Scottsdale Memorial Hospital v. Industrial Commission

OPINION

JACOBSON, Presiding Judge.

The primary issue raised by this review of an Industrial Commission award is whether inadequate notice under A.R.S. § 23-1062(A) of an imminent hospitalization, coupled with a failure to obtain authorization for a change of doctors under A.R.S. § 23-1071(B), operates to relieve a carrier for the costs of compensable medical care. Subsidiary issues include wheth er claimant established to a reasonable medical probability that the industrial incident on April 23, 1986, was a substantial contributing cause of his depression and pain syndrome complex and whether…