Vega Marin, Paula

Lien claimant Spectrum Medical Group sought reconsideration of a WCJ's January 16, 2024 Findings, Award and Orders that allowed only $940.44 for the 3/25/22 date of service (plus penalty and interest) and disallowed the remaining dates of service. Applicant Paula Vega Martin had settled her January 5, 2022 industrial back and shoulder injury claim via a Compromise and Release approved June 2, 2022, in which defendant agreed to pay, adjust, or litigate outstanding lien claims. The dispute centered on physical therapy treatment provided between March 25, 2022 and April 26, 2022, where Dr. Nia (the authorized PTP) performed only the initial evaluation while Dr. Krause performed the subsequent treatment that was never authorized through utilization review. The Board denied reconsideration, holding that authorization was never provided for the course of physical therapy under Labor Code section 4610 et seq. The WCAB affirmed the WCJ's reasoning that all treatment beyond Dr. Nia's initial evaluation required utilization review, which the provider failed to properly obtain.