JOSE CARDENAS vs. COSTA VIEW FARMS, ZENITH INSURANCE COMPANY
The Workers' Compensation Appeals Board denied Monrovia Hospital's petition for reconsideration, upholding the original decision that the hospital was entitled to nothing further on its lien. The Board found that the hospital failed to meet its burden of proving its charges were based on a "reasonable cost basis" as required for long-term care facilities exempt from the Official Medical Fee Schedule. Expert testimony presented by both parties, particularly regarding cost-to-charge ratios derived from OSHPD data, supported the finding that the hospital's proposed methodologies did not adequately demonstrate reasonable costs. The Board affirmed that the hospital, not the defendant, bears the affirmative burden of proving the reasonableness of its lien.