Acosta, Jennifer

Lien claimant RMS Medical Group sought reconsideration of a January 31, 2024 Supplemental Findings and Order finding that defendant timely paid the reasonable value of medical treatment ($1,292.44) and that no penalties or interest were due. The dispute centered on whether penalties and interest should accrue from the date RMS first submitted its bills or from the date it served the corrected bill on June 23, 2022. At the initial 2022 trial, the WCJ found there was no substantial evidence as to the reasonable value of the services, so the earlier bills could not establish a determinable amount owed. RMS served a corrected bill on June 23, 2022, which defendant reviewed and paid on July 19, 2022, within 45 days. The WCAB denied reconsideration, holding that because the corrected bill was timely paid, no entitlement to penalties or interest arose.