What the panel ordered
The Appeals Board denied defendant's Petition for Reconsideration, upholding the WCJ's Findings and Award that the utilization review decision was untimely and the requested inpatient rehabilitation treatment was reasonable and medically necessary.
Defendant filed a Petition for Reconsideration of the Findings and Award issued on September 5, 2025, challenging the timeliness of the utilization review decision and the medical necessity of requested treatment. The WCJ recommended denial of the Petition, and the Appeals Board reviewed and denied reconsideration on December 22, 2025.
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 Appeals Board found the requested inpatient rehabilitation treatment reasonable and medically necessary based on substantial medical evidence, including the RFA and supporting reports from Dr. Prasad and PQME Dr. Richman.
From the decision · page 8B. Although timely Utilization Review was not completed, applicant remains with the burden of establishing the treatment requested is reasonable. (Lab. Code § 5705.) For the treatment to be found industrial, the applicant must establish that the treatment is reasonable under the Medical Treatment Utilization Schedule (MTUS). (Lab. Code § 4600(b), 5307.27; Cal. Code Reg., title 8, § 9792.20-9292.27.23.) This is because "to carry this burden, the employee must present substantial medical evidence." (Dubon v. World Restoration, (2104) (Dubon II) 79 Cal.Comp.Cases 1298, 1312, (Appeals Board en banc).) The RFA at issue seeks inpatient post-acute comprehensive rehabilitation for traumatic brain injury (TBI).