ROBERTO ESCOBAR-IZARRARAS vs. ACCORN ENGINEERING, PACIFIC COMPENSATION INSURANCE COMPANY
The Appeals Board reconsidered a WCJ's decision disallowing the remainder of a hospital's lien. The WCJ found the lien unreasonable based on an incorrect standard, as the hospital's services were not subject to the Official Medical Fee Schedule and were to be paid on a "reasonable cost basis." The Appeals Board rescinded the prior decision, returning the case to the trial level for further proceedings and a new decision. This decision clarifies that the lien claimant bears the burden of proving the reasonableness of its charges on a cost basis, not just its usual fees.