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PanelMed-legalIBRLienDenied

Cruz, Erika

ERIKA CRUZ, Applicant vs. CAPAY, INC.; BERKSHIRE HATHAWAY, Defendants

ADJ number: ADJ12250535
Decision date: Nov 26, 2023
District office: Long Beach
WCJ: Diana L. Marsteiner
Claim administrator: Berkshire Hathaway Homestate Companies (administering Redwood Fire & Casualty Insurance Company)
Commissioners: —

Injury / body parts: low back, right knee, shoulders, upper extremities

LC §4603.3LC §4603.6LC §4622LC §5813LC §5814LC §5814.5CCR §9792.5.6CCR §9794CCR §9795CCR §10786

Summary

Cost Petitioner Neil J. Halbridge, M.D. sought the unpaid balance for a supplemental record review report prepared on January 19, 2020, by filing a Petition for Determination of Medical-Legal Expense Dispute. Defendant had partially paid the bill via an EOR, and Dr. Halbridge requested a timely second bill review but did not request Independent Bill Review (IBR). The WCJ found that IBR was mandatory and that the cost petition was not the correct remedy, denying the petition. On reconsideration, the WCAB adopted and incorporated the WCJ's report and denied reconsideration, holding that defects in the EOR coding did not excuse the provider's failure to pursue mandatory IBR.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.