Gary v. Workers' Compensation Appeal Board (Philadelphia School District), No. 1736 C.D. 2010 (Pa.Cmwlth., April 21, 2011)
Holding: In a Utilization Review petition, an employer always retains the burden of proof. In order to prevail, however, the carrier is not required to show a change in condition since a prior UR determination, nor must its medical expert refer to prior UR determinations.