Frances Welch vs. East Ventura Medical Group, The Hartford

This case concerns a lien claim filed by Center for Orthopedic Surgery (COSI) for medical treatment provided to Frances Welch. The Workers' Compensation Appeals Board affirmed a prior decision barring COSI's lien. The Board found COSI's lien was filed outside the six-month limit from the final award issuance, despite their argument that timely billing and lack of settlement document service should toll the statute. COSI's inaction for seven years after partial payment, without filing a lien, precluded any claim of tolling. The Board clarified that partial payment does not obligate the defendant to serve the provider with all settlement documents if no lien is on file.