Workers’ Compensation · Primary-source case analysis

Knight: Defective MPN Notice Can Shift Liability for Self-Procured Treatment

By Aneeta Mishra and Timothy Chan

Published May 18, 2026

Bruce Knight v. United Parcel Service examined the consequences of directing care through a medical provider network without proving that the injured worker received the notices necessary to understand and use that system.

An MPN is more than a list of doctors

The statutory system depends on timely notices explaining the network, treatment access, second and third opinions, and independent medical review.

The employer had to prove notice compliance

An assertion that notices normally were sent did not substitute for evidence establishing that the required information was provided in the worker’s case.

Missing notice affected medical control

Without the required information, the worker could not reasonably be expected to navigate the MPN’s selection and dispute procedures.

Reasonable outside care could become compensable

Where defective notice amounted to neglect or refusal to provide treatment, the employer could be liable for reasonable medical care the worker obtained independently.

Key takeaways

• Preserve each MPN notice and proof of delivery.
• Document the network-access instructions actually given to the worker.
• Investigate whether the worker could obtain timely appropriate care.
• Measure self-procured treatment against reasonableness and necessity.