Supreme Court Won’t Decide Whether MPN Doctors’ Opinions Are Subject to UR/IMR

The California Supreme Court has declined a request for review of the Workers’ Compensation Appeals Board’s (WCAB) decision in Parrent v. SBC-Pacific Bell Telephone Company. The case addresses whether applicant Gregory Parrent’s employer should be able to refer a medical provider network (MPN) doctor’s treatment recommendation through utilization review (UR) and independent medical review (IMR). 

The WCAB decided in August 2016 that Parrent’s employer could rely on UR to acquire his doctor’s treatment recommendation, noting that UR could be replaced with IMR if Parrent was dissatisfied with its decision.

Parrent appealed on the claim that MPNs have a review procedure separate from UR and IMR. After his petition for review by the 4th DCA was denied, Parrent filed for review by the Supreme Court, but was again denied. 

The Supreme Court’s decision not to weigh in on the dispute indicates that the WCAB’s decision should remain intact, and ultimately that case law will hold MPN doctors’ opinions subject to UR and IMR.

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