Workers’ Compensation • Utilization Review • Compromise and Release Agreement • Relation of Condition to Work-Injury

Haslam v. Workers’ Compensation Appeal Bd. (London Grove Commc’n), PICS Case No. 17-1409 (Pa. Commw. Sep. 1, 2017) Hearthway, J. (13 pages).

Where relation of treatment to work-related injury appeared to be obvious, employer had burden to demonstrate that treatment was unrelated to or not caused by the work injury to avoid liability for treatment expenses. Order of the WCAB reversed.