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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. SBR 0311485
Regular
Jun 28, 2006

KIMBERLY STOKES vs. PATTON STATE HOSPITAL / DEPARTMENT OF MENTAL HEALTH / STATE OF CALIFORNIA, legally uninsured, administered by STATE COMPENSATION INSURANCE FUND

This case concerns the lien claim of Ambulatory Surgery Center of Pomona (ASCP) for services rendered to an injured worker. The prior decision disallowed the lien because ASCP lacked a fictitious-name permit from the Medical Board of California. ASCP argues a permit wasn't required for "facility fees" and it possessed necessary accreditations. The Appeals Board rescinded the decision, remanding for a determination of whether ASCP operated as a "clinic" requiring a permit or an "outpatient setting" exempt from such if accredited, and whether its accreditation was valid for ASCP.

Fictitious-name permitMedical BoardAmbulatory Surgery CenterClinicOutpatient settingAccreditationBusiness and Professions CodeHealth and Safety CodeLien claimantProfessional services
References
Case No. WCK 0063425
Regular
Jul 30, 2007

JACQUELINE SYLVESTER vs. EASTBAY MUNICIPAL UTILITY DISTRICT, OCTAGON RISK SERVICES

The Workers' Compensation Appeals Board (WCAB) granted reconsideration to address the defendant's contention that the lien claimant, Webster Surgery Center, failed to prove proper licensure and accreditation for services rendered to the applicant. The WCAB rescinded the prior award and remanded the case for further proceedings to determine if Webster met the necessary licensing or accreditation requirements to provide the claimed medical services. This decision aligns with recent appellate court rulings placing the burden on lien claimants to demonstrate compliance with applicable licensure or accreditation standards.

Workers' Compensation Appeals BoardLien ClaimantReconsiderationFindings and OrderMedical TreatmentReasonable ValueLicensureAccreditationBurden of ProofAmbulatory Surgical Centers
References
Case No. SFO 0481476
Regular
Jan 24, 2008

JEANNE MANN vs. AEROVENTURE CLUB, INC., STATE COMPENSATION INSURANCE FUND

The Appeals Board granted reconsideration to Marin Surgery Center (MCSC) and rescinded the trial judge's denial of MCSC's lien. The Board found that MCSC, as an "outpatient setting," was not required to obtain a license or fictitious-name permit from the Medical Board. However, the case is returned to the trial level to further address MCSC's accreditation by the AAAASF at the time of the procedure and the reasonableness of its claimed fee.

Workers' Compensation Appeals BoardLien ClaimantMarin Surgery CenterMarin Cosmetic Surgery CenterMedical Board of CaliforniaAAAASFFictitious Name PermitAccreditationOutpatient SettingLicensed
References
Case No. ANA 0356755
Regular
Aug 22, 2007

YAZMINA VERDUZCO vs. EXECUTIVE AIR WASH, INC., STATE COMPENSATION INSURANCE FUND

This case involves a lien claim by Outpatient Spine & Surgery Center (OSSC) for over $74,000 in surgical services. The original ruling disallowed the lien, finding OSSC failed to prove it had a fictitious name permit from the Medical Board. The Appeals Board rescinded this decision, remanding the case for further proceedings to determine OSSC's compliance with licensure and accreditation requirements and the reasonableness of its charges.

Fictitious Name PermitMedical BoardLien ClaimantOutpatient SettingAccreditationBusiness and Professions CodeLicensureBurden of ProofRescindReturn to Trial Level
References
Case No. ADJ1004728 (OAK 0312941)
Regular
Dec 31, 2008

MARTHA HASSLER vs. FUTURE EXPLORE, INC., STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board granted reconsideration to address the WCJ's award to a lien claimant for surgical services. The Board found the WCJ erred in determining licensure and accreditation requirements, specifically regarding a fictitious business name permit, and in awarding a fee without sufficient evidence per established precedent. The case is remanded for further proceedings to develop the record on the lien claimant's proper licensure and the reasonableness of their claimed fee.

Workers' Compensation Appeals BoardFictitious Business Name PermitLien ClaimantLicensed ProfessionalOutpatient SettingSurgical ClinicMedical BoardReasonable FeeLicensureAccreditation
References
Case No. RIV 0037205, RIV 0070473
Regular
Jul 24, 2007

LORRIE AVERETTE vs. STATE OF CALIFORNIA, DEPARTMENT OF SOCIAL SERVICES, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board affirmed a prior ruling that Premier Outpatient Surgery Center was properly licensed and not required to have a fictitious name permit for services rendered. The defendant argued Premier lacked proper licensure and a fictitious name permit, but the Board found Premier met its burden of proof by submitting evidence of its licensure and accreditation. Premier was determined to be an "outpatient setting" rather than a "clinic," thus not requiring a fictitious name permit from the Medical Board.

Workers' Compensation Appeals BoardLien claimantFictitious name permitMedical Board of CaliforniaOutpatient surgery servicesLicensureAccreditationAmbulatory surgical centersZenith Ins. Co. v. Workers' Comp. Appeals Bd. (Capi)Stokes v. Patton State Hospital
References
Case No. AHM 074034
Regular
Jul 20, 2007

JAMES C. SKIDMORE vs. STATE OF CALIFORNIA / CALIFORNIA HIGHWAY PATROL, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) granted reconsideration to determine if Premier Outpatient Surgery Center, Inc. (Premier) met its burden to prove proper licensing and accreditation for its lien claim. The original ruling disallowed the lien because Premier failed to provide a fictitious-name permit from the Medical Board, which was deemed necessary by the administrative law judge. The WCAB rescinded the initial decision and returned the case for further proceedings to fully address whether Premier provided services as a facility or directly as a medical treatment provider requiring specific permits.

Workers' Compensation Appeals BoardPremier Outpatient Surgery CenterMedical Boardfictitious-name permitlicensingaccreditationlien claimantfacility feessurgical clinicStokes v. Patton State Hospital
References
Case No. unavailable
Regular
Jul 12, 2007

MORA vs. SOUTH BAY UNION SCHOOL DISTRICT, KEMPER INSURANCE COMPANY

This case concerns a lien claim by Beach Cities Surgery Center for medical treatment provided to an applicant injured in an admitted industrial incident. The WCJ initially disallowed the lien because the Surgery Center failed to prove its licensure/accreditation at the time of treatment. Although the petition for reconsideration appeared untimely, the Board accepted it as timely based on affidavits indicating hand delivery. Ultimately, reconsideration was denied on the merits, upholding the WCJ's original disallowance of the lien claim.

Workers' Compensation Appeals BoardLien claimantReconsiderationFindings and OrderIndustrial injuryLicensed or accreditedMedical treatmentLien claim disallowedPetition for reconsiderationUntimely filing
References
Case No. OAK 0315547
Regular
Jan 24, 2008

CECILE DJAFAR vs. UCSF MEDICAL CENTER, SEDGWICK CLAIMS MANAGEMENT SERVICES

The Workers' Compensation Appeals Board granted reconsideration to address the lien claimant's (Bay Area Surgery Center) claim for unpaid medical services. The Board rescinded the previous order disallowing the lien and remanded the case to the trial level. This action was taken because the lien claimant's crucial evidence of accreditation, which was believed to have been submitted and admitted, was missing from the official file, and further review is necessary to ensure substantial justice.

Workers' Compensation Appeals BoardUCSF Medical CenterSedgwick Claims Management ServicesBay Area Surgery CenterLien claimantCarpal tunnel releaseCompromise and release agreementAccreditation Association for Ambulatory Health CareOutpatient settingDue process
References
Case No. RIV 0047694, RIV 0063415 RIV 0063416, RIV 0063417
Regular
Jul 19, 2007

DEADRA FRANKLIN vs. STATE OF CALIFORNIA / DEPARTMENT OF MENTAL HEALTH / PATTON STATE HOSPITAL, legally uninsured, adjusted by STATE COMPENSATION INSURANCE FUND

This case concerns a lien claim by Premier Outpatient Surgery Center for unpaid services. The WCAB rescinded a previous order disallowing the lien due to Premier's lack of a fictitious-name permit, finding that the distinction between providing medical treatment versus an "outpatient setting" was not adequately addressed. The matter is returned to the trial level to determine if Premier, as an outpatient facility, was required to obtain a fictitious-name permit from the Medical Board.

Workers' Compensation Appeals BoardPremier Outpatient Surgery Centerfictitious-name permitBusiness and Professions CodeMedical Boardlien claimantoutpatient facilitycliniclicensureaccreditation
References
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