Krouse v. Workers' Compensation Appeal Board

837 A.2d 671, 2003 Pa. Commw. LEXIS 907
CourtCommonwealth Court of Pennsylvania
DecidedDecember 9, 2003
StatusPublished
Cited by12 cases

This text of 837 A.2d 671 (Krouse v. Workers' Compensation Appeal Board) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Krouse v. Workers' Compensation Appeal Board, 837 A.2d 671, 2003 Pa. Commw. LEXIS 907 (Pa. Ct. App. 2003).

Opinions

OPINION BY

Judge COHN.

In this case, we are asked to decide whether, under Workers’ Compensation Appeal Board (Board) regulations, a Uti[673]*673lization Review (UR) petition may be filed prior to a claimant filing a claim petition and, if so, whether the UR proceeding becomes moot upon the filing of the claim petition. We are also asked to determine whether a worker’s compensation claimant can avoid application of the doctrines of res judicata and collateral estoppel to a request for medical benefits set forth in a Petition to Review Medical Treatment (Review Petition) where those same medical benefits have previously been deemed unnecessary and unreasonable in an unap-pealed UR decision.

The facts here are not in dispute. Leeann Krouse (Claimant) sustained a work-related injury in the nature of bilateral carpel tunnel syndrome on May 6, 1997, while in the employ of Barrier Enterprises, Inc. (Employer). Employer, thereafter, filed a UR request seeking review of treatment, testing and therapy performed by Dr. Michael Dunigan, D.C. (Provider) for the period from May 6, 1997 through August 22, 1997. This UR request pre-dated Claimant’s filing of a claim petition. The UR determination found that the treatment was not reasonable and necessary. Claimant filed a petition to review this determination, but later withdrew it after the parties entered into an agreement that the bills would be paid. This UR proceeding is not at issue here.

On October 9, 1997, Employer filed a second UR petition, this time seeking a review of chiropractic treatments supplied by Provider for the period from September 12, 1997 forward. This UR request also pre-dated Claimant’s filing of a claim petition. A determination was issued, finding the treatments were not reasonable and necessary. Claimant did not appeal this decision.

On November 3, 1997, Claimant filed her claim petition and a Workers’ Compensation Judge (WCJ) granted disability benefits pursuant to an April 7, 1999 decision.1 Then, two years after the decision, on April 27, 2001, she filed a Review Petition alleging that Employer was not paying her medical bills from September 12, 1997 forward. The WCJ treated this petition as a UR petition, granted Claimant’s request, and ordered that medical bills incurred from Provider’s treatment to be paid. Employer appealed.

On appeal, the Board granted Employer’s supersedeas request and, then, reversed the WCJ. The Board determined that the WCJ should have dismissed the Review Petition because Claimant was seeking payment for the same medical treatment that was found not to be reasonable and necessary in the prior UR decision from which Claimant had not appealed. In reaching its decision, the Board relied on the principles of res judicata and collateral estoppel. It further stated that its regulations did not prevent Employer from fifing a UR petition prior to the time Claimant had filed a claim petition.

Claimant appealed to this Court. On appeal, she maintains that the Board erred in construing Board Regulation 127.405, 34 Pa.Code § 127.405, to permit Employer to file its UR petition prior to the date her claim petition had been filed. She also contends that the principles of res judicata and collateral estoppel are not applicable to her case.

First, we examine Claimant’s argument that Regulation 127.405 was erroneously applied by the Board in reaching its conclusion that Employer was not prohibited from filing its UR request prior to the time Claimant filed her claim petition. That Regulation provides:

[674]*674UR of medical treatment in medical only cases
(a) In medical only cases, when an insurer is paying for an injured worker’s medical treatment but has not either filed documents with the Bureau admitting liability for a work-related injury nor has there been a determination to the effect, the insurer may still seek review of the reasonableness or necessity of the treatment by filing a request for UR.
(b) If the insurer files a request for UR in a medical only case, the insurer is responsible for paying for the costs of the UR.
(c) If the insurer files a request for UR in a medical only case, then the insurer shall be liable to pay for treatment found to be reasonable or necessary by an uncontested UR determination.

(Emphasis added.)

Claimant argued before the Board that, because the UR request had been filed prior to the time she filed her claim petition, Employer was prohibited from seeking a review of the necessity and reasonableness of her treatment for any injury that had not been recognized or accepted. The Board, noting that the Regulation allowed for the procedure utilized by Employer, disagreed.

Claimant asserts, on appeal,2 that the WCJ was correct in determining that, when she filed her claim petition, her case could no longer be classified as “medical only,” a term used in the Regulation and, accordingly, that any decision arising from the UR process was “rendered moot,” regardless of whether the original filing of the UR request was proper. We disagree for two reasons. First, since the passage of Act 57,3 it is clear that a WCJ never has original jurisdiction over issues concerning reasonableness and necessity. Nothing in Section 306(f.l)(6) of the Workers’ Compensation Act,4 which governs UR proce[675]*675dures, even remotely suggests that, if a claimant files a claim petition subsequent to an employer’s filing of a UR request, the UR reviewer is divested of jurisdiction to act or the UR claim is somehow rendered moot. Second, we are persuaded by Employer’s argument that the purpose of this Regulation is to encourage payment of medical bills in cases that are treated, at least initially, as medical only. Were insurers unable to avail themselves of the UR process, they might well be less inclined to pay, voluntarily, for medical treatment, thus, resulting in more litigation. The present system encourages payment of medical bills by providing insurers with a method to limit payments where they believe treatment becomes unnecessary and unreasonable. Therefore, we reject Claimant’s theory that the mere filing of her claim petition rendered the UR proceeding moot.

Turning now to the question of whether Claimant’s Review Petition is barred by the doctrine of res judicata, in Patel v. Workmen’s Compensation Appeal Board (Sauquoit Fibers Co.), 88 Pa.Cmwlth.76, 488 A.2d 1177, 1179 (1985), petition for allowance of appeal denied, 515 Pa. 616, 530 A.2d 869 (1987), the Court observed that, for this doctrine to apply, there must be a concurrence of four conditions:

(1) Identity in the thing sued upon or for;
(2) Identity of the cause of action;
(3) Identity of persons and parties to the action;
(4) Identity of the quality or capacity of the parties suing or sued.

We also recognized that “[a]n identity of causes of action exists when, in both the prior and the subsequent proceedings the subject matter and the ultimate issues are the same....

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Krouse v. Workers' Compensation Appeal Board
837 A.2d 671 (Commonwealth Court of Pennsylvania, 2003)

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Bluebook (online)
837 A.2d 671, 2003 Pa. Commw. LEXIS 907, Counsel Stack Legal Research, https://law.counselstack.com/opinion/krouse-v-workers-compensation-appeal-board-pacommwct-2003.