JCC Awards Shoulder Surgery After CNA Rotator Cuff Injury

In Deborah Conway v. Washington Rehabilitation and Nursing Center/Normandy Insurance Company, OJCC Case No. 26-001133JLN, the claimant sought authorization for right shoulder surgery, a shoulder immobilizer, and post-surgical physical therapy after a September 24, 2025 workplace accident while working as a certified nursing assistant.

Judge Jacquelyn L. Newman found the authorized orthopedic surgeon's opinions credible and unrefuted. The order accepts that the work accident was the major contributing cause of the right shoulder injury and that arthroscopic rotator cuff repair, biceps tenodesis, acromioplasty, distal clavicle excision, and a shoulder immobilizer were medically necessary.

The JCC granted authorization for the right shoulder surgery and shoulder immobilizer, denied post-surgical physical therapy as premature because no specific referral had been proven, and awarded attorney fees and costs to the claimant. The order also criticized the employer/carrier's extended investigation and delay in authorizing care after the compensable injury was accepted.

Source: Compensation Order