Ramirez Lara, Cristofer

Cost petitioner Physical Rehabilitation Services, Inc. and Arbi Mirzaians, D.C. sought reconsideration of an October 22, 2025 F&O finding no good cause to sanction defendant under Labor Code section 5813. Cost petitioner, who served as applicant's PTP and performed a medical-legal evaluation, argued defendant's failure to timely pay for services rendered constituted bad faith warranting sanctions under section 5813 and WCAB Rules 10786 and 10421. The Board found that while defendant may have failed to timely respond to a July 5, 2024 demand and a second review request, these were routine errors that did not rise to the level of bad faith actions or tactics that are frivolous or solely intended to cause unnecessary delay. The Board agreed with the WCJ that cost petitioner failed to demonstrate frivolous or bad-faith conduct and denied the Petition for Reconsideration.