Joiner, Colin

Applicant Colin Joiner sought reconsideration of a WCJ's October 21, 2024 Findings of Fact, which held there was no good cause to order defendant to pay Casa Colina for inpatient treatment services beyond what was previously ordered, finding that the WCAB lacked authority to award payment because Casa Colina had never filed a lien under Labor Code section 4903(b). Applicant argued the WCJ's findings conflicted with the Board's prior February 27, 2024 Opinion and Order finding applicant entitled to reasonable and necessary medical treatment under section 4600, and that non-payment to Casa Colina amounted to a denial of care. Defendant answered that the WCAB lacked jurisdiction absent a filed lien and that an express agreement fixing payment amounts existed. The Board granted reconsideration, reasoning that the existence or non-existence of a lien is not dispositive of defendant's duty to provide care, and that failure to pay the facility risks premature discharge amounting to a denial of care. The Board deferred a final decision on the merits pending further review and possible development of the record.