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

Case No. ADJ8094646
Regular
Jan 17, 2014

ALEJANDRINA BARRETO vs. OUT OF THE SHELL, SOUTHERN INSURANCE COMPANY, REPUBLIC INDEMNITY COMPANY, PHARMAFINANCE, LLC, HEALTHCARE FINANCE MANAGEMENT, LLC

This case involves lien claimants PharmaFinance and Healthcare Finance Management, and their representatives Landmark Medical Management and Brian Hall, who sought reconsideration of a decision disallowing their liens for medical treatment. The Appeals Board granted reconsideration solely to notice its intention to impose sanctions of up to $2,500 against the lien claimants and their representatives. This action is due to a pattern of allegedly filing petitions containing false statements about not receiving notices, which violates the Board's Rules of Practice and Procedure and Labor Code Section 5813. The Board found these claims not persuasive and indicative of a tactic to avoid responsibility.

Workers' Compensation Appeals BoardPetition for ReconsiderationSanctionsLien ClaimantsHearing RepresentativesIndustrial InjuryFindings and OrderCompromise and ReleaseNotice of IntentionLabor Code section 5813
References
0
Case No. ADJ1601443 (AHM106445)
Regular
Jun 29, 2015

LAUREANO MENDOZA vs. OAK GROVE, INC., STATE COMPENSATOIN INSURANCE FUND

The Workers' Compensation Appeals Board affirmed a finding and order disallowing a lien filed by PharmaFinance, LLC. The lien was disallowed because PharmaFinance failed to prove timely compliance with Labor Code section 4903.8(d) by not filing the required sworn declaration and supporting documentation at the appropriate times. The Board found the declaration, though eventually located, was untimely filed, and the lien was incomplete without the necessary supporting documentation. Therefore, PharmaFinance failed to meet its burden of proof to establish its lien.

WCABPharmaFinanceLandmark Medical ManagementLien claimantReconsiderationLabor Code section 4903.8(d)DeclarationEAMSStipulations and AwardPermanent disability
References
4
Case No. ADJ7677731
Regular
Mar 21, 2016

Antonio Vasquez vs. Royal Marble and Tile, State Compensation Insurance Fund

The Workers' Compensation Appeals Board denied PharmaFinance, LLC's petition for reconsideration of the denial of its $\$ 5,512.80$ lien. The Board affirmed the administrative law judge's finding that PharmaFinance failed to meet its burden of proof to establish the reasonableness and necessity of the compound treatment it provided. Despite the employer's potential failure in utilization review, the lien claimant was still required to substantiate the medical treatment's validity with substantial evidence. As no such evidence was presented, the lien was disallowed in its entirety.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationFindings and OrderIndustrial InjuryCompound PrescriptionUtilization ReviewBurden of ProofMedical TreatmentReasonableness and Necessity
References
6
Case No. ADJ8610515
Regular
Jun 07, 2016

PEDRO GONZALEZ vs. OLYMPIC HOTEL, ILLINOIS MIDWEST INSURANCE COMPANY

The Workers' Compensation Appeals Board is dismissing a Petition for Removal filed by lien claimants PharmaFinance, LLC, and Healthcare Finance Management, LLC. The lien claimants sought removal in response to an administrative law judge's Orders Rescinding. However, they voluntarily withdrew their petition for removal on April 27, 2016. Therefore, the Board is formally dismissing their petition.

Petition for RemovalOrders RescindingLien claimantsWCJWorkers' Compensation Appeals BoardOlympic HotelIllinois Midwest Insurance CompanyPharmaFinanceHealthcare Finance ManagementAdministrative Law Judge
References
0
Case No. ADJ7375714
Regular
Feb 18, 2014

MARIE YOUNG vs. VALLEY HEALTH CARE, AMTRUST NORTH AMERICA

This case concerns a lien claimant, PharmaFinance, whose lien was dismissed for failing to pay a lien activation fee. The Workers' Compensation Appeals Board granted reconsideration of the dismissal. Crucially, a federal district court subsequently issued a preliminary injunction enjoining the enforcement of the lien activation fee provisions. Therefore, the Board rescinded the dismissal order and returned the matter to the trial level for further proceedings.

Lien claimantPharmaFinancePetition for ReconsiderationOrder Dismissing Lien ClaimLien Activation FeeLabor Code section 4903.06(a)(4)preliminary injunctionAngelotti Chiropractic v. Bakerenjoined enforcementworkers' compensation administrative law judge (WCJ)
References
1
Case No. ADJ7970704
Regular
Jun 15, 2015

IRMA MONROY vs. GROMAN MORTUARIES, INC., SOUTHERN INSURANCE COMPANY

The Workers' Compensation Appeals Board denied a petition for reconsideration filed by lien claimants PharmaFinance, LLC, and Healthcare Finance Management, LLC. The Board affirmed the finding that the lien claimants failed to meet their burden of proof to establish the reasonableness and necessity of the treatment provided. Specifically, they did not present substantial evidence demonstrating proper authorization or designation of a treating physician as required by law. Therefore, the services rendered by the un-designated physician were deemed not the defendant's responsibility.

Workers' Compensation Appeals BoardPetition for ReconsiderationLien ClaimantPrimary Treating Physician4600 LetterMedical NecessityBurden of ProofCompromise and ReleaseLabor Code Section 4603.2Uncontroverted Medical Treatment
References
0
Case No. ADJ7263890
Regular
Apr 25, 2013

JOSETTE RENTERIA vs. BLYTHE NURSING CARE, MIDWEST INSURANCE

This case involves a lien claimant, Pharmafinance, seeking reconsideration after its lien was dismissed by the WCJ for failure to pay the lien activation fee. The Workers' Compensation Appeals Board (WCAB) granted reconsideration, finding the lien claimant's petition timely filed. Crucially, the WCAB noted a lack of evidence that the lien claimant received notice of the lien conference. Therefore, the WCAB rescinded the dismissal order and returned the matter to the trial level for further proceedings and a new decision.

Lien claimantPetition for ReconsiderationWCJdismissallien activation feelien conferencenoticeReport and Recommendationrescindedtrial level
References
0
Case No. ADJ8323423
Regular
Nov 13, 2014

JAIME VILLEGAS vs. NOVY RANCH MARKET, STATE FARM INSURANCE COMPANY

This case involves a lien claimant, PharmaFinance, seeking to prove its lien for pharmaceuticals. The Workers' Compensation Appeals Board (WCAB) granted a petition for removal, rescinding a WCJ's order compelling the production of a contract. The WCAB found the contract irrelevant to the reasonable value of pharmaceuticals, which is governed by a statutory fee schedule. However, the lien claimant must still prove its legal assignment and identity to establish the validity of its lien. The matter was returned to the trial level for further proceedings on establishing the lien.

Petition for RemovalLien ClaimantsCompromise and ReleaseAssignment of ReceivablesPharmaceutical Fee ScheduleReasonable Value of ServicesTrade SecretDecertified OpinionBurden of ProofPreponderance of Evidence
References
3
Case No. ADJ66 99348
Regular
Apr 11, 2016

KANON MONKIEWICZ vs. RM STORE FIXTURES, STATE COMPENSATION INSURANCE FUND

This case involves lien claimants Rx Funding Solutions and PharmaFinance seeking payment for assigned medical expenses. The Workers' Compensation Appeals Board (WCAB) reconsidered a prior ruling that disallowed these liens under Labor Code section 4903.8(a). The WCAB found that the 2014 amendments to section 4903.8(a)(2) specifically exempt assignments made before January 1, 2013, from preclusion. Therefore, the WCAB amended the prior order to allow the lien claimants to proceed with further proceedings on the merits of their claims.

WCABReconsiderationLien ClaimantsLabor Code Section 4903.8AssignmentCeased Doing BusinessPharmacyPharmacistSB 863AB 2732
References
10
Case No. ADJ6699348
Regular
Mar 17, 2016

KANON MONKIEWICZ vs. RM STORE FIXTURES, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) issued a Notice of Intention to find that Labor Code section 4903.8(a) does not preclude awards to lien claimants Rx Funding Solutions, LLC and PharmaFinance, LLC. This is because the 2014 amendments to section 4903.8(a)(2) specify that it does not apply to assignments completed prior to January 1, 2013. Both of the lien claimants' assignments were made before this date, thus exempting them from the preclusion. The WCAB is amending its previous order and returning the case to the trial level for further proceedings on the merits of the liens.

Labor Code 4903.8Lien claimantsAssignment of receivablesCessation of businessPharmacy lienMedical lienSB 863AB 2732Prospective vs. retrospective applicationWCAB rules
References
10
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