Judge Can't Place Worker at MMI Without Finding From Doctor

The Colorado Court of Appeals ruled that an administrative law judge cannot make a finding that an injured worker is at maximum medical improvement without a finding from the treating physician or an independent medical examiner. Case: Burren v. ICAO, No. 18CA0565, 03/07/2019, published. Facts: Susan Burren worked for Destination Maternity. In September 2014, she suffered injuries to her arm and shoulder while at work. Burren received treatment from several doctors over the next three years, but she continued to complain of worsening pain. In June 2015, Destination Maternity asked Dr. Alli...