WCPanelIQ
PanelLienDenied

Watkins Bullock, Remonia

REMONIA WATKINS BULLOCK, Applicant vs. DEPARTMENT OF STATE HOSPITALS – PATTON, legally uninsured; administered by STATE COMPENSATION INSURANCE FUND, STATE EMPLOYEES RIVERSIDE, Defendants

ADJ number
ADJ4637058
Decision date
Nov 11, 2024
District office
Riverside
WCJ
Eric Thompson
Claim administrator
State Compensation Insurance Fund
Commissioners
—

Injury / body parts: low back, both knees, feet

LC §5909LC §5900LC §4603.2LC §5905LC §3202.5LC §5705LC §5307.1LC §5307.6CCR §10600CCR §9789.22CCR §9792CCR §9792.5

Summary

Lien claimant Kindred Hospital Rancho sought reconsideration of an 08/12/2024 decision finding it take nothing on its lien for a knee replacement and related hospital services because it failed to prove the reasonable value of its lien. Although the facility was exempt from the Official Medical Fee Schedule (OMFS) under CCR 9789.22(k), the lien claimant did not provide reliable, foundationally supported evidence (exhibits 2 and 3 were found inadmissible) to establish reasonable value beyond the $17,797.86 already paid by SCIF. The WCJ found SCIF's witness credible and her fee calculation based on a comparable hospital persuasive. The Appeals Board adopted and incorporated the WCJ's report and denied reconsideration, also addressing the timeliness of its action under amended Labor Code section 5909.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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