Case Law Database

SANDRA L. BOYD vs. COUNTY OF SACRAMENTO

This case concerns whether lien claimant MBM Boutique Acupuncture could bill for multiple units of electro-acupuncture (CPT code 97801) per session. The defendant, County of Sacramento, argued that under the Official Medical Fee Schedule (OMFS), 97801 is an untimed code billable only once per session. The Appeals Board reversed the WCJ's decision, finding the defendant's expert bill reviewer's unrebutted testimony established 97801 as an untimed code, limiting reimbursement to one unit per session. Therefore, the defendant's payment was deemed reasonable and consistent with the OMFS, and the lien claimant was awarded nothing further.