Pre-Claim Petition UR Binds the Parties

In L. Krouse v. WCAB (Barrier Enterprises, Inc.) a UR found chiropractic treatment not reasonable and necessary in what was then a medical only claim. The Claimant did not appeal. The Claimant later filed a Claim Petition and received an award. The Board and Commonwealth Court rejected her efforts to include the chiropractic treatment subject to the UR in her Claim Award on the basis of res judicata, collateral estoppel and the principle that the WCJ never has original jurisdiction of reasonableness and necessity.