Moreno, Norma

Lien claimant Medland Medical sought reconsideration of a WCJ's F&O that found applicant failed to prove injury AOE/COE and that the lien charges were unreasonable, ordering lien claimant to take nothing on its medical treatment lien. The WCAB granted reconsideration, finding that the primary treating physician's report constituted substantial medical evidence establishing an industrial cumulative injury to the lumbar spine and bilateral knees. The Board rejected the WCJ's reasons for discounting the report (pronoun error, missing ROM measurements, lack of prior records) as minor or mistaken. Because defendant had deferred utilization review pending resolution of the AOE/COE dispute, and injury was now found industrial, defendant must conduct retrospective UR of the deferred treatment requests. The Board rescinded the F&O, substituted a new Findings and Award finding industrial injury, awarded medical-legal expenses, deferred the medical treatment lien, and returned the matter to the trial level.