Reed, Mashan

Lien claimant Spectrum Medical Group settled its lien for $5,750.00 via an informal, non-court-approved agreement with defendant on January 12, 2023, which provided that payment within 30 days would resolve any claim for penalties, interest, costs, fees, and sanctions. Defendant issued two checks (totaling $5,750.00) bearing the correct claim number and date of loss but incorrect dates of service, both of which Spectrum acknowledged receiving by February 7, 2023. Spectrum applied one check ($2,069.72) to a different account based on the erroneous date of service and asserted defendant still owed that amount plus penalties and interest. The WCJ found Spectrum was fully paid and timely paid, and that it was not entitled to penalties, interest, costs, or fees because the settlement was never approved by the WCAB under Labor Code section 5001 and was fully satisfied as of February 7, 2023. The Appeals Board adopted the WCJ's Report and denied reconsideration. The Board also addressed timeliness under amended Labor Code section 5909, finding the decision was timely issued within 60 days of transmission.