Workers’ Compensation · Primary-source case analysis

Patterson: An Employer Could Not Unilaterally Terminate an Authorized Nurse Case Manager

By Aneeta Mishra and Timothy Chan

Published August 25, 2026

Patterson v. The Oaks Farm reviewed an order restoring nurse case-management services that the defendant had previously authorized and then stopped without a new request for authorization.

Nurse case management was medical treatment

The service was furnished to cure or relieve the effects of industrial injury and therefore fell within the medical-treatment framework of Labor Code section 4600.

Ongoing authorized care could not simply be withdrawn

The defendant’s unilateral termination bypassed the process governing medical-necessity review of treatment already being provided.

A new RFA was not required on the facts presented

The Board distinguished a request for new treatment from reinstatement of previously authorized continuing services that the employer had stopped on its own.

The decision is significant but not en banc

Significant panel decisions are persuasive and intended for guidance, but they are not binding precedent like an en banc WCAB decision or published appellate opinion. Current statutes and later decisions must be checked.

Key takeaways

• Document the original authorization and course of treatment.
• Identify who stopped care and why.
• Separate new treatment requests from unilateral termination of ongoing care.
• Check later authority and current utilization-review regulations.