Facundo-Guerrero v. Workers' Compensation Appeals Board
California Court of Appeal
1Opinion of the Court
Opinion
RUVOLO, P. J.—
I. INTRODUCTION
Labor Code 1 section 4604.5, subdivision (d) (section 4604.5(d)) was enacted in 2003 as Senate Bill No. 228 (2003-2004 Reg. Sess.) (Stats. 2003, ch. 639, § 27) (Senate Bill 228), and provided that, unless approved by an injured employee’s employer, benefits for chiropractic treatments and physical therapy sessions were limited to no more than 24 visits per industrial injury, if the injury occurred after January 1, 2004. The statute was amended the following year as part of Senate Bill No. 899 (2003-2004 Reg. Sess.) (Stats. 2004, ch. 34, § 25) (Senate Bill…
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