Workers’ Compensation · Primary-source case analysis

Babbitt: An Employer Could Transfer Future Care Into a Valid Medical Provider Network

By Aneeta Mishra and Timothy Chan

Published April 26, 2026

Babbitt addresses whether the medical-provider-network system can govern continuing treatment for an injury and award that predate the network statutes.

The worker had an award of future medical care

Sharon Babbitt’s industrial injury and treatment rights existed before the employer implemented an authorized medical provider network. The employer later sought to move her continuing care into that network.

The network rules were procedural treatment provisions

The Board concluded that applying the MPN requirements to future treatment did not improperly reopen or reduce the underlying award. The worker retained the right to reasonable treatment, delivered through the new statutory system.

Compliance remains essential

Transfer authority depends on a validly established MPN and conformity with notice, access, continuity-of-care, and other governing requirements. The decision did not excuse defective implementation.

Disposition

The WCAB permitted transfer into the authorized network under the applicable facts. Disputes over reasonable treatment and compliance remained adjudicable.

Key takeaways

• Confirm that the MPN was validly established.
• Audit every required transfer and access notice.
• Analyze continuity-of-care protections.
• Distinguish treatment delivery rules from the underlying award.