Trustees of the University of PA v. N. Braas (WCAB)

Commonwealth Court of Pennsylvania·Decided August 20, 2026·No. 481 C.D. 2025·Published·McCullough

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Trustees of the University of : Pennsylvania, :

Petitioner :

:

v. : No. 481 C.D. 2025 :

Natalie Braas, Corey Grink, : Argued: May 13, 2026 and Dean Kenniff (Workers’ : Compensation Appeal Board), :

Respondents :

:

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE ANNE E. COVEY, Judge HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE MATTHEW S. WOLF, Judge HONORABLE STELLA M. TSAI, Judge

OPINION BY JUDGE McCULLOUGH FILED: August 20, 2026

Trustees of the University of Pennsylvania (Employer) petitions for review of the March 19, 2025 order of the Workers’ Compensation Appeal Board (Board), which vacated and remanded the June 18, 2024 decision of the Workers’ Compensation Judge (WCJ). In the June 18, 2024 decision, the WCJ granted Employer’s petition to terminate workers’ compensation benefits (Termination Petition) awarded to Natalie Braas (Claimant), denied the Petitions for Review of a Utilization Review Determination (UR Petitions) filed by Claimant and her medical providers, and dismissed Employer’s Petition Seeking Approval of a Compromise and

Release Agreement (C&R Petition) without first holding an expedited hearing on the C&R Petition.1 The Board concluded that in so doing, the WCJ violated Section 449 of the of the Workers’ Compensation Act2 (Act). The Board further held that the WCJ erred by imposing non-statutory or non-regulatory conditions on the parties’ ability to receive a hearing on the C&R Petition. After careful review, we affirm.

I. Factual and Procedural History Claimant was employed by Employer as a registered nurse. On January 22, 2021, she sustained a work-related injury while moving a patient. Employer issued a medical only Notice of Compensation Payable describing the injury as an upper back strain. By a decision and order circulated on October 13, 2022, the WCJ expanded the work injury description to include cervicalgia; cervical disc protrusions at C5-6 and C6-7; electrodiagnostic pathology on the right at C6-7; cervical strain and sprain; muscle spasticity with an ongoing active trigger point; thoracic strain and sprain; and lumbosacral strain and sprain.

On February 9, 2023, Employer filed a Termination Petition, alleging that Claimant fully recovered from her work injury as of January 10, 2023. Claimant filed an Answer denying that she fully recovered.

On March 24, 2023, Corey Grink, D.C., filed a UR Petition seeking review of the reasonableness and necessity of any and all chiropractic treatment he provided to Claimant on and after November 9, 2022. On June 29, 2023, Dean C. Kenniff, D.C., filed a UR Petition seeking review of the reasonableness and necessity of any and all

1 The Pennsylvania Association for Justice has filed a brief as Amicus Curiae in support of Claimant.

2 Act of June 2, 1915, P.L. 736, as amended, 77 P.S. §§1-1041.4, 2501-2710. Section 449 was added by the Act of June 24, 1996, P.L. 350.

chiropractic treatment that he provided to Claimant on and after March 28, 2023. Thereafter, litigation of the Termination and UR Petitions commenced before a WCJ.

While these petitions were pending, the parties participated in a voluntary mediation conference on December 21, 2023. Although the mediation did not result in a settlement, the parties continued to negotiate. In compliance with the WCJ’s briefing schedule, Employer filed its briefs with respect to the Termination Petition on January 16, 2024, and the UR Petitions on March 7, 2024. Claimant’s and her providers’ briefs were due on March 27, 2024.

Meanwhile, prior to Claimant filing her brief, the parties reached an amicable resolution in the amount of $225,000.00, plus reimbursement of Claimant’s litigation costs in the amount of $4,912.95. On March 22, 2024, Employer filed a “Petition To/For (LIBC-378) Seek Approval of a Compromise and Release Agreement” (Petition for Approval), stating that the “parties have reached a settlement in principle with respect to the Claimant’s future claim to workers’ compensation benefits and seek approval of a [C&R] Agreement.” (Reproduced Record (R.R.) at 33a.) The Petition for Approval was assigned to the WCJ under the same dispute number as the Termination and UR Petitions. Paragraph 19 of the C&R Agreement provided:

This Agreement is executed with the understanding that it completely resolves not only the work injury claim from 1/22/2021, but it also fully resolves any and all other work injury claims suffered while Claimant was employed with the Employer.

(c) This Agreement fully resolves all future workers’ compensation claims from the circulation date of the [WCJ’s] decision approving the instant Agreement onward with respect to the 1/22/2021 work injury. This Agreement does not affect the following issues currently in litigation and on which a judicial decision is requested by the parties:

i. Whether [] Claimant fully recovered under the pending Termination Petition as of 1/10/2023, per the medical opinions of Dr. Gene Salkind, based on the evidence of record.

ii. Whether the chiropractic treatment under review from Dr. Cory Grink in the pending Petition for Review of the Utilization Review Determination (LIBC-403) was reasonable and necessary, based on the evidence of record.

iii. Whether the chiropractic treatment under review from Dr. Dean Kenniff in the pending Petition for Review of the Utilization Review Determination (LIBC-403) was reasonable and necessary, based on the evidence of record.

(Board Decision, 3/19/25 at 6-7; R.R. at 123a-24a.)

On March 27, 2024, Claimant and her providers filed their briefs with respect to the Termination and UR Petitions.

On March 28, 2024, the WCJ issued an Interlocutory Order containing “Instructions to Attorneys.” The instructions state: “PLEASE READ AND FOLLOW THESE INSTRUCTIONS CAREFULLY. IF THEY ARE NOT FOLLOWED, YOU WILL NOT RECEIVE A HEARING DATE FOR YOUR C&R AND/OR YOUR PETITION MAY BE DISMISSED.” (R.R. at 41a) (emphasis in original). The instructions further state in relevant part:

A redacted and an unredacted Compromise and Release Agreement must be uploaded as separate exhibits before the matter will be listed for a hearing. No exhibit shall be uploaded separately. All exhibits shall be uploaded with the Agreement.

It is expected that the Agreements will be uploaded within 30 days.

CHECK JUDGE INSTRUCTIONS AND JUDGE COMMUNICATIONS IN WCAIS FOR ANY JUDGE REQUIRED REVISIONS. If changes are required, they will be stated in Judge Instructions and/or Judge Communications in WCAIS. The required changes must be made and revised redacted and unredacted Agreements must be uploaded before the matter will [be] listed for a hearing.

Please ensure that Claimant has the Compromise and Release Agreement with them at the time of the hearing.

Id. (emphasis in original).

On April 26, 2024, Employer’s counsel uploaded redacted and unredacted versions of the C&R Agreement in accordance with the WCJ’s instructions.

On April 29, 2024, the WCJ notified the parties that “[t]he [C&R]

Agreement must resolve all issues raised by all petitions or it will not be entertained.” (Board Decision, 3/19/25 at 7; R.R. at 124a.) The WCJ did not hold a hearing on the Petition for Approval.

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