DARNELLA SCOTT STREET vs. SAN FRANCISCO BAY AREA RAPID TRANSIT DISTRICT, ATHENS ADMINISTRATORS
The Workers' Compensation Appeals Board denied reconsideration of a decision allowing a lien claim for an H-Wave machine. The applicant found more relief with the H-Wave than a TENS unit. The Agreed Medical Examiner opined that while not convinced the H-Wave was superior to other inferential stimulation units, it was superior to a TENS unit. The WCAB found the lien claimant met its burden of proof regarding the medical necessity of the H-Wave.