CompFox AI Summary
This case concerns a medical treatment lien disallowance for non-compliance with Labor Code § 4903.8(d), which requires a declaration from a competent person attesting to services rendered and accurate billing. The Appeals Board rescinded the initial decision, finding that the lien claimant had substantially complied with the statute. The Board held that an electronic "S" signature was sufficient and that the billing clerk, Jennifer Zambrana, was competent to make the declaration given the circumstantial evidence of treatment. Consequently, the lien was not disallowed, and the case was returned for further proceedings.
Full Decision Text1 Pages
This case concerns a medical treatment lien disallowance for non-compliance with Labor Code § 4903.8(d), which requires a declaration from a competent person attesting to services rendered and accurate billing. The Appeals Board rescinded the initial decision, finding that the lien claimant had substantially complied with the statute. The Board held that an electronic "S" signature was sufficient and that the billing clerk, Jennifer Zambrana, was competent to make the declaration given the circumstantial evidence of treatment. Consequently, the lien was not disallowed, and the case was returned for further proceedings.
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