2nd DCA: No Exception to Statutory Requirement That Medical Professionals Determine Necessity

There is no exception to the requirement that medical professionals determine medical necessity that allows the Workers' Compensation Appeals Board or any other court to decide the necessity of ongoing or continual treatments, a California appeals court ruled. Reforms enacted in 2004 and 2013 require all disputes over requested medical treatments to go through utilization review and independent medical review, the 2nd District Court of Appeals said in Illinois Midwest Insurance Agency v. WCAB (Rodriguez). "There is no statutory authority for a two-prong system in which only initial ...