured employees to treat with any MPN physician after the first visit without regard to where physician is located. See Menicucci panel decision.