A nail gun to the head. A move across state lines. Tennessee's Appeals Board just affirmed the rules carriers must follow when claimants relocate.
That is the upshot of a Tennessee workers' compensation appeal decided on May 19, 2026. The state's Workers' Compensation Appeals Board affirmed the trial court and sent the case back for more proceedings.
Britt was a program coordinator for Center for Youth Ministry Training, a Williamson County employer. On March 14, 2022, she was working at a site in Shelby County when a nail gun fell from a roof and struck her on the head. She reported head and neck injuries and raised concerns about a traumatic brain injury. The employer accepted the claim as compensable and started authorized medical care.
The first panel-selected physician, Dr. Lloyd Robinson, diagnosed a head contusion and a cervical sprain. An authorized neurologist, Dr. Rance Wilbourn, ordered nerve testing that came back normal.
Then Britt moved to Colorado, and the trouble started.
Rather than offering her a panel of doctors in her new area to choose from, the decision says, the nurse case manager pointed her to a specific provider, Dr. Carol Dombro. Dr. Dombro referred her to Dr. John Sacha, who found no closed head injury but identified degenerative changes in her cervical spine, with disc bulging at C4-5 and C6-7. Dr. Sacha noted those changes were advanced for her age and could trace back to her years doing gymnastics. He concluded the work accident had produced whiplash-related symptoms, placed her at maximum medical improvement on September 19, 2022, and assigned a 7% impairment rating using the revised 3rd edition of the AMA's Guides.
A footnote in the decision flags a wrinkle there: Tennessee law requires the 6th edition of the AMA's Guides for permanent impairment ratings.
Britt sought an expedited hearing to compel the employer to provide more medical benefits and to have her physical therapist, Dr. David Bruton, designated as her authorized treating physician. The hearing ran across two days, December 2, 2025 and February 12, 2026. On the second day, the employer filed a notice offering Britt a panel of Colorado neurologists, conceding the panel issue mid-hearing.
The trial court ruled Britt was entitled to a panel of neurologists in her geographical area but refused to designate her physical therapist as her authorized treating physician. She appealed, representing herself.
The Appeals Board affirmed.
On the panel issue, the Board noted the employer had now complied. Expedited hearing orders are interlocutory and can be revised later, so Britt's bid to reopen the proof failed. She can file another expedited hearing request if she wants more relief.
On the physical therapist question, the Board went straight to the statute. Tennessee Code Annotated section 50-6-204(a)(3)(A)(i) requires employers to offer a choice of three or more independent reputable physicians, surgeons, chiropractors, or specialty practice groups. A doctor of physical therapy is not on that list. Britt offered no legal authority to argue otherwise.
The Board also upheld the trial court's refusal to certify Britt's summary of evidence, which the trial judge found mixed background and argument with descriptions of testimony.
For insurers and claims handlers, the case is a clean reminder on two points. When an injured worker relocates, the panel obligation moves with them – steering a claimant to a single provider through a nurse case manager will not satisfy the statute. And the list of providers who can be designated as an authorized treating physician is narrow. A physical therapist, even one with a doctorate, does not qualify.
The Appeals Board affirmed and remanded. The underlying claim continues.
