Jacobsmeyer: Late IMR Is Valid IMR

The 2nd Appellate District has issued the first of what should prove to be several appellate decisions on the timeliness of independent medical review decisions and the assertion by a Workers' Compensation Appeals Board panel decision that IMR timelines were mandatory, and late IMR vested jurisdiction with the WCAB to determine issues of medical necessity. The court in SCIF v WCAB (Margaris) therefore annulled the WCAB decision and remanded with instructions to issue a new decision consistent with the award. The court’s reason for accepting this case was set...