Workers’ Compensation · Primary-source case analysis

Knight: Defective MPN Notice Can Restore Liability for Self-Procured Treatment

By Aneeta Mishra and Timothy Chan

Published April 27, 2026

Knight shows that merely asserting the existence of an MPN does not satisfy an employer’s treatment obligation when the worker cannot meaningfully exercise network rights.

The worker could not obtain the network information

After an admitted injury, Bruce Knight and counsel repeatedly sought the MPN provider list and information needed to select care. The record did not show notice of provider choice, second opinions, or third opinions.

Notice failure can amount to neglect of treatment

An employer’s duty is to provide reasonable medical care, not simply maintain a network. When required notice failures prevent access and result in neglect or refusal, the worker may obtain reasonable treatment outside the network.

Causation and reasonableness remain separate

Loss of network control does not make every outside service compensable. The worker must still establish that the self-procured treatment was reasonable and connected to the industrial injury.

Disposition

The Board held the defendant liable for the reasonable self-procured treatment on the record. Its rule tied the remedy to notice failure that actually caused a breakdown in care.

Key takeaways

• Audit every MPN notice and its delivery.
• Document requests for provider information and responses.
• Connect the defect to delayed or denied care.
• Prove reasonableness and industrial causation of outside treatment.