JCC Denies Separate Pain Management Referral After Orthopedist Begins Care

In Lisa Corbin v. Washington Rehabilitation and Nursing Center/Normandy Insurance Company, OJCC Case No. 26-006245JLN, the claimant sought authorization of interventional pain management with Dr. Andrew Dec after a compensable low back injury from a February 5, 2026 work accident.

Judge Jacquelyn L. Newman denied the requested referral after finding that the employer/carrier had authorized orthopedic care with Dr. Spencer Stoetzel, who was already providing pain management through injections, therapy, and medication. The order accepted Dr. Stoetzel's testimony that another pain management physician was not currently needed and that a later referral could be made if future treatment required modalities he did not perform.

The JCC also rejected the claimant's waiver argument under section 440.13(3)(d), while expressly noting that the carrier's initial delay of more than four months conflicted with the statutory goal of quick and efficient delivery of benefits. Because the carrier was not denying medical necessity and had consented to pain management through the authorized orthopedist, the claim for a separate provider, attorney fees, and costs was denied.

Source: Compensation Order