Insurer’s refusal to authorize out-of-state treatment leads to liability

In an unpublished decision, the New Jersey Superior Court, Appellate Division held that an employer and its insurer were liable for the costs of a worker’s second surgery because the insurer’s refusal to authorize out-of-state medical treatment was a cause of her deteriorating medical condition requiring the surgery. In New Jersey, an employer can be required to authorize out-of-state medical treatment for a worker.