McKenzie, Patricia

The County of Los Angeles Department of Health Services, permissibly self-insured and adjusted by Sedgwick, entered into written lien settlement agreements with lien claimants Park Compounding and Pro Rx Management resolving two pharmaceutical liens. After agreeing to settle the liens at a 2022 lien conference, defendant refused to pay, asserting the liens were never perfected, the settlements were void for fraud/fee splitting, and the lien claimants were not properly licensed. The WCJ found the settlement agreements valid and enforceable and ordered payment, holding defendant failed to meet its burden to set aside the stipulations. The WCAB denied reconsideration, adopting the WCJ's Report, reasoning that defendant submitted to Board jurisdiction by settling, waived underlying jurisdictional defenses, and failed to prove fraud, mistake of fact, or other good cause to rescind.