In-Person Exam Not Required for Doctor to Assign Permanent Impairment Rating

In a case of first impression, the Colorado Court of Appeals ruled that a doctor's failure to examine a claimant in person does not render invalid his impairment report. Keith Rosten worked for the City of Durango as a bus driver. He suffered injuries in a fall at work in January 2020. In October 2020, Dr. Adam Owens examined Rosten and reported that he was at maximum medical improvement. At the time, Owens was affiliated with the Centura Centers for Occupational Medicine. When Owens left Centura, Dr. Thomas Centi became Rosten’s authorized treating physician. Centi was the...