SILVIA MORA vs. STEELCASE, INC., LIBERTY MUTUAL INSURANCE COMPANY
The Workers' Compensation Appeals Board (WCAB) granted reconsideration and rescinded a prior decision that ordered a lien claimant to reimburse the defendant for chiropractic treatment exceeding the statutory limit. The WCAB held that Labor Code section 4604.5(d)(1) limits chiropractic visits but does not authorize restitution for voluntary payment of excessive treatment. Citing the equitable principles established in *American Psychometric Consultants, Inc. v. Workers' Compensation Appeals Board (Hurtado)*, the Board found that both parties were equally aware of the legal limits, and the defendant voluntarily paid the excess charges. The WCAB emphasized transactional stability, stating that undoing such payments would negatively impact the workers' compensation system.