Morales Gomez, Carlos

Cost petitioner DocCentral, Inc., a professional photocopy service, sought reconsideration of a WCJ's Findings of Fact and Order that found it was not entitled to medical-legal expenses for copy services because no 'contested claim' existed during the 90-day delay period (January 26, 2018 to April 25, 2018) when the expenses were incurred. The WCJ had found that during the delay period the claim was neither accepted nor denied, so it was not a contested claim under Labor Code section 4620. The Appeals Board granted reconsideration, holding that a contested claim is not limited to denied claims but includes situations where liability has not been timely accepted. Citing the subsequent Compromise and Release and the settlement of EDD's lien for benefits paid during the delay period as evidence, the Board found a contested claim existed when the copy expenses were incurred. The Board rescinded the WCJ's decision, substituted new Findings of Fact finding a contested claim existed, deferred all remaining issues, and returned the matter to the trial level.