Arch Coal Group, Inc. v. David Woolum, 25-ica-91

David Woolum, with over forty years of coal mining experience, was diagnosed with coal workers' pneumoconiosis, restrictive lung disease, and chronic hypoxemic respiratory failure.
Woolum's lung function had declined, requiring oxygen therapy as documented by multiple physicians, including Dr. Craig and the Occupational Pneumoconiosis Board (OP Board).
Woolum also had a history of COVID-19 pneumonia and was assessed for sarcoidosis, complicating his respiratory issues.
The claim administrator twice denied coverage for oxygen therapy and related equipment, arguing the ongoing respiratory issues were not linked to occupational pneumoconiosis.
The Workers’ Compensation Board of Review reversed these denials, authorizing oxygen therapy and equipment; Arch Coal, Inc. appealed this decision to the Intermediate Court of Appeals.
The appellate court reviewed whether the Board erred in authorizing these medical devices and therapy as compensable treatments under the claim.

Issue	Woolum's Argument	Arch Coal's Argument	Held
Authorization of oxygen therapy and equipment for pneumoconiosis	Oxygen therapy is medically required due to progression of occupational pneumoconiosis; medical evidence supports need	Medical evidence is insufficient; impairment is equally due to occupational and non-occupational causes, including COVID-19	Affirmed Board’s order authorizing therapy; substantial evidence supports need due to occupational pneumoconiosis

Duff v. Kanawha Cnty. Comm’n, 250 W. Va. 510, 905 S.E.2d 528 (W. Va. 2024) (standards for appellate review of Board of Review decisions)
In re Queen, 196 W. Va. 442, 473 S.E.2d 483 (W. Va. 1996) (deferential review of agency decisions supported by substantial evidence)
Delbert v. Murray American Energy, Inc., 247 W. Va. 367, 880 S.E.2d 89 (W. Va. 2022) (guidance on authorization for oxygen therapy in workers’ compensation claims)