Travelers Indemnity of Illinois v. Curtis

Travelers Indemnity of Illinois (insurer) seeks review of a final order of the Director of the Department of Consumer and Business Services (DCBS) that holds that insurer must pay for surgery performed by a physician who was not a member of insurer’s certified managed care organization (MCO). We review for errors of law and affirm.

The facts are straightforward. Claimant had an accepted cervical injury for which she received treatment from Dr. Brett, a non-MCO provider who had been her physician before claimant’s enrollment in insurer’s MCO. The claim was closed. Claimant challenged the notice…