Stafford v. Workers' Compensation Appeal Board

933 A.2d 139, 2007 Pa. Commw. LEXIS 537
CourtCommonwealth Court of Pennsylvania
DecidedSeptember 21, 2007
StatusPublished
Cited by6 cases

This text of 933 A.2d 139 (Stafford 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
Stafford v. Workers' Compensation Appeal Board, 933 A.2d 139, 2007 Pa. Commw. LEXIS 537 (Pa. Ct. App. 2007).

Opinions

OPINION BY

Judge LEAVITT.

Craig Stafford (Claimant) petitions for review of an adjudication of the Workers’ Compensation Appeal Board (Board) that affirmed a decision by a Workers’ Compensation Judge (WCJ) that he lacked jurisdiction to hear Claimant’s appeal of a utilization review determination. In this appeal, we consider whether a WCJ has jurisdiction to review the reasonableness and necessity of Claimant’s medical treatment where, as here, Claimant’s provider failed to provide medical records to a Utilization Review Organization (URO) but a written report is, nevertheless, prepared by a peer review physician. For the reasons set forth below, we affirm.

On June 12, 2001, while employed by Advanced Placement Services (Employer), Claimant fell from a scaffold and landed on his left side. Employer issued a Notice of Compensation Payable accepting Claimant’s multiple injuries. Thereafter, Claimant filed a petition for review, seeking to amend the NCP.to include an injury to his cervical spine. After a hearing, the WCJ granted Claimant’s review petition.

Several months after the WCJ rendered his decision, Employer filed a request for utilization review of the medical treatment provided to Claimant by Dr. Paul Heberle, from July 18, 2002, and thereafter to treat Claimant’s cervical spine. The Bureau of Workers Compensation assigned Employer’s request to a URO, Quality Assurance Reviews, Inc. Although the URO was unable to obtain Dr. Heberle’s medical records, the URO assigned Employer’s request to a reviewing physician, Dr. Paul Miller, D.O. He issued a report that stated, in relevant part, as follows:

Paul Heberle, DO, did not submit records for this review. Therefore there is no medical information provided from Dr. Heberle, which would detail his clinical encounters with the patient ... Established treatment protocols cannot be addressed because there is no diagnosis provided from the provider under review
Due to the lack of records submitted by Paul Heberle, DO, there is no way to effectively evaluate if all treatment and medications ... were reasonable and necessary.
Therefore, all treatment and medications provided by Paul Heberle DO to [Claimant] from 7/18/02 and into the future is not reasonable and unnecessary.

Reproduced Record at 9a. Based on this report, the URO issued a determination concluding that Dr. Heberle’s treatment was not reasonable and necessary.

Claimant petitioned for review of the URO’s determination. The WCJ concluded that the URO’s assignment to Dr. Miller was improper because the regulation at 34 Pa.Code § 127.464 precludes a substantive review if a provider fails to provide medical records to the URO.1 The WCJ [141]*141held that notwithstanding Dr. Miller’s report, he lacked subject matter jurisdiction, relying upon County of Allegheny (John J. Kane Center-Ross) v. Workers’ Compensation Appeal Board (Geisler), 875 A.2d 1222 (Pa.Cmwlth.2005). The Board affirmed, and the present appeal followed.

On appeal,2 Claimant presents three issues for our consideration. First, he contends that the present matter is factually distinguishable from Geisler because here a report was filed by a reviewing doctor. Further, Claimant contends that he will be responsible for the medication prescribed by Dr. Heberle through his third party health insurer and, thus, will be disadvantaged by the URO’s determination with respect to Dr. Heberle’s prescribed treatment. Second, he contends that Geisler was wrongly decided. Third, he contends that the application of Geisler to his case violates his due process right to a hearing on his petition.

We begin with a review of Geisler. In that case, a URO determined the provider’s treatment was neither reasonable nor necessary because the provider failed to provide the requested medical records, and the claimant appealed to the WCJ. After a hearing on the merits, the WCJ concluded that the provider’s treatment was reasonable and necessary. The employer appealed the decision to this Court, arguing that the WCJ lacked jurisdiction to review the merits of the URO determination. We agreed with the employer, holding that “if a report by a peer physician is not prepared because the provider has failed to produce medical records to the reviewer, the WCJ lacks jurisdiction to determine the reasonableness and necessity of medical treatment.” Id. at 1228.

Claimant contends that his case is different from Geisler because Dr. Miller actually prepared a written report, the existence of which allows for a de novo review by a WCJ. Claimant acknowledges, as he must, that Dr. Miller’s report concluded that there was no way to evaluate the reasonableness and necessity of Dr. Heberle’s treatment because Dr. Miller never received Claimant’s medical records from Dr. Heberle. Nevertheless, Claimant argues that because the physician assigned to do the peer review reached this conclusion, as opposed to the URO itself, an appeal to a WCJ is appropriate. We disagree.

The applicable regulation sets forth the requirements of a peer review report. It states as follows:

The written reports of reviewers shall contain, at a minimum, the following elements: a listing of the records reviewed; documentation of any actual or attempted contacts with the provider under re[142]*142view; findings and conclusions; and a detailed explanation of the reasons for the conclusions reached by the reviewer, citing generally accepted treatment protocols and medical literature as appropriate.

34 Pa.Code § 127.472. Dr. Miller’s report contained none of these elements because Dr. Miller had no records to review. As in Geisler, the challenge to the reasonableness and necessity of Claimant’s medications and treatment before the URO was never addressed substantively, and the WCJ lacked jurisdiction to review the URO determination.

Claimant also argues that the policy considerations identified in Geisler do not pertain here. Specifically, it was observed in Geisler that Section 306(f.l)(7) of the Workers’ Compensation Act (Act), Act of June 2, 1915, P.L. 736, as amended, 77 P.S. § 531(7),3 punishes the doctor who does not produce his records. This is because the provider, whose services are found not to be reimbursable, cannot then turn around and pursue the claimant for unpaid invoices. Claimant contends that regardless of what happens to Dr. He-berle’s invoices, his private health insurer will have to pay for the prescriptions and that will leave a burden upon Claimant (presumably for the deductible).4

However, we are not free to revise the Act because it does not perfectly carry out a policy. See Gustine Uniontown Associates v. Anthony Crane Rental, Inc., 577 Pa. 14, 34, 842 A.2d 334, 347 (2004) (noting “the courts of this Commonwealth may not refuse to enforce on grounds of public policy that which the legislature has prescribed.”) (quoting Pantuso Motors, Inc. v. CoreStates Bank, N.A., 568 Pa. 601, 610, 798 A.2d 1277

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Stafford v. Workers' Compensation Appeal Board
933 A.2d 139 (Commonwealth Court of Pennsylvania, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
933 A.2d 139, 2007 Pa. Commw. LEXIS 537, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stafford-v-workers-compensation-appeal-board-pacommwct-2007.