SAIF Corp. v. Ross

In SAIF v. Ross, 191 Or App 212, 82 P3d 1035 (2003), we held that the Workers’ Compensation Board (board) did not err in interpreting former OAR 436-010-0230(3)(a) (1999), renumbered as OAR 436-010-030(4)(a) (2003), which provides, in part:

“[S]ervices * * * by a medical service provider other than the attending physician shall not be reimbursed unless carried out under a written treatment plan prescribed * * * and approved by the attending physician * * *. The treatment plan shall include objectives, modalities, frequency of treatment and duration. The treatment plan may be recorded in any…