Stanton v. Equity Lifestyle Properties, Inc. / Liberty Mutual Insurance
Scott B. Miller JCC Beck – Sarasota (7-12-19) – Denied authorization of PCP. Claimant, rendered a quadriplegic from a surgical fracture, sought authorization of a PCP, costs, and attorney fees. E/C argued it timely authorized Dr. Cosmo (pulmonologist and internist) as Claimant’s PCP, and no costs/fees were due. Since 440.13(1) does not contain a definition of PCP, the JCC looked to “PCP” as defined in the managed care section 440.134(1)(k), which states that “Primary care provider” means, except in the... View More