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

Case No. MON 0292635
Regular
May 20, 2008

ZENA GARCIA vs. SANTA MONICA MALIBU UNIFIED SCHOOL DISTRICT

The Appeals Board denied the lien claimant's petition for reconsideration, upholding the administrative law judge's decision that the lien claimant failed to meet its burden of proving the reasonableness of its charges for surgery. Despite prior direction to develop the record regarding rebuttal evidence, the lien claimant presented no further evidence, leaving its charges appearing disproportionate. The Board affirmed the use of the 2004 fee schedule as a guide to establish the reasonable value of the services.

KunzOutpatient Surgery Fee ScheduleReconsiderationLien ClaimantReasonable ValueRebuttal EvidenceBurden of ProofGeographic ComparablesComparative StudyIndustrial Injury
References
Case No. MON 0316585
Regular
Jun 27, 2008

GUY AZOLAY vs. ARM CONTRACTORS FIRST/STONE TILE, ACE FIRE UNDERWRITERS INSURANCE COMPANY

The Workers' Compensation Appeals Board granted reconsideration and increased the allowed lien claim for S&B Surgery Center from $\$ 1,361.70$ to $\$ 3,100.00$. This decision was based on evidence showing that $\$ 3,100.00$ was a reasonable fee for the surgical services rendered, considering comparable geographic facility fees and PacMed's review. The Board also clarified the penalty and interest provisions applicable if the defendant fails to pay the adjusted amount within 60 days.

Workers' Compensation Appeals BoardLien claimantReconsiderationFindings and OrderLabor Code section 4603.2Arthroscopic partial synovectomyArthroscopic chondroplastyArthroscopic partial lateral meniscectomyArthroscopic debridementOpen removal of plate and screw
References
Case No. ADJ1210556 (AGO 0018589)
Regular
Oct 10, 2008

EDWIN MILLER vs. KEEBLER COMPANY

The Workers' Compensation Appeals Board (WCAB) dismissed the defendant's petition for removal and granted reconsideration of the WCJ's prior decisions regarding medical mileage and penalties. The Board found the WCJ failed to properly consider statutory factors in determining a "reasonable geographic area" for the applicant's medical treatment. Consequently, the WCAB rescinded the WCJ's decisions and returned the case to the trial level for further proceedings and a new decision addressing all outstanding issues, including the definition of a reasonable geographic area for treatment.

WCABPetition for RemovalPetition for ReconsiderationMedical MileageReasonable Geographic AreaLabor Code Section 4600Administrative Director Rule 9780(h)WCJBoltonRamirez
References
Case No. LAO 0824281
Regular
Jan 28, 2008

LOY VOTAW vs. METRO FOURSLIDE MANUFACTURING, STATE COMPENSATION INSURANCE FUND

This case involves a lien claimant seeking reconsideration of a workers' compensation judge's decision regarding the reasonableness of a medical bill. The Appeals Board granted reconsideration, rescinded the prior order, and returned the case for further proceedings. The Board clarified that the lien claimant bears the burden of proving the reasonableness of their charges, and that further development of the record is necessary for a proper determination.

WCABLien ClaimantReconsiderationFacility FeeReasonablenessBurden of ProofKunzOutpatient SurgeryMedical SuppliesBilling Statement
References
Case No. ADJ2283259
Regular
Sep 19, 2000

SHAWN COOPER vs. UNITED PARCEL SERVICE, LIBERTY MUTUAL INSURANCE COMPANY

Reconsideration denied for lien claim for carpal tunnel release surgeries. The WCJ's decision, which is adopted and incorporated, found the lien claimant's billing unreasonable and grossly disproportionate to amounts accepted by other facilities.

Workers' Compensation Appeals BoardPetition for ReconsiderationAdministrative Law JudgeLien ClaimantFacility FeeCarpal Tunnel ReleaseCPT CodeOfficial Medical Fee ScheduleGeographic ComparablesReasonableness of Billing
References
Case No. ADJ10021120 ADJ8949346
Regular
Apr 14, 2017

ANTHONY BERNARD EDWARDS (Dec'd), CANDACE EDWARDS (Widow), ASHLEY EDWARDS (Daughter), ANTHONY EDWARDS, JR. (Son) vs. CITY OF LOS ANGELES; LOS ANGELES WORLD AIRPORTS, Permissibly Self-Insured

This case involves a workers' compensation death benefit claim for Anthony Bernard Edwards, who died in the course of his employment. The dependents seek death benefits and burial expenses, which were initially awarded by the WCJ. The employer, City of Los Angeles, sought reconsideration, arguing it should receive credit for a third-party settlement the dependents obtained from Kaiser Permanente. The Board agreed to reconsider the issue of credit, specifically whether Civil Code section 3333.1 bars such credit. The Board ultimately deferred the credit issue, affirming the death benefit award and returning the matter for further proceedings to determine the applicability of Civil Code section 3333.1 and potential employer negligence.

Workers' Compensation Appeals BoardADJ10021120ADJ8949346death benefitsLabor Code section 4702burial expensesCivil Code section 3333.1Medical Injury Compensation Reform ActMICRAthird-party settlement
References
Case No. POM 0261983
Regular
Feb 08, 2009

SARA LARA vs. POMONA UNIFIED SCHOOL DISTRICT, CALIFORNIA COMPENSATION INSURANCE/BROADSPIRE

The lien claimant, Premier Outpatient Surgery Center, sought reconsideration of an administrative law judge's decision that reduced their billed costs for applicant's medical treatment. The Workers' Compensation Appeals Board denied the petition, upholding the judge's finding that the billed costs were unreasonable and that the lien claimant failed to present a persuasive case supporting their charges. The Board also found no evidence of a violation of Labor Code section 4603.2 regarding timely reimbursement.

Kunz v. PattersonWCABLien claimantAmended Findings of FactReasonable and necessary costsBilled costs unreasonableStipulations with Request for AwardIndustrial injuryBilateral upper extremitiesNeck injury
References
Case No. ADJ3110837
Regular
Nov 09, 2009

BERTA GUILLEN vs. LINZER PRODUCTS, RISK ENTERPRISE 2314 BREA, STATE COMPENSATION INSURANCE FUND

The Board denied reconsideration of a lien claim, finding the lien claimant failed to meet its burden of proof and that the defendant's expert testimony was credible.

Workers' Compensation Appeals BoardReconsiderationLien ClaimantBurden of ProofCredibility DeterminationWCJ ReportDocumentary EvidenceTestimonial EvidenceReasonable ValueFee Schedule
References
Case No. ADJ5744485 ADJ6979008 ADJ6979031
Regular
Sep 16, 2010

BRIAN MENICUCCI vs. STATE OF CALIFORNIA, DEPARTMENT OF TRANSPORTATION, STATE COMPENSATION INSURANCE FUND/STATE CONTRACT SERVICES

This Workers' Compensation Appeals Board decision clarifies that injured employees are not geographically restricted when selecting a physician within a defendant's Medical Provider Network (MPN). While general treatment under Labor Code section 4600(c) has a reasonable geographic limitation, this restriction does not apply to MPN physicians. The Board affirmed the ALJ's decision, holding that an employee can choose any MPN physician, regardless of distance, after their initial visit. The case specifically avoided ruling on travel expense reimbursement or injuries sustained during travel to the chosen physician.

Medical Provider NetworkMPNreasonable geographic areaLabor Code section 4600(c)Labor Code section 4616 et seq.Administrative Director Rule 9780(h)Administrative Director Rule 9767.6(e)physician of his or her choicestatutory constructionstatutory omission
References
Case No. ADJ20141319
Regular
Jun 20, 2025

CHARLES FRANKLIN vs. COUNTY OF SAN BERNARDINO

Applicant Charles Franklin sustained a low back injury. Defendant County of San Bernardino filed a petition for reconsideration concerning a scrivener's error in the case number and the geographic reasonableness of the applicant's chosen treating physician, Dr. Nassos. The Appeals Board granted reconsideration to correct the case number from ADJ20141320 to ADJ20141319. However, the Board denied the substantive arguments, affirming the original decision that the defendant failed to demonstrate the unreasonableness of Dr. Nassos's geographic location for treatment by not presenting evidence of a suitable alternative closer to the applicant's residence.

WORKERS' COMPENSATION APPEALS BOARDPETITION FOR RECONSIDERATIONLABOR CODE SECTION 5909TIMELY ACTIONELECTRONIC ADJUDICATION MANAGEMENT SYSTEMTRANSMISSION DATEBUSINESS DAYNOTICE OF TRANSMISSIONREPORT AND RECOMMENDATIONSCRIVENER'S ERROR
References
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