En Banc WCAB Clarifies Requirements for Apportionment by Reporting Physicians, Vocational Experts

The California Workers’ Compensation Appeals Board last week issued an en banc decision clarifying the requirements for doctors and vocational experts to properly opine on apportionment. The issue arose in a case called Nunes v. California Department of Motor Vehicles. Grace Nunes worked for the DMV as a field representative. She filed two workers’ compensation claims based on injuries to her arms, neck and left shoulder. The parties selected Dr. Melinda Brown to act as the qualified medical evaluator for the claims. Brown reported that Nunes’ condition was permanent ...