Richard Faria vs. GHILOTTI BROTHERS, INC., STATE COMPENSATION INSURANCE FUND
The Workers' Compensation Appeals Board granted reconsideration and rescinded a previous award to lien claimant Bay Surgery Center (BSC). The Board found the record deficient regarding BSC's licensure and the reasonableness of its charges. The case is returned to the trial level for further proceedings to develop evidence on whether BSC was properly licensed to operate as an outpatient setting and to determine the reasonable value of services rendered. Specifically, the Board clarified that BSC is not required to have a fictitious-name permit if it operated as an outpatient facility, but must prove proper licensure as such.