Edward Koren v. City of Kissimmee and Preferred Governmental Claim Solutions
The First District affirmed a JCC order denying workers'-compensation psychiatric benefits because the claimant failed to challenge an independent alternative ground (medical necessity) for the denial. A lengthy special concurrence clarified that the section 440.20(4) 120-day pay-and-investigate window is not automatic and must be affirmatively invoked, and that an employer who pays benefits without invoking it accepts compensability while retaining the right to contest entitlement to ongoing treatment.
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