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

Case No. ADJ9120523
Regular
Jan 25, 2018

Guillermo Reyes Perez vs. Colorama Wholesale Nursery, Zenith Insurance Company

This Workers' Compensation Appeals Board case concerns disputed payments for copying services provided by lien claimant Citywide Scanning Services, Inc. The Board granted reconsideration to amend the original decision based on the WCJ's report. While most of the lien claimant's invoices were deemed satisfied due to failure to request a second review after receiving Explanations of Review (EORs), two invoices were specifically addressed. The Board found the defendant failed to provide valid EORs for services related to Colorama Wholesale Nursery and the California Secretary of State. Therefore, the lien claimant is entitled to full payment for these two invoices, less any amounts already paid by the defendant.

EORLabor Code section 4622WCAB Rule 9794(c)Petition for ReconsiderationLien claimantCopying servicesSecond reviewInvoicesDefendant's answerReport and Recommendation
References
Case No. ADJ9615494
Regular
Oct 08, 2019

CARLOS SOTO TORRES vs. THE CLIFF RESTAURANT, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board rescinded an Amended Findings of Fact and Order because essential documentation regarding the timeliness of medical-legal billings and reviews was missing. Specifically, the record lacked proof of service for the provider's invoice, the defendant's initial Explanation of Review (EOR), and the subsequent second bill review. This prevented determination of whether the defendant timely objected to the bill and whether the provider timely requested a second review, necessitating further proceedings at the trial level.

Workers' Compensation Appeals BoardReconsiderationAmended Findings of Fact and OrderQualified Medical EvaluatorQMEDr. Payam MoazzazZenith Insurance CompanyStatute of LimitationsLabor Code section 4903.5Independent Bill Review
References
Case No. ADJ9531226
Regular
Dec 04, 2018

JULICES MARTINEZ vs. SUN VALLEY GROUP, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board denied a lien claimant's petition for reconsideration, upholding the administrative law judge's decision. The lien claimant argued that the defendant's explanations of review (EORs) were deficient and did not trigger the lien claimant's obligation to request a second review. However, the Board found that the defendant's EORs substantially complied with statutory requirements and provided sufficient guidance to the lien claimant. Because the lien claimant failed to request a second review within the statutory timeframe, their objections to the billing were deemed waived.

Workers' Compensation Appeals BoardLien ClaimantExplanation of Review (EOR)Labor Code Section 4622Medical-legal ExpensesContested ClaimPetition for ReconsiderationAdministrative Director Rule 9794Second ReviewBill Review
References
Case No. ADJ8949526, ADJ8672351
Regular
Nov 05, 2018

ALFREDO ARGUETA vs. LA BREA DINING, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board denied reconsideration, upholding the administrative law judge's finding that the defendant was not liable for further payment on the lien claimant's invoices. The lien claimant argued the defendant's Explanation of Review (EOR) was deficient and thus they were not obligated to pursue a second bill review. The Board found this argument inconsistent with Labor Code section 4622, which requires timely objection to denied amounts, and adopted the WCJ's report. A dissenting opinion argued that a deficient EOR negates the requirement for a second bill review.

WCABLien claimantPetition for ReconsiderationExplanation of Review (EOR)Labor Code Section 4603.3Labor Code Section 4622Second Bill ReviewWCAB Rule 10451.1Perez v. Colorama Wholesale NurseryMedical-legal billing disputes
References
Case No. ADJ9040755
Regular
Apr 26, 2018

JUAN MARTINEZ vs. AREVALO LANDSCAPING SERVICE, CYPRESS INSURANCE COMPANY

This case concerns a lien claimant, Citywide Scanning Service, seeking reconsideration of a Workers' Compensation Appeals Board (WCAB) finding that their services were valued at $\$2,091.61$. The lien claimant argued that the defendant waived objections by failing to submit timely explanations of review (EORs) and that their billing was supported by evidence, entitling them to penalties. The WCAB denied reconsideration, finding that the issue of timely EORs was waived as it was not raised at the initial trial. The only remaining issue for trial was the reasonable value of the services, and the WCAB upheld the administrative law judge's determination.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationFinding and OrderExplanation of Review (EOR)Reasonableness and NecessityLachesPhotocopy ServicesCompromise and ReleaseLien Trial
References
Case No. ADJ8764706
Regular
Dec 28, 2018

JOSE GARCIA vs. THE SHADY CANYON GOLF CLUB

This case concerns a lien claimant, California Imaging Solutions (CIS), seeking reconsideration of a Workers' Compensation Judge's decision regarding payment for services. The initial decision awarded CIS $1,137.33, of which $814.40 had been paid, leaving a balance of $322.93. CIS argues the defendant waived objections due to non-compliant Explanation of Review (EOR) forms. The Appeals Board granted reconsideration, rescinded the initial order, and returned the matter for further proceedings. The Board found issues with the WCJ's reasoning regarding defendant's objections and the sufficiency of EORs under Labor Code section 4603.3.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationFindings and OrderExplanation of Review (EOR)Labor Code Section 4603.3Medical-Legal ExpensesContested ClaimReasonable and Necessary ServicesBill Review Expert
References
Case No. ADJ9733920
Regular
Feb 26, 2020

SYLVERIA VILLALOBOS vs. GIUMARRA VINEYARDS, ESIS

The Workers' Compensation Appeals Board affirmed the Administrative Law Judge's decision disallowing a photocopy lien claim. The Board found the lien claimant failed to prove they actually provided the billed "page capture/conversion and processing" services, as the records were provided on CD-ROM by the defendant. Furthermore, the defendant issued a timely and valid Explanation of Review (EOR) with a reduced payment, which the lien claimant did not object to within the statutory period. Consequently, the Board ruled the defendant was not liable for the denied portion of the lien.

Workers' Compensation Appeals BoardLien claimantReconsiderationFindings of Fact and OrderExplanation of ReviewSection 4903.8(d)Declaration of Custodian of RecordsCD-ROMInvoicePage capture/conversion
References
Case No. ADJ9838074 ADJ9838134
Regular
Nov 25, 2019

LEON SIMPSON vs. COLLEGE MEDICAL CENTER, NATIONAL CASUALTY INSURANCE, Administered by BROADSPIRE

The Workers' Compensation Appeals Board granted the lien claimant's petition for reconsideration regarding copy service invoices. The Board rescinded the prior decision, finding the administrative law judge's analysis inconsistent with Labor Code section 4622. The case is returned to the WCJ for further proceedings and a new decision consistent with the Board's en banc opinion in *Colamonico*, particularly addressing timely EOR submissions and the proper application of bill review statutes. Specifically, the WCJ must determine if defendants submitted timely explanations of review for all invoices.

Workers' Compensation Appeals BoardLien claimantMedical-legal expenseExplanation of Review (EOR)Labor CodePetition for ReconsiderationRescindFurther proceedingsColamonico v. Secure TransportationReasonable value
References
Case No. ADJ6843683
Regular
Dec 03, 2019

ELIZABETH FUERTE vs. B&H EDUCATION INC., ZENITH INSURANCE COMPANY, ICW GROUP

The Workers' Compensation Appeals Board (WCAB) rescinded a prior award, returning the case to the trial level for further proceedings. The WCAB clarified that lien claimants bear the burden of proving their copy services were reasonable, actual, and necessary, as clarified by the en banc decision in *Colamonico*. The Board also noted that services performed after the applicant settled her claim may require further justification. Finally, the WCAB indicated that if the lien claimant meets its initial burden, penalties and interest under Labor Code section 4622 may apply, as the defendant did not submit an Explanation of Review (EOR).

Lien claimantWCJReconsiderationFindings and AwardLabor Code section 4622PenaltyInterestCopy servicesCompromise and ReleaseColamonico
References
Case No. ADJ2588415
Regular
Jun 04, 2012

Hilda Marron vs. Celstron International, Continental Casualty Company, c/o CNA ClaimPlus

This case involves a petition for reconsideration by CNA Claims Plus/American Casualty Company concerning a prior Workers' Compensation Appeals Board (WCAB) decision. CNA was ordered to reimburse the California Insurance Guarantee Association (CIGA) $203,208.35 for payments made. CNA argued CIGA failed to prove the necessity and reasonableness of these payments, but the WCAB denied reconsideration. The Board adopted the Workers' Compensation Judge's report, finding CNA had ample opportunity to rebut CIGA's evidence at trial and failed to do so.

WORKERS' COMPENSATION APPEALS BOARDCELESTRON INTERNATIONALCONTINENTAL CASUALTY COMPANYCNA CLAIMPLUSCalifornia Insurance Guarantee AssociationCIGAREIMBURSEMENTMEDICAL REPORTSBILLSEOR
References
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