MARIA FIGUEROA vs. HELP NET, INC., STATE COMPENSATION INSURANCE FUND
This case concerns a lien claimant's petition for reconsideration of a WCJ's decision disallowing his lien for chiropractic services provided between 2001 and 2005. The Appeals Board rescinded the WCJ's decision, finding the claimant's petition timely due to defective service. Crucially, the Board determined that the Medical Treatment Utilization Schedule (MTUS) was improperly applied; instead, the American College of Occupational and Environmental Medicine (ACOEM) guidelines, in effect during the treatment period, should govern the determination of reasonable and necessary care. The matter is remanded to the WCJ for further proceedings consistent with the ACOEM guidelines.