Given this holding, the board also found that the <a href="https://thelomad.com/getmad.today/wp-contentduplicate-3602675.findlaw5.flsitebuilder.com/blog/2014/11/in-kigin-v-wcb-the-court-of-appeals-upholds-the-presumption-that-treatment-outside-the-mtgs-is-not-medically-necessary-and-the-attending-physician-has-the-burden-of-proof-of-the-need-for-a-variance/">variance procedure also applies to out-of-state treatment</a> although it refused to require out-of-state providers to use New York Worker’s Compensation board forms