Permanent Disability; Rating; AMA Guides. WCAB rescinded WCJ's finding that applicant incurred 78 percent permanent disability as a result of injuries to her psyche, skin and in forms of headaches, chronic pain and fibromyalgia, when WCAB held that, in making permanent disability finding, WCJ improperly rejected opinion of AME in rheumatology, who had combined applicant's WPI using Table 13-4 of AMA Guides with WPI utilizing Table 13-8 of AMA Guides, based upon his interpretation that Chapter 13.2 of AMA Guides precluded combining of impairments from Tables 13-4 and 13-8, and that AME's opinion constituted substantial evidence and should have been followed because (1) AME clearly incorporated descriptions of impairments in AMA Guides as required under LC 4660(b)(1), (2) since there is no impairment rating relating to fibromyalgia in AMA Guides, there was no scheduled rating to rebut and therefore the rules set forth in Almaraz/Guzman and Milpitas Unified School Dist. v. W.C.A.B. (Guzman) were not strictly applicable, and (3) AME used tables within four corners of AMA Guides and explained his methodology. See Mrozek-Payne panel decision.

Reminder: Be sure to check the subsequent history of a case before citing to it.