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Despite earlier decisions concluding that downcoding of provider's bills for TMR treatment was appropriate, it's still necessary for insurer to demonstrate compliance with procedural requirements in §127.207 of medical cost containment regulations.

This is a case involving multiple fee review applications that were dismissed by a hearing officer on the basis of prior decisions from another hearing officer that upheld identical downcoding by the insurer in previous challenges from East Coast Case Law Alerts, 3rd Quarter 2013

A claimant who settles his claim by final and binding C&R Agreement cannot later petition to expand the nature of the work injury, arguing that the employer is precluded from denying causation by voluntarily making a medical bill payment.

The claimant settled his indemnity claim by Compromise and Release Agreement (C&R). The C&R that was approved by the Workers’ Compensation Judge described the injuries as "[a]ny and all injuries . . . Case Law Alerts, 3rd Quarter 2013