Martinez, Maria

Lien claimant The Dental Trauma Center sought reconsideration of a December 20, 2024 1st Amended Joint Findings and Order in which the WCJ found applicant Maria Martinez sustained industrial injuries during 1999 and ordered the lien claimant to take nothing, finding it failed to meet its burden to prove entitlement to additional reimbursement for dental treatment. The lien claimant argued the WCJ erred by failing to find it entitled to additional reimbursement for dental treatments and by failing to find defendant estopped from denying reimbursement for dental reporting. The Board first addressed the timeliness of its action under amended Labor Code section 5909, concluding it timely acted on the petition. On the merits, the Board determined that the billing statement, the Utilization Review certification, and the lien claimant's brief, read together, may demonstrate what treatments were authorized and unpaid, and that defendant may be bound by its UR certification and cannot decline authorization ex post facto based on AD Rule noncompliance. The Board granted reconsideration and deferred a final decision pending further review of the merits and possible development of the record.