Marks, Debbie

Lien claimants Comprehensive Outpatient Surgery Center (COSC) and Marina Russman, M.D., sought reconsideration of a WCJ's May 29, 2024 decision that found certain dates of service were not reasonably required to cure or relieve the effects of applicant's industrial injury. The WCJ awarded COSC limited payment for the March 23, 2011 service (authorized but unpaid) and the timely-paid August 4, 2011 service, but disallowed the remaining epidural injection dates (September 8 and 29, 2011) and entirely disallowed Dr. Russman's lien because the records lacked MTUS justification and there was no evidence of a proper referral or incorporation of her reports by the primary treating physician. The WCJ also found defendant engaged in bad faith and imposed $500 in sanctions. The Appeals Board granted reconsideration to allow further review, finding it unclear whether the legal issues were properly identified, whether the record was sufficient, and whether further development of the record was necessary. The Board deferred a final decision pending further review of the merits and the entire record.