Can medical panels override treating physicians in workers' compensation cases? Hoffman v. Labor Commission Explained

In a significant workers’ compensation decision, the Utah Court of Appeals examined the authority of medical panels to determine the necessity of prescribed medications, even when those determinations conflict with treating physicians’ recommendations.

Background and facts: Elizabeth Hoffman suffered a work-related back injury in 1986 that resulted in chronic pain requiring multiple surgeries. For thirty years, Delta Air Lines and its insurer Hartford paid for her opioid medications prescribed by treating physicians. After a defense medical examination in 2016, Hartford stopped all payments. A medical panel later determined that only 120 mg of extended-release oxycodone daily was necessary, significantly less than Hoffman had been prescribed, and that benzodiazepines and Soma were not medically necessary.

Key legal issues: The case presented questions about whether the Labor Commission could rely on a medical panel’s determination of necessary medical care over treating physicians’ prescriptions, and whether such determinations could be applied retroactively to past expenses.

Court’s analysis and holding: The court affirmed the Commission’s decision, applying the substantial evidence standard of review. The court emphasized that Utah Code section 34A-2-601 expressly permits administrative law judges to base findings on medical panel reports. The court rejected Hoffman’s argument that treating physicians should have greater authority than medical panels, noting that a medical panel’s report alone can provide substantial evidence for the Commission’s determination. The court found the Board properly relied on the panel’s conclusions regarding both past and future medication needs.

Practice implications: This decision reinforces the significant authority of medical panels in workers’ compensation proceedings. Practitioners should understand that medical panels can override treating physicians’ recommendations when determining what care is “necessary” under the statute. The decision also clarifies that compensability determinations are tied directly to medical necessity findings, and that carriers who cease payments risk liability only for care ultimately deemed necessary through the adjudicative process.