In Linda Davis v. WCAB (Woolworth Corporation), the Commonwealth Court addressed the issue of whether the “mere passage of time” constituted sufficient grounds to require a claimant to submit to an independent medical examination. The employer filed a Petition to Compel the claimant to attend an IME in March of 2005, alleging that the claimant’s last IME had occurred in 1997. There was no other evidence submitted, and the judge denied the employer’s request, finding that the employer had failed to present a reasonable basis upon which to compel the claimant to attend the IME. The Commonwealth Court found that Section 314 of the Act does not require the employer to present any reason for the request for an IME, and found that the mere passage of time was sufficient grounds to compel the claimant to submit to an IME.