Petitioner Roberta Adams seeks review of the Industrial Commission’s decision to deny her benefits under the Utah Occupational Disease Disability Law, Utah Code Ann. §§ 35-2-1 to -65 (1988). We vacate the Commission’s order.
FACTS
Adams worked as a telemarketer for Un-icorp. Her duties consisted primarily of dialing telephone numbers and talking on the telephone while sitting at a desk. She was not equipped with a headset or any type of automatic dialing equipment. She was required to dial manually and hold the receiver to her ear and mouth. After working at Unicorp for approximately one year, Adams left Unicorp to seek medical attention for debilitating pain she claimed had developed gradually as a result of her employment. In general, Adams now claims that the repetitive motion of calling on a manual phone and holding the phone to her mouth and ear caused her neck pain, neck stiffness, muscle spasm, pain in her right arm and shoulder, a “pins and needles” sensation and numbness in her right shoulder and arm, and fatigue.
When Adams informed her supervisor of her pain, he referred her to his chiropractor, Dr. Robert Pope, for treatment. Dr. Pope examined her and diagnosed her as having “cervico-brachial syndrome, carpal tunnel syndrome, myofascitis, and brachial neuralgia.” Adams’s condition was subsequently described by Dr. Pope as “repetitive motion syndrome.” Dr. Pope also indicated that he believed there was a very high probability that Adams’s condition resulted from her job duties.
Adams then began to see another chiropractor, Dr. Arnold Otterson, whose office was closer to her home. Dr. Otterson diagnosed Adams as having acute traumatic cervico-brachial syndrome with associated brachial neuralgia. Dr. Otterson likewise described Adams’s condition as repetitive motion syndrome. He treated her for several months and her condition improved. Dr. Otterson indicated to the Industrial Commission that in his professional opinion, Adams’s “condition was directly related to her employment due to repetitive use of the phone.”
Adams was next seen and evaluated by Dr. Richard Jackson, an orthopedic surgeon. His evaluation indicated that Adams was suffering from a degenerative C5-6 disc. Inasmuch as Dr. Jackson did not deal with head and neck problems, he referred Adams to Dr. Joseph R. Watkins, a neurologist. Dr. Watkins diagnosed Adams as having “work related cervical strain with some head discomfort and right shoulder discomfort” and “stress syndrome with multiple other symptoms, essentially resolved with resolution of work.”
The Workers’ Compensation Fund (the Fund) required Adams to undergo an independent medical evaluation by Dr. Edward Spencer. Dr. Spencer observed from the medical records that Adams had spondylo-sis of the C4-5 and C5-6 disc with narrowing at the C5-6 level. He also observed a narrowed L4-5 and L5-S1 disc with osteo-phyte formation from L5 at the L5-S1 level. Dr. Spencer diagnosed Adams as having probable “conversion disorder,” “chronic cervical and lumbar disc disease,” “chon-dromalacia of the patello-femoral joint,” and “obesity and poor conditioning.” He further found that her major problem was psychological and did not require any additional medical or surgical treatment for her condition.
The Fund then required Adams to be examined by Dr. Leonard W. Jarcho, the *4 former head of the Neurology Department at the University of Utah. Dr. Jarcho concluded that Adams did not have any neurological problem that he could identify. He also indicated that he believed that the minimal orthopedic problem was not connected to Adams’s complaints or her prior employment. Dr. Jarcho described Adams’s reactions, activities and movements during the examination as “strange,” and concluded that Adams was in need of psychiatric diagnosis and treatment.
As directed by the Fund, Adams was then examined by Dr. David L. McCann, a psychiatrist, who was assisted by Dr. Leslie M. Cooper, a clinical psychologist. Dr. McCann concluded that Adams suffered from a personality disorder and did not have any physical impairment or other problems associated with her employment, but that her complaints were motivated by a desire to obtain compensation.
A hearing was then held where the foregoing conflicting diagnoses were presented to an administrative law judge (A.L.J.). The A.L.J. denied benefits. Adams appealed the A.L.J.’s decision to the Commission, which affirmed the decision and adopted the findings and conclusions of the A.L.J. as its own. Adams now seeks review of the Commission’s decision.
Adams presents three claims for our determination: (1) the Commission’s findings and conclusions should be reversed because they are insufficient as a matter of law, (2) the Commission’s factual findings are not supported by substantial evidence, and (3) her condition constitutes a compensable condition under
Nyrehn v. Industrial Commission,
STANDARD OF REVIEW
Our review of the Commission’s denial of benefits is governed by the Utah Administrative Procedures Act (UAPA). UAPA provides, in relevant part:
The appellate court shall grant relief only if, on the basis of the agency’s record, it determines that a person seeking judicial review has been substantially prejudiced by any of the following:
[[Image here]]
(h) the agency action is ... (iv) otherwise arbitrary or capricious.
Utah Code Ann. § 63-46b-16(4) (1990).
Adams claims that she is entitled to relief under subsection (h). 1 The question of whether the Commission’s action constitutes arbitrary action for want of adequate findings is governed by our determination of whether this court is able to conduct a meaningful review. Whether the findings are adequate is therefore a legal determination that requires no deference to the Commission.
ADEQUACY OF FINDINGS
An administrative agency must make findings of fact and conclusions of law that are adequately detailed so as to permit meaningful appellate review.
In order for us to meaningfully review the findings of the Commission, the findings must be “sufficiently detailed and include enough subsidiary facts to disclose the steps by which the ultimate conclusion on each factual issue was reached.” Acton v. Deliran,737 P.2d 996 , 999 (Utah 1987) (quoting Rucker v. Dalton,598 P.2d 1336 (Utah 1979))....
*5 [T]he failure of an agency to make adequate findings of fact in material issues renders its findings “arbitrary and capricious” unless the evidence is “clear, uncontroverted and capable of only one conclusion.” Id. (quoting Kinkella v. Baugh,660 P.2d 233 , 236 (Utah 1983)).
Nyrehn v. Industrial Comm’n,
The Utah Supreme Court has clearly described the detail required in administrative findings in order for findings to be deemed adequate.
[An administrative agency] cannot discharge its statutory responsibilities without making findings of fact on all necessary ultimate issues under the governing statutory standards. It is also essential that [an administrative agency] make subsidiary findings in sufficient detail that the critical subordinate factual issues are highlighted and resolved in such a fashion as to demonstrate that there is a logical and legal basis for the ultimate conclusions. The importance of complete, accurate, and consistent findings of fact is essential to a proper determination by an administrative agency. To that end, findings should be sufficiently detailed to disclose the steps by which the ultimate factual conclusions, or conclusions of mixed fact and law, are reached. See generally, Rucker v. Dalton,598 P.2d 1336 , 1338 (Utah 1979). Without such findings, this Court cannot perform its duty of reviewing [an administrative agency’s] order in accordance with established legal principles and of protecting the parties and the public from arbitrary and capricious administrative action.
Milne Truck Lines, Inc. v. Public Serv. Comm’n,
If agency findings reveal the steps taken by the agency in reaching its decision, the failure to disclose a specific subsidiary finding may or may not be fatal to the agency’s decision. A finding may be implied if it is clear from the record, and therefore apparent upon review, that the finding was actually made as part of the tribunal’s decision.
See State v. Ramirez,
For this Court to sustain an order, the findings must be sufficiently detailed to demonstrate that the Commission has properly arrived at the ultimate factual findings and has properly applied the governing rules of law to those findings. ... It is not the prerogative of this Court to search the record to determine whether findings could have been made by the Commission to support its order, for to do so would be to usurp the function with which the Commission is charged.
Mountain States Legal Found. v. Public Serv. Comm’n,
The findings made by the A.L.J. and adopted by the Commission in the present case are inadequate in that they do not disclose the steps taken by the Commission in reaching its decision to deny Adams benefits. The Commission’s “findings” amount to the following single conclusory statement as to causation: “The preponderance of medical evidence in this case establishes that the applicant’s various listed symptoms are not related to her work as a telemarketer at Unicorp.”
Because the Commission concluded that Adams failed to prove causation, the Commission denied her benefits. The Commission correctly indicated in its adopted conclusions of law that causation is one of the ultimate factual conclusions that must
*6
be proven by a claimant.
See, e.g., Allen v. Industrial Comm’n,
While the purported “Findings of Fact” written by the A.L.J. contain an informative summary of the evidence presented, such a rehearsal of contradictory evidence does not constitute findings of fact. In order for a finding to truly constitute a “finding of fact,” it must indicate what the A.L.J. determines in fact occurred, not merely what the contradictory evidence indicates might have occurred. “[I]t is the responsibility of the administrative law judge to resolve factual conflicts.”
Lancaster v. Gilbert Dev.,
As is apparent in the recitation of the various diagnoses presented to the A.L.J., the doctors each had differing explanations for-Adams’s medical condition and whether it was caused by her employment. The evidence did not merely indicate two possible versions of a fact whereby we could conclude that the denial of benefits necessarily indicates that the Commission accepted one version over another. The evidence shows several possible configurations and degrees of injury and/or disease, if any, and the causes, if any, thereby creating a matrix of possible factual findings. A mere summary of the conflicting evidence in this case therefore does not give a clear indication of the A.L.J.’s or the Commission’s view as to what in fact occurred. Since we cannot even determine why the Commission found there was no causation shown, we clearly cannot assume that the Commission actually made any of the possible subsidiary findings. The findings are therefore inadequate.
In order for this court to address the errors claimed by Adams, we must have findings that indicate respectively (1) the issues decided, see section 63-46b-16(4)(c); (2) the legal interpretations and applications made, see section 63-46b-16(4)(d); and (3) the subsidiary factual findings in support of the decision, see section 63-46b-16(4)(g). A simple conclusion that Adams failed to prove medical causation does not contain any of the foregoing information.
At a minimum, there should have been a finding in the present case identifying the occupational disease or injury, if any, suffered by Adams. The Commission could not logically conclude that Adams’s medical condition, if any, was not caused by her employment without first establishing what her medical condition was.
4
This it failed to do. The Commission’s findings of fact simply do not “resolve all issues of material fact necessary to justify the conclusions of law and judgment entered thereon.”
Parks v. Zions First Nat’l Bank,
The Commission should have also given some explanation, factual or legal, as to how Adams failed to prove causation.
*7
An applicant with a pre-existing condition must prove both legal and medical causation.
See Allen,
When multiple conflicting versions of the facts create a matrix of possible factual findings, we are unable on appeal to assume that any given finding was in fact made.
See, e.g., Carlton v. Carlton,
PREJUDICE
Our conclusion that the Commission acted arbitrarily by failing to enter adequate findings and legal conclusions does not end our inquiry, however. As required by section 63-46b-16(4), the agency’s error must “substantially prejudice” the petitioner before we may grant relief. The Utah Supreme Court recently indicated in
Morton International, Inc. v. Utah State Tax Commission,
We recognize as a matter of law the substantial prejudice inherent in the failure to make adequate findings when the evidence is not clear and uncontrovert-ed.
Nyrehn,
*8 than anticipated, or that its initial logic is flawed. In such situations, a result contrary to the initial conclusions of the body may be dictated. The process of articulation clearly enhances agency self-discipline and protects against arbitrary and capricious decisions. Without the safeguard of adequate findings, there is no guarantee that the agency followed a logical process in reaching its decision. If, on the other hand, the agency identifies the facts, law, and reasoning supporting its decision, it reveals its logical process and the parties can be assured that a logical process oc-cured, even if it is in some manner flawed.
If an agency’s logical process is flawed, its shortcomings can be corrected on review, but only if the agency creates findings revealing the evidence upon which it relies, the law upon which it relies, and its interpretation of the law. Absent adequate findings, a petitioner wishing to challenge an agency’s factual findings will not be able to marshal the evidence in support of the findings.
See generally Grace Drilling Co. v. Board of Review of the Indus. Comm’n,
If findings are inadequate, this court will also be unable to effectively and efficiently perform its duty of review. “To enable this Court to determine whether an order is arbitrary and capricious, the Corn-mission must make findings of fact that are sufficiently detailed to apprise the parties and the Court of the basis for the Commission’s decision.”
Mountain States Legal Found.,
The Fund has not established that the Commission’s failure to make adequate findings of fact and conclusions of law was harmless as defined in Morton International, at 584-585. 6 We therefore resolve any doubt in Adams’s favor and hold that Adams was prejudiced by the Commission’s failure to make adequate factual findings and legal conclusions.
RELIEF
As a general rule, the appropriate relief for an agency’s failure to make adequate findings is to vacate the- order complained of and to order the agency to “make more adequate findings in support of, and more fully articulate [the] reasons for, the determination ... made."
Vali Convalescent & Care Insts.,
*9 CONCLUSION
We vacate the Commission’s order denying Adams benefits and direct the Commission to produce adequate findings of fact and conclusions of law and enter a new order.
GREENWOOD and ORME, JJ., concur.
Notes
. Adams also claims the following subsections of section 63-46b-16(4) constitute grounds for relief:
(c) the agency has not decided all of the issues requiring resolution;
(d) the agency has erroneously interpreted or applied the law;
[[Image here]]
(g) the agency action is based upon a determination of fact, made or implied by the agency, that is not supported by substantial evidence when viewed in light of the whole record before the court;
Inasmuch as we reverse the Commission's order because its failure to make adequate findings constituted arbitrary action warranting relief under subsection (h), we need not address the standards of review for subsections (c), (d), and ⅛).
. In so stating, we acknowledge that our ruling in
Nyrehn,
.
See, e.g.,
Utah Code Ann. § 35-2-27(28) (1988);
Allen v. Industrial Comm’n,
.
See, e.g., Nyrehn,
. We recognize that an administrative agency may hear evidence that is legally inadmissible under the technical rules of evidence; under the “residuum rule,” however, its findings of fact cannot be based exclusively on such inadmissible evidence. "They must be supported by a residuum of legal evidence competent in a court of law.”
Yacht Club v. Utah Liquor Comm’n,
. It is possible in some cases that the failure to make adequate findings is nevertheless harmless.
See, e.g., Nyrehn,
. We express no opinion on the merits of Adams’s remaining claims inasmuch as they may be resolved by the Commission’s entry of *9 adequate findings. Her remaining claims are best left for another day.