On February 3, 2026, the Supreme Court of Oklahoma, in St. Anthony South Behavioral Health v. Goodwin, considered whether a workers compensation claimant is limited to one change of treating physician per claim.
In this case, the claimant sustained an injury to the right arm and requested a change of treating physician after the employer-selected physician determined that no further treatment was necessary. The employer opposed the request, asserting that Oklahoma workers compensation statute 85A O.S. §56(B) only allows one change of physician per claim and this was the claimant's second request.
The supreme court reviewed the statute, which requires the Workers' Compensation Commission to grant a claimant's first application for a change of treating physician. The court reasoned that while the statute guarantees the claimant one automatic change, it does not limit the number of additional applications a claimant may file or the number of changes the Commission may order. Thus, the court concluded, because the statute is silent on subsequent physician changes, an administrative law judge can authorize an additional change of treating physician and that authorization can be appealed like any other order.
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