What the panel ordered
Petition for Reconsideration granted; final decision deferred pending further review of merits and entire record.
Applicant seeks reconsideration of the May 5, 2025 Findings of Fact by the WCJ, which denied authorization for a functional restoration program and found no jurisdiction to determine medical necessity. The WCAB granted reconsideration and deferred final decision pending further review.
What was disputed, and how it came out
Each issue the panel decided, with the reasoning it gave. An outcome is what this panel did on this record — not a rule, and not a prediction.
The WCJ found no jurisdiction to determine medical necessity because the February 24, 2025 RFA did not document a change of material facts to require utilization review. The WCAB granted reconsideration to further review this jurisdictional issue.
From the decision · page 1Applicant seeks reconsideration of the May 5, 2025 Findings of Fact, wherein the workers' compensation administrative law judge (WCJ) found, as stipulated by the parties, that applicant sustained a specific injury of August 12, 2021 to the bilateral wrists, bilateral shoulders, neck, bilateral elbows arising out of and in the course of employment by permissibly self-insured employer United Continental Holdings as a customer service representative. The WCJ also found that the February 24, 2025 report of primary treating physician (PTP) Timothy Lo, M.D., did not document a change of material facts and does not constitute substantial evidence in support of his February 24, 2025 Request for Authorization (RFA) of a functional restoration program. The WCJ further found that Utilization Review (UR) of Dr. Lo's February 24, 2025 RFA was not required, and that the WCAB has no jurisdiction to determine the medical necessity of the functional restoration program requested in that RFA.