Lien claimant Dental Trauma Center petitioned for reconsideration of a July 12, 2024 Findings and Order that allowed its dental treatment lien in the amount of $5,499.07 (the value recommended by defendant's billing expert) rather than the $15,548.84 recommended by the lien claimant's billing expert. The dental services were not covered by the Official Medical Fee Schedule, so valuation had to be established by written evidence under Kunz v. Patterson and expert testimony. The WCJ found defendant's billing expert, Donald Hodge, more persuasive than lien claimant's expert, Manuel Fuentes, based on Hodge's greater experience, broader sourcing, more objective approach, and more detailed explanation of his Kunz study. The Appeals Board adopted and incorporated the WCJ's report, including a supplemental explanation curing any LC 5313 defect, and denied reconsideration. The decision also addressed timeliness of the Board's action under the amended Labor Code section 5909.
Issues
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Applicant takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Provider takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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