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

Case No. ADJ3463668 (AHM 0129255) ADJ3379175 (AHM 0128291)
Regular
Nov 07, 2013

LEO CORCORAN vs. C.A.T., INC.; TIG SPECIALTY INSURANCE SOLUTIONS

The Workers' Compensation Appeals Board denied a petition for reconsideration filed by a lien claimant, Midas Recovery Services, representing the Sheet Metal Workers Trust Fund. The claimant sought over $330,000 for services rendered, but the Board affirmed the judge's award of only $23,694.58. This was because the lien claimant failed to meet its burden of proving the reasonableness and necessity of its services and their value. Specifically, the provided documentation did not adequately itemize or detail the goods and services rendered to support the claimed amount.

WCABPetition for Reconsiderationlien claimantburden of proofreasonablenessnecessityreasonable valueC.A.T.Inc.TIG Specialty Insurance Solutions
References
Case No. ADJ7348520, ADJ7343936, ADJ7321306
Regular
Oct 25, 2016

Mauricio Arciniega vs. Santa Monica Seafood Company, Compwest Insurance Company

This case involves a lien claimant, Med-Legal Photocopy, seeking payment for subpoenaed medical records. The defendant objected to the lien on grounds of unreasonable necessity, but their objections were untimely and inadequately raised. The Appeals Board rescinded the prior decision disallowing the lien and remanded the case. This will allow the trial judge to determine the amount due to the lien claimant, as the defendant is precluded from objecting to the reasonableness and necessity of the expenses due to their procedural failures. However, the cost of a consultative rating obtained by the lien claimant is not a recoverable medical-legal expense.

Med-Legal PhotocopyReconsiderationDisallowed LienContested ClaimLabor CodeMedical-Legal ExpensesSubpoenaReasonablenessNecessityObjection
References
Case No. ADJ8117409
Regular
May 07, 2018

Tracy Hall vs. Bixby Knolls Towers, American Casualty Co.

The Workers' Compensation Appeals Board (WCAB) granted reconsideration of a prior award in favor of lien claimant Preferred Scan. The defendant contested the lien, arguing the claimant failed to prove the reasonableness, necessity, and contested nature of the services, and that settlement had been reached. The WCAB found the original decision lacked sufficient factual findings and legal analysis regarding contested claims, reasonableness of expenses, timely objections, duplicative subpoenas, and the alleged settlement. Therefore, the WCAB rescinded the award and returned the matter to the trial level for further proceedings and findings on these issues.

Workers' Compensation Appeals BoardReconsiderationLien ClaimantBurden of ProofReasonablenessNecessityContested ClaimDuplicative RecordsSubpoenas Duces TecumExplanation of Review
References
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
Case No. ADJ8097174
Regular
Jul 01, 2016

JORGE PICENO vs. BRIAN DEVRIES CONSTRUCTION, EVEREST NATIONAL INSURANCE COMPANY, AMERICAN CLAIMS MANAGEMENT, INC.

The defendant sought reconsideration of a Findings and Award regarding nine medical treatment liens. The defendant argued the lien claimants failed to prove reasonableness and necessity of treatment and that penalties/interest were improper. The Appeals Board granted reconsideration, rescinded the prior award, and returned the case to the trial level for further proceedings. This decision was based partly on the Board's error in failing to properly serve all parties.

COMPROMISE AND RELEASEMEDICAL TREATMENTLIEN CLAIMANTSREASONABLENESS AND NECESSITYPENALTIES AND INTERESTMEDICAL PROVIDER NETWORKPANEL QUALIFIED MEDICAL EXAMINERFURTHER PROCEEDINGSFINDINGS AND AWARDPETITION FOR RECONSIDERATION
References
Case No. ADJ779198 (SJO 0267719)
Regular
Nov 19, 2010

EVELIN GARCIA vs. SERVICE PERFORMANCE CORPORATION, ZURICH AMERICAN INSURANCE COMPANY

The WCAB granted reconsideration and reversed a prior award for interpreting services, finding the lien claimant failed to meet its burden of proof. The claimant did not demonstrate the interpreting services were reasonable, necessary, or provided by qualified interpreters. Crucially, the medical provider's office advertised Spanish-speaking staff, and the doctor himself spoke Spanish, negating the necessity for external interpretation services. Therefore, the lien for interpreter fees was disallowed.

WCABReconsiderationLien ClaimantInterpreting ServicesQualified InterpreterReasonablenessNecessityBurden of ProofLabor Code Section 4600Labor Code Section 5811
References
Case No. ADJ577900 (STK 0187827)
Regular
Jul 18, 2011

DARIO MEDRANO vs. FEIST CABINETS, VIRGINIA SURETY

The Workers' Compensation Appeals Board granted reconsideration of a prior decision regarding Dr. Brown's medical lien. The Board found that the reasonableness and necessity of Dr. Brown's treatment charges for applicant's 2003 industrial neck and back injury require further review. While defendants failed to properly object to bills, Dr. Brown still bears the burden of proving reasonableness. The case is remanded for the WCJ to determine which specific charges were reasonable and necessary, subject to OMFS, penalties, and interest.

Workers' Compensation Appeals BoardReconsiderationMedical Treatment LienReasonableness and NecessityOfficial Medical Fee ScheduleBurden of ProofIndustrial InjuryCompromise and ReleaseBill ReviewAdministrative Director Rules
References
Case No. VNO 0301388
Regular
Sep 05, 2007

JACQUELYN GREEN vs. GENERAL MOTORS CORPORATION, SEDGWICK CLAIMS MANAGEMENT

This case involves an employer's attempt to present non-medical evidence regarding the reasonableness of expenses for an applicant's home elevator. The Appeals Board granted removal, reversing the trial judge's exclusion of these exhibits and witnesses. The Board found that while the medical necessity of the elevator was stipulated, the "reasonable expense" of its installation was a valid issue for which non-medical evidence should be admissible.

removalevidentiary rulingnon-medical exhibitsmedical necessitydue processsubstantial prejudiceirreparable harmpermanent disabilitystipulated awardreasonable expense
References
Case No. ADJ2302824 (LBO 0318405) ADJ4306138 (LBO 0318432)
Regular
Jun 17, 2009

MICHAEL BLACKWELDER vs. INDUSTRIAL DISTRIBUTION GROUP, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION, INTERCARE INSURANCE SERVICES, RELIANCE INDEMNITY

The Workers' Compensation Appeals Board granted reconsideration of a prior decision that disallowed a lien claimant's claim for over $2,000,000. The Board found the original decision lacked sufficient reasoning and did not adequately address the reasonableness and necessity of the claimant's billing. Due process requires further development of the record to allow for a complete adjudication of the issues. Therefore, the case is returned to the trial level for further proceedings and a new decision.

Workers' Compensation Appeals BoardLien claimantReconsiderationJoint Findings and OrderCompromise and ReleaseLien trialSubstantial evidenceMedical evidenceBill reviewAbuse of discretion
References
Case No. ADJ2296444 (LAO 0786271)
Regular
Feb 10, 2015

CAROLYN HOLMAN vs. LOS ANGELES UNIFIED SCHOOL DISTRICT, P S-I, A B SEDGWICK CLAIMS MANAGEMENT SERVICES

The Workers' Compensation Appeals Board affirmed a WCJ's decision denying liens for Dr. Burstein and The Prescription Center. The Board found no evidence Dr. Burstein treated the applicant for industrial injuries, nor that his services or charges were reasonable and necessary. Consequently, The Prescription Center's lien for filling prescriptions from Dr. Burstein was also denied as not related to the industrial injury. Both lien claimants failed to meet their burden of proof regarding the reasonableness and necessity of their claims.

Workers' Compensation Appeals BoardLien claimantPetition for ReconsiderationFindings and OrdersWCJStipulations with Request for AwardIndustrial injuryReasonableness of chargesNecessity of servicesBurden of proof
References
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