NORMA GARCIA vs. WARNER BROTHERS; Permissibly Self-Insured

Defendant Warner Brothers seeks reconsideration of an award for medical treatment and durable medical equipment liens. The defendant argues the WCJ erred in awarding Vision Quest's lien for durable medical equipment, claiming timely utilization review established it was not necessary. Defendant also disputes Sobol Orthopedic's lien, asserting the awarded physical therapy visits exceeded the statutory cap and that penalties were unwarranted as they timely objected. The Appeals Board granted reconsideration, rescinded the award, and returned the case to the trial level to further develop the record.