Kwah v. San Mateo County Transit District (2024 Cal. Wrk. Comp. P.D. LEXIS 32)

 The WCAB held that an applicant who had moved to Georgia was entitled to reimbursement for cost of travel to California for medical care.

The applicant testified that he tried unsuccessfully to find a doctor near his home in Georgia who would accept the California medical fee schedule and comply with California’s UR and reporting requirements.

There was no evidence of any efforts by the defendant to find the applicant a doctor in Georgia.

The parties agreed that the applicant could be seen by his treating doctor for future visits by telehealth and that he would obtain lab work locally in Georgia.

However, the WCAB concluded that the defendant was responsible for travel-related expenses for the three trips to California per the agreement.