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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. ADJ9873183
Regular
Feb 24, 2020

WONDA BRAZILE TRAYLOR vs. COUNTY OF LOS ANGELES/PUBLIC HEALTH SERVICES; Permissibly SelfInsured, Administered by TRISTAR RISK MANAGEMENT

The WCAB affirmed the prior award finding the County of Los Angeles liable for copy services provided by lien claimant Med-Legal, LLC. The defendant failed to issue a timely and compliant Explanation of Review (EOR) for invoice 1313134, thereby waiving objections to its reasonableness. Consequently, the lien claimant is entitled to the reasonable value of the invoice, plus penalties and interest retroactive to receipt. The case is remanded to the WCJ to determine the exact reasonable value of the services.

WCABReconsiderationLien ClaimantCopy ServicesExplanation of ReviewMedical-Legal ExpensesLabor Code Section 4622PenaltiesInterestReasonable Value
References
Case No. ADJ9052447
Regular
Oct 13, 2018

JACQUELINE FINDLER vs. WALMART, AVIZENT, YORK INSURANCE

The Workers' Compensation Appeals Board denied the petition for reconsideration in *Findler v. Walmart*. The WCAB adopted the findings of the WCJ, who found that the lien claimant failed to provide sufficient evidence of the reasonable value of services rendered. This was because the applicable fee schedule did not control for services provided before its effective date. Therefore, the lien claimant was required to present evidence of reasonable value, which they did not adequately do.

Jacqueline FindlerWalmartAvizentYork InsuranceADJ9052447Petition for ReconsiderationWorkers' Compensation Appeals BoardWCJOpinion and Order DenyingAdministrative Director Rule 9983
References
Case No. ADJ9668315
Regular
Jan 10, 2020

MARTIN AMADOR vs. CAL CENTRAL HARVESTING, STAR INSURANCE COMPANY

This case concerns a lien claimant, Citywide Scanning, seeking payment for medical-legal discovery services. The Workers' Compensation Appeals Board (WCAB) affirmed the initial award but deferred the issue of the reasonable value of services. The WCAB found the defendant waived objections to the invoices by failing to provide timely explanations of review, thus incurring a penalty and interest. However, the WCAB returned the matter for further proceedings to establish a reasonable value, as the initial evidence was insufficient.

WCABReconsiderationLien ClaimantCitywide ScanningFindings of FactAward and OrderMedical-Legal Discovery ServicesCopy ServicesExplanation of Review (EOR)Labor Code Section 4622
References
Case No. ADJ8092562 MF ADJ8222911
Regular
Feb 22, 2016

JULIA OZUNA vs. KERN COUNTY SUPERINTENDENT OF SCHOOLS

The Appeals Board granted reconsideration and rescinded the WCJ's decision regarding lien claimant Associated Reproduction Services, Inc. (ARS). The Board found that ARS was acting as an agent for the applicant's attorney, making its copying services potentially compensable medical-legal expenses. Crucially, ARS is not required to prove that every copied record was specifically relied upon by the AME, only that the copying was reasonably undertaken to discover relevant information. The case is returned to the trial level for further proceedings to determine a reasonable fee for ARS's services and address the claim for interest.

Associated Reproduction ServicesAMEDr. Roger Sohnlien claimantcopy service feesmedical-legal expensesLabor Code §4620(a)Labor Code §4622interestfee schedule
References
Case No. AD-J7246984
Regular
Apr 05, 2016

COURDES ESTRADA vs. OXNARD HARVEST COMPANY, LIBERTY MUTUAL INSURANCE COMPANY

This case concerns a lien claimant's petition for reconsideration of a Workers' Compensation Appeals Board decision. The claimant argued the administrative law judge (WCJ) erred in valuing their services at $105,972.59 and denying interest. The Board denied reconsideration, finding the bill reviewer appropriately considered usual and customary charges and relied on a reasonable cost basis per administrative directives. The Board also found the defendant complied with Labor Code section 4603.2 regarding payment and explanation of bill review.

Workers' Compensation Appeals BoardPetition for ReconsiderationFindings and AwardLien claimantMonrovia Memorial HospitalInnovative Medical Managementreasonable value of servicesinterest on awardindependent bill reviewerusual and customary charges
References
Case No. ADJ2831572 (OXN 0131269)
Regular
Dec 09, 2008

GRACIELA BELTRAN vs. TECHSTAFF WEST, INC., STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board denied a lien claimant's petition for reconsideration, upholding the original finding that the reasonable value of their services was $4,792.00, not the $12,435.54 claimed. The Board affirmed the Administrative Law Judge's decision, finding the lien claimant failed to meet its burden of proving the reasonableness of its charges under established precedent. The judge properly considered various evidence, including comparative data and the reasonableness of the charges in context, to arrive at the determined amount.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationFindings and OrderReasonable ValueIndustrial InjuryCompromise and ReleaseDiagnostically Related GroupMedicareFee Schedule
References
Case No. ADJ7834593
Regular
Oct 06, 2014

GEORGE MOEN, III vs. COUNTY OF SAN BERNARDINO

The Appeals Board granted reconsideration of a WCJ's decision regarding a lien claim for a human tendon used in applicant's knee surgery. While the WCJ correctly found the services were necessary, neither party provided sufficient evidence to determine the reasonable value of the lien. The Board rescinded the WCJ's decision and returned the case for further development of the record. Lien claimant must prove its bill was not bundled and present evidence of a reasonable fee.

Workers' Compensation Appeals BoardLien ClaimantAccess MediquipIndustrial InjuryKnee InjuryDeputy SheriffACL Tendon ReplacementPatella Tendon AllograftHuman TendonBundled Payment
References
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. ADJ3010720 (OXN 0128433) ADJ2325811 (OXN 0140121)
Regular
Nov 17, 2008

JACK WOESSNER vs. BLUE CROSS OF CALIFORNIA, ZURICH OF NORTH AMERICA

This case concerns a dispute over the reasonable value of services provided by a lien claimant, Westlake Spine & Outpatient Surgery Center, to the applicant. The Workers' Compensation Appeals Board (WCAB) rescinded the prior award and determined that the reasonable fee for services rendered on three specific dates in 2003 was $844.77 per date. Additionally, the WCAB imposed a 15% penalty and interest on any payments not made in a timely manner, as required by Labor Code section 4603.2(b).

Workers' Compensation Appeals BoardReconsiderationLien ClaimantReasonable ValueOutpatient Surgery CenterFee ScheduleExpert WitnessBurden of ProofPenaltiesInterest
References
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