Not Forwarding Medical Records to the Utilization Review Organization

In UPMC-Work Partners v. Workers' Compensation Appeal Board (Geisler), 875 A.2d 1222 (Pa. Cmwlth. 2005), the provider failed to forward his medical records to the Utilization Review Organization (URO), and a reviewer was never assigned to examine the reasonableness of the provider's treatments. No report from a reviewing physician was issued due to this failure; in the absence of a reviewer's report, there was nothing for a Workers' Compensation Judge (WCJ) to review on appeal. Thus, we held that "if a report by a peer physician is not prepared because the provider has failed to produce medical records to the reviewer, the WCJ lacks jurisdiction to determine the reasonableness and necessity of medical treatment." Geisler, 875 A.2d at 1228.