Cotteta v. Siemans Med. Solutions USA, Inc., 22 A.3d 189 (Pa. 2011). · Go Syfert
Cotteta v. Siemans Med. Solutions USA, Inc., 22 A.3d 189 (Pa. 2011). Cases Citing This Book View Copy Cite
118 citation events (118 in the last 25 years) across 4 distinct courts.
Strongest positive: J. Marten v. PPB (pacommwct, 2026-06-25)
Treatment trajectory · 2011 → 2026 · click a year to view as-of
2011 2018 2026
Top citers, strongest first. 27 distinct citers. How cited ↗
discussed Cited as authority (rule) J. Marten v. PPB
Pa. Commw. Ct. · 2026 · confidence medium
Mandamus requires “[1] a clear legal right in the [petitioner], [2] a corresponding duty in the [respondent], and [3] a lack of any other adequate and appropriate remedy at law.” Crozer Chester Medical Center v. Bureau of Workers’ Compensation, Health Care Services Review Division, 22 A.3d 189, 193 (Pa. 2011) (citations omitted).
cited Cited as authority (rule) Fort Washington Surgery Center v. Indemnity Ins. Co. of N.A. & ESIS, Inc. (Bureau of WC Fee Review Hearing Office)
Pa. Commw. Ct. · 2025 · confidence medium
Div., 22 A.3d 189, 198 (Pa. 2011).
discussed Cited as authority (rule) Crawford, S., Aplts. v. Commonwealth
Pa. · 2024 · confidence medium
Ctr. v. Dep’t of Lab. & Indus., 22 A.3d 189, 194 (Pa. 2011) (quoting Bayada Nurses, Inc. v. Dep’t of Lab. & Indus., 8 A.3d 866, 884 (Pa. 2010)); Krentz v. Consol.
discussed Cited as authority (rule) J. LoDuca v. Pa. D.O.C. & Probation and Parole (2×)
Pa. Commw. Ct. · 2024 · confidence medium
Crozer Chester Medical Center, 22 A.3d at 193.
discussed Cited as authority (rule) Elite v. Premier Apl of: Premier Comp & Brick St. (2×)
Pa. · 2024 · confidence medium
Ctr. v. Dept. of Lab. & Indus., 22 A.3d 189, 196 (Pa. 2011). 10 Id. at 197 . 11 Armour Pharmacy v. Bureau of Workers’ Comp.
discussed Cited as authority (rule) R. Glahn & D. Gorencel v. DEP
Pa. Commw. Ct. · 2024 · confidence medium
Mandamus requires “[1] a clear legal right in the [petitioner], [2] a corresponding duty in the [respondent], and [3] a lack of any other adequate and appropriate remedy at law.” Crozer Chester Medical Center v. Bureau of Workers’ Compensation, Health Care Services Review Division, 22 A.3d 189, 193 (Pa. 2011) (citations omitted).
cited Cited as authority (rule) Solid Waste Services, Inc. v. St. Luke's Hospital (Bureau of WC)
Pa. Commw. Ct. · 2023 · confidence medium
Div., 22 A.3d 189, 198 (Pa. 2011).
discussed Cited as authority (rule) State Workers' Insurance Fund v. Harburg Medical Sales Co., Inc. (Bureau of Workers' Compensation Fee Review Hearing Office) (2×) also: Cited "see"
Pa. Commw. Ct. · 2022 · confidence medium
SWIF highlights the statement of the Pennsylvania Supreme Court in Crozer Chester II that “in cases in which liability for a particular treatment is at issue, the claimant, not the medical provider, must pursue compensation before a workers’ compensation judge in the regular course.” Id. at 12-13 (quoting Crozer Chester II, 22 A.3d at 195).
examined Cited as authority (rule) UPMC Benefit Management Services, Inc. d/b/a UPMC Work Partners v. United Pharmacy Services (Bureau of Workers' Compensation Fee Review Hearing Office) (16×) also: Cited "see", Cited "see, e.g."
Pa. Commw. Ct. · 2022 · confidence medium
UPMC contends that even where a claimant’s injury is accepted by means of an open NCP, “the insurer may nonetheless question liability for a particular treatment.” Id. at 21 (quoting Crozer Chester II, 22 A.3d at 195); see also Crozer Chester II, 22 A.3d at 197 (explaining that “liability for an injury is distinct from liability for a particular treatment or its cost.
cited Cited as authority (rule) Ivy, G. v. Acker, P.
Pa. Super. Ct. · 2020 · confidence medium
S62045/19 Comp., 22 A.3d 189, 194 (Pa. 2011) (citation omitted).
discussed Cited as authority (rule) Workers' First Pharmacy Services, LLC v. Bureau of WC Fee Review Hearing Office (Gallagher Bassett Services) (2×)
Pa. Commw. Ct. · 2020 · confidence medium
This Court dismissed Crozer’s request for a writ of mandamus, and Crozer appealed. 11 The Department argued that there were practical considerations for a “regulatory prohibition against litigating liability within the context of the fee review process.” Id. at 193.
discussed Cited as authority (rule) Workers' First Pharmacy Services, LLC v. Bureau of WC Fee Review Hearing Office (Gallagher Bassett Services) (2×)
Pa. Commw. Ct. · 2020 · confidence medium
This Court dismissed Crozer’s request for a writ of mandamus, and Crozer appealed. 11 The Department argued that there were practical considerations for a “regulatory prohibition against litigating liability within the context of the fee review process.” Id. at 193.
cited Cited as authority (rule) S. Landes, PH.D. v. Bureau of WC Fee Review Hearing Office (Vigilant Ins. Co.)
Pa. Commw. Ct. · 2020 · confidence medium
Health Care Review Div., 22 A.3d 189, 196 (Pa. 2011).
examined Cited as authority (rule) Scomed Supply v. Bureau of WC Fee Review Hearing Office (Lackawanna American Ins. Co.) (3×)
Pa. Commw. Ct. · 2018 · confidence medium
This Court has explained that a “fee review is designed to be a ‘simple process’ with a ‘very narrow scope’ limited to determining the ‘relatively simple matters’ of ‘amount or timeliness’ of payment for medical treatment.” Selective Ins., 86 A.3d at 303 -04 (quoting Crozer, 22 A.3d at 196-97). “[T]he fee review process ‘presupposes that liability has been established.’ Accordingly, a fee review proceeding is not undertaken to determine liability for a particular treatment.” Id. at 304 (quoting Nickel v. Workers’ Comp.
cited Cited as authority (rule) Kegerise, S. v. Delgrande, Aplts.
Pa. · 2018 · confidence medium
Ctr. v. Dep’t of Labor and Indus., Bureau of Workers’ Comp., 22 A.3d 189, 194 (Pa. 2011).
cited Cited as authority (rule) Brimmeier v. Pennsylvania Turnpike Commission
Pa. Commw. Ct. · 2016 · confidence medium
Bureau of Workers’ Comp[.], Health Care Serv[s.] Review Div[.], ... 22 A.3d 189, 193 ([Pa.]2011) (citations omitted).
discussed Cited as authority (rule) American Body Care v. WCAB (Kmart Corporation and Sedgwick Mgmt. Svcs.)
Pa. Commw. Ct. · 2016 · confidence medium
As the Supreme Court in Crozer Chester Medical Center v. Department of Labor & Industry, 22 A.3d 189, 195-96 (Pa. 2011), stated: [U]nder the Act, if an insurer accepts that compensation is due for a particular treatment, a medical care provider may file an application for fee review to dispute the ‘amount or timeliness’ of the payment. 77 P.S. § 531(5); Catholic Health Initiatives v. Health Family Chiropractic, 720 A.2d 509, 511 (Pa. Cmwlth. 1998) (commencement of fee review process ‘presupposes’ that liability has been established). … 6 Provider argues liability was never establish…
discussed Cited as authority (rule) A.S. v. Pennsylvania State Police (2×)
Pa. · 2016 · confidence medium
Ctr. v. Dep't of Labor & Indus., 22 A.3d 189, 193 (Pa. 2011), quoting Delaware River Port Auth. v. Thornburgh, 493 A.2d 1351 , 1355–56 (Pa. 1985). (continuedP) [J-36-2016] - 11 ascertain and effectuate the intent of the General Assembly.
examined Cited as authority (rule) Zurich American Ins. Co. v. Bureau of Workers' Compensation Fee Review Hearing Office (Lehigh Valley Hospital) (3×)
Pa. Commw. Ct. · 2015 · confidence medium
The 90-day period therefore did not begin to run until November 13, 2012, when the utilization review determinations were issued and did not expire until February 11, 2013, after the Bureau accepted Hospital’s fee review application. 6 Bureau of Workers’ Compensation, Health Care Services Review Division, 22 A.3d 189, 196 (Pa. 2011); Catholic Health Initiatives v. Heath Family Chiropractic, 720 A.2d 509, 511 (Pa. Cmwlth. 1998).
examined Cited as authority (rule) Prescription Partners, LLC v. Bureau of Workers' Compensation Fee Review Hearing Office (Healthsmart Casualty Claims Solutions) (4×)
Pa. Commw. Ct. · 2015 · confidence medium
Id. at 196 (alteration in original) (emphasis added) (quotation omitted).
cited Cited as authority (rule) Selective Insurance Co. of America v. Bureau of Workers' Compensation Fee Review Hearing Office
Pa. Commw. Ct. · 2014 · confidence medium
Id. at 470 , 22 A.3d at 196 (internal punctuation omitted).
cited Cited as authority (rule) Friedman v. Corbett
Pa. · 2013 · confidence medium
Ctr. v. Dep’t of Labor & Indus., 610 Pa. 459, 466 , 22 A.3d 189, 194 (2011).
cited Cited as authority (rule) County of Carbon v. Panther Valley School District
Pa. Commw. Ct. · 2013 · confidence medium
Crozer Chester Medical Center v. Department of Labor and Industry, Bureau of Workers' Compensation, 610 Pa. 459, 466 , 22 A.3d 189, 194 (2011).
cited Cited as authority (rule) Kohn v. SCHOOL DIST. OF CITY OF HARRISBURG
M.D. Penn. · 2011 · confidence medium
Ctr. v. Dep’t of Labor & Indus., — Pa. -, -, 22 A.3d 189, 193 (2011) (quoted case omitted).
discussed Cited "see" Elite Care, RX v. Premier Comp Solutions (2×)
Pa. Super. Ct. · 2023 · signal: see · confidence high
See Crozer Chester Medical Center v. Bureau of Workers’ Compensation, Health Care Services Review Division, 22 A.3d 189, 196-97 (Pa. 2011). 3 The Fee Review Hearing Office conducts evidentiary hearings on the validity of a fee-review determination.
discussed Cited "see" Elite Care, RX v. Premier Comp Solutions
Pa. Super. Ct. · 2022 · signal: see · confidence high
See Crozer Chester Medical Center v. Bureau of Workers’ Compensation, Health Care Services Review Division, 22 A.3d 189, 196-97 (Pa. 2011). -3- J-A25005-21 issue of whether Elite Care was an agent of these providers.” Id. at ¶ 32.
discussed Cited "see" D. Colagreco v. WCAB (Vanguard Group Inc.)
Pa. Commw. Ct. · 2020 · signal: see · confidence high
See Crozer Chester Medical Center v. Department of Labor and Industry, Bureau of Workers’ Compensation, Health Care Services Review Division, 22 A.3d 189 , 195 15 (Pa. 2011) (URO determines only the reasonableness or necessity of a treatment offered for “an accepted work-related injury”).
Retrieving the full opinion text from the archive…
Natalie COTTETA, Respondent
v.
SIEMANS MEDICAL SOLUTIONS USA, INC., Petitioner
159 EM 2010.
Supreme Court of Pennsylvania.
Mar 4, 2011.
22 A.3d 189
Per Curiam.
Published

ORDER

PER CURIAM.

AND NOW, this 4th day of March, 2011, the “Petition for Allowance of Appeal,” treated as a Petition for Permission to Appeal, is DENIED.