Parveen, Asma

Lien claimant Premier Psychological Services sought reconsideration of a WCJ's F&O that found applicant did not sustain industrial injury, disallowed its lien, and denied its filing fee, penalties, and interest. The WCAB affirmed that the reports of treating psychologist Dr. Mark H. Michaels, Ph.D., were not substantial evidence of injury AOE/COE or of a compensable consequence psyche injury, because they were conclusory and Dr. Michaels improperly assumed orthopedic injuries he was not qualified to diagnose. However, the Board held that because Dr. Michaels was a treating physician who reported on a disputed causation issue in a denied claim, his reports qualified as reimbursable comprehensive medical-legal expenses under Labor Code section 4060. The Board granted reconsideration, rescinded the F&O, and substituted a new Findings and Order allowing the lien as a medical-legal expense in an amount to be adjusted, deferring the issues of amount, penalties, interest, and filing fee with jurisdiction reserved at the trial level.