Background
Mr. Hottle sustained a compensable left arm injury on January 4, 2019. He underwent left shoulder arthroscopy with biceps tenodesis and labral repair on June 10, 2020. Despite the surgery, Mr. Hottle continued to experience left shoulder pain, limited range of motion, and numbness in his left hand into 2024 and 2025.
In February 2025, Dr. Garth Wright, Mr. Hottle’s treating surgeon, recommended a platelet rich plasma (PRP) injection of the left glenohumeral joint after reviewing an MRI showing moderate to advanced articular cartilage loss and attenuation of the labral repair. The claim administrator denied the PRP injection on February 10, 2025. The Workers’ Compensation Board of Review modified the denial on August 6, 2025, ordering the employer (Quad Graphics) to authorize the injection. Quad appealed, arguing that Mr. Hottle had reached maximum medical improvement (MMI) and required no further treatment.
The key factual dispute centered on the significance of MMI determinations by the employer’s independent medical examiner, Dr. Mark Rowley, who opined in September 2023 and reaffirmed in February 2025 that Mr. Hottle had reached MMI and required no additional treatment. The treating physician, Dr. Wright, by contrast, recommended the PRP injection based on ongoing objective findings of cartilage loss and continued pain.
The Court’s Holding
The Intermediate Court of Appeals affirmed the Board’s order requiring authorization of the PRP injection. The court applied the deferential “clearly wrong” standard of review and found substantial evidence supported the Board’s decision. The court reasoned that Mr. Hottle’s left shoulder labral tear and rotator cuff tendinopathy are compensable components of his claim, his continued left shoulder pain is documented, and the PRP injection is medically related and reasonably necessary to treat the compensable injury.
The court explicitly rejected the employer’s argument that an MMI determination precludes ongoing treatment. The court stated: “We find no merit in Quad’s argument that Dr. Rowley’s finding of MMI should affect Mr. Hottle’s ability to continue to receive treatment for pain that is related to the compensable injury.” The opinion further clarified that “Mr. Hottle is not precluded from seeking further treatment for pain and any other symptoms or complications found to be related to the compensable injury.”
The court gave substantial deference to the Board’s reliance on Dr. Wright’s opinion as the treating physician over Dr. Rowley’s independent medical evaluation. Under West Virginia law, claim administrators must provide claimants with medically related and reasonably necessary treatment for compensable injuries under West Virginia Code § 23-4-3, and the court found no violation of this statutory obligation.
Key Takeaways
- Maximum medical improvement does not eliminate an employer’s obligation to authorize medically necessary treatment for an ongoing compensable injury.
- Treating physicians’ recommendations receive significant judicial deference over independent medical examiner opinions when supported by objective medical findings.
- An employee may continue seeking treatment for pain and symptoms related to a compensable injury even after reaching MMI status.
- The Board properly exercised its discretion in authorizing the PRP injection based on ongoing shoulder pathology and documented pain related to the compensable injury.
Why It Matters
This decision clarifies a critical principle in West Virginia workers’ compensation law: reaching MMI does not terminate an employee’s right to continued medical treatment for the compensable injury. This holding has significant implications for employers, insurers, and injured workers. It means that MMI determinations, while establishing when vocational rehabilitation and wage loss benefits end, do not completely sever the employer’s duty to authorize reasonably necessary medical treatment addressing ongoing pain and symptoms stemming from the work injury.
The decision also reinforces the weight accorded to treating physician opinions in workers’ compensation disputes. By affirming the Board’s reliance on Dr. Wright’s clinical judgment over the employer’s retained expert, the court signaled that medical recommendations from providers actively treating the claimant carry substantial evidentiary weight, particularly when supported by objective imaging findings. This may influence how parties litigate medical authorization disputes and the strategic role of IME physicians in workers’ compensation cases.