LISA VALDEZ vs. SAINT HELENA HOSPITAL
The Workers' Compensation Appeals Board reversed a prior order denying a lien claimant's fee, allowing payment for a psychiatric consultation. The Panel Qualified Medical Examiner (PQME) Dr. Burt reasonably requested the consultation with Dr. Goldfield under former AD Rule 32, which permitted PQMEs to obtain necessary consultations. The defendant failed to investigate the potential psychiatric component of the applicant's industrial injury as required by AD Rule 10109, despite being notified by the PQME. Therefore, the Board found that Dr. Goldfield should be compensated for services rendered in the interest of substantial justice.