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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ3034844 (LBO 0392601) ADJ 4614655 (LBO 0396565)
Regular
Oct 17, 2014

ANGEL AVILA vs. PHILIPPS SERVICES CORPORATION, CIGA, SEDGWICK CMS, RELIANCE INSURANCE COMPANY

The Workers' Compensation Appeals Board (WCAB) granted reconsideration of orders dismissing lien claims from several medical providers. These lien claimants argued the dismissal was erroneous because they had not abandoned their liens and deserved a continued hearing to identify witnesses. The WCAB found the Petition for Reconsideration timely and determined that lien claimants may have been denied due process if their representative left the hearing prematurely without adequate notice. Therefore, the WCAB is providing an opportunity for lien claimants to demonstrate good cause why the dismissal orders should not be affirmed, and ordering the defendant to respond to any filings.

Workers' Compensation Appeals BoardPetition for ReconsiderationLien ClaimsWCJDismissal of LiensMedical Lien ManagementRepresentative AbandonmentPrima Facie ShowingDue ProcessNotice of Intention to Dismiss
References
0
Case No. ADJ716826 (VNO 0465033)
Regular
Feb 03, 2012

Frances Welch vs. East Ventura Medical Group, The Hartford

This case concerns a lien claim filed by Center for Orthopedic Surgery (COSI) for medical treatment provided to Frances Welch. The Workers' Compensation Appeals Board affirmed a prior decision barring COSI's lien. The Board found COSI's lien was filed outside the six-month limit from the final award issuance, despite their argument that timely billing and lack of settlement document service should toll the statute. COSI's inaction for seven years after partial payment, without filing a lien, precluded any claim of tolling. The Board clarified that partial payment does not obligate the defendant to serve the provider with all settlement documents if no lien is on file.

Labor Code section 4903.5lien claimantCenter for Orthopedic SurgeryPetition for ReconsiderationtollingLabor Code section 4904(a)Stipulations with Request for Awardpermanent disabilitystatute of limitationsLabor Code section 4903.1(c)
References
0
Case No. ADJ7564894
Regular
Jun 07, 2013

FLOR DE MARIA DE LEON vs. PORTO'S BAKERY, INC, TRAVELERS

Here's a summary for a lawyer: This case involves a lien claimant, First Choice Health UBC, whose lien was dismissed for failure to provide proof of timely payment of the lien activation fee at a lien conference. While the claimant's representative appeared for "FCH" and later submitted proof of payment for a different, similarly named entity (First Choice Medical Group), no proof was provided for First Choice Health UBC itself. The WCJ recommended denial of reconsideration, finding that the claimant failed to meet the requirements of Labor Code section 4903.06(a)(4) by not presenting evidence of activation fee payment for the correct entity at the conference, thus warranting dismissal with prejudice. The Appeals Board adopted the WCJ's report and denied the petition.

Lien ClaimantActivation FeePetition for ReconsiderationDismissal with PrejudiceContinuous TraumaServerBack InjuryKnee InjuryLower ExtremitiesNervous/Psyche
References
0
Case No. ADJ1298503 (LAO 0876726) ADJ4673153 (LAO 0876725)
Regular
Jan 13, 2015

MAUDE TATE vs. LOS ANGELES UNIFIED SCHOOL DISTRICT, SEDGWICK

Lien claimants Frontline Medical Associates and Firstline Health sought reconsideration after their medical treatment liens for Maude Tate's 2006 industrial injuries were dismissed with prejudice. The Workers' Compensation Appeals Board denied their petition, affirming the WCJ's decision that the lien claimants failed to meet their initial burden of proof. Specifically, they presented no evidence to substantiate their claims for medical treatment provided outside the defendant's Medical Provider Network. The Board found that the lien claimants waived the right to further hearing by submitting the matter on the existing record without any supporting documentation.

Workers' Compensation Appeals BoardLien ClaimantsPetition for ReconsiderationMedical Treatment LiensMedical Provider Network (MPN)Burden of ProofWCJ OrderLien ConferenceStipulations with Request for AwardIndustrial Injuries
References
0
Case No. ADJ6507434
Regular
Jun 07, 2013

GABINO DANIEL MARTINEZ MONTES vs. MURRAY'S IRON WORKS, COMPWEST INSURANCE COMPANY

This case involves a lien claimant, Frontline Medical Associates, seeking reconsideration of the denial of their lien for medical treatment provided to an applicant, Gabino Daniel Martinez Montes. The lien was denied because the claimant failed to prove membership in the defendant's Medical Provider Network (MPN) or demonstrate the necessity of treatment for denied body parts. The Appeals Board adopted the WCJ's report, which found the lien claimant's evidence inadmissible due to non-disclosure and upheld the denial of reconsideration. The claimant also failed to establish that treatment for denied body parts was medically necessary or that the MPN process was properly bypassed.

Workers' Compensation Appeals BoardPetition for ReconsiderationWorkers' Compensation Administrative Law JudgeFrontline Medical AssociatesLien ClaimantMedical Provider Network (MPN)Pre-Trial Conference StatementAdmissible EvidenceDue ProcessLabor Code Section 4062
References
2
Case No. ADJ9772441
Regular
Feb 06, 2017

DOUGLAS NELSON vs. FINISH LMZ'S PERFECT, GUARD INSURANCE

This case concerns a dispute over payment for medical treatment provided by Western Medical Center. The Appeals Board determined it lacks jurisdiction over the lien claimant's claim because an express contract exists between the medical provider and the defendant regarding payment amounts. Consequently, the Board rescinded the prior order and substituted a finding that it does not have jurisdiction over the lien. The lien claimant shall take nothing further on its lien.

Workers' Compensation Appeals BoardReconsiderationFindings and OrderLien ClaimantReimbursementContractual DisputeJurisdictionLabor Code Section 5304Medical TreatmentExpress Agreement
References
1
Case No. ADJ8094646
Regular
Jan 17, 2014

ALEJANDRINA BARRETO vs. OUT OF THE SHELL, SOUTHERN INSURANCE COMPANY, REPUBLIC INDEMNITY COMPANY, PHARMAFINANCE, LLC, HEALTHCARE FINANCE MANAGEMENT, LLC

This case involves lien claimants PharmaFinance and Healthcare Finance Management, and their representatives Landmark Medical Management and Brian Hall, who sought reconsideration of a decision disallowing their liens for medical treatment. The Appeals Board granted reconsideration solely to notice its intention to impose sanctions of up to $2,500 against the lien claimants and their representatives. This action is due to a pattern of allegedly filing petitions containing false statements about not receiving notices, which violates the Board's Rules of Practice and Procedure and Labor Code Section 5813. The Board found these claims not persuasive and indicative of a tactic to avoid responsibility.

Workers' Compensation Appeals BoardPetition for ReconsiderationSanctionsLien ClaimantsHearing RepresentativesIndustrial InjuryFindings and OrderCompromise and ReleaseNotice of IntentionLabor Code section 5813
References
0
Case No. ADJ4550283 (RIV 0082494)
Regular
May 06, 2016

PEDRO CABRERA vs. BUILDERS TRIM & DOOR, INC., GOLDEN EAGLE INSURANCE COMPANY

This case involves a lien claimant seeking reconsideration of a disallowed medical lien for psychological services. The Workers' Compensation Appeals Board denied reconsideration, upholding the judge's decision that the lien claimant failed to prove its services were medically necessary or rendered within the defendant's Medical Provider Network (MPN). The lien claimant also improperly attached unadmitted documents to its petition, violating procedural rules. Therefore, the defendant is not liable for the services provided outside the MPN.

Workers' Compensation Appeals BoardLien claimantPetition for ReconsiderationFindings and OrderMedical legal expenseCompromise and ReleaseIndustrial injuryPsychological injuryCompensable consequenceMedical provider network (MPN)
References
3
Case No. ADJ7184220
Regular
Jul 05, 2012

RICARDO ZUNIGA vs. BARRETT BUSINESS SERVICES, INC.

Defendant appealed an administrative law judge's order allowing partial payment of a medical lien. The defendant argued it was not liable because the applicant received treatment outside its Medical Provider Network (MPN), and the lien claimant was not part of that network. The Appeals Board granted reconsideration, finding the defendant provided sufficient notice of its MPN to the applicant. Furthermore, the lien claimant failed to prove the medical services were reasonably necessary or that the claimed fees were reasonable. Consequently, the Board reversed the prior order and disallowed the lien claim in its entirety.

Workers' Compensation Appeals BoardBarrett Business ServicesMedical Provider NetworkMPNself-procured treatmentlien claimantreasonable medical treatmentburden of proofindustrial injurycompromise and release
References
13
Case No. ADJ2401554
Regular
Apr 02, 2013

JOSHUA GROSSMAN vs. ARAMARK UNIFORM SERVICE, ACE AMERICAN INSURANCE COMPANY

The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration, upholding its prior decision to grant the lien claimant's claim for medical treatment costs. The Board found that the defendant failed to properly notify the applicant of their Medical Provider Network (MPN) and that the applicant's attempts to secure an MPN physician were unsuccessful. Defendant's failure to provide sufficient assistance in transferring care was deemed a neglect to provide reasonable medical treatment, making them liable for self-procured treatment. The Board also found the lien claimant's treatment reasonable and consistent with the Agreed Medical Examiner's recommendations.

MPNMedical Provider NetworkLien ClaimantReconsiderationSelf-Procured Medical TreatmentAgreed Medical ExaminerPrimary Treating PhysicianLabor Code Section 4600Substantial Medical EvidenceIndustrial Injury
References
7
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