Jin Hao, Liang

Lien claimant Optimal Health Medical Center sought reconsideration of a WCJ's December 2024 Findings and Order disallowing its lien on the ground that it failed to prove that applicant, a kitchen helper, sustained industrial injury AOE/COE to his wrist, shoulder, arm, and respiratory system. The case in chief had been resolved by Compromise and Release in 2021, leaving the lien to be litigated at trial. The Board found that the QME's reporting (Dr. Warren) did not constitute substantial evidence because it lacked an accurate history, omitted job duties analysis, was internally inconsistent, and reduced causation to a single conclusory sentence. However, the Board found that the primary treating physician's reports (Dr. Shen) did constitute substantial medical evidence establishing injury AOE/COE. The Board granted reconsideration, rescinded the F&O, found injury AOE/COE to the right wrist, shoulder, and arm, and deferred issues of nature/extent (including respiratory injury), value, and timeliness of the lien, remanding for further proceedings.