On Dec. 12, 2015, applicant Miguel Arana, 40, a roofer, was working on the third story of a building when he fell backward off a ladder and landed on a concrete surface. He sustained of his head and face. Arana filed a workers’ compensation claim against his employer, Aries Roofing Co. Inc., which was insured by State Compensation Insurance Fund. Arana sought workers’ compensation benefits., Arana suffered closed fractures of the skull and face, including a right frontotemporal fracture that extended to the frontal sinus and skull-based fractures that extended bilaterally through the suboccipital region to the clivus. He also suffered a severe traumatic brain injury, with acute respiratory failure, hypoxia, an epidural hematoma, a subdural hematoma and subarachnoid bleeding. Arana lost consciousness at the scene and was emergently transported to the nearest hospital. Given the mechanism of injury and likely brain swelling post-operatively, Arana underwent a hemicraniectomy and was monitored through intracranial-pressure monitors during his stay at the intensive-care unit, where he regained consciousness. Arana claimed that, after his discharge, he continued to suffer visual disturbances, jaw pain, impaired cognition and dysphagia: impairment of the ability to swallow. He was admitted to a home and community rehabilitation program and later admitted to a neurorehabilitation facility, where he underwent occupational therapy, speech therapy, physical therapy and neuropsychological counseling. On March 5, 2018, a neurologist concluded that Arana is permanently and totally disabled, pursuant to Labor Code § 4662(a)(4), noting that Arana suffers an injury to the brain that resulted in incurable mental incapacity. Thereafter, on March 30, 2018, Arana was declared 100 percent totally and permanently disabled by his primary treating physician, pursuant to Labor Code § 4662(a)(4). Arana’s counsel asserted that, based on the medical findings in doctor reports, Arana should be considered 100 percent totally and permanently disabled and that Arana would require long-term neurorehabilitation care in a structured living environment with 24-hour supervision for the foreseeable future. Aries Roofing’s counsel disputed the nature and extent of Arana’s , and contended that Arana did not require long-term care in a structured living environment with 24-hour supervision for the foreseeable future.