Wiltz, Gloria

Applicant Gloria Wiltz sustained a right knee injury in 1994 while working as a receiving clerk for the self-insured City of Los Angeles; her case resolved by 1997 Award with future medical care. The Prescription Center Pharmacy filed a lien for compounded medications and lidocaine/Lidoderm patches provided 2011-2014, which the WCJ allowed for $50,871.51 plus statutory increase and interest, finding defendant's UR untimely and the medications reasonable and necessary. Defendant sought reconsideration, arguing the F&O failed to address the Siena Management lien, the UR untimeliness finding was unsupported, and the lien claimant failed to carry its burden of proving medical necessity. The Board rescinded the F&O and remanded, finding the WCJ improperly applied a 2017 statute (4610(c)(1)) not in effect during the relevant dates, that Patterson did not apply because there was no prior authorization, and that the record inadequately addressed UR validity/timeliness and medical necessity under the MTUS. The matter was returned to the trial level for further proceedings on both liens.