Seamon v. Workers' Compensation Appeal Board

I dissent from the majority opinion in this case which raises a very important question of first impression regarding the utilization review (UR) provisions of the Workers’ Compensation Act (Act).1 The majority holds that the clear, mandatory language of applicable regulations requiring a utilization review organization (URO) to obtain medical records from all treating providers does not render the report of the URO which was based on only some of the records inadmissible or incompetent in subsequent proceedings before a Workers’ Compensation Judge (WCJ) to determine the reasonableness and…