With commentary by Robert G. Rassp, Esq.

In Oranje v. Crestwood Behavioral Health, 2014 Cal. Wrk. Comp. P.D. LEXIS --, a WCAB panel affirmed the WCJ's finding that an applicant who suffered an admitted industrial injury to her left arm, left hand and psyche on 3/14/2010 in California but now lives in Nevada, was entitled to further medical treatment in form of counseling, including "telephonic therapy" with California marriage and family therapist (MFT) Chris Jones...read more.

Can an insurer submit medication prescription requests to utilization review (UR) even where those medications have been repeatedly authorized before? That question has been hotly debated in California workers' comp circles after a recent WCAB Significant Panel Decision, Patterson v. The Oaks Farm (2014) 79 CCC 910. The issue comes up again and again in cases, including cases of workers injured decades ago. The scenario goes like this. Medications are approved, sometimes for years without question. But emboldened by the availability of UR and the 2013 advent of Independent Medical Review dispute resolution procedures, the insurer...read more.