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The Oklahoma Supreme
Court found recently there is no limit on the number of Form A's that an
injured worker can be granted to change the treating physician, as long as the
Administrative Law Judge agrees.
In the case of St. Anthony v. Goodwin, 2026 OK 3, the Court examined 85A O.S. Sec. 56(B) which the insurance carrier argued allowed only one Form A per case. The ALJ ordered a second Form A. That was appealed, and the ALJ's decision was reversed 2-1 by the Court of Civil Appeals. The Supreme Court granted certiorari and reversed COCA.
Justice Kane, writing for the 6-2 majority, said the statute does not say what happens after the ALJ grants the first automatic Form A. The Supreme Court said it should be up to the ALJ to determine if further changes of the treating physician for different body parts are warranted. Justice Kane wrote:
"The
statute does not limit the number of applications that may be filed, the number
of changes that may be ordered per claim, or the number of changes per injured
body part. Nor does the statute require the ALJ to order one change per body
part."
Bottomline, the ALJ and the Commission shall make the judgment call on changes in the treating physician based upon the facts in each individual case. The case grants the ALJ a lot of discretion regarding the treating physician on a claim.