CLEMENTE MEJIA vs. PACIFIC MAT, INC., STATE COMPENSATION INSURANCE FUND
The Workers' Compensation Appeals Board (WCAB) affirmed a prior decision disallowing the balance of a lien for medical treatment provided by Dr. Arroyo. The administrative law judge found Dr. Arroyo failed to prove the reasonableness of services beyond progress and permanent and stationary reports, and that he was adequately compensated for reasonable services. The WCAB held that Labor Code section 4600(b), requiring medical treatment to be consistent with the Medical Treatment Utilization Schedule (MTUS) to be considered reasonably required, applied retrospectively to all open cases, including this one. Therefore, the original decision disallowing the remaining portion of the lien was affirmed.