JCC Orders Lumbar RFAs; Denies Shoulder Pain-Management Evaluation

In Bales v. Modern Business Associates Inc. / Bridgefield Casualty Insurance Company, OJCC Case No. 22-007404RAA, Judge Robert A. Arthur entered a Final Compensation Order after a final hearing addressing medical benefits for the claimant’s spine and left shoulder.

The JCC found that bilateral radiofrequency ablations (RFAs) at the L3, L4, and L5 levels were reasonable and medically necessary, and ruled that the employer/carrier must authorize and provide those procedures. The order also rejected a “two-dismissal rule” defense asserted as a bar to the December 18, 2025 Petition for Benefits seeking the RFAs.

The claimant also sought authorization for Dr. Navdeep Jassal to evaluate the left shoulder. The JCC denied that claim, finding the evaluation was not medically necessary based on the record and the testimony presented. The order awarded entitlement to attorney’s fees and taxable costs for benefits obtained, with jurisdiction reserved as to amount.

Source: Final Compensation Order