3rd DCA to Review WCAB's Order for Home Modifications for Worker after UR Denial

California's 3rd District Court of Appeal has agreed to weigh in on whether a workers' compensation judge had the authority to order a carrier to pay for the modification of a worker's bathroom to accommodate his wheelchair after utilization review denied authorization for the remodel, or if he should have let the dispute go through the independent medical-review process. The judge had decided he could evaluate Don Smith's need for a wheelchair-accessible bathroom since the underlying utilization review was invalid – even though there was no issue with its timeliness...